  SEQ CHAPTER \h \r 1 MEMORANDUM

DATE:	February 18, 2009

SUBJECT:	Overview of the Paints and Allied Products Manufacturing Area
Source Category

FROM:	Bradley Nelson, EC/R Inc.

		

TO:		Melissa Payne, EPA/OAQPS/RDPAG   SEQ CHAPTER \h \r 1 

1.0	INTRODUCTION

This memorandum presents an overview of the Paints and Allied Products
Manufacturing area source category and a summary of control technologies
used by the industry to reduce the emissions of volatile and particulate
hazardous air pollutant (HAP) emissions.  This information is in support
of the development of National Emission Standards for Hazardous Air
Pollutants (NESHAP) for the Paints and Allied Products Manufacturing
category.  The first section of this memorandum contains a brief
background of the Urban Air Toxics Area Source Program and the listing
of the Paints and Allied Products Manufacturing category.  The following
sections provide a brief introduction to the paints and allied products
manufacturing industry processes, emission sources, and associated
control techniques to reduce HAP emissions.  

2.0	URBAN AIR TOXICS AREA SOURCE PROGRAM

Section 112 of the Clean Air Act (CAA) outlines the statutory
requirements for the EPA’s stationary source air toxics program. 
Section 112(k) requires the development of standards for area sources
which account for 90% of the emissions of the 33 urban HAPs listed in
the Integrated Urban Air Toxics Strategy (UATS).  These area source
standards can require control levels which are equivalent to either
maximum achievable control technology (MACT) or generally available
control technology (GACT), as defined in the CAA under section 112(d)(3)
and section 112(d)(5), respectively. 

EPA discussed the legal basis for using GACT for area sources in
(National Air Toxics Program:  The Integrated Urban Strategy( (64 FR
38706, July 19, 1999):

We read section 112(d)(5) to authorize promulgation of at least two
types of rules:  rules that set emission levels based on specific
controls or management practices (analogous to MACT standard setting),
and rules that establish permitting or other regulatory processes that
result in the identification and application of GACT.  As long as the
result of section 112(d)(5) rulemaking is that sources use enforceable
generally available control technologies or management practices,
section 112(d)(5) appears to give us flexibility in choosing between the
adoption of numerical emission limits and the promulgation of other
requirements that result in sources applying GACT. 

The general procedure used to evaluate emission control methods as
possible candidates for GACT involve: (1) identifying and characterizing
emissions streams for the source category, (2) identifying control
measures applicable to these emission streams, (3) determining the level
of use of these control measures in the sector, (4) estimating the cost
of these control measures, and (5) estimating the emission reductions
achieved by the control measures.  Once these steps were completed, we
calculated the cost per ton of emission reduction achieved (cost
effectiveness) by each emission control method.

The Paints and Allied Products Manufacturing category was added to the
categories being listed pursuant to section 112(c)(3) and
112(k)(3)(B)(ii) in November 2002 (67 FR 70427).  The portion of the
1990 112(k) inventory pertinent to paint and allied products
manufacturing was compiled using the 2002 North American Industry
Classification System (NAICS) codes.  These manufacturing sectors
included NAICS codes 325510 (Paint and Coating Manufacturing), 325520
(Adhesive Manufacturing), 325910 (Printing Ink Manufacturing) and 325998
(All Other Miscellaneous Chemical Product and Preparation Manufacturing-
Writing and Stamp Inks).  The Paints and Allied Products Manufacturing
source category was listed based on the urban HAP emissions of benzene,
cadmium, chromium, lead, methylene chloride, and nickel.  

The HAP emissions from this category can be broadly characterized by two
types of emission streams: volatiles and particulate.  Volatile HAP
emissions are a result of solvents that evaporate during the
manufacturing process, and include benzene and methylene chloride. 
Particulate HAP emissions occur from the handling of solid materials,
such as pigments, during the manufacturing process.  The particulate
HAPs for this listing are cadmium, chromium, lead, and nickel.  A
summary of the 1990 baseline emissions for the listed urban HAP for the
paints and allied products manufacturing industry in tons per year (TPY)
is presented in Table 1.

Table 1.  Urban Air Toxics Strategy HAP Emissions

Pollutant	1990 Baseline Area Source Urban HAP Listing (tpy)

Benzene	9.50

Cadmium	0.25

Chromium	6.73

Lead	10.8

Methylene Chloride	93.7

Nickel	0.131



Number of Facilities 

The 2002 Economic Census for the Paint and Coating Manufacturing,
Adhesive Manufacturing, Printing Ink Manufacturing, and the
Miscellaneous Chemical Product and Preparation Manufacturing – Writing
and Stamp Inks categories listed a total of 1,409 Paint and Coating
Manufacturing, 585 Adhesive Manufacturing, and 508 Printing Ink
Manufacturing establishments operating in the U.S.  For the
Miscellaneous Chemical Product and Preparation Manufacturing category,
the census only provided the number of writing and stamp ink
manufacturing facilities that had shipments over $100,000, which was
listed as 4 facilities.  To estimate the total number of writing and
stamp ink manufacturing facilities, we looked at the printing ink census
information and found that 51% of the facilities in that category had
shipments greater than $100,000.  We used this same percentage to
estimate the total number of writing and stamp ink manufacturing sector
and estimated 8 facilities in the stamp and writing ink category. 
Therefore the total inventory of paints and allied products
manufacturing facilities operating in the U.S. was estimated to be
2,510.  It was estimated that 2,190 of these facilities are area
sources, based on data obtained from the 2002 NEI database. The area
source total includes: 1,185 paint and coating manufacturing facilities,
509 adhesive manufacturing facilities, 488 printing ink manufacturing
facilities, and 8 writing and stamp ink manufacturing facilities.

3.0	DESCRIPTION OF THE MANUFACTURING PROCESS 

The Paints and Allied Products Manufacturing source category includes
establishments primarily engaged in the production of paints, inks,
stains, varnishes, shellacs, putties, sealers, caulks, adhesives and
other coatings, the intended use of which is to leave a dried film of
solid material on a substrate.  The manufacturing process may include,
but is not limited to, any combination of the following steps: weighing,
mixing, grinding, tinting, thinning, heating, cooking, flushing, and
packaging.  The coatings may be manufactured in liquid or solid form. 
The source category does not include the following: (1) products that do
not leave a dried film of solid material on the substrate, such as
thinners, paint removers, brush cleaners, and mold release agents; (2)
electroplated and electroless metal films; and (3) the manufacture of
the raw materials, such as resins, pigments, and solvents, used in the
production of paints and coatings.

Paints and coatings manufacturing can be classified as a batch process
and generally involves the blending and mixing of resins, pigments,
solvents, and additives.  This manufacturing process consists of four
major steps: 

•	Preassembly and premix; 

•	Pigment grinding, milling, and dispersing; 

•	Product finishing and blending; and 

•	Product filling and packaging.

A diagram of the process is shown in Figure 1 below, and the steps are
described in more detail in the following sections.

3.1	Preassembly and Premix

In the preassembly and premix step, raw materials are added to a high
speed dispersion tank to form an intermediate product referred to as the
base or mill base.  This high speed dispersion tank type may be fixed or
portable, depending on the batch size and type of coating produced.  The
raw materials added include resins, organic solvents, plasticizers, dry
pigment, and pigment extenders for solvent-based coatings, and water,
ammonia, dispersant, pigment, and pigment extenders for water-based
coatings.  

Ink manufacturing typically uses oils, resins, solvents, and driers as
raw materials.  The type of equipment used in the premix step depends on
the batch size and the type of coating being produced.  Drums equipped
with a portable mixer may be used for drum-sized batches; these mixers
normally have an impeller with three or four blades.  Other materials
made in portable mix tanks may be blended using larger, permanent
high-speed dispersers or variable-speed mixers fitted with paddle,
propeller, turbine, or disc-type agitators.  Coating manufacturing
facilities may use typical grinding equipment for premix operations. 
This approach, common with water-based paints and inks, eliminates the
need to transfer the material to another type of equipment for the
grinding/milling step described below.



