EPA
United States
— -°'"°'~''°»
control Technology Center
EPA-600/9-91-023
July 1991
CONTROL TECHNOLOGY CENTER
1990
A YEAR OF EXPANDING SERVICE
control £ technology center
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RESEARCH REPORTING SERIES
Research reports of the Office of Research and Development, U.S. Environmental
Protection Agency, have been grouped into nine series. These nine broad cate-
gories were established to facilitate further development and application of en-
vironmental technology. Elimination of traditional grouping was consciously
planned to foster technology transfer and a maximum interface in related fields.
The nine series are:
1. Environmental Health Effects Research
2. Environmental Protection Technology
3. Ecological Research
4. Environmental Monitoring
5. Socioeconomic Environmental Studies
6. Scientific and Technical Assessment Reports (STAR)
7. Interagency Energy-Environment Research and Development
8. "Special" Reports
9. Miscellaneous Reports
This report has been assigned to the MISCELLANEOUS REPORTS series. This
series is reserved for reports whose content does not fit into one of the other specif ic
series. Conference proceedings, annual reports, and bibliographies are examples
of miscellaneous reports.
Sponsored by:
Emission Standards Division
Office of Air Quality Planning and Standards
U. S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
Air and Energy Engineering Research Laboratory
Office of Research and Development
U. S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
EPA REVIEW NOTICE
This report has been reviewed by the U.S. Environmental Protection Agency, and
approved for publication. Approval does not signify that the contents necessarily
reflect the views and policy of the Agency, nor does mention of trade names or
commercial products constitute endorsement or recommendation for use.
This document is available to the public through the National Technical Information
Service, Springfield, Virginia 22161.
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EPA-600'9-91-023
July 1991
CONTROL TECHNOLOGY CENTER
1990
A YEAR OF EXPANDING SERVICE
by
Charles H. Darvin
Air and Energy Engineering Research Laboratory
U.S. Environmental Protection Agency
Research Triangle Park, NC 27711
Robert J. Blaszczak
Office of Air Quality Planning and Standards
U.S. Environmental Protection Agency
Research Triangle Park, NC 27711
and
Beth Crabtree
Acurex Corporation
4915 Prospectus Drive
Durham, NC 27713
Prepared for:
Control Technology Center
Air and Energy Engineering Research Laboratory
Office of Research and Development
U.S. Environmental Protection Agency
Research Triangle Park, NC 27711
Emission Standards Division
Office of Air Quality Planning and Standards
U.S. Environmental Protection Agency
Research Triangle Park, NC 27711
Center for Environmental Research Information
Office of Research and Development
U.S. Environmental Protection Agency
Cincinnati, OH 45268
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PREFACE
This report is one of the Control Technology Center's (CTC's) continuing efforts to inform
participants about the CTC's contribution to the Nation's air quality program. The CTC's success reflects
the need to share technical assistance and technology transfer. The CTC encourages cooperation
among State and local air pollution control agencies and the U.S. Environmental Protection Agency's
(EPA's) Regional Offices and the three CTC lead organizations. Those lead organizations are the Office
of Air Quality Planning and Standards (OAQPS), the Air and Energy Engineering Research Laboratory
(AEERL), and the Center for Environmental Research Information (CERI).
The CTC provides a unique and crucial service to air pollution control agencies. It gives technical
support to State and local air pollution control agencies enabling them to make decisions on a strong
technical basis. We expect the CTC to grow to fulfill the changing needs for technical assistance and
technology transfer. <
This report documents CTC activities from October 1989 through September 1990. It
summarizes CTC projects and provides statistics on use of CTC services. It describes the CTC's growth
and its immediate and long-term plans to support the Nation's air quality program.
Charles H. Darvin /Robert
Co-Chair / Co-<
Air and Energy Engineering ' Officrof Air Quality Planning
Research Laboratory and Standards
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ACKNOWLEDGEMENT
Many people have contributed to the success of the CTC, especially EPA staff members who
have responded to requests for assistance. The support and guidance of the CTC Steering Committee
(SC) and the Advisory Work Group have also played an important role in the CTC's development. The
Advisory Work Group is made up of representatives of the State and Territorial Air Pollution Program
Administrators/Association of Local Air Pollution Control Officials (STAPPA/ALAPCO) and EPA's
Region 3. Even more critical to the success of the CTC are the many callers from the pollution control
community. They have shown their support and confidence in the CTC by continuing to use its services
and recommending them to their colleagues.
Hi
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TABLE OF CONTENTS
Page
Preface H
Acknowledgment Hi
Rgures vi
Tables vl
Executive Summary / 1
Introduction 1
The CTC Program 1
Background 2
Organization and Operation of the CTC 3
Types of CTC Assistance Provided 6
FY90 Program Activity 7
Introduction 7
Program Budget 7
HOTLINE Activity 7
Process and Pollutant Analysis 9
Engineering Assistance and Technical Guidance Projects 17
CTC Capability Enhancement 17
HOTLINE Data Base 21
CTC Outreach 21
Future Direction 23
Conclusions 24
iv
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Appendices
A. Summaries of Completed Projectsf ............................ 25
"Affordability Analysis of Lead Emission
Controls for a Smelter-Refinery" .............................. 25
Alaska Oil Spill Support
"ASPEN Expert System for Steam Stripping
Calculations: Users' Manual" ............................... 26
"Assessment of the Controllability of
Condensible Emissions" .................................. 27
"Assessment of VOC Emissions from
Fiberglass Boat Manufacturing1' ..... • ......................... 27
Colorado Weighted Carbon Monoxide Emission
Correlation for Woodstoves ................................. "
"Emission Factors for Iron Foundries-
Criteria and Toxic Pollutants" ................................ Z8
"Emission Factors for Iron and Steel
Sources— Criteria and Toxic Pollutants"
Estimate of Excess Benzene Emissions from Equipment Leaks ............. 29
"Evaluations of Emission Control Devices
at Waferboard Plants" .................. • ................. du
"Evaluation of Emission Control Options
at Leeds Architectural Products" .............................. JU
"Evaluation of Emission Factors for Formaldehyde
from Certain Wood Processing Operations" ........................ dl
"Industrial Wastewater Volatile Organic Compound Emissions-
Background Information for BACT/LAER Determinations" ................ J1
"Powder Coatings Technology Update" .......................... 32
"Surface Impoundment Modeling System
(SIMS) 2.0 Users' Manual" .................................
"Test Report: Method Development and Evaluation
of Draft Protocol tor Measurement of Condensible
Particulate Emissions" ...................................
34
References ................................... " .....
35
B. Summary of Current Projects ................................
tTitles in quotation marks represent projects for which the CTC published formal reports.
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FIGURES
Number Page
1 Participants in the CTC 4
2 Monthly HOTLINE figures for FY88.FY89. and FY90 8
3 Comparison of HOTLINE calls received in FY88,
FY89, and FY90 10
4 Distribution of FY90 calls by origin 11
t
5 Distribution of State Agency HOTLINE calls by Region 12
6 Distribution of HOTLINE calls by State 13
TABLES
Number Paoe
1 Distribution of Calls Received by Process 14
2 Distribution of Calls Received by Pollutant 13
3 CTC Projects Funded in FY90 18
4 CTC Projects by Type 20
vi
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EXECUTIVE SUMMARY
INTRODUCTION
In June 1985, the Environmental Protection Agency (EPA) announced a strategy to reduce public
exposure to toxic pollutants in the ambient air. The strategy called for State and local authorities to
assume a greater regulatory role with EPA's technical and financial assistance. As a result, EPA's Office
of Research and Development (ORD) and Office of Air Quality Planning and Standards (OAQPS)
developed the Control Technology Center (CTC). The CTC is an innovative technical assistance program
for State and local air pollution agencies and EPA's Regional Offices.
Since the CTC's inception, the program has expanded to address more than just air toxics issues.
It now addresses emission source and control technology problems associated with air toxics, paniculate
matter, oxides of sulfur and nitrogen, carbon monoxide, lead, PM10, and volatile organic compounds
(VOCs). The CTC is designed to be flexible, so that it can quickly respond to many client needs as they
arise.
THE CTC PROGRAM
The CTC provides three categories of services: telephone HOTLINE assistance, direct
engineering assistance, and technical guidance. The CTC HOTLINE is a telephone number that State
and local agencies may call for easy access to EPA personnel. EPA staff provides prompt assistance in
a variety of ways including consultations, references to pertinent literature, and access to EPA technical
data and analyses. The CTC HOTLINE number is (919) 541-0800. Direct engineering assistance
projects are short-term, averaging about 3 months to complete. Projects in this category provide
technical assistance to an individual State or local agency without regard to the projects' national utility.
They are specific in nature and may not apply to problems in other locations. Technical guidance projects
are usually long-term, taking up to a year to complete. They are broader in scope than direct engineering
assistance projects and have national applications and impacts.
In FY90, the CTC experienced a 37% increase over FY89 in the number of HOTLINE calls it
received. The CTC funded 24 projects, completing 16 before the end of the fiscal year, and expended
$562,400 to fund all CTC activities. These statistics reflect both a growing need for CTC services and the
Center's advancement to meet those needs. Over the past fiscal year the CTC responded to increased
demand for its services by building its resources, staffing, outreach efforts, and base of expertise. The
program expects to see a growing need for its services and its capacity to fulfill that need.
