  SEQ CHAPTER \h \r 1 MEMORANDUM

DATE:	February 5, 2009

SUBJECT:	Population and Baseline HAP Emissions for the Paint and Allied
Products Area Source Category  SEQ CHAPTER \h \r 1 

FROM:	Bradley Nelson, EC/R Inc.

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

1.0	INRODUCTION

The purpose of this memorandum is to estimate the facility population
and baseline emissions for the Paint and Allied Products Manufacturing
source category.  Data from the 2002 National Emissions Inventory (NEI)
were used to calculate facility emission factors for each of the urban
air toxics.  In addition, data from the 2002 Census were used to
estimate the total population of paint and allied products manufacturing
facilities in the inventory.

2.0	BACKGROUND

Section 112(k) requires the development of standards for area sources
that account for 90% of the emissions of each of the 30 HAPs listed for
urban areas, as prescribed by the Integrated Urban Air Toxics Strategy
(UATS).  The Paint and Allied Products Manufacturing area source
category was added to the listed categories pursuant to section
112(c)(3) and 112(k)(3)(B)(ii) in November 2002 (67 FR 70427).  The UATS
listed the Paint and Allied Products Manufacturing category as a
category that accounts for a proportion of the 90% emissions for 6 of
the targeted 30 area source air toxic pollutants: benzene, cadmium,
chromium, lead, methylene chloride, and nickel.  The goals of the UATS
reflect both the statutory requirements stated in Section 112(k) and the
goals of EPA’s overall air toxics program. 

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 sectors include
NAICS codes 325510 (Paint and Coating Manufacturing), 325520 (Adhesive
Manufacturing), 325910 (Printing Ink Manufacturing), and 325998
(Miscellaneous Chemical Product and Preparation Manufacturing –
Writing and Stamp Inks).  

3.0	POPULATION

The 2002 U.S. Economic Census for Paint and Coating Manufacturing,
Adhesive Manufacturing, Printing Ink Manufacturing, and Miscellaneous
Chemical Product and Preparation Manufacturing was used to estimate the
total number of paint and allied products establishments or facilities. 
The census listed 1,409 Paint and Coating Manufacturing, 585 Adhesive
Manufacturing, and 508 Printing Ink Manufacturing establishments
operating in the U.S. in 2002.  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 were 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 a total of 8 facilities in the stamp and writing
ink category.  Therefore the total population of paint and allied
products manufacturing facilities is estimated to be 2,510 facilities
operating in the U.S.

The next step was to estimate the number of area source paint and allied
products manufacturing facilities that were operating in the U.S. in
2002.  A search of the 2002 NEI database was conducted using the
following paint and allied products manufacturing NAICS codes: 325510,
325520, 325910, and 325998.  This generated a list of 981 facilities;
320 facilities were classified as major sources, and 665 facilities were
classified as area sources.  

The census does not provide information on whether facilities are major
or area sources.  To estimate whether the 1,529 (2,510 – 981)
facilities in the Census but not reported in the 2002 NEI are major or
area sources, data collected for the Miscellaneous Organic NESHAP (MON)
were reviewed.  The Basis and Purpose Document for the MON listed 127
major sources operating in the coatings manufacturing source category. 
The 2002 NEI database identified 320 facilities as major sources; we
subsequently believe that the NEI database has captured the total number
of major sources in the Paint and Allied Products Manufacturing
category.  Therefore, we assumed that all 1,529 facilities from the 2002
Census not in the 2002 NEI were area sources.  Therefore, we estimate a
total of 2,190 total area sources in the paint and allied products
manufacturing category.  Table 2 lists, by NAICS code, the facilities
identified in the 2002 NEI database and the unidentified facilities
based on the census count.  

Table 2.   Paint and Allied Products Manufacturing Facilities: 

(2002 NEI Database and the 2002 Census Count)

NAICS	2002 Census Number of Facilities	2002 NEI Number of Major Source
Facilities	2002 NEI Number of Area Source Facilities	Census Facilities
Not In The  NEI	Total Estimated Area Source Facilities1

325510 – Paint & Coating Manufacturing	1,409	224	450	735	1,185

325520 – Adhesive Manufacturing	585	76	142	367	509

325910 – Printing Ink Manufacturing	508	20	69	419	488

325998 – Writing and Stamp Ink Manufacturing	8	0	4	4	8

Total	2,510	320	665	1,525	2,190

1 The total estimated number of area source facilities includes the area
source facilities identified in the 2002 NEI plus the census facilities
not in the NEI.

4.0	ESTIMATION OF BASELINE HAP EMISSIONS 

To estimate baseline emissions for the paint and allied products
manufacturing area source category, we used the emissions data from the
2002 NEI database.  The NEI database was used because the database
provided not only more facilities than the Toxics Release Inventory
(TRI), but also provided process information, major and area source
designations, and control technology information.  The NEI database
provided HAP emissions for 665 area source facilities, whereas the TRI
only provided pollutant information for 434.  We compared the pollutant
emissions from facilities that were in both the NEI and TRI database and
found that the emission totals were comparable.  Tables that present the
comparisons between the NEI and TRI data are presented in Appendix C.   


To estimate HAP emissions from area source facilities not represented in
the NEI, we calculated an emission factor for each of the urban air
toxic pollutants in each of the NAICS categories.  The urban air toxic
emission factors were calculated by summing the total individual urban
air toxic emissions and dividing by the number of facilities reporting
that urban air toxic.  The emission factor is a ton per facility factor
since no production data were available.  