Figure 1.  Basic Flow Sheet for Paints and Allied Products Manufacturing
Processes

3.2	Pigment Grinding or Milling

In this step, pigment is added to the liquid intermediate coating
product to yield fine particle dispersion via three stages: wetting,
grinding, and dispersion.  In the wetting step, a surfactant is used to
wet the pigment particles by displacing air, moisture, and gases that
are adsorbed on the surface of the pigment particles.  The grinding step
involves the mechanical breakup and separation of pigment clusters into
small particles.  This is normally done using pebbles, balls, or beads. 
The dispersion step mixes the wetted particles to form a particle
suspension.  The equipment depends on the type of pigment used in the
coating, and includes attritors, sand mills, bead and shot mills,
high-speed stone and colloid mills, high-speed dispersers, high-speed
impingement mills, and horizontal media mills.  High-speed dispersion is
the most common method of mixing in the paints and allied products
manufacturing industry.  Roller and ball mills are sometimes used;
however this equipment has become outdated because of high emissions of
volatile organic compounds (VOC) due to its more open design.  The use
of roller mills is normally used by manufacturers of very high quality
paint and inks and viscous pigmented products that require fine
dispersion and clean color.

3.3 	Product Finishing

In this step, the final product specifications for color, viscosity, and
other coating characteristics are met.  This generally consists of
thinning, tinting, and blending.  For solvent-based coatings and inks
this may involve the addition of various combinations of pigments,
organic solvents, and resins.  For water-based coatings, this typically
involves the addition of an antifoaming agent, a polyvinyl acetate
emulsion, and water.  Additional ingredients may be blended in to meet
product specifications through additional milling in a ball mill or
mixing and dispersing in a portable mix tank/high-speed disperser setup.

3.4 	Product Filling

The final step in the paint and allied products manufacturing process is
product filling.  Filtration removes impurities and catches small
particles of grinding media.  The product end use determines the type of
filtration required.  The most common methods include filtering through
a cloth bag filter or the use of equipment such as strainers or sieves. 
Once the coating has been filtered, it can be transferred into pails,
drums, totes, tank wagons, or other containers for shipment.  This
process may be completed either manually or mechanically depending on
the number and size of containers being filled.  

3.5	HAP Emission Points

The majority of volatile and particulate HAP emissions occur during the
four steps discussed above.  Volatile HAP is emitted through evaporation
and can occur any time during the manufacturing process.  Particulate
HAP emissions occur during the grinding, milling, and dispersing
processes.  Other sources of HAP emissions are raw material storage,
wastewater treatment operations, and equipment leaks.  The process
operations that generate the highest HAP emissions include: loading of
materials into the mixing tanks; heat-up losses during operation of the
high speed dispersers and mixers; surface evaporation during mixing,
blending, and dispersing; and filling losses that occur during transfer
into the receiving container.  In addition, miscellaneous operations
that can generate HAP emissions include: solvent reclamation; process
equipment cleaning; wastewater treatment of contaminated water generated
during the manufacturing process; storage of solvents, pigments, and
resins; equipment leaks; and accidental spills.	

Data obtained from the 2002 NEI database was used to determine the
source of HAP emissions from the paint and allied products manufacturing
process.  Using the source classification code (SCC) and the process
identification field, HAP emissions were broken into five process
categories.  The categories include;

Product manufacturing,

Combustion processes,

Raw material storage,

Equipment cleaning and fugitive emissions, and

Other miscellaneous processes.

Table 2 shows the percent of emissions from the major categories in the
manufacturing process.

The product manufacturing category comprises the four major steps
discussed earlier in this section.  The combustion process includes
emissions from boilers and process heaters used to produce heat and
steam for the manufacturing process.  The raw material storage category
includes emissions from fixed roof and floating roof storage tanks.  The
equipment cleaning and fugitive emissions category includes emissions
from equipment cleaning operations and fugitive emissions from the
facility.  The other miscellaneous processes category includes emissions
that were not identified in the SCC or process description.  These
emissions are believed to be either fugitive or wastewater HAP
emissions.  

 

The area source HAP emissions identified in the 2002 NEI database totals
1,406 Mg/year (1,550 tons/year).  A summary of the area source HAP
emissions by category is presented in Table 2.  The main source of HAP
emissions from the Paints and Allied Products Manufacturing sector
occurs during the manufacturing processes.  The majority of HAP
emissions from the area sources identified in the 2002 NEI database are
volatile HAP emissions, which comprise 1,403 Mg/year (1,546 tons/year)
of the total 1,406 Mg/year of HAP emissions.  Accordingly, the
particulate HAP totals 4.4 Mg/year (4 tons/year).

Table 2.  Paints and Allied Products Manufacturing Area Source HAP
Emissions

Category	HAP Mg/year (Ton/year)	Percentage of Total

Product Manufacturing	1,275  (1,406)	90.7

Combustion Processes	1.5  (1.6)	0.1

Raw Material Storage	13.5  (14.9)	1.0

Equipment Cleaning and Fugitive Emissions	36.7  (40.5)	2.6

Other Miscellaneous Processes	57.9  (63.8)	4.1

Paint Testing	20.0  (22.0)	1.4

	Source:  2002 NEI Database

EMISSION CONTROL TECHNIQUES

This section details techniques that are currently utilized by the
paints and allied products manufacturing industry to control organic HAP
and volatile organic compound (VOC) emissions.  

4.1 	Pollution Prevention- Common Practices

Common pollution prevention practices used in the Paints and Allied
Products Manufacturing category include;

Reformulation of coatings to water-based or low solvent products

Elimination of heavy metals and chlorinated compounds

Materials management 

Use of sandmills instead of ballmills.  

Distillation and re-use of waste solvents

Cleaning tanks with wipers and squeegees rather than solvents

Process tank covers

Many coating manufacturers now produce water-based, high solids, powder,
and radiation curable coatings that contain less solvent than
traditional coatings, thereby reducing HAP emissions.  Water-based
coatings may contain up to 80 percent water and 20 percent solids. 
These coatings emit less organic HAP and VOCs than conventional
solvent-based coatings, although they still contain 5 to 20 percent
solvent for wetting, viscosity control, and pigment dispersion. 
Coatings that contain greater than 60 percent solids by volume and
require some solvent to induce flow are generally considered high solids
coatings.  Powder coatings are produced from dry synthetic resins
pigments, solid additives and as much as 10 percent volatile compounds. 
Powder coatings contain no liquid solvents and typically do not produce
volatile emissions.    

In addition to reformulation, other pollution prevention practices
center around the re-use and management of materials used to manufacture
coatings.  Coating manufacturers reduce waste by minimizing stock,
returning unused materials to the supplier, using materials on a
first-in/first-out basis, and dating materials to avoid spoilage.  

Changes in manufacturing equipment have also reduced the emissions of
HAP from paint and allied products manufacturing processes.  The most
common change is to cover process and storage tanks to reduce material
addition, evaporative, and mixing losses.  Closed system and other
process equipment have also reduced the emissions of HAP.  Sandmills,
for example, are more efficient than the traditional ballmills and
require less solvent for cleaning.  In addition, new cleaning methods
have been established to reduce the use of solvents; for example,
equipment can be dedicated to a specific color or color ranges and does
not have to be cleaned as often. 

4.2 	Pollution Prevention Opportunities

Some of the pollution prevention opportunities in the Paints and Allied
Products Manufacturing sector include;

Materials tracking

High-pressure wash systems

Counter-current rinsing

Automated tank cleaning

Some manufacturers use software to more efficiently track and manage raw
materials.  These software programs can record raw material usage,
production, and generate hazardous waste and emission reports.  Using
material management software can also allow manufacturers to exchange or
sell unused resins, pigments, and raw materials to other manufacturers. 
 

A number of new cleaning techniques are becoming adopted in the paints
and allied products manufacturing industry, including high-pressure wash
systems and counter-current rinsing.  High-pressure wash systems use
pressurized water to remove product coating from the tank wall.  The
high pressure reduces the amount of cleaning liquid used, and therefore
the liquid waste generated.  Counter-current rinsing uses various levels
of spent solvent to clean process equipment.  The first rinse uses a
nearly spent solvent solution, followed with a second rinse of slightly
cleaner solvent, ending with a final rinse of clean solvent.  Automated
tank cleaning systems also reduce chemical and water consumption, along
with their related disposal costs.