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BACKGROUND
In June 1985, EPA announced a strategy to reduce public exposure to toxic pollutants in the
ambient air. The Air Toxics Strategy addressed concerns about routine and accidental releases. It also
addressed the responsibilities of traditional Federal regulatory programs, such as the National Emission
Standards for Hazardous Air Pollutants (NESHAPs) and New Source Performance Standards (NSPS).
The Air Toxics Strategy's goal was to support State and local agencies in their new regulatory
responsibilities to achieve reduced public air toxics risks. EPA's 5-year Air Toxics Implementation Plan
identified the enhancement of State and local air toxics programs as one of six key components for
accomplishing EPA's strategy.
The shift in regulatory responsibility from the Federal to State and local levels identified a need to
transfer control technology. EPA's ORD and OAQPS implemented an innovative technical assistance
program to help State and local agencies carry out their new responsibilities. The CTC is a collaborative
effort among OAQPS's Emission Standards Division (ESD), ORD's AEERL, and CERI. As the program
progressed, it began addressing a broader range of its clients' technical needs. Thus, the scope of the
CTC has expanded significantly since its inception in FY87. It presently responds to environmental
problems in the areas of sulfur oxides, nitrogen oxides, paniculate emissions, VOCs, and air toxics. It
also responds to questions concerning manufacturing technologies, consumer products, and most
sources of air pollution.
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ORGANIZATION AND OPERATION OF THE CTC
I
Representatives of OAQPS, AEERL, and CERI met in early 1986, to discuss the CTC concept.
They agreed to form a Steering Committee (SC) to provide direction for the program. The management
staff chose SC members from the three groups with Chair and Chair-designate positions (referred to as
the CTC Co-chairs) rotating annually between AEERL and OAQPS. The Co-chairs work with the staffs of
ORD and OAQPS and may access contractor support to accomplish CTC goals.
The SC recognized the importance of close interaction with State and local air toxics program
staff members. They established the Advisory Work Group to ensure that the CTC effectively addressed
the needs of State and local air toxics programs. The Group includes State and local agency personnel
and an air program representative from an EPA Regional Office. The basic program structure has been
the same since the CTC's formation. Figure 1 shows a block diagram of the CTC's functional structure.
Early in the history of the CTC, the SC realized that air pollution control programs at State and
local agencies are interrelated. The CTC, therefore, decided to broaden CTC assistance from air toxics
control to control of other air pollutants including criteria pollutants (nitrogen oxides, sulfur oxides,
paniculate, lead, carbon monoxide, and ozone). Since that time, the CTC has expanded its scope to
address concerns from other related technical areas. The program now encompasses emission source
and control technology assessments associated with air toxics, criteria pollutants, and VOCs.
The SC established a set of guidelines to formalize the CTC's operational protocol. These
guidelines define the CTC's purpose, SC membership and responsibilities, Co-chair duties, and
communication procedures among CTC participants. The SC made another early key decision regarding
funding. Although each organization represented in the CTC receives separate funding, the three
organizations agreed to pool resources for allocation by the SC. Finally, the CTC established a set of
guidelines for project selection and funding. In ranking projects for funding, the SC considers:
- The needs identified by State and local agencies (as opposed to the CTC's perception of
their needs)
The urgency of each problem as perceived by the requesting State or local agency
- The availability of expertise needed to provide a useful product
- The breadth of the product's application to other State and local jurisdictions
- The required resources compared with the value of the product
- The project's cost considering the available funds
- The relationship of a project to other EPA efforts (e.g., the potential to combine efforts with
or extend the work of other projects).
The Co-chairs manage the day-to-day operation of the CTC. They are the first CTC contact for
State and local personnel, usually through the HOTLINE. The Co-chairs work with the managers in their
respective organizations to select the technical personnel qualified to respond to each request.
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CTC
HOTLINE
State and Local
Air Pollution Control and
EPA Regional Personnel
CTC Co-Chairs
OAQPS ORD CERI
Contractor Support
Steering
Committee
Advisory
WorkGroup
Figure 1. Participants in the CTC
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The Co-chairs inform the SC of the status of projects conducted by their respective organizations.
Finally, the Co-chairs work with the technical personnel to ensure that each project is within the technical,
budgeting, and scheduling guidelines established by the CTC. The Co-chairs may approve small projects
(costing up to $10,000) and additional funding (up to 20%) for current projects without the SC's input.
This authority allows the Co-chairs to respond quickly to needs that arise between monthly SC meetings.
The SC meets to discuss the CTC budget and the status of current projects. The meeting gives
the SC an opportunity to discuss potential projects and choose those it will fund. The line managers of
each organization ensure the quality of work performed for the CTC and that projects follow established
guidelines. The CTC asked project leaders to form teams for each project in order to combine the
strengths of each lead organization. Each project team includes representatives from at least two of the
three lead organizations.
The Advisory Work Group meets with members of the SC twice a year. During these meetings.
the CTC briefs the Work Group on current CTC activities and addresses issues requiring guidance from
this special group. The Work Group input has been valuable in helping the CTC determine how to most
effectively meet State and local agency needs.
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TYPES OF CTC ASSISTANCE PROVIDED
The CTC provides three types of services: telephone HOTLINE assistance, direct engineering
assistance, and technical guidance. The CTC HOTLINE provides a telephone number for State and local
agencies to call for easy access to EPA personnel who provide prompt assistance in several ways.
HOTLINE assistance includes consultations, references to pertinent literature, and access to EPA
technical data and analyses. The HOTLINE number is (919) 541-0800. A tracking system ensures that
each request receives a prompt response. The Co-chairs monitor each response to ensure that each
requestor receives satisfactory assistance. For example, even if no EPA staff or consultant expertise is
available for a certain request, the CTC may perform a literature search.
Direct engineering assistance is the second type of CTC service. Engineering assistance
projects are short-term (taking about 3 months or less to complete). They provide technical assistance to
one State or local agency. These projects are usually specific in nature and applicable to particular
locations. They may result from HOTLINE calls requiring in-depth engineering analysis. In general, these
projects have included review of control technology applications, plant inspections, and consultation on
specific problems.
Technical guidance projects, undertaken by the CTC in its third level of assistance, are usually
long-term (taking up to a year to complete). These projects are broader in scope than engineering
assistance projects and are of national interest. They may result from several HOTLINE calls on the
same source or industry. A technical guidance project may result from a request from a group of air
pollution agencies, or comments and suggestions by the Advisory Work Group. These projects may
result in control technology documents, microcomputer software, or seminars and workshops. The type
of assistance the CTC provides depends on which method it chooses as the most effective technology
transfer mechanism.
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FY90 PROGRAM ACTIVITY
INTRODUCTION
The HOTLINE is the focal point of the CTC. HOTLINE activity has increased significantly during
FY90 over previous years. Written requests to initiate additional and more complex technical guidance
and engineering assistance activities have also increased. However, most CTC projects are initiated by
HOTLINE requests. The large volume of HOTLINE activity has prompted the CTC to expand its scope
from air toxics alone to include other areas of air emissions. Thus, the CTC has enlisted the help of other
organizations to expand its base of expertise to support CTC objectives.
Comments from State and local agency personnel and groups such as STAPPA/ALAPCO have
been positive. These comments and the significant increase in requests for assistance are evidence of
the success of the CTC concept and resulting programs. This growth also foretells a continued increase
in support requests in future years. Additionally, the stringent requirements that the proposed Clean Air
Act Amendments are likely to impose will probably result in further CTC growth.
PROGRAM BUDGET
The CTC had an operating budget of $562,400 for FY90. The program used these funds to
conduct technical studies, provide engineering assistance, and support CTC administrative requirements.
The CTC used $506,000 or over 90% of the program budget to fund direct technical assistance and
engineering assistance projects. The remaining funds covered CTC administrative costs such as
maintaining the data base, mailing documents, and preparing promotional materials.
HOTLINE ACTIVITY
The CTC has experienced significant growth since its formation. The number of HOTLINE
requests that the Center receives from State and local agencies and EPA Regional Offices continues to
increase. In FY90 the HOTLINE received 1097 calls, which represent a 37% increase over the 803 calls
received in FY89. The CTC has received favorable responses to engineering assistance and technical
guidance projects that it conducted in response to HOTLINE calls and written requests.
Since its inception, the Center has received over 400 requests for one CTC-produced software
program "Controlling Air Toxics" (EPA-600/8-88-092a; PB89-158745, tutorial manual, and PB89-158737,
diskette). The program has become a standard tool of many air pollution agencies. In FY90 the CTC
distributed over 4000 reports documenting its activities and projects.
The CTC developed a dBASE program to track HOTLINE calls. The program has allowed
detailed analysis of the types of calls and issues received through the HOTLINE. It has enabled the CTC
to identify areas of widespread interest. These data also identify the sources of calls, which assists the
CTC in supporting projects of broad application.
Figure 2 shows the increase in HOTLINE calls received between October 1,1987, and
September 30,1990. Figure 2 does not include the hundreds of telephone requests for CTC documents
or calls made directly to EPA air program staff from referrals by previous callers. In addition, the figure
does not include follow-up to HOTLINE calls. Although many calls escape official documentation, the
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Months
Figure 2. Monthly HOTLINE figures for FY88. FY89, and FY90
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technical staff has noted an increase in telephone volume. The CTC managers are taking steps to
monitor calls that are presently by-passing the HOTLINE. HOTLINE data, records of documents
requests, and estimates of direct-to-slaff calls reflect approximately 165 requests for assistance per
month. Figure 3 illustrates the rate of increase in officially documented HOTLINE calls of FY90 over
FY88 and FY89. FY90 HOTLINE calls show an increase over FY89 calls similar to that of FY89 over
FY88.