Because not all facilities emit the same air toxic pollutants, we used a
ratio approach to estimate the emissions from the facilities without
emissions data.  The ratio was calculated by dividing the total number
of sources reporting an individual urban air toxic pollutant by the
total number of facilities in that NAICS category.  This emissions
estimation approach assumes that the unidentified facilities emit HAPs
based on the same area source distribution as the facilities in the 2002
NEI database.  For example, only 59 of the 450 area source Paint and
Coating Manufacturing (NAICS 325510) facilities reported emissions for
benzene in the NEI.   This may be due to the facility not using benzene
or materials with benzene in their manufacturing process, or because of
under-reporting of benzene emissions to the NEI database.  For the
purposes of these calculations, we made the assumption that those
facilities that did not report emissions for an individual urban air
toxics pollutant did not have emissions of that pollutant in 2002. 
Therefore, the ratio of facilities that reported emissions for each
individual urban air toxic pollutant also applies to the undefined area
source facilities.  Following is an example of how the benzene emissions
were calculated for NAICD 325510.

Example of the Benzene Emissions Calculation (NAICS 325510)

This example shows the benzene emission calculation for the Paint and
Coating Manufacturing sector (NAICS 325510).  The example uses the ratio
of facilities reporting benzene emissions in the 2002 NEI database and
the average emissions per reporting facility, and multiplies this value
by the number of unidentified area source facilities.

(735) * (59/450) * (0.00338 Ton/yr) = 0.326 Ton/yr

Where:

735 = Number of area source 325510 facilities in the Census that did not
report HAP emissions in the 2002 NEI database;

59 = Number of area source 325510 facilities that reported benzene
emission in the 2002 NEI database;

450 = Total number of area source 325510 facilities that reported HAP
emissions in the 2002 NEI database;

0.00338 Ton/yr = Average benzene emissions of 59 area source 325510
facilities that reported benzene emissions in the 2002 NEI.  The total
benzene emissions reported by these 59 facilities was 0.199 tons/yr;

0.326 Ton/yr = Total estimated benzene emissions for the area source
325510 facilities that did not report HAP emissions in the 2002 NEI
database.

The total benzene baseline emissions for the Paint and Coating
Manufacturing category are calculated by summing up the benzene
emissions reported in the 2002 NEI database with the estimated benzene
emissions from the area source facilities that did not report HAP
emissions to the 2002 NEI database.  The example calculation for benzene
is shown below;

0.326 Ton/yr + 0.199 Ton/yr = 0.525 Ton/yr

Where:

0.326 Ton/yr = Total estimated benzene emissions for the area source
325510 facilities that did not report HAP emissions in the 2002 NEI
database; 

0.199 Ton/yr = Total benzene emissions from the area source 325510
facilities reported in the 2002 NEI database;

0.525 Ton/yr = Total benzene emissions for the area source 325510
facilities.

Table 3 presents a summary of the baseline emissions for each of the
listed urban HAP (benzene, cadmium, lead, methylene chloride, and
nickel), in addition to other urban HAP that were reported in the 2002
NEI database.  A summary of the calculations and emission factors used
to calculate the baseline emissions for each of the NAICS categories is
presented in Table A-1 in Appendix A.  

	The baseline total HAP emissions for the Paint and Allied Products
Manufacturing category were calculated by developing a total HAP
emission factor for each NAICS code and multiplying that by the total
number of facilities for that NAICS code that were not contained in the
NEI.  A summary of the total HAP emissions for each of the NAICS
categories and the total HAP emissions for the paint and allied products
manufacturing category are presented in Table A-2 in Appendix A. 

4.0	SUMMARY OF RESULTS 

	The total baseline HAP emissions for the Paint and Allied Products
Manufacturing industry category were estimated to be 4,761 Tons/yr from
area source facilities.  This total includes listed urban HAP emissions
of 0.588 Tons/yr for benzene, 0.00963 Tons/yr for cadmium (includes both
cadmium and cadmium & compounds), 2.28 Tons/yr for chromium (includes
both chromium and chromium & compounds), 4.05 Tons/yr for lead (includes
both lead and lead & compounds), 213 Tons/yr for methylene chloride, and
1.40 Tons/yr for nickel.  A summary of the urban HAP emissions are
presented in Table 3 and Table A-2 in Appendix A.  Appendix B presents a
summary of the estimated individual urban and non urban HAP pollutant
emissions for the paint and allied products manufacturing sector.

Table 3.   2002 Urban Area Source Air Toxics Baseline Emissions

For NAICS Categories 325510, 325520, 325910, 325998

Urban Air Toxics Pollutant	2002 Baseline Air Toxics Area Source
Emissions (Ton/yr)

Benzene	0.588

Cadmium	0.00343

Cadmium & Compounds	0.00662

Chromium	0.344

Chromium & Compounds	1.94

Lead	0.192

Lead & Compounds	3.86

Methylene Chloride	213

Nickel	1.05

Nickel & Compounds	0.349

Acrylonitrile	1.03

Formaldehyde	9.20

Manganese	0.00901

Manganese & Compounds	0.0780

Mercury	0.000498

Mercury & Compounds	0.00179

Tetrachloroethylene	5.42

Trichloroethylene	40.0

Total HAP	4,761

Note:  Shaded cells indicate individual air toxic pollutants contributed
by the Paint and Allied Products Manufacturing category to the 90% total
emissions from area sources, and are listed for reduction in the UATS.

 

Appendix A

Area Source Baseline Urban HAP Emissions by NAICS Code

 









Appendix B

Area Source Baseline HAP Emissions by Pollutant

 







Appendix C

2002 NEI/TRI HAP Data Comparison





 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.

 Basis and Purpose Document for Proposed Standards, Hazardous Air
Pollutant Emissions from Miscellaneous Organic Chemical Manufacturing
and Miscellaneous Coating Manufacturing. U.S. EPA, September 2001.

 Based on the 2002 Census data, EPA is assuming that all of the writing
and stamp ink manufacturing facilities are area sources.

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