 

4.3 	Add-on Control Devices

Organic HAP and VOC emissions from paints and allied products
manufacturing operations can be reduced through the use of add-on
control technology, including;

Capture devices

Oxidation control devices

Absorption control devices

Adsorption control devices

Condensation

UV oxidation

Filtration devices

4.3.1 	Capture Devices

Emissions from process areas can be captured using a total or partial
enclosure system.  Total enclosure systems completely enclose the
process area and duct all emissions to a control device or stack.  These
systems are common in facilities that use automated equipment to produce
coatings.  Partial enclosure systems are similar to total enclosures
except that the capture efficiency is less than 100 percent.

Capture systems can be designed to capture emissions from a particular
piece of processing equipment rather than the entire room by using
flexible duct work or a hood attached to a capture device.  The hood or
flexible duct can be moved from equipment to equipment during the
coating manufacturing process.

4.3.2 	Oxidation

HAP, VOC, carbon monoxide, and condensable organic particulate matter
emissions in an air stream may be destroyed by exposure to an oxidizing
atmosphere at high temperatures.  Oxidizers may be of thermal or
catalytic design and may use primary or secondary heat recovery to
reduce energy consumption.  Catalytic oxidizers employ a catalyst to aid
in the oxidation reaction, which helps lower the required combustion
temperature relative to that achieved in thermal oxidizers.  In general,
thermal oxidizers achieve destruction efficiencies of greater than 95
percent as applied to coating manufacturing operations with high and
constant concentrations of organic emissions.  Primary heat recovery
ranges from approximately 55 to 95 percent.

4.3.3 	Absorption 

The absorption process consists of contact between a gas stream and a
liquid so that one or more of the components of the exhaust stream will
dissolve in the liquid.  Water is the most common absorbent, but organic
solvents are also used. Removal efficiency can be enhanced by adding
reactive chemicals to the absorbent to either increase solubility of the
absorbed pollutant or to change the equilibrium. Some particulate matter
may also be removed by the liquid, although excessive particulate matter
can lead to plugging.

4.3.4	Adsorption

In adsorption, the unbalanced molecular forces on a solid surface
attract and retain gases and particulate matter that come in contact
with it. Several materials are widely used as the adsorbent, including
activated carbon, organic resin polymer, and inorganic materials; each
has substantial surface area per unit of volume.  Adsorption is used for
coating application operation exhaust streams at ambient temperature to
approximately 38°C (100°F).  Carbon adsorption removal efficiency is
dependent upon several factors, including the flow rate of the inlet air
stream, the inlet concentration of the pollutant, the chemical and
physical characteristics of the pollutant, and the bed design. Existing
systems have generally been designed for efficiencies between 90 to 95
percent, although efficiencies of up to 99 percent can be achieved in
some cases.

4.3.5	Condensation

Volatile compounds can be removed from gas streams by cooling the gas to
a temperature less than the dew point of the volatile compounds.  The
gas can be cooled using either direct or indirect heat exchangers, and
the typical coolant is cold water.  Refrigerant coolant is used for low
concentrations streams (i.e., less than 1 percent, or 10,000 ppmv). 
Condensation systems are typically not cost effective for low
concentration streams of varied composition.

4.3.6	UV Oxidation

An air stream is mixed with oxidants such as ozone and peroxide and
irradiated with ultraviolet (UV) light to produce highly reactive
hydroxy and oxygen radicals.  These radicals then react with the
organics in the air stream, converting them into carbon dioxide and
water.  The chemistry of this process is similar to that by which
sunlight degrades organics in the atmosphere.  UV/ozone oxidation
technology has been successfully demonstrated for controlling coating
manufacturing operation emissions.  This technology can achieve VOC
destruction efficiencies of greater than 95 percent.

4.3.7	Filtration Devices

Baghouses are the most commonly used control device for airborne dust
and particulate matter in the paint and allied products manufacturing
industry.  The baghouses are used with a capture device and typically
control emissions in the pigment loading area.  In addition to
baghouses, some facilities also use cartridge filters or cyclones.

5.0 	DATA SOURCES

An important consideration when determining GACT emission control
measures is prevalence of use in the industry.  To determine this, we
examined state permits, data from the 2002 NEI database, the
Miscellaneous Organics NESHAP (MON), and other sources (e.g.,
conversations with industry representatives).  When possible, the
information was separated by area source and major source status.  A
summary of the facilities and facility information provided in the state
permits is presented in Table 1 of the Appendix.

5.1	Process Vessels - Volatile HAP Emission Streams

5.1.1  	State Permit Data

Add-on Controls.  Add-on controls were listed for 9 facilities, and are
summarized in the Appendix in Table 2.  Only one true area source
reported an add-on control for volatile emissions, which was used on a
varnish mixing tank.  Two synthetic minor facilities reported using
add-on controls for volatile emissions.  One uses a thermal oxidizer to
control unspecified process emissions, the other uses a condenser to
control processing and holding tanks.  The other six facilities that
reported controls on volatile emission streams were major sources.  Two
of the major sources reported the use of a thermal oxidizer to control
emissions from paint manufacturing operations.  Another major source
used a thermal oxidizer on paint manufacturing operations and also used
a stripping column on wastewater treatment operations.  A major source
that produces both resins and paints reported the use of a thermal
oxidizer only on the resin manufacturing operations, which are not in
this source category.  One major source facility reported using a
condenser, although it is only used for resin manufacturing.  The final
major source used a carbon adsorber to control emissions from raw
material storage tanks.

Assuming that both synthetic minor and area sources will be subject to
the area source rule, about 10 percent (3 out of a total of 29 area and
synthetic minor sources) of these facilities for which permits were
obtained reported controls on volatile emission streams.  If all of the
permit data is considered without regard to area source status, about 18
percent (9 out of a total of 50 facilities) of the facilities used
add-on controls on volatile emissions streams.

Management Practices and Housekeeping Measures.  Many of the permits
also listed various management practices and housekeeping measures, such
as covering tanks and solvent containers when not in use.  Management
practices and housekeeping requirements were specified in the permits
for 16 facilities and are summarized in Table 3 in the Appendix. 
Management practices or housekeeping measures were reported for 28
percent of the area source and synthetic minor facilities and for 38
percent (8 of 21 facilities) of the major sources.

5.1.2  	2002 NEI Data

Add-on Controls.  Add-on control devices for HAP emissions were reported
for 52 facilities, 12 area source and 40 major source.  Some of the
control devices listed for these facilities are typically used for
particulate matter control and have little or no effect on volatile HAP
emissions, but only those technologies that apply to volatile HAP
emissions were counted for this section.  Only 8 of the 665, or 1.2
percent, of the area source facilities used control equipment for
volatile HAP control.  A summary of the descriptions is provided in
Table 4 in the Appendix.  For major source facilities, 23 of 326
facilities (7.1 percent) used control technology that reduces volatile
HAP.  A summary of the volatile control descriptions for major sources
is shown in the Appendix in Table 5.

Management Practices and Housekeeping Measures.  The NEI database did
not include any management practices or housekeeping measures for the
control of volatile HAP from these sources.  Therefore, no information
can be provided on the prevalence of these measures for reducing HAP
emissions.  

5.2	Process Vessels - Particulate HAP Emission Streams

5.2.1  	State Permit Data

Add-on Controls.  Add-on control devices for particulate HAP emissions
were reported by a total of 35 out of 50 facilities (70 percent) for
which permits were obtained.  For area source and synthetic minor
facilities, about 79 percent (23 out of 29 facilities) of the facilities
used add-on controls for particulate HAP emissions.  Major sources used
particulate HAP control at a rate of about 57 percent (12 out of 21
facilities).  This information is summarized in Table 6 of the Appendix.

According to the permit data, not all process vessels where particulate
HAP emissions may originate, or storage silos where solid raw materials
are stored, are equipped with particulate HAP controls.  An attempt was
made to determine whether there was a minimum tank size that was
controlled, but there were not sufficient data to ascertain any trends. 