The 1097 CTC HOTLINE calls received in FY90 were from a wide range of governmental clients.
Figure 4 shows the distribution of those calls received from EPA Regional Offices, State and local
agencies, and other governmental sources. The CTC received the majority of HOTLINE calls (59%) from
State agencies and clients in the District of Columbia and U.S. Territories. The percentage of calls from
Regional Offices was approximately 12%. However, this number represents an 18% increase over the
number of Regional calls received in FY89. This increase indicates the significant success of outreach
activities the CTC conducted in FY90. Those activities included formal briefings to staffs at EPA Regional
Offices 6,8,9, and 10. The Center initially targeted only State and local agencies as primary CTC clients.
Since local agencies employ approximately the same number of people as State agencies, the
CTC expected the two groups to initiate a similar percentage of calls. However, the CTC received only
249 calls (22.70% of the total) from local agencies as opposed to 645 calls (58.80%) from State agencies.
The difference suggests that local agencies are less familiar with CTC assistance than are State
agencies. Foreign agencies, universities, EPA contractors, non-Regional EPA offices, and other
governmental agencies initiated the remaining 71 calls representing 6.5% of total HOTLINE calls received
in FY90.
Figure 5 shows the numbers of HOTLINE calls from State agencies within the 10 EPA Regions.
Figure 6 shows the distribution of FY90 HOTLINE calls among the States. The relatively low number of
calls received from some Regions and States may provide a basis for additional targeted outreach
activities.
PROCESS AND POLLUTANT ANALYSIS
Tables 1 and 2 show the results of a HOTLINE data analysis to determine which processes and
pollutants were the most frequent subjects of HOTLINE calls. The tables combine processes with similar
control strategies, and similar pollutants. The tables reflect only processes and pollutants for which the
HOTLINE received two or more calls.
FY90 CTC projects show a correlation with the processes which were the subject of the most
calls. Nine of the CTC's technical guidance and engineering assistance projects (on asphalt, fiberglass,
foam blowing, painting and coating, printing and graphics, miscellaneous incineration, and natural gas
and petroleum products) correspond to processes ranking in the top 10 shown in Table 1. The topics of
other FY90 projects which appear in Table 1 are chemical manufacturing, dry-cleaning, food and
beverage manufacturing, hazardous waste incineration, iron and steel, landfills, Pharmaceuticals, tire
burning, wastewater treatment, wood combustion, and waferboard. The processes which were the
subjects of two or more HOTLINE calls represent about 68% of the total calls received.
Table 2 shows that more than 80% of the calls received were on one of the pollutants listed in the
table. Correlations between this list and actual CTC projects are less obvious. This is because most
CTC projects relate to processes which include multiple pollutants. However, most CTC projects relate to
VOCs or air toxics. Forty-four percent of FY90 HOTLINE calls related to VOCs and toxics emissions.
9
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FY88
FY89
FY90
Oct Nov Dec Jan Feb Mar Apr May Jun
Jul
Aug Sep
Figure 3. Comparison of HOTLINE calls received in FY88, FY89, and FY90
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State (58.80%)
Other (6.47%)
Regional (12.03%)
Local (22.70%)
Figure 4. Distribution of FY90 calls by origin
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(Number of calls in Region)
O
Figure 5. Distribution of State agency HOTLINE calls by Region
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1-10 H-20 21-30
Figure 6. Distribution of HOTLINE calls by State
>30
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Table 1. Distribution of Calls Received by Process*
Process
Painting & Coating
Miscellaneous Incineration
Boilers
Printing
Natural Gas & Petroleum Processing
Medical Waste Incineration
Asphalt
Foam Blowing
Municipal Waste Incineration
Fiberglass Manufacturing
Tire Burning ,
Steel Mills/Electric Arc Furnaces
Dry-cleaning
Electroplating
Food & Beverage Manufacturing
Treatment, Storage & Disposal Facilities
Hazardous Waste Incineration
Landfills
Wastewater Treatment
Wood Products
Chemical Manufacturing
Contaminated Soil Treatment
Hospital Sterilizers
Kraft Pulp/Paper Mills
Air Stripping
Gas Turbines
Power Plants
Above Ground Storage Tanks
Waferboard
Coke Ovens & By-Products
Diesel Engines
Autobody Refinishing
Cement Manufacturing
Rares
Foundries
Gasoline Handling
Internal Combustion Engines
Metal Fabrication
Welding
Degreasers
Iron Foundries
Copper Smelters
Wood Combustion
Wood Stoves
Aerospace
(Degeneration
No. of Calls
73
63
44
32
30
28
22
19
18
17
16
15
14
14
14
14
13
13
13
12
11
11
10
10
9
9
9
9
8
7
7
6
6
6
6
6
6
6
6
5
5
5
5
5
4
4
% of Calls
6.65
5.74
4.01
2.92
2.73
2.55
2.01
1.73
1.64
1.55
1.46
1.37
1.28
1.28
1.28
1.28
1.19
1.19
1.19
1.09
1.00
1.00
0.91
0.91
0.82
0.82
0.82
0.82
0.73
0.64
0.64
0.55
0.55
0.55
0.55
0.55
0.55
0.55
0.55
0.46
0.46
0.46
0.46
0.46
0.36
0.36
(Continued)
14
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Table 1. Distribution of Calls Received by Process (Continued)
Process No. of Calls % of Calls
Fabrics
Furniture Manufacturing
Lead-acid Storage Batteries
Plastic Manufacturing
Refrigeration/Air Conditioning
Transportation
Adhesives
Automobile Manufacturing
Brick Manufacturing
Dust Control
Fertilizer
Grain Processing ,
Rock Quarries
Lead Smelters
Aluminum Smelters
Underground Storage Tanks
Abrasive Blasting
Accidental Release
Concrete Crushing
Electrostatic Precipitators
Metal Recycling
Silver Recycling
Rubber Curing & Recycling
Solvent Substitution
Stack Testing
Unrelated to a Process
Other Processes
4
4
4
4
4
4
3
3
3
3
3
3
3
3
3
3
2
2
2
2
2
2
2
2
2
216
144
0.36
0.36
0.36
0.36
0.36
0.36
0.27
0.27
0.27
0.27
0.27
0.27
0.27
0.27
0.27
0.27
0.18
0.18
0.18
0.18
0.18
0.18
0.18
0.18
0.18
19.69
13.13
Total 1097 100.00
'Figures represent processes for which two or more calls were received and the percentage of
the number of calls for each process to the total number of calls received in FY90.
15
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Table 2. Distribution of Calls Received by Pollutant*
Pollutant
Volatile Organic Compounds
Various Pollutants**
Air Toxics (General)
Particulates
Nitrogen Oxides
Chtorofluorocarbons
Sulfur Oxides
Chromium
Formaldehyde
Styrene
Lead
Odors
Dioxins
Carbon Monoxide
Asbestos
Ethylene Oxide
Perchloro Ethylene
Mercury
Ammonia
Fluorides
Metals
Ozone
Chloroform
Benzene
Hydrogen Sulfide
Dust
Sufuric Acid
Methylene Chloride
Pentane
Trichloro Ethylene
Visible Emissions
Acetone
Arsenic
Carbon Disulfide
Isocyanates
Magnesium
Methyl Ethyl Ketone
Toluene
Other Pollutantst
Unrelated to Pollutantsff
Totals
No. of Calls
235
156
152
74
39
18
17
15
15
15
14
13
12
11
9
9
9
7
6
6
6
6
5
4
4
3
3
3
3
3
3
2
2
2
2
2
2
2
40
168
1097
% of Calls
21.42
14.22
13.86
6.75
3.56
1.64
1.55
1.37
1.37
1.37
1.28
1.19
1.09
1.00
0.82
0.82
0.82
0.64
0.55
0.55
0.55
0.55
0.46
0.36
0.36
0.27
0.27
0.27
0.27
0.27
0.27
0.18
0.18
0.18
0.18
0.18
0.18
0.18
3.65
15.31
100.00
'Figures respresent pollutants for which two or more calls were received and the percentage of
the number of calls for each pollutant to the total number of calls received in FY90.
"Calls relating to more than one pollutant, which may or may not be included in this table.
fCalls relating to pollutants not on this table.
tfGeneral questions not related to pollutants.
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ENGINEERING ASSISTANCE AND TECHNICAL GUIDANCE PROJECTS
The CTC provides all products resulting from its projects to State, local, and Federal Agency
personnel free of charge. The CTC directs industry and consultants to the National Technical Information
Service (NTIS) for documents and software. The CTC's technical guidance products, as anticipated,
have found large audiences. For example, the CTC has received over 400 requests for the document,
"Air Stripping of Contaminated Water Sources—Air Emissions and Controls" (EPA-450/3-87-017; PB88-
106166) and the computerized permit review program, Tutorial Manual for CAT (Controlling Air Toxics),
Version 1.0" (EPA-600/8-88-092a; PB89-158745). The CTC attributes the far fewer requests for reports
on its engineering assistance projects than on its technical assistance efforts to the specificity of the
former. In FY90 the CTC received over 4000 requests for reports on completed CTC projects.
Table 3 lists the 24 engineering assistance and technical guidance projects that the CTC funded
in FY90. The list demonstrates the breadth of CTC activity during the year. The projects range from
efforts with very specific and unique scopes to efforts with broad application and interest. Appendix A
presents abstracts of completed CTC projects. These abstracts reflect CTC projects which resulted in
formal published reports or informal reports to CTC clients. Appendix B presents summaries of FY90
projects that were still ongoing at the end of the fiscal year.
Table 4 shows a breakdown of FY90 CTC projects by project type. Four of the 24 projects relate
to control technology evaluation, and 6 relate to emission characterization. Of the 24 projects that the
CTC funded in FY90,6 were engineering assistance and 18 were technical guidance.
The CTC spent more than $506,400 to fund projects in support of its clients during FY90. The
CTC expended $196,000 to fund engineering assistance projects and $310,400 to fund technical
guidance projects during the year. The distribution of CTC funds illustrates the program's emphasis on
developing technical guidance reports. That emphasis reflects the broadest interests of CTC clients as
identified by HOTLINE activity and written requests for technical assistance.
CTC CAPABILITY ENHANCEMENT
Some CTC HOTLINE requests involve complex issues that require assistance from multiple
organizations. For example, the CTC sometimes receives inquiries on the controls and health effects of
the same emission stream. Such issues are directed to organizations with different expertise, who
respond separately to each part of the request. Sometimes appropriate expertise is not immediately
available, or a request is beyond the scope of the CTC. In such cases, the Center may direct the caller to
resources outside the CTC. However, the CTC's ability to direct the requestor to the appropriate EPA
resources has typically satisfied the requestor.
The CTC is continuing to improve the broad technical capabilities of its many areas of
responsibility. Efforts to broaden the base of CTC expertise include the use of contractor assistance.
EPA has issued several general work assignments allowing the CTC to employ contractors for different
CTC project requirements. This expansion not only broadens the base of CTC expertise but also
supplements EPA expertise when workloads restrict in-house staff participation in technical efforts.
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Table 3. CTC Projects Funded in FY90
Project Title*
Amount Funded
in FY90 ($1000)
"Emission Factors for Iron Foundries—
Criteria and Toxic Pollutants'
Landfill Air Emissions Estimation Model
•Surface Impoundment Modeling System (SIMS)
Version 2.0 Users' Manual*
Cotorado/Waferboard Press Vent Emissions
Colorado/Weighted Carbon Monoxide
Emission Correlation for Woodstoves ,
Test Report: Method Development and Evaluation
of Draft Protocol for Measurement of Condensible
Paniculate Emissions"
"Assessment of the Controllability of
Condensible Emissions"
"Affordability Analysis of Lead Emission
Controls for a Smelter-Refinery"
Evaluation of Alternatives to
Asphalt Roofing
Evaluation of Excess Benzene Emissions
"Assessment of VOC Emissions from
Fiberglass Boat Manufacturing"
Flexible Packaging
HAP Manual Update
Maryland/Yeast Manufacturing
New Mexico/Mixed Waste Combustion
NOx Control Technology Data Source Book
Pennsylvania/Iron Oxide Process Analysis
PERC Waste Test Method
Pharmaceutical Plant Evaluation
10.0
29.0
12.0"
15.0
7.0
8.0t
4.0t
6.6t
45.0
7.4
2.0f
6.0f
4.0f
70.0
70.0
20.0t
13.2t
6.0
11.2
(Continued)
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Table 3. CTC Projects Funded in FY90 (Continued)
Amount Funded
Project Title in FY90 ($1000)
Polystyrene Foam Manufacturing 35.0
Tire Burning, Additional Analysis 10.0
Ultraviolet Coating Technology 20.0
Vermont/Wood Waste Incineration 35.0
Virginia/Fluff Combustion 60.0
Total 506.4
'Titles in quotation marks represent projects for which the CTC published formal reports, which are
referenced in Appendix A.
"The CTC portion of the funding for a project that was co-funded by the Technical Support Division of
OAQPS.
fThe FY90 portion of the funding for a project that was initially funded in a previous fiscal year.
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Table 4. CTC Projects by Type
Project Type Total Percent of Total
Control Technology Evaluation
Emission Characterization
Industry and Process Studies
Software Tools*
Permitting Assistance
Testing Methods
Technical Evaluation
4
6
7
2
2
2
1
16.7
25.0
29.2
8.3
8.3
8.3
4.2
Total 24 100
'The CTC targets software tools for permit review, engineering evaluation, and estimation of emission
factors.
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The CTC has taken steps to expand its technical support capability into areas not presently
addressed by the CTC. The CTC has identified technical experts in State agencies and Regional Offices,
who have agreed to respond to technical requests. Other EPA offices have made agreements with the
CTC to provide technical assistance in areas not already serviced by the CTC base of expertise.
HOTLINE DATA BASE
The HOTLINE data base has assisted the CTC in improving communication within EPA and
recognizing staff participation in CTC efforts. The CTC generates reports from the data base for several
purposes. The data base provides information for tables like those presented earlier in this report to aid
in the selection of CTC projects. It also provides reports that show managers which of their staff
members are responding to HOTLINE calls. The reports also demonstrate how much time staff members
spend responding to HOTLINE requests. These reports inform the managers of HOTLINE activity and
recognize staff members contributing to the program. The CTC also sends reports to each Regional
Office. These reports detail the number of calls from that region and the origins and subjects of calls.
In late FY90, the CTC evaluated a random, non-statistical set of HOTLINE assistance records.
The CTC contacted 26 individuals who had called the HOTLINE between July and September 1990. The
individuals represented 9 different EPA Regions and requested HOTLINE assistance on 14 different
processes. Only one of the callers commented that the CTC did not have the information that he
required, but he stated that he would use the HOTLINE again. The remaining callers were satisfied with
the CTC's responses to their requests. Many individuals contacted said that the CTC provides a valuable
service.
CTC OUTREACH
The increasing number of HOTLINE calls has historically shown a direct correlation with activities
to promote the CTC program. For the first 6 months of operation, the CTC received about 6 calls per
month. During June 1987, the first outreach activities began. The CTC distributed more than 3000 one-
page placards at the Air Pollution Control Association (APCA) meeting in New York City. The first of
several articles discussing the CTC appeared in the National Air Toxics Information Clearinghouse
(NATICH) newsletter about the same time. The CTC Co-chairs also sent more than 500 letters to State
and local agency personnel on the NATICH mailing list informing them of CTC services. For the next 6
months, the CTC received about 20 calls per month. In January 1988, the CTC Co-chairs presented
information on the CTC at an EPA Air Pollution Training Institute course for permit writers. Following the
course, the number of calls increased to about 40 per month. In FY89, the number of calls received by
the HOTLINE averaged 70 per month.
The monthly rate of HOTLINE calls gradually increased during the first three quarters of FY89.
The CTC's quarterly newsletter, developed as a CTC outreach tool, was first published in July 1989. It
resulted in a dramatic increase in CTC HOTLINE calls in FY89. Calls averaged 70 per month and
continued to increase in FY90 to an average of 92 calls per month. The CTC News highlights current
CTC efforts and recently completed projects. The newsletter also provides ordering information for
reports on those projects. The quarterly publication circulates the CTC HOTLINE number and provides a
form for those wishing to be on the CTC News mailing list. The newsletter also solicits feedback on CTC
assistance. The mailing list for the CTC News has grown to almost 2000 addressees. Many recipients of
the newsletter have commented that CTC activities relate to their work. The Center maintains a list of
project descriptions for individuals requesting information about the CTC. In early 1990, the CTC News
included a checklist for ordering CTC documents. The checklist resulted in more than 1500 requests for
documents, once again expanding the CTC's audience.
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The CTC Co-chairs initiated a program of Regional Office and State and local agency visits to
further promote CTC services. During these visits the CTC informs Regional, State, and local agency
personnel on CTC objectives. By September 1990, CTC staff had visited four Regional Offices and
several State and local agencies and presented program updates to STAPPA/ALAPCO.
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FUTURE DIRECTION
The CTC management constantly identifies and reviews ideas for improving CTC services to its
clients. Those new ideas include update briefings to various agencies, expansion of the CTC expertise
base, and an increase in the scope of research activities. The CTC plans to continue its present efforts.
while improving the existing system and identifying new areas for improvement.
The CTC is informally linked with other OAQPS and ORD service centers such as Air RISC and
the Emission Measurement Technical Information Center. The CTC has coordinated activities with these
centers and seeks to improve this coordination. For example, the CTC and Air RISC have worked
together to address requests for assistance which involve both control technology and health effects. The
CTC has referred State and local agencies to other EPA hotlines and clearinghouses when those
services could best respond to the callers' needs.
The CTC management will continue outreach activities for specific target agencies and
organizations. For example, few CTC requests came from Region 8, which encompasses six States.
The CTC will, therefore, initiate further State and Regional outreach activities in that area.
The CTC's plans for FY91 also call for the acquisition of new staff members to help meet new
CTC responsibilities. New responsibilities may include providing support, not only to State and local
governmental agencies, but also to the business community. The CTC would play a major part in
providing technical services to this potential new client category. To support this responsibility the CTC
will establish a computer tracking system (similar to the one used to track assistance to State, local, and
Federal agencies) to track calls from non-governmental agencies.
The CTC also plans to establish an electronic bulletin board in FY91 for access by clients who
have personal computers equipped with communication software and modems. The bulletin board will
allow CTC clients to enter requests for assistance during non-business hours, order CTC documents, and
download CTC-devetoped software and certain documents. Bulletin board users will be able to check the
progress of CTC projects, review technical bulletins on emerging emission control issues, and exchange
messages with other clients. The bulletin board will benefit the CTC in other ways. It should absorb
some of the increase in requests for assistance due to the CTC's growing popularity and expanded
clientele resulting from the 1990 Clean Air Act Amendments.