Management Practices and Housekeeping Measures.  The permits did not
provide any specific information for management practices or
housekeeping measures for reducing emissions of particulate HAP. 
However, many of the management practices and housekeeping measures used
to reduce the emissions of volatile HAP are appropriate for reducing
emissions of particulate HAP.

We also examined the State permits for particulate HAP emission rate
information after control.  Although many of the permits provided an
equation for allowable particulate emissions in terms of the process
weight rate, there was very little information on the process weight
rates themselves.  Therefore, particulate HAP emission rate data for use
in the GACT analysis could not be established.

5.2.2.  2002 NEI Data

Add-on Controls.  Only 31 of the 665 paint manufacturing facilities
identified in the NEI database listed a particulate HAP control device
(4 area sources, 27 major sources).  A summary of the facilities and
add-on particulate control is presented in the Appendix in Table 7. 
This reported use directly contradicts that listed in the permits.  One
possible explanation is that the particulate control devices are not
typically used for regulatory compliance purposes.  The facilities may
simply be trying to avoid worker exposure and reduce potentially
hazardous inorganic emissions (e.g., chromium, cadmium, and lead
compounds), and did not list the particulate controls in the reports
compiled for the NEI.  For these reasons, we believe that the permit
data provide a more accurate depiction of particulate control device use
in the paints and allied products manufacturing industry.  

Management Practices and Housekeeping Measures.  The NEI database did
not include any management practices or housekeeping measures for the
control of particulate HAP from these sources.  Therefore, no
information can be provided on the prevalence of these measures for
reducing HAP emissions.  

5.3	Storage Vessels – Volatile and Particulate HAP

Data from State permits were reviewed for information on volatile and
particulate HAP controls for storage vessels.  No controls were reported
for any of the facilities (area or major sources) for paint
manufacturing operations.  In general, however, the permits were found
to contain little usable information regarding controls on storage
vessels.  Consequently, the background information for the storage
vessel MACT floor analysis for the major source paint manufacturing
NESHAP was reviewed to determine if there are controls that may be
applicable to area sources.  This documentation stated that the MACT
floor for storage vessels at major sources was no control, and above the
floor options were considered to have (reasonable( cost effectiveness
values only for storage vessels above 20,000 gallons.  According to the
available permit data, all of the storage vessels at area source
facilities were below 10,000 gallons.

5.4	Wastewater Treatment Operations – Volatile and Particulate HAP

The State permits and NEI database were reviewed for information related
to air emission controls for wastewater treatment operations.  None were
found.  To look at options, we therefore reviewed the background
information for the major source paint manufacturing NESHAP.  According
to this documentation, the MACT floor was established to be controls on
wastewater streams with a HAP concentration of at least 4,000 ppmw.  The
cost effectiveness of this level of control was estimated to be
$28,700/Mg.  No information on the HAP concentration in wastewater
streams at area source paint manufacturing facilities was available;
therefore, no assessment can be made on whether the major source level
of control may be applicable to area sources.

5.5	Equipment Leaks – Volatile HAP

According to the information reported in the State permits, none of the
area source facilities reported leak detection and repair (LDAR)
programs.  One major source reported an LDAR program, but it was limited
to railcar unloading operations.  The background information for the
major source paint manufacturing NESHAP states that a visual inspection
program equivalent to the bulk gasoline terminal NESHAP was determined
to be the MACT floor, with a cost effectiveness of $1,690/Mg.  Because
there is no information on the number and type of piping connections at
area source facilities, we cannot make a determination on whether this
level of control and cost effectiveness is applicable to area source
paints and allied products manufacturing facilities.

6.0	HAP CONTROL TECHNOLOGY SUMMARY

The data indicate that controls to reduce volatile HAP were used only
sparingly on process vessels, as reported in both the State permits and
the NEI database.  This is probably due to the absence of federal
regulation of this industry and a lack of specific State or local rules
other than general VOC and air toxics rules.  Another factor that may
contribute to the lack of existing volatile HAP control may be the
generally high capital investment needed for add-on control devices. 
Taken together, these factors have produced little incentive to control
these emissions, and may explain why volatile HAP controls are not
prevalent in the industry.  

The data analysis showed that add-on controls for particulate HAP
emissions from process vessels are widespread throughout the industry. 
The permits indicated that 7 of 8 area source and 15 of 20 synthetic
minor source facilities used add-on controls for particulate emissions. 
However, there are neither federal regulations for particulate emissions
from paints and allied products manufacturing operations nor concerted
State or local regulatory efforts to explain the difference in the level
of control between particulate emissions and volatile emissions.  The
analysis showed that both the total capital investment and the annual
costs of particulate HAP controls are far less than volatile HAP
controls, which helps explain this difference.  However, we assume that
the use of particulate HAP controls is driven by factors other than just
costs.  Concerns such as workplace safety the environmental effects of
inorganic HAP emissions, and in some cases OSHA regulations, probably
override simple cost considerations.  

The area source facilities appear to use little if any controls on
storage vessels, wastewater treatment operations, and equipment leaks. 
The background information for the major source rule provided some
insight into emission controls for these operations.  However, the
information could not be directly transferred to the area source
analysis due to a lack of specific data (e.g., concentration of
pollutants in wastewater streams and number and type of fittings at area
source facilities).  



APPENDIXTable 1.  Summary of Facility Information as Reported in State
Permits

Facility Name and Location	Status	SIC Code	Emission Streams Controlled?



	Volatiles	Particulate



U.S. Ink

Jacksonville, FL	Area	2893	No	Yes



ChemRex, Inc.

Ft. Wayne, IN	Area	2851	No	Yes



A.F. Wolke Paint Co.

Corydon, IN	Area	2851	Insufficient information	Insufficient information



Iowa Paint Manufacturing Co.

Des Moines, IA	Area	2851	No	Yes



Vogel Paint & Wax Co.

Orange City, IA	Area	2851	No	Yes



Sun Chemical

Hopkinsville, KY	Area	2893	Yes	Yes



Textured Coatings of America

Panama City, FL	Area	2851	No	Yes



American Inks and Coatings

Pine Bluff, AR	Area	2893	No	Yes



Jellico Chemical Co.

Louisville, KY	Area	2851	No	No



Matthews Paint

Pleasant Prairie, WI	Area	2851	Yes	Yes



Engineered Polymer Solutions

Elkhart, IN	Synthetic Minor	2851	No	Yes



Engineered Polymer Solutions

Indianapolis, IN	Synthetic Minor	2851	No	Yes



Plasti-Kote Co.

Medina, OH	Synthetic Minor	2851	No	No



DAP, Inc.

Tipp City, OH	Synthetic Minor	2851	Yes	Yes



Table 1.  Summary of Facility Information as Reported in State Permits

(Continued)

Facility Name and Location	Status	SIC Code	Emission Streams Controlled?



	Volatiles	Particulate



Red Devil, Inc.

Pryor, OK	Synthetic Minor	2891	No	Yes



Delta Laboratories

Ocala, FL	Synthetic Minor	2851	No	No



Baker Paint Mfg.

St. Petersburg, FL	Synthetic Minor	2851	No	Yes



Ameron International

Little Rock, AR	Synthetic Minor	2851	No	Yes



NCP Coatings

Mishawaka, IN	Synthetic Minor	2851	No	Yes



Morton International

Warsaw, IN	Synthetic Minor	2851	No	Yes



H.B. Fuller Co.

Elkhart, IN	Synthetic Minor	2891	No	Yes



Elpaco Coating Corp.

Elkhart, IN	Synthetic Minor	2851	No	No



Davie Imperial Coatings

Hammond, IN	Synthetic Minor	2851	No	Yes



HyKlas Paints

Louisville, KY	Synthetic Minor	2851	No	No



Progress Paint Co.

Louisville, KY	Synthetic Minor	2851	No	Yes



PPG Architectural Finishes, Inc.

(Courtaulds Coatings)

Louisville, KY	Synthetic Minor	2851	No	Yes



Blatz Paint Co.

Louisville, KY	Synthetic Minor	2851	No	No



Marcus Paint Co.

Louisville, KY	Synthetic Minor	2851	No	Yes

Table 1.  Summary of Facility Information as Reported in State Permits

(Continued)

Facility Name and Location	Status	SIC Code	Emission Streams Controlled?