Cooperation between the CTC and the RACT/BACT/LAER (Reasonably Available Control
Technology/Best Available Control Technology/Lowest Achievable Emission Rate) Clearinghouse
(formerly the BACT/LAER Clearinghouse) has increased over the years. That increased cooperation was
a result of the programs' common goal, to transfer control technology to State and local agencies. In
FY91, these service activities will be more closely integrated within the structure of the CTC. As a result,
the expanding and improved Clearinghouse data base will become a common tool in addressing the
needs of CTC callers.
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CONCLUSIONS
The CTC has shown that it is an effective mechanism for technology transfer from EPA to State
and local agencies. The structure of the CTC has allowed cooperation among the three EPA lead
organizations (OAQPS, AEERL, and CERI) and input from STAPPA/ALAPCO and the Regional Offices.
The CTC's team approach to projects has combined the expertise and experience of regulatory and
research and development personnel. That combination has improved the quality and depth of CTC
assistance.
The CTC has received positive feedback from its State, local, and Federal clients on its three
levels of assistance (engineering assistance, technical guidance, and HOTLINE assistance). The number
of HOTLINE calls and requests for assistance continues to increase. Many requestors continue to
contact the HOTLINE with new requests.
Increased demand for CTC services and positive feedback indicate that this program has
satisfied a need among its clients. The CTC anticipates expansion into the private sector. That
expansion suggests that the CTC may have an even greater role to play in the overall air program. The
CTC SC has recommended continued expansion of its technical base and resources to satisfy the
anticipated demand within available funding.
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APPENDIX A
SUMMARIES OF COMPLETED PROJECTS
"Affordabilitv Analysis of Lead Emission Controls for a Smelter-Refinery" (1)
The CTC (Control Technology Center) responded to a request by the Environmental Protection
Agency (EPA) Region 7 to evaluate the affondability and economic impact of additional control measures
for a smelter-refinery to meet the lead emissions standard. The analysis emphasized the impact of
control costs on the smelter-refinery's profitability. The study incorporated cost data from two lead
smelter studies and existing firm and industry data.
*
The CTC published a report that examines the economic impacts of EPA's ambient air lead
standard on a primary lead smelter-refinery in Herculaneum, Missouri. The facility is the largest primary
lead producer in the U.S. However, it has been impacted by the decrease in lead consumption, worldwide
overcapacity, tow prices and environmental regulations. The decline in lead consumption is considered to
be completed and demand has stabilized. The facility currently complies with EPA's sulfur dioxide (SOa)
emissions standard, but faces other environmental, safety, and health regulations that contribute
significantly to control costs. For example, EPA may establish stricter lead and SO2 standards, and
surface impoundment solids at lead smelters may be regulated as hazardous waste under the Resource,
Conservation and Recovery Act.
The CTC report presents two alternative estimates of the cost of controls for Herculaneum to
comply with the current lead emissions standard. The two compliance cost estimates examined varied
greatly. Although, the facility could afford either option, the higher cost would impact Herculaneum's
earnings significantly. Additional research may be necessary for a more definitive estimate of compliance
costs.
Alaska Oil Spill Support
The Alaska Department of Environmental Conservation (ADEC) requested an EPA evaluation of
technical questions pertaining to the incineration of wastes resulting from the Exxon oil spill at Valdez. In
response, the CTC formed a team to provide quick expert advice to Alaska. Project leaders visited the
site, attended public hearings, and participated in public workshops. The CTC provided
recommendations to the State of Alaska.
Exxon had suggested incineration of the estimated 8,000 tons of solid waste resulting from the
Valdez oil spill. However, the oil company raised concerns over the environmental acceptability of the
disposal process. The CTC concluded that use of appropriate technology and operating procedures
would cause no adverse environmental impact.
The CTC presented a brief review and assessment of the thermal treatment technologies that
Exxon might use to dispose of certain waste resulting from the oil spin. Generally, EPA and the ADEC
concurred with Exxon's basic waste management plan, but questioned the appropriateness of the
proposed incineration technologies. EPA and Alaska considered four major issues in approving the
thermal treatment:
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Compliance with applicable environmental regulations
Compatibility with specific waste characteristics
Public perception of the plan, and
Cost
The State's consideration of public concern, which establishes acceptable performance levels,
prompted them to recommend that incinerators meet certain criteria. The criteria were similar to
requirements for hazardous waste incineration operation to meet environmental regulations and permit
conditions. The CTC provided a brief review of regulatory requirements, a discussion of various generic
classes of incineration technologies, and an assessment of their applicability to the Valdez waste.
"ASPEN Expert System for Steam Stripping Calculations: Users' Manual" 12)
The CTC and the Office of Air Quality Planning and Standards (OAQPS) developed the Expert
System, a personal computer (PC) software program that uses the "Advanced System for Process
Engineering" (ASPEN) user model. The model describes the process of steam stripping of volatile
organic compounds (VOCs) from wastewater feed streams. It allows the user to run an ASPEN steam
stripping simulation without any knowledge of ASPEN programming.
ASPEN is a commercial software package for chemical process design and simulation, which
allows modular building of flowsheet blocks to represent a steam stripper with or without air emission
controls. It also contains an extensive physical property library and costing routines.
The "front-end" Expert System will read a general ASPEN input file, modify it according to data
supplied by the user, and create a new input file tailored to the problem at hand. The program can be run
on an IBM-compatible (MS-DOS) PC equipped with 640K of RAM. The software has interactive menus
and on-screen help and instructions making most operations self-explanatory.
The user loads an existing data set or chooses default values using the Expert System's first
screen. The user then selects the items of interest from the main menu and enters the appropriate data.
When data entry is complete the program returns to the main menu. After creating a custom ASPEN
input file on the Expert System, the input file is uploaded from the PC to an EPA-VAX for execution by
telephone with a modem-equipped PC and appropriate communications software.
The Expert System user can run the model in either the rating or design mode. The user can
evaluate an existing stripper design in the rating mode, by entering basic design parameters such as flow
rates, concentrations, and tower dimensions. In the design mode, the model will calculate the necessary
optimum tower design to achieve the specified effluent limits and provide sizing information for the
selected control equipment. The user need enter only the wastewater flow rate, influent concentrations,
desired removal rates or effluent concentrations, and the air emission control selected. In both modes the
steam stripper ASPEN model determines the capital and operating costs associated with the stripper as
well as the control equipment.
State and local pollution control agencies may use the ASPEN steam stripper model for
evaluating control technologies and determining potential air toxics emissions. The model offers three
options for controlling VOC air emissions from the steam stripper: condensation using a refrigerant in a
secondary condenser, fixed-bed carbon adsorption, and catalytic oxidation.
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"Assessment of the Controllability of Condensible Emissions" (3)
The CTC provided support to the State and Territorial Air Pollution Program
Administrators/Association of Local Air Pollution Control Officials (STAPPA/ALAPCO) Air Toxics
Subcommittee in acquiring a better understanding of condensible emissions from an air toxics
perspective. The major objectives of the study were to: (a) develop a data base on condensible
emissions, (b) determine chemical makeup of condensible emissions, (c) evaluate the effectiveness of
various control devices in reducing condensible emissions , and (d) identify modifications to improve
performance.
Two data bases were developed from a review of emissions source test reports from EPA's
Emission Measurement Branch (OAQPS/Technical Support Division) files and from the State of
California. The Condenslbles Data Base contains information on condensible emissions covering 43
emission source categories. The Speciated Condensibles Data Base focuses on the chemical
composition of condensible emissions. For the purposes of this study, the back-half catch of the EPA
Reference Method 5 or its equivalent was considered to represent the condensible fraction.
Based on the data contained in the Condensibles Data Base, source categories with a relatively
high percentage of Condensibles in the total paniculate catch (i.e., greater than 50%) included the
following: plywood manufacturing, asphattic concrete, electric utilities, fertilizer manufacturing, and
secondary lead smelting. From the limited data on chemical composition of condensed paniculate matter,
the toxic fraction of condensed paniculate matter (composed of arsenic, beryllium, cadmium, chromium,
lead, mercury, and vanadium) was less than 1% in most cases.
For many sources in the Condensibles Data Base, wet scrubbers including venturi scrubbers,
fabric filters, electrostatic precipitators (ESP's), and wet ESP's were the commonly employed paniculate
matter control devices. There was a wide variation in performance of these devices in controlling
condensible emissions. This variation was attributed to differences in emission source characteristics
such as temperature, composition, and concentration. Although limited performance data were available
for specific control devices, venturi scrubbers and other wet scrubbers appeared to be more effective in
reducing condensible emissions than other control devices.
No general conclusions were drawn regarding controllability of specific components because of
limited data. Modifications in control device operation or design that would affect potential reductions in
condensible emissions include: (a) operating at lower temperatures and higher humidity levels to
enhance condensed paniculate formation prior to the control device, (b) adding an ionizing section before
wet and venturi scrubbers to improve collection efficiency of the fine paniculate, and (c) using gas
conditioning agents to induce condensed particle agglomeration.
•Assessment of VOC Emissions from Fiberglass Boat Manufacturing" (4)
The CTC conducted a survey to define the nature and scope of VOC emissions from the
production of fiberglass marine craft. Earlier studies indicated that over 22,000 tons of VOC per year are
emitted from fiberglass boat manufacturing in the U.S., mainly from styrene and cleanup solvents.