	Volatiles	Particulate



PPG Architectural Finishes, Inc.

(Porters Paints)

Louisville, KY	Synthetic Minor	2851	No	Yes



Color Corporation of America

(Valspar Corp)

Louisville, KY	Synthetic Minor	2851	No	Yes



Engineered Polymer Solutions

Ft. Wayne, IN	Major	2851	No	Yes



CP Inc.

Connersville, IN	Major	2851	No	No



Color Converting Industries

Des Moines, IA	Majora	2893	No	Yes



Sherwin-Williams Auto Finishes

Richmond, KY	Major	2851	Yes	Yes



PPG Industries

Delaware, OH	Major	2851	Yes	Yes



PPG Industries

Cleveland, OH	Major	2851	Yes	Yes



Sherwin-Williams

Bedford Heights, OH	Majorb	2851	Yes	No



BASF Corp.

Greenville, OH	Majorc	2851	Yes	No



Star Bronze, Inc.

Alliance, OH	Majord	2851	No	No



Siegwerk, Inc.

Lynchburg, VA	Major	2893	No	No



DuPont

Front Royal, VA	Majore	2851	Yes	Yes



Table 1.  Summary of Facility Information as Reported in State Permits

(Continued)

Facility Name and Location	Status	SIC Code	Emission Streams Controlled?



	Volatiles	Particulate



Coronado Paint Co.

Edgewater, FL	Major	2851	No	Yes



Valspar Industries

Little Rock, AR	Major	2851	No	Yes



Bondo Corp.

Atlanta, GA	Majorf	2851	No	Yes



PPG Industries

East Point, GA	Major	2851	No	Yes



Worwag Coatings

Lafayette, IN	Major	2851	No	No



Uniroyal Technology Corp.

South Bend, IN	Major	2891	No	Yes



Red Spot Paint & Varnish Co.

Evansville, IN	Major	2851	No	No



Patriot Paint Co.

Portland, IN	Major	2851	No	No



IVC Industrial Coatings

Indianapolis, IN	Major	2851	No	No



Flint Ink

Warsaw, IN	Major	2893	No	Yes



a No HAP emissions listed in the permit.  Major source status based on
VOC PTE of 250 tpy.

b No HAP emissions listed in the permit.  Major source status based on
VOC PTE of 125 tpy.

c No HAP emissions listed in the permit.  Major source status based on
VOC PTE of 295 tpy.

d No HAP emissions listed in the permit.  Major source status based on
VOC PTE of 95 tpy.

e No HAP emissions listed in the permit.  Major source status based on
VOC PTE of 175 tpy.

f No HAP emissions listed in the permit.  Major source status based on
VOC PTE of 49 tpy.

Table 2.  Summary of Add-on Controls for Volatile Emissions Used by

Paints and Allied Products Manufacturing Facilities as Reported in State
Permits

Facility	

Major or Area Source	

Controlled Operation	

Control Measure	

Comments



Sun Chemical

Hopkinsville, KY	

Area	

Varnish mixing tanks	

Condenser followed by water scrubber	





Matthews Paint

Pleasant Prairie, WI	

Area	

Manufacturing operations	

Thermal oxidizer	

Oxidizer used to limit emissions to synthetic minor levels



DAP, Inc.

Tipp City, OH	

Synthetic Minor	

Adhesive processing and holding tanks	

Condenser	





Sherwin-Williams

Richmond, KY	

Major	

Steam heated resin reactor tanks and thinning tanks for resin
manufacturing	

Condenser	

Resin manufacturing is not part of the source category



PPG

Delaware, OH	

Major	

Resin reactor tanks; solvent recovery distillation	

Thermal oxidizer	

Resin manufacturing is not part of the source category



PPG

Cleveland, OH	

Major	

Mills; process tanks; mixers; lab operations	

Thermal oxidizer	





Sherwin-Williams

Bedford Heights, OH	

Major	

Propellant filling and propellant line purging operations	

Thermal oxidizer	





Table 2.  Summary of Add-on Controls for Volatile Emissions Used by

Paints and Allied Products Manufacturing Facilities as Reported in State
Permits

(Continued)

Facility	

Major or Area Source	

Controlled Operation	

Control Measure	

Comments



BASF

Greenville, OH	

Major	

Resin reactor tanks; wastewater treatment (process water from resin
manufacturing); clearcoat manufacturing; solvent recovery; wastewater
storage tank; fuel oil storage tank	

Stripping column (wastewater treatment)

Thermal oxidizer (all other operations)	

Resin manufacturing and fuel oil storage are not part of the source
category



DuPont

Front Royal, VA	

Major	

Raw material storage tanks	

Carbon adsorber	



	Table 3.  Summary of Management Practice and Housekeeping Measures as
Reported in State Permits

Company/Location	

Status	

Management Practices and Housekeeping Measures



Textured Coatings of America

Panama City, FL	

Area	

1. VOC storage containers must be kept covered.

2. Minimize leaks, fugitives, and spills.



Matthews Paint

Pleasant Prairie, WI	

Area	

1. All portable mixing tanks must be covered except to add ingredients
or take samples.  Lids must extend ( inch past outer rim and be
maintained in good condition such that contact is maintained along 90%
of rim.  Can allow for clearance for mixer shaft.

2. All stationary tanks covered except to add ingredients or to take
samples.



Engineered Polymer Solutions

Indianapolis, IN	

Synthetic minor	

Waste solvent kept in closed containers



PlastiKote Co.

Medina, OH	

Synthetic minor	

Dispersers and mixers must be covered



DAP, Inc.

Tipp City, OH	

Synthetic minor	

Tanks must be covered



Red Devil, Inc.

Pryor, OK	

Synthetic minor	

Containers with VOC must be kept tightly closed when not in use.  Rags
must be placed in covered containers.



Delta Laboratories

Ocala, FL	

Synthetic minor	

1. Close all VOC containers when not in use.

2. Cover tanks, troughs, basins when not in use.

3. Maintain piping, valves, fittings in good condition.

4. Prevent excessive air turbulence across exposed VOC.

5. Immediately confine and clean up VOC spills and place material in
closed containers.



Table 3.  Summary of Management Practice and Housekeeping Measures as
Reported in State Permits

(Continued)

Company/Location	

Status	

Management Practices and Housekeeping Measures



Blatz Paint Corp.

Louisville, KY	

Synthetic minor	

VOC storage tanks 250 - 40,000 gal limited to vapor pressure of less
than 1.5 psia or install submerged fill pipe



PPG Industries

Delaware, OH	

Major	

High speed dispersers covered with lid at all times except when adding
ingredients or taking samples.



PPG Industries

Cleveland, OH	

Major	

1. Stationary process vessels equipped with tightly fitting vented cover
when averaging.

2. Subpart HHHHH:  portable and stationary process vessels must be
equipped with cover or lid whenever vessel contains HAP.

3. All mixing and blending tanks must be equipped with cover or lid that
completely covers opening of tank except for safe clearance of mixing
shaft.  Cover must be kept closed except when adding ingredients or
taking samples.



Star Bronze, Inc.

Alliance, OH	

Major

	

Mix tanks must be enclosed



DuPont

Front Royal, VA	

Major

	

Open equipment for conveying or transporting materials likely to create
objectionable air pollution must be covered



Coronado Paint Co.

Edgewater, FL	

Major	

1. Close all VOC containers when not in use.

2. Cover tanks, troughs, basins when not in use.

3. Maintain piping, valves, fittings in good condition.

4. Prevent excessive air turbulence across exposed VOC.

5. Immediately confine and clean up VOC spills and place material in
closed containers.



Table 3.  Summary of Management Practice and Housekeeping Measures as
Reported in State Permits

(Continued)

Company/Location	

Status	

Management Practices and Housekeeping Measures



Bondo Corp.

Atlanta, GA	

Major

	

1. Portable and stationary mixing tanks must be equipped with covers
that completely cover the tank except for safe clearance of mixer shaft.
 Must be kept covered at all times except when operator access is
necessary.

2. Free fall of VOC materials must be accomplished by utilizing drop
tubes, fill pipes, or low-clearance equipment design.



Siegwerk, Inc.

Lynchburg, VA	

Major	

Open equipment for conveying or transporting materials likely to create
objectionable air pollution must be covered



PPG Industries

East Point, GA	

Major	

1. Portable and stationary mixing tanks must be equipped with covers
that completely cover the tank except for safe clearance of mixer shaft.
 Must be kept covered at all times except when operator access is
necessary.

2. Free fall of VOC materials must be accomplished by utilizing drop
tubes, fill pipes, or low-clearance equipment design.

Table 4.  Summary of Add-on Controls for Volatile Emissions Used by
Area Source

Paints and Allied Products Manufacturing Facilities as Reported in the
2002 NEI Database

Facility	Controlled Operation(s)	Control Measure	Comments



DeGussa Construction Chemicals Operation

Brighton, CO	

Breather Vent of WC100 UST

Xylene UST	

Vapor recovery system	

System include condensers, hooding, and other enclosures



DeGussa Construction Chemicals Operation

Brighton, CO	

HLM packaging line	

Activated carbon adsorption	





U.S. Polymers

St. Louis, MO	

(2) Process tanks 

(2) Closed kettle varnish thinning

(3) Resin thinning tank	

Tube and shell condenser	





Sovereign Pkg Group

Phoenixville, PA	

 (2) Mixers	

Tube and shell condenser	





Engineered Polymer Solutions

Birmingham, AL	

Fixed roof VOC tank	

Submerged filling	

12,000 gallon tank



Engineered Polymer Solutions

Birmingham, AL	

Fixed roof VOC tank	

Miscellaneous control devices	

Not specified in NEI database



NCP Coatings

Mishawaka, IN	

Paint mixing line	

Miscellaneous control devices	

Not specified in NEI database



Lenmar Inc

Baltimore, MD	

Paint mixing and handling equipment	

Miscellaneous control devices	

Not specified in NEI database



Tnemec Company

Baltimore, MD	

Paint mixing and handling equipment	

Condenser	



Table 4.  Summary of Add-on Controls for Volatile Emissions Used by Area
Source

Paints and Allied Products Manufacturing Facilities as Reported in the
2002 NEI Database

(Continued)

Facility	Controlled Operation(s)	Control Measure	Comments



Rust-Oleum Corporation

Williamsport, MD	

Paint mixing and handling equipment	

Afterburner	

Flare



Table 5.  Summary of Add-on Controls for Volatile Emissions Used by
Major Source

Paints and Allied Products Manufacturing Facilities as Reported in the
2002 NEI Database

Facility	Controlled Operation(s)	Control Measure	Comments



MRX Facility

Brownwood, TX	

(4) Tandem maker ovens	

Direct flame afterburner	

Coating oven



Cook Composites and Polymers

North Kansas City, MO	

Resin production	

Thermal oxidizer	





E I DuPont de Nemours

Front Royal, VA	

(3) Paint and resin manufacturing units	

Activated carbon adsorption	

Ethyl acrylate, methyl methacry, styrene



P D George Co.

St Louis, MO	

(2) Thinning tanks	

Tube and shell condenser	





Kelly-Moore Paint Co

Hurst, TX	

(2) Monomer storage tanks	

Vapor recovery system	

System include condensers, hooding, and other enclosures



Mid-West Industrial Chemical

St. Louis, MO	

(4) 10,500 gal storage tank

(3) 4,300 gal storage tank	

Bottom filling	

Tanks are fixed roof



GE Sealants and Adhesives 

Fort Worth, TX	

(4) Underground storage tanks

Reactor	

Vapor recovery system	

System include condensers, hooding, and other enclosures



Foster Products Corp.

Houston, TX	

Batch Mixer	

Vapor recovery system	

System include condensers, hooding, and other enclosures



Eastman Resins

Pleasant Prairie, WI	

Resin production	

Direct flame afterburner	





Table 5.  Summary of Add-on Controls for Volatile Emissions Used by
Major Source

Paints and Allied Products Manufacturing Facilities as Reported in the
2002 NEI Database

(Continued)

Facility	Controlled Operation(s)	Control Measure	Comments



Magni Industries

Independence, KY	

Paint manufacturing process	

Miscellaneous control devices	

Not specified in NEI database



Dow Corning

Elizabeth, KY	

Not specified	

Miscellaneous control devices	

Not specified in NEI database



Sherwin Williams Auto Finishes 

Richmond, KY	

(3) Resin reactors	

Vapor recovery system	

System include condensers, hooding, and other enclosures



Royston Laboratories

Pittsburgh, PA	

 MEK storage tank	

Conservation vent	





Elmers Products

Bainbridge, NY	

Polymerization reactors 	

Refrigerated condenser	





Cytec Engineered Materials

Havre de Grace, MD	

Solvent mixing	

Condenser	





Sherwin-Williams Company

Baltimore, MD	

Varnish manufacturing process

Storage tank	

Miscellaneous control devices	

Not specified in NEI database



DuPont Performance Coatings

Fort Madison, IA	

Pigment handling	

Condenser	





Table 5.  Summary of Add-on Controls for Volatile Emissions Used by
Major Source

Paints and Allied Products Manufacturing Facilities as Reported in the
2002 NEI Database

(Continued)

Facility	Controlled Operation(s)	Control Measure	Comments



DuPont Performance Coatings

Fort Madison, IA	

(6) Thinner blending tanks

Solvent recovery unit

Product training spray booths

Thinner filling machine	

Miscellaneous control devices	

Not specified in NEI database



Iowa Paint Tech & Manufacturing Center

Des Moines, IA	

(8) Paint mixing tanks

(3) Product finishing

(2) Lab spray paint booths

(3) Storage tanks

Tank washer

Pigment grinding & milling

Sandmill

Oil base dilling line	

Miscellaneous control devices	

Not specified in NEI database



Poly One Corporation

St. Louis, MO	

Ball and sand mill	

Process enclosed	

Fugitive emissions



Poly One Corporation

St. Louis, MO	

Lacquer mixing handling	

Submerged filling	

Fugitive emissions



Blending Facility

Irving, TX	

(7) Mixers	

Tray type gas absorption	





Blending Facility

Irving, TX	

(1) Reactor

(5) Mixers	

Gas Scrubber	





Blending Facility

Irving, TX	

(2) Reactors	

Vapor recovery system	

System include condensers, hooding, and other enclosures

Table 5.  Summary of Add-on Controls for Volatile Emissions Used by
Major Source

Paints and Allied Products Manufacturing Facilities as Reported in the
2002 NEI Database

(Continued)

Facility	Controlled Operation(s)	Control Measure	Comments



Paint Mfg

Garland, TX	

Reactor

Resin Building	

Direct Flame Afterburner	





Watson Standard Company

Pittsburgh, PA	

Mixer	

Process enclosed	

Fugitive emissions



Lymtal International

Lake Orion, MI	

Natural gas boiler	

Activated carbon adsorption	



Table 6.  Summary of Add-on Controls for Particulate Matter Emissions
Used by

Paints and Allied Products Manufacturing Facilities as Reported in State
Permits

Company/Location	

Status	

Particulate Controls	

Operations Controlled	

Size of Tanks Controlled	

Emission Limitsa



US Ink

Jacksonville, FL	

Area	

Portable and stationary dust collectors	

Color mixing tanks (portable dust collectors)

Carbon black handling (stationary dust collectors)	

Not listed	

0.78 lb/hr, 3.4 tpy for each stationary dust collector

No limits on portable dust collectors



ChemRex, Inc.

Ft. Wayne, IN	

Area	

Baghouse	

Storage silos

Mixing and filling line	

Silos - 45 and 85 tons

Mixing tanks - 50 to 2,500 gals.	

E = 4.10P0.67



Iowa Paint Manufacturing Co.

Des Moines, IA	

Area	

Baghouse	

Mixers and dispersers	

Dispersers - 1,250 gal

Mixers - not listed	

0.1 gr/scf, 3.21 lb/hr, 14.08 tpy



Vogel Paint & Wax Co.