Studies have also shown that the fiberglass industry may impact local air quality in coastal areas and
locations near recreation waters, where boat manufacturing is concentrated.
The CTC study identified total industry VOC emissions and emissions from different industry
segments, specific processes used by the industry, industry structure, and economic data. The CTC
published a report summarizing its findings, including the evaluation of VOC control options. The report
also described the geographic distribution of fiberglass boat manufacturing facilities. Although directed
mostly toward boat manufacturing, the findings of the study are also applicable to other molded fiberglass
operations.
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The study's findings include industry characterization, process emissions, emission reductions
through process or material changes, and emission reductions through add-on controls. The report
includes the recommendation of additional study of the potential control options that it described. The
report cited the substitution of lower VOC-containing materials as having the greatest potential for VOC
emission reductions with low costs. The study also concluded that three control devices are reputed to
potentially control VOC and styrene emissions from fiberglass boat manufacturing facilities. However,
U.S. fiberglass boat manufacturing facilities are not applying the add-on controls cited yet, pending further
evaluation of their technical and economic viability.
Colorado Weighted Carbon Monoxide Emission Correlation for Woodstoves
The CTC assisted the State of Colorado in expanding EPA's certified stove data base to calculate
Colorado weighted particulate and carbon monoxide (CO) averages. The project's objective was to
investigate and clarify possible relationships between the emissions of particulate matter (PM) and CO for
residential wood burning appliances. The more specific goal of the study was to determine if applicants
certified under the EPA 1990 Phase II PM standard could also meet the Colorado Phase II CO standard.
The CTC accomplished these objectives by compiling a data base of woodstoves meeting the EPA 1990
standard, listing the EPA weighted PM, and calculating Colorado weighted CO emission averages.
The CTC used 19 woodstove reports containing measured emissions passing EPA's 1990
standard. The reports also contained sufficient CO emission data to achieve the study's objectives. The
woodstoves included in the reports consisted of 6 stoves equipped with catalysts and 13 for non-catalytic
units.
The CTC produced a table listing the catalytic woodstoves with the corresponding weighted
average PM and CO emissions. The study also produced a graph plotting the Colorado weighted CO
emissions against the EPA- weighted PM emissions. No relationship appeared between emissions of CO
and PM. However, all of the catalytic units which passed EPA's 1990 PM standard would also meet the
Colorado CO limit. Another table depicts non-catalytic woodstoves, which produce significantly higher
CO emissions than the catalytic units. Only three of the non-catalytic stoves, those with EPA PM
emissions below about 3.6 g/hr, would meet the Colorado CO standard.
The study also generated a graph plotting Colorado weighted CO emissions against the EPA
weighted PM emissions. A correlation was evident between emissions of CO and PM for the non-
catalytic stoves. Carbon monoxide emissions generally increased with rising PM emissions up to a
maximum of about 300 g/hr for CO at a PM level of about 6 g/hr. The CO emissions then appear to
decline with further increases in PM emissions, possibly because of a relationship between bum rate and
PM emissions. Increased PM emissions may correspond to increased bum rates for the non-catalytic
appliances. The higher firebox temperatures associated with higher bum rates generally lead to more
efficient incineration of CO.
The CTC woodstove study resulted in a listing of residential woodstoves certified by the EPA as
of November 8,1989. The effort also produced Lotus worksheets to serve as working tables for catalytic
and non-catalytic stoves.
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a compilation of current emission factor data that State and local agencies may use in estimating
emissions from iron foundries.
The CTC study sought to provide a comprehensive set of emission factors for sources of criteria
and toxic air pollutants in gray and ductile iron foundries. The Center identified emission factors for
process sources, process fugitive, and open source fugitive emissions. The emission factors are not
specific to any one facility.
Studies over the past several years have focused chiefly on emissions of criteria pollutants.
These pollutants include PM, sulfur dioxide, carbon dioxide, nitrogen oxide, VOCs, and lead. More recent
work has focused on air toxic pollutants, which include many different compounds. The CTC report on
iron foundries summarizes the data available for both types of pollutants, and serves as a guide for
estimating the emissions when emission measurements are not available.
The CTC accomplished its study of emission factors for iron foundries by conducting a literature
search of the library of the U.S. EPA and the American Foundry men's Society. The CTC reviewed
publications for information which could be used for developing emission factors for any of the processes
associated with iron foundries. The resulting report presents emission factors in terms of an average
value or range of values as well as a rating of quality or reliability.
"Emission Factors for Iron and Steel Sources—Criteria and Toxic Pollutants" (6)
In response to a request by EPA's Region 8, the CTC conducted a study to acquire a
comprehensive set of emission factors for sources of both criteria and toxic air pollutants in integrated
iron and steel plants and specialty electric arc shops. The study identified emission factors for process
sources, process fugitive, and open source fugitive emissions. The CTC identified the literature source
for each emission factor, the range of values found, and the recommended best value with its rating.
The study resulted in a recommendation to use published emission factors whenever possible.
When published emission factors are not available, the study recommended using the emission factors
developed for the 1985 National Acid Precipitation Assessment Program emissions inventory. The
literature search conducted in the study also discovered older studies conducted primarily on uncontrolled
sources.
The CTC study found only limited information on toxic air pollutant emission factors. The report
suggested the toxic air pollutant emission factors reported in the "Toxic Air Pollutant Emission Factors - A
Compilation for Selected Air Toxic Compounds and Sources* (EPA-450/2-90-011, PB90-126003) despite
the limitations of that study. The CTC report concluded that additional work on quantifying the emissions
of toxic air pollutants from the iron and steel industry would be helpful.
Estimate of Excess Benzene Emissions from Equipment Leaks
The CTC provided technical assistance to EPA Region 3 in estimating excess emissions from
equipment leaks at a Chevron U.S.A., Inc. Philadelphia refinery. Region 3 was providing the estimate for
a civil action in the U.S. District Court for the Eastern District of Pennsylvania. The U.S. had filed the
action against Chevron U.S.A., Inc. claiming that the refinery had failed to implement an equipment leak
detection program resulting in emissions of benzene into the environment.
Excess benzene emissions are not explicitly defined in the "National Emission Standard for
Hazardous Air Pollutants," nor are they discussed in the notices of proposal or promulgation published in
the "Federal Register." For the purposes of this evaluation, excess emissions were viewed as those
emissions associated with components that continue to leak beyond the allowable 15-day period for
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repair of the equipment, and for which sufficeint documentation for delay of repair has not been provided.
Emission estimates were developed for those pieces of equipment for which repair was delayed, but for
which documentation was unavailable or inadequate to justify delay of repair.
"Evaluations of Emission Control Devices at Waferboard Plants* (7)
In 1987 the CTC published a report in response to a request from the State of Colorado following
complaints of eye and lung irritation from residents near a waferboard manufacturing plant. More
recently, the State of Colorado requested additional CTC assistance in determining the effectiveness of
control devices for emissions from wood chip dryers in waferboard plants. This report describes the
general process of waferboard production, an analysis of the extractable organics in wood, and a
characterization of wood chip dryer effluents. The report discusses aerosol formation, an evaluation of
emission control options, and a review of available information on press vent emissions.
The study concluded that insufficient data are available to adequately characterize wood chip
dryer effluents, because of the variety of factors affecting the composition of the effluents. The study
further concluded that EFB's are more suited for controlling effluents generated from the drying of
hardwoods and other low-resin-content woods. Wet ESP'Sjare better than EFB's for the control of sticky,
hydrocarbon-laden wood chip dryer effluent streams. However, wet ESP's have higher capital and
operating costs that do EFB's. The study also identified three factors that affect formaldehyde emission
from press vents: (1) the excess formaldehyde content of the resin, (b) the amount of resin used, and (c)
the press temperature.
Characterization of emissions from wood chip dryers is difficult because of the limited data
available. Wood species, dryer temperature, dryer loading rate, and previous drying history of the wood
affect the composition of dryer effluents. An understanding of relationships between these factors and
composition of wood chip dryer exhaust emissions would require comprehensive parametric test data that
are currently unavailable.
"Evaluation of Emission Control Options at Leeds Architectural Products'1 (8)
The Connecticut Department of Environmental Protection (CTDEP) requested assistance from
the CTC in evaluating alternatives for controlling VOC emissions from a specialty aluminum coating
facility. The facility had presented a best available control technology (BACT) evaluation to the CTDEP
stating that added emission control was not economically feasible. The CTDEP questioned the
conclusion and requested an independent evaluation.
The CTC identified several broad options for reducing emission that it planned to investigate.
The options were: ,
Conventional VOC control devices to control the existing exhaust streams
Conventional methods to reduce exhaust flow and treatment with conventional VOC control
devices, and
Novel or developmental methods of achieving more cost-effective emission control
The CTC, an EPA contractor, and CTDEP visited the facility to observe the operations and gather
data for a technical and economic evaluation of control options. They concluded that controlling
emissions would permit the facility to increase production, and that the revenues from the production
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increase could help offset the added cost of the emission controls. The cost data provided in the report
can also be used to estimate emission rates and costs of alternatives involving partial emission control.
"Evaluation of Emission Factors for Formaldehyde from Certain Wood Processing Operations" (91
;
The CTC conducted a project to supplement an earlier CTC report, "Evaluation of Emission
Factors for Formaldehyde from Certain Wood Processing Operations" (EPA-450/3-87-023, PB88-
118492). The new study includes information that became available between October 1987 and May
1989. The focus of this effort was on existing data that would allow calculation of emission factors for four
unit operations in wood veneer plants. The four operations are the formulation of the urea- and
phenol-formaldehyde resin glues, the application of the glues, the curing operation, and storage of
finished products.