Orange City, IA	

Area	

Dust collector	

Pigment silo

Mixing tanks	

Not listed	

0.1 gr/scf each dust collector



Textured Coatings of America

Panama City, FL	

Area	

Dust collector	

Paint manufacturing	

Not listed	

Not listed



Table 6.  Summary of Add-on Controls for Particulate Matter Emissions
Used by

Paints and Allied Products Manufacturing Facilities as Reported in State
Permits

(Continued)

Company/Location	

Status	

Particulate Controls	

Operations Controlled	

Size of Tanks Controlled	

Emission Limitsa



American Inks and Coatings

Pine Bluff, AR	

Area	

Dust collectors	

Not listed	

Not listed	

0.1 lb/hr, 0.1 tpy



Sun Chemical

Hopkinsville, KY	

Area	

Dust collector	

Resin dump station	

Not listed	

E = 3.59P0.62



Matthews Paint

Pleasant Prairie, WI	

Area	

Dust collector	

Paint manufacturing	

Not listed	

1.0 lb/hr



Engineered Polymer Solutions

Elkhart, IN	

Synthetic minor	

Baghouse	

Gelcoat mixing	

1 tank - 1,000 gal

7 tanks - 1,100 gal

2 tanks - 1,200 gal

2 tanks - 2,400 gal	

E = 4.10P0.67



Engineered Polymer Solutions

Indianapolis, IN	

Synthetic minor	

14 Portable baghouses

2 Stationary baghouses	

Dry ingredient handling

Raw material loading	

Not listed	

E = 4.10P0.67



DAP, Inc.

Tipp City, OH	

Synthetic minor	

Fabric filters	

Mixing tanks	

3 - 350 gal	

0.069 lb/hr each mixer (AP-42)



Red Devil, Inc.

Pryor, OK	

Synthetic minor	

Baghouse	

Powdered material silos, Mixers	

Mixers - 5 to 1,000 gal	

Overall - 2.0 tpy

Table 6.  Summary of Add-on Controls for Particulate Matter Emissions
Used by

Paints and Allied Products Manufacturing Facilities as Reported in State
Permits

(Continued)

Company/Location	

Status	

Particulate Controls	

Operations Controlled	

Size of Tanks Controlled	

Emission Limitsa



Baker Paint Manufacturing

St. Petersburg, FL	

Synthetic minor	

Baghouse	

Pigment handling	

Not listed	

Not listed



Ameron International

Little Rock, AR	

Synthetic minor	

Dust collector	

Mills

Mixers

Tanks	

Not listed	

5.4 lb/hr, 68.2 tpy



NCP Coatings

Mishawaka, IN	

Synthetic minor	

Dust collector	

Mixing tanks

Holding tanks	

Not listed	

11.3 lb/hr each mixing line



Morton International

Warsaw, IN	

Synthetic minor	

Cyclone and dust collector

Dust collection system	

Mills

Weigh-up and blending

Extrusion area	

Not listed	

Mills - 4.76 lb/hr, 1.64 tpy

Weigh-up and blending - 8.6 lb/hr, 0.34 tpy

Extrusion - 8.6 lb/hr, 0.21 tpy



H.B. Fuller Co.

Elkhart, IN	

Synthetic minor	

Baghouse	

Mixers	

Not listed	

0.68 to 5.38 lb/hr

E = 4.10P0.67



Davies Imperial Coatings

Hammond, IN	

Synthetic minor	

Bag filter	

Bag dump operations	

Not listed	

Overall - 10.8 lb/h

Table 6.  Summary of Add-on Controls for Particulate Matter Emissions
Used by

Paints and Allied Products Manufacturing Facilities as Reported in State
Permits

(Continued)

Company/Location	

Status	

Particulate Controls	

Operations Controlled	

Size of Tanks Controlled	

Emission Limitsa



Progress Paint Co.

Louisville, KY	

Synthetic minor	

Baghouse	

Mixers	

Not listed	

Not listed



PPG Architectural Finishes, Inc. (Courtaulds Coatings)

Louisville, KY	

Synthetic minor	

Baghouse

Cartridge filter	

Coating manufacturing	

Not listed	

Not listed



PPG Architectural Finishes (Porters Paints)

Louisville, KY	

Synthetic minor	

Bag filters

Dust collector	

Dispersers

Latex manufacturing	

Not listed	

Not listed



Color Corporation of America (Valspar Corp.)

Louisville, KY	

Synthetic minor	

Bag filter	

Premix	

Not listed	

Not listed



Marcus Paint Co.

Louisville, KY	

Synthetic Minor	

Dust collector	

Paint manufacturing	

Not listed	

Not listed



Table 6.  Summary of Add-on Controls for Particulate Matter Emissions
Used by

Paints and Allied Products Manufacturing Facilities as Reported in State
Permits

(Continued)

Company/Location	

Status	

Particulate Controls	

Operations Controlled	

Size of Tanks Controlled	

Emission Limitsa



Engineered Polymer Solutions

Ft. Wayne, IN	

Major	

Baghouse	

15 Premix tanks

2 Portable mixers

2 Dispersion mixers	

Not listed	

Paint manuf. - 4.28 lb/hr

Paint fill line - 2.0 lb/hr

Bentone mixing - 3.4 lb/hr



Color Converting Industry

Des Moines, IA	

Major	

Dust collector	

Mixing operations

Waterbased product mixing	

Not listed	

3.9 lb/hr, 16.89 tpy



Sherwin-Williams Auto Finishes

Richmond, KY	

Major	

Dust collector	

Dry base weigh and mix

Small batch mixers

Mixers, dispersers	

Small batch - 5 to 120 gal

Mixers - 5 to 8,000 gal

Dispersers - 250 to 1,400 gal	

39.9 lb/hr



PPG

Delaware, OH	

Major	

Fabric filters

Baghouse	

Resin reactor system

Dispersers	

Not listed	

Resin reactors - 2.13 lb/hr, 2.1 tpy

Dispersers - 0.003 to 2.24 lb/hr



PPG

Cleveland, OH	

Major	

Dust collector

Baghouses	

Paint manufacturing	

Not listed	

1.4 lb/hr, 6.0 tpy

Table 6.  Summary of Add-on Controls for Particulate Matter Emissions
Used by

Paints and Allied Products Manufacturing Facilities as Reported in State
Permits

(Continued)

Company/Location	

Status	

Particulate Controls	

Operations Controlled	

Size of Tanks Controlled	

Emission Limitsa



DuPont

Front Royal, VA	

Major	

Fabric filters	

Paint manufacturing

Resin manufacturing	

Not listed	

E = 4.10P0.67



Coronado Paint

Edgewater, FL	

Major	

Baghouse	

Paint manufacturing	

Not listed	

Not listed



Valspar Industries

Little Rock, AR	

Major	

Dust collectors	

Not listed	

Not listed	

2.1 lb/hr, 1.8 tpy



Bondo Corp.

Atlanta, GA	

Major	

Baghouses	

Storage silos

Dispersers

Mixers

Putty line

Dynaglass line

Elgin line

Simplex line

Packaging line

Primer mix line	

Not listed	

E = 4.10P0.67



Uniroyal Technology Corp.

South Bend, IN	

Major	

Dust collectors	

Mixing tanks	

55 to 2,000 gal (total of 16 tanks)	

Not listed



Table 6.  Summary of Add-on Controls for Particulate Matter Emissions
Used by

Paints and Allied Products Manufacturing Facilities as Reported in State
Permits

(Continued)

Company/Location	

Status	

Particulate Controls	

Operations Controlled	

Size of Tanks Controlled	

Emission Limitsa



Flint Ink

Warsaw, IN	

Major	

Baghouse	

Dry material handling	

Not listed	

E = 4.10P0.67



PPG Industries

East Point, GA	

Major	

Dust collectors	

Paint manufacturing	

Not listed	

E = 4.10P0.67

a E=allowable emission rate, P=process weight rate.

Table 7.  Summary of Add-on Controls for Particulate HAP Emissions Used
by

Paints and Allied Products Manufacturing Facilities as Reported in the
2002 NEI Database

Company/Location	

Status	

Particulate Controls	

Operations Controlled



EPS Inc.

Elkhart, IN	

Area	

Mat or panel filter	

(2) Spray booth



Alpha Systems 

Elkhart, IN	

Area	

Mat or panel filter	

(2) Mold prep operations



INX International Ink Company

Charlotte, NC	

Area	

Fabric filter – Medium temperature	

Organic dyes and pigments



Chemcraft International

Winston-Salem, NC	

Area	

Fabric filter – Low temperature	

Paint manufacturing mixing and handling



MRX Facility

Brownwood, TX	

Major	

Gravel bed filter	

(4) Drum mixers

(2) Kettle mixers



Quad/Greenfield LLC

Greenfield, IA	

Major	

Single cyclone	

(3) Dispersion unit



Valspar Corporation

Garland, TX	

Major	

Fabric filter – Medium temperature	

Latex paint manufacturing

Paint mixing building



Not specified

Mineral Wells, TX	

Major	

Fabric filter – Medium temperature	

Powder addition process



Macco Adhesive Glidden

Temple, TX	

Major	

Fabric filter – Medium temperature	

Adhesive mixing

Table 7.  Summary of Add-on Controls for Particulate HAP Emissions Used
by 

Paints and Allied Products Manufacturing Facilities as Reported in the
2002 NEI Database

(Continued)

Company/Location	

Status	

Particulate Controls	

Operations Controlled



Sherwin-Williams Company

Garland, TX	

Major	

Fabric filter – Medium temperature	

(2) High speed dispersion mills



Kelly-Moore Paint Company 

Hurst, TX	

Major	

Fabric filter – Medium temperature	

Paint plant building fugitives



International Paint Inc

Houston, TX	

Major	

Fabric filter – Medium temperature	

(2) Paint mixing and handling areas



Not specified

Houston, TX	

Major	

Fabric filter – Low temperature	

(2) Paint booths



Ici Paints

Carrollton, TX	

Major	

Fabric filter – Medium temperature	

(10) Raw material storage areas



Poly One Corporation

St Louis, MO	

Major	

High efficiency particulate air filter (HEPA)	

Plastisol manufacturing fugitives



Vogel Paint & Wax

Orange City, IA	

Major	

Single cyclone	

Pigment grinding

Silo



E I DuPont de Nemours

Front Royal, VA	

Major	

Fabric filter – Low temperature	

Paint & resin manufacturing



Not specified

Fort Worth, TX	

Major	

Fabric filter – Low temperature	

Tote tank booth



Table 7.  Summary of Add-on Controls for Particulate HAP Emissions Used
by 

Paints and Allied Products Manufacturing Facilities as Reported in the
2002 NEI Database

(Continued)

Company/Location	

Status	

Particulate Controls	

Operations Controlled



Not specified

Fort Worth, TX	

Major	

Fabric filter – Medium  temperature	

Paint mixing area

Mixing building



Valspar Coatings

Grand Prairie, TX	

Major	

Fabric filter – Medium temperature	

Mixing process



Champion Coatings

Houston, TX	

Major	

Fabric filter – Medium temperature	

Coatings production building



Eastman Resins

Pleasant Prairie, WI	

Major	

Fabric filter – Low temperature	

Mixing and handling process

Pigment handling



Sheboygan Paint Company

Sheboygan, WI	

Major	

Mat or panel filter	

Mixing and handling process



Ceramic Industrial Coatings

Osseo, MN	

Major	

Fabric filter – Low temperature	

(4) Storage tanks



Chemical Coatings Inc

Hudson, NC	

Major	

Baghouse	

Paint mixing/blending areas



Sherwin-Williams Company

Greensboro, NC	

Major	

Baghouse	

Paint manufacturing



Engineered Polymer Solutions

Statesville, NC	

Major	

Baghouse	

Latex paint manufacturing 

Table 7.  Summary of Add-on Controls for Particulate HAP Emissions Used
by 

Paints and Allied Products Manufacturing Facilities as Reported in the
2002 NEI Database

(Continued)

Company/Location	

Status	

Particulate Controls	

Operations Controlled



Blending Facility

Irving, TX	

Major	

Fabric filter – Medium temperature	

Slurry mixer



DuPont Performance Coatings

Fort Madison, IA	

Major	

Baghouse	

(5) Thinner blend tanks

Solvent recovery unit

Lab spray booths

Thinner filling machine

Latex resin production



DuPont Performance Coatings

Fort Madison, IA	

Major	

Fabric filter	

Latex resin production

PM dust collector



DuPont Performance Coatings

Fort Madison, IA	

Major	

Single cyclone	

(7) Thinner blend tanks

Solvent recovery unit

Lab spray booths

Thinner filling machine

PM dust collector



DuPont Performance Coatings

Fort Madison, IA	

Major	

Water sprays	

PM dust collector



Table 7.  Summary of Add-on Controls for Particulate HAP Emissions Used
by 

Paints and Allied Products Manufacturing Facilities as Reported in the
2002 NEI Database

(Continued)

Company/Location	

Status	

Particulate Controls	

Operations Controlled



Iowa Paint Tech & Manufacturing Center

Des Moines, IA	

Major	

Baghouse	

(12) Mixing tanks

(3) Product finishing lines

(2) Lab spray booth

Sandmill

Oil base dilling line

(3) Resin storage tanks

Latex filling line

(2) Tank washer

Lightning mixers

Pigment grinding



Iowa Paint Tech & Manufacturing Center

Des Moines, IA	

Major	

Single cyclone	

(5) Mixing tanks

(2)  Lab spray booth

Lightning mixers

Pigment grinding



Iowa Paint Tech & Manufacturing Center

Des Moines, IA	

Major	

Water sprays	

Cowells mixing tank



Table 7.  Summary of Add-on Controls for Particulate HAP Emissions Used
by 

Paints and Allied Products Manufacturing Facilities as Reported in the
2002 NEI Database

(Continued)

Company/Location	

Status	

Particulate Controls	

Operations Controlled



Iowa Paint Tech & Manufacturing Center

Des Moines, IA	

Major	

Spray dryer	

(9) Mixing tanks

 (2) Lab spray booth

Sandmill

Oil base dilling line

Latex filling line

Lightning mixers

Pigment grinding



Color Converting Industries

Des Moines, IA	

Major	

Spray dryer	

(7) Product finishing mix tank and dispersers

(3)  Mixers



 The 2002 NAICS codes and industry descriptions were obtained from the
U.S. Census website, http://www.census.gov/epcd/www/naics.html.

 Paint and Coating Manufacturing: 2002, U.S. Department of Commerce,
Economics and Statistics Administration, February 2005.

 Adhesive Manufacturing: 2002, U.S. Department of Commerce, Economics
and Statistics Administration, December 2004.

 Printing Ink Manufacturing: 2002, U.S. Department of Commerce,
Economics and Statistics Administration, December 2004.

 All Other Miscellaneous Chemical Product and Preparation Manufacturing:
2002, U.S. Department of Commerce, Economics and Statistics
Administration, December 2004.

 Emission Inventory Improvement Program, Volume II: Chapter 8, Methods
for Estimating Air Emissions from Paint, Ink, and Other Coating
Manufacturing Facilities, February 2005

 Emission Inventory Improvement Program, Volume II: Chapter 8, Methods
for Estimating Air Emissions from Paint, Ink, and Other Coating
Manufacturing Facilities, February 2005

 Although not specifically listed in all of the permits for the major
sources, the National Emission Standards for Hazardous Air Pollutants
(NESHAP) for Miscellaneous Coating Manufacturing (40 CFR 63, subpart
HHHHH) specifies certain work practice standards that apply to all major
sources.

 For example, an equation seen in several permits was E = 4.10P0.67,
where E is the allowable PM emission rate and P is the process weight
rate.

 Memorandum from David Randall and Jennifer Fields, Midwest Research
Institute, to MON Project File.  February 15, 2000.  MACT Floor,
Regulatory Alternatives, and Nationwide Impacts for Storage Tanks at
Coating Manufacturing Facilities.

 Memorandum from Brenda Shine, North State Engineering, and David
Randall, Midwest Research Institute, to MON Project File.  March 1,
2000.  MACT Regulatory Alternatives and Impacts for Wastewater at
Surface Coating Facilities.

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