The CTC sought information on formaldehyde emissions from wood veneer operations to develop
emission factors for the industry. Formaldehyde releases of 246 kg (542 Ib) were reported under Title III
of the Superfund Amendments and Reauthorization Act of 1986 (SARA) from a large plywood plant in
Mississippi. However, existing data found during the study period were insufficient to allow reliable
emission factors to be calculated.
Mandatory submittals of formaldehyde release estimates under SARA Title III and the California
Air Toxic Hot Spot Act of 1987 should become available within the next few years. These data could be
combined with available production statistics for the wood veneer industry to compile emission factors.
More reliable data may become available from compliance tests that follow permit decisions in States that
regulate formaldehyde emissions from wood veneer plants now and in the future. A comprehensive test
program performed in several plants and unit operations would provide the highest quality, most useful
data for emission factor development. This report discusses data sources and information gathering
methodology and study results.
The CTC collected emission data for this study by conducting telephone surveys of regulatory
personnel, industry contacts, and trade organization contacts. It also conducted a computerized literature
search and a search of data bases containing air toxics emissions data. Those data bases included the
National Air Toxics Information Clearinghouse (NATICH), recent supplements to the Best Available
Control Technology/Lowest Achievable Emission Rate (BACT/LAER) Clearinghouse document, and
estimates of 1967 releases of formaldehyde from plants provided to the EPA under Title III of SARA.
Formaldehyde emissions information from wood veneer operations found during the study period
is insufficient to relate emission rate, production rate, and free formaldehyde content of the
urea-formaldehyde resin used. Reliable factors could be developed from emission data collected during a
test program designed to measure actual emissions, production rate, and percent free formaldehyde in
the glue from several wood veneer unit operations at several plants. The number of plants and sources
tested would determine the quality of the emission factors generated.
•Industrial Waste water Volatile Organic Compound Emissions-Background Information for BACT/LAER
Determinations''^
In response to requests by several States and EPA Regional Offices, the CTC prepared a
technical guidance document for controlling air emissions from the collection and treatment of industrial
wastewater. The document provides technical information on estimating emissions of VOC and
BACT/LAER determinations for controlling the emissions. The document applies to the organic chemicals
industry, plastics and synthetic fibers, pesticides, Pharmaceuticals, and hazardous waste treatment,
storage, and disposal. The document's application could be expanded to include additional industries as
information becomes available.
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The industries covered in this document have the potential to generate wastewaters containing
high concentrations of organic compounds. These wastewaters typically pass through a series of
collection and primary treatment units. They are then treated to reduce the concentration of organic
compounds prior to discharge. Many of these collection and treatment units are open to the atmosphere
and allow organic-containing wastewaters to contact ambient air. Atmospheric exposure of these
organic-containing wastewaters results in significant volatilization of VOC from the wastewater.
The VOC emissions can be reduced by applying one of three control strategies. The most
effective strategy is to apply waste minimization techniques to reduce the organic concentration of the
wastewaters, or to produce a more manageable wastewater stream through waste segregation or
recycling. Even with waste minimization, some waste streams will be generated. Emissions from these
wastewater streams can be reduced by applying treatment at the point of generation. Numerous controls
are suitable in specific cases. However, the most universally applicable technology for controlling
emissions from wastewater generated by these industries is steam stripping. A third control strategy for
some situations is to enclose the wastewater collection system and treat all processing units for removal
or destruction of the organic compounds.
State and local agencies and EPA Regional offices may refer to this CTC document for a
description of each industry covered in the report. The'document enumerates the sources of organic
containing wastewater, the sources of VOC air emissions, and available VOC emission control strategies.
The report also includes the secondary impacts and control costs associated with the recommended
control strategy, steam stripping.
'Powder Coatings Technology Update' (11)
The CTC provided a report summarizing the status of powder coating technology. Industries are
using powder coating at an increasing frequency because of environmental concerns associated with
solvent-based coatings, which cause VOC emissions. Recent improvements in powder coating
technology have also contributed to the growing trend toward this coating method. The application of
powder coatings, which are dry, finely divided particles, causes no release of VOCs. And the curing
process associated with powder coating produces only minute amounts of VOCs. Air pollution control
agencies are encouraging industrial finishing operations to use powder coatings as a means of reducing
VOC emissions.
The CTC report on powder coating technology provides information on the performance,
applicability, costs, and availability of powder coatings to assist State and local agencies in evaluating
powder coating as an air pollution control technology. The CTC based its report on literature searches,
contacts with several State and local air pollution control agencies, and written survey questionnaires to
powder coating manufactures, users, and equipment suppliers. The report provides a brief history of
powder coatings, the different classes of available powder coatings, and recently developed powder
resins. The document also discusses the types of equipment required for a powder coating line and the
types of products that are typically powder coated. And finally, the report presents the economic
advantages of this technology and a cost comparison between powder and liquid coatings.
•Surface Impoundment Modeling System (SIMS1 2.0 Users' Manual" (12)
The CTC updated its software for use by State and local air pollution control agencies in
preparing VOC and air toxics emission inventories. Together with the Technical Support Division of
OAQPS the CTC developed SIMS, a menu-driven PC system. State and local agencies may employ
SIMS to estimate emissions of organic compounds from impoundments at hazardous waste treatment,
storage, and disposal facilities (TSDFs), publicly owned treatment works (POTWs), industrial wastewater
treatment facilities, and other similar operations.
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The OAQPS developed a set of emission models for sources including surface impoundments to
estimate VOC emissions based on input parameters such as impoundment type and dimensions, influent
flow rate, and inlet pollutant concentrations. The CTC incorporated these models into the SIMS software,
which includes default values for use by State and local agency personnel who may not have information
on all of the input parameters required by the models.
The SIMS program applies to flow-through and disposal impoundments and turbulent or
quiescent flow. The program can also account for btodegradation when appropriate. The user must
provide the type of impoundment, whether it is used for biological treatment, and the total flow into the
impoundment. The user must also supply the total surface area of the impoundment and the type of
industries discharging wastewater into the impoundment. The agency using SIMS may supply as much
additional information as is available and use the program's default values as necessary.
Impoundments at facilities such as TSDFs, POTWs, and industrial wastewater treatment facilities
may account for a significant amount of the total VOC or air toxic emissions in some areas of the U.S.
SIMS provides State and local air pollution control agencies with a valuable tool in estimating these
emissions. The CTC has expanded the compound data base in SIMS 2.0 and added models for diffused
air systems and systems with an oil film layer for junction boxes, lift stations, sumps, and weirs. SIMS
was also upgraded for application to multiple impoundment systems.
Test Report: Method Development and Evaluation of Draft Protocol for Measurement of Condensible
Paniculate Emissions" (13)
The CTC responded to requests by several States and the State and Territorial Air Pollution
Program Administrators (STAPPA) for a test method for condensible paniculate matter (CPM). Because
current methods measure only in-stack PM, EPA considered a CPM method to be vital. EPA made the
impinger catch method of measuring CPM the subject of this study. This method allowed the
determination of both filterable PM and CPM simultaneously, uses existing methodology and equipment,
and is being used by several State agencies. The CTC published a report which details the laboratory
and field evaluations of the study.
The evaluation sought to determine the adequacy of the test method and produce supporting
documentation. A further objective was to revise the candidate method based on the results of the
laboratory experiments, to validate the method in field tests, and to revise the method, if necessary.
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REFERENCES
1. Scherer, T.M. Aftordability Analysis of Lead Emission Controls for a Smetter-Refinery.
EPA-450/3-90-001 (PB90-120122), October 1989.
2. Rogers, T., A. Damle. ASPEN Expert System for Steam Stripping Calculations: Users'
Manual. EPA-450/3-90-003, July 1990.
3. Shareef, G.S., J.T. Waddell. Assessment of the Controllability of Condensible Emissions.
EPA-600/8-90-075 (PB91-125807), October 1990.
4. Stockton, M.B., I.R. Kuo. Assessment of VOC Emissions from Fiberglass Boat
Manufacturing. EPA-600/2-90-019 (PB90-216532), May 1990.
• t
5. Gschwandtner, G., S. Fairchild. Emission Factors for Iron Foundries—Criteria and Toxic
Pollutants. EPA-600/2-90-044 (PB90-266743), August 1990.
6. Barnard, W.R. Emission Factors for Iron and Steel Sources—Criteria and Toxic Pollutants.
EPA-600/2-90-024 (PB90-242314), June 1990.
7. Vaught, C.C. Evaluations of Emission Control Devices at Waferboard Plants.
EPA-450/3-90-002 (PB90-131442), October 1989.
8. Bolstad, J.N. Evaluation of Emission Control Options at Leeds Architectural Products.
EPA-450/3-89-001 (PB90-120106), September 1989.
9. White, T.S. Evaluation of Emission Factors for Formaldehyde from Certain Wood
Processing Operations. EPA-600/8-90-052 (PB90-254988), June 1990.
10. Elliott, J., S. Watkins. Industrial Wastewater Volatile Organic Compound Emissions-
Background Information for BACT/LAER Determinations. EPA-450/3-90-004
(PB90-194754), January 1990.
11. Hester, C.I., R.L. Nicholson. Powder Coatings Technology Update. EPA-450/3-89-033
(PB90-127341), October 1989.
12. Watkins, S.L. Surface Impoundment Modeling System (SIMS) 2.0 Users' Manual.
EPA-450/4-90-019a (PB91-156711), September 1990.
13. DeWees, W.G., K.C. Steinsberger. Test Report: Method Development and Evaluation of
Draft Protocol for Measurement of Condensible Paniculate Emissions. EPA-450/4-90-012
(PB90-240805), April 1990.
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APPENDIX B
SUMMARIES OF CURRENT PROJECTS
Estimate of Landfill Emissions
The CTC has received several HOTLINE requests for information on landfill emissions. The
Center responded by producing a floppy disk and user's guide for estimating landfill emissions based on
an existing model. The project is scheduled for completion in December 1990. (Susan Thomeloe.
919-541-2709)
Investigation of Improved VQC Controls in the Graphic Arts Industry
The CTC is documenting volatile organic compound (VOC) control applications in graphic arts
facilities using rotogravure orflexographic printing. The CTC gathered data during several plant visits,
and is identifying sources using unique air flow management and capture techniques. The report will be
complete in February 1991. (Karen Catlett. 919-541-0835)
NO* Control Technology Data Source Book
The CTC is preparing a document to guide State and local agencies and EPA Regional Offices in
reviewing permits for non-utility combustion sources. The CTC visited several key vendors in Europe to
gather data. The report is scheduled for completion in May 1991. (Charlie Sedman, 919-541-7700)
Vermont/Wood Waste Incineration
The State of Vermont requested CTC assistance after receiving complaints from citizens about
odors coming from two plants that bum wood waste. The CTC conducted a preliminary study of wood
waste combustion to determine if one of the Vermont plants is typical of the industry. The CTC will
conduct a field test or simulated combustion to collect additional data. The results of the study may affect
the State's regulations on incineration, which presently apply to combustion of wood waste. The project is
scheduled for completion in May 1991. (Bob McCrillis, 919-541-2733)
PERC Waste Test Method
The CTC received a request from EPA Region 1 for assistance in evaluating a test method for
determining the perchtoroethylene (PERC) content of wastes from dry cleaning facilities. The project is
scheduled for completion by April 1991. (Tony Wayne, 919-541-3576)
New Mexico/Mixed Waste Combustion
The State of New Mexico requested CTC support in developing rules for the combustion of mixed
waste (contaminated by radioactive material). The CTC is assisting the State by evaluating alternative
emission controls and monitoring devices at mixed waste combustors. The project is scheduled for
completion in April 1991. (Bob Blaszczak, 919-541-5432)
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Hazardous Air Pollutants Program (HAP-PROl
The CTC is replacing "Controlling Air Toxics" (CAT) with new user-friendly software called HAP-
PRO, based on the "Handbook: Control Technologies for Hazardous Air Pollutants" (the HAP Manual),
EPA-625/6-86/014. The program will speed up and improve the reviewing of permit applications for
control of air toxics. HAP-PRO is mouse-driven, includes pop-up menus, and enables access to data on
several plants simultaneously. The program is scheduled for distribution in June 1991
(Carlos Nunez, 919-541-1156)
Colorado/Waferboard Press Vent Emissions
The CTC assisted the State of Colorado and EPA Region 8 in an in-depth engineering analysis of
alternative methods for the control of condensible VOC emissions from waferboard press vents. Upon
completion of the analysis, the CTC sent the State of Colorado a letter summarizing its findings. The
project is scheduled for completion in March 1991. (Mike Kosusko, 919-541-2734)
Pennsylvania/Iron Oxide Process Analysis
The Pennsylvania Department of Environmental Resources requested CTC assistance in
analyzing a substance that is deposited on cars, buildings, and other surfaces in the vicinity of an
industrial plant. The plant produces iron oxide for use in the recording tape industry. The CTC is
receiving monthly samples for x-ray diffraction and elemental analysis. The project is scheduled for
completion in May 1991. (Frank Briden, 919-541-7808)
"Handbook: Control Technologies for Hazardous Air Pollutants" (HAP Manual) Update
The CTC is updating the HAP Manual (EPA-625/6-86/014), which provides assistance to State
and local agencies and EPA Regional Offices in selecting, evaluating, and determining the cost of
controls for hazardous air pollutants from commercial sources. The manual contains information for
authorities reviewing permit applications and for individuals requesting information on HAP control
systems. The manual is scheduled for completion in June 1991. (Carlos Nunez, 919-541-1156)
Ultraviolet Coating Technology
The Bay Area Air Quality Management District in California requested engineering assistance in
researching ultraviolet curable coatings to reduce emissions of ozone precursors. A CTC report is
scheduled for completion in June 1991. (Chuck Darvin, 919-541-7633)
Evaluation of Alternatives to' Asphalt Roofing
The CTC conducted an evaluation of alternatives to asphalt roofing, which produces volatile
organics and condensibles. The evaluation resulted in this project to determine air toxics emissions from
hot asphalt roofing. The project is scheduled for completion in June 1991. (Bobby Daniel,
919-541-0908)
Electrostatic Precipitator (ESP) Models
The CTC, in conjunction with the Electric Power Research Institute, is developing two ESP
models. One is a full-feature ESP model with in-depth analysis capability for use by scientists and
engineers. The other model will be "user-friendly,* primarily for use by State and local agencies. The two
ESP models will be complete in May 1991. (Norman Plaks, 919-541-3084)
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Marvland/Yeast Manufacturing
The Maryland Department of the Environment requested a CTC study of VOC emissions from the
manufacture of baker's yeast and available control technologies. The initial phase of the project
evaluated the source category, its potential emissions, and identified its impact on ozone non-attainment.
Phase II will consider alternative controls and their costs and impacts. The project is scheduled for
completion in June 1991. (Martha Smith, 919-541-2421)
Tire Bumino—Additional Analyses
The CTC is conducting further analyses as a follow-up to its earlier study to estimate emissions
from the open burning of scrap tires. The follow-up will be an evaluation of the biological activity in the
results of the original tire burning study. The study is scheduled for completion in October 1991.
(Paul Lemieux, 919-541-0962)
Virginia/Fluff Combustion
The Virginia Department of Air Pollution Control requested CTC assistance in identifying
emissions from the open burning of non-metallic automobile components known as "fluff." The CTC will
obtain fluff samples and analyze samples from simulated bums. The project is scheduled for completion
in October 1991. (Paul Lemieux, 919-541-0962)
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
\. REPORT NO.
EPA-600/9- 91-023
2.
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
Control Technology Center, 1990, a Year of
Expanding Service
5. REPORT DATE
July 1991
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S) ~
Charles H. Darvin (EPA/AEERL), Robert J. Blasz-
czak (EPA/OAQPS). and B. Crabtree (Acurex)
8. PERFORMING ORGANIZATION REPORT NO
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Acurex Corporation
4915 Prospectus Drive
Durham, North Carolina 27713
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-DO-0141, Task 005
12. SPONSORING AGENCY NAME AND ADDRESS
EPA, Office of Research and Development
Air and Energy Engineering Research Laboratory
Research Triangle Park, North Carolina 27711
13. TYPE OF REPORT AND PERIOD COVERED
Final; 10/89-9/90
14. SPONSORING AGENCY CODE
EPA/600/13
»««T AEERL Project officer is C. H. Darvin, Mail Drop 61, 919/541-
7633. R. J. Blaszczak is with EPA's Office of Air Quality Planning and Standards,
Mail Drop 13, Durham, NC 27711. 919/541-5432.
f^^^^oc^^BMir^T^^^^^^^^^™^^^^^™^^^^^^^^^^^™^^^^^^^^^^^^^"^^^^™™^^^^^^^^™^™^^^^^^^^^^^^^^™
16.
RACT The report discusses services provided by EPA's Control Technology Cen-
ter (CTC) during FY90. The CTC, developed by EPA's Office of Research and Devel
opment (ORD) and Office of Air Planning Quality and Standards (OAQPS), is an inno-
vative technical assistance program for state and local air pollution agencies and
EPA's regional offices. Since the CTC's inception, its program has expanded to ad-
dress more than just air toxics issues. It now addresses emission source and con-
trol technology problems associated with air toxics, particulate matter, oxides of
sulfur and nitrogen, carbon monoxide, lead, PM10, and volatile organic compounds.
The CTC is designed to be flexible so that it can respond quickly to many client needs
as they arise. The CTC provides three categories of services: telephone HOTLINE
assistance (919/541-0800), direct engineering assistance, and technical guidance.
The HOTLINE permits easy access for state and local agencies to EPA personnel
who can provide prompt assistance in a variety of ways, including consultations,
references to pertinent literature, and access to EPA technical data and analyses.
Direct engineering assistance is short-term, averaging about 3 months and providing
technical assistance without regard to national utility. Technical guidance is longer
term, up to a year, broader in scope, and with national applications.
7.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS
c. COSATI Field/Group
Pollution Organic Compounds
Emission Volatility
Toxicity Sulfur Oxides
Information Centers Nitrogen Oxides
Environmental Engi- Carbon Monoxide
neering Lead (Metal)
Pollution Control
Stationary Sources
Control Technology Cen-
ter (CTC)
Particulate
PM10
Volatile Qrganics
13B
14G
06T
05B
05E
07C
20M
07B
8. DISTRIBUTION STATEMENT
Release to Public
19. SECURITY CLASS (ThisReport}'
Unclassified
21. NO. OF PAGES
44
20. SECURITY CLASS (Thispage)
Unclassified
22. PRICE
EPA Form 2220-1 (9-73)
38
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