  SEQ CHAPTER \h \r 1 MEMORANDUM

DATE:	February 16, 2009

SUBJECT:	Development of HAP Reduction Costs for the Paints and Allied
Products Manufacturing 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	INTRODUCTION

This memorandum presents the development of costs for hazardous air
pollutants (HAP) control technologies to reduce the emissions of
volatile and particulate HAP from uncontrolled area source paints and
allied products manufacturing facilities.  This analysis is in support
of the development of National Emission Standards for Hazardous Air
Pollutants (NESHAP) for the Paints and Allied Products Manufacturing
area source 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 will look at pollution prevention measures and
control technologies that are currently utilized by the Paints and
Allied Products Manufacturing industry to control hazardous air
pollutant (HAP) emissions.  The memorandum will also present the tools
and assumptions used to estimate capital and annual costs of the HAP
reduction techniques or technologies.

2.0	BACKGROUND

Section 112(k) requires the development of standards for area sources
that account for 90 percent of the emissions of the 30 HAPs listed for
urban areas, as prescribed by the Integrated Urban Air Toxics Strategy
(UATS).  The 30 HAPs were specifically identified as being emitted from
smaller industrial sources known as “area” sources.  The Paints 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 Paints and Allied
Products Manufacturing category as one of the area sources that account
for a proportion of the 90 percent emissions for 6 of the targeted 30
area source air toxic pollutants: benzene, cadmium, chromium, lead,
methylene chloride, and nickel, and is therefore subject to standards. 
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.  

3.0  	CATEGORY DESCRIPTION AND INDUSTRY CHARACTERIZATION

The population of paints and allied products manufacturing was presented
in the memorandum, Population and Baseline HAP Emissions for the Paints
and Allied Products Area Source Category.  In this memorandum, we
estimated a total of 2,510 facilities from all the categories.  We
estimated that 2,190 of these 2,510 facilities are area sources.  A
breakdown of 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
facilities.

The Paints and Allied Products Manufacturing source category comprises
of establishments primarily engaged in the production of paints, inks,
adhesives, stains, varnishes, shellacs, putties, sealers, caulks, 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 paints and 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.

Paint and coatings manufacturing can be classified as a batch process
and generally involves the blending and mixing of resins, pigments,
solvents, and additives.  Traditional paint and allied products
manufacturing consists of four major steps: 

Preassembly and premix; 

Pigment grinding, milling, and dispersing; 

Product finishing and blending; and 

Product filling and packaging.

	The majority of volatile and particulate HAP emissions occur during
these four major steps.  Volatile HAP is emitted due to evaporation
during the manufacturing process.  Particulate HAP emissions occur
during the grinding, milling, and dispersing processes.  Other sources
of HAP emissions include raw material storage, wastewater treatment
operations, and equipment leaks.  The process operations that generate
the highest HAP emissions include: emissions from 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 can generate
HAP emissions and include: solvent reclamation during the purification
of dirty or spent solvent; cleaning of the process equipment; wastewater
treatment of contaminated water generated during the manufacturing
process; material storage of solvents, pigments, and resins; equipment
leaks from the transport of stored materials to the process; and
accidental spills during manufacturing and cleaning activities.

	To understand the sources of HAP emissions from the paints and allied
products manufacturing industry, the Source Classification Codes (SCC)
and the individual HAP emissions from each of these SCC’s were
extracted from the 2002 NEI database.  The sorted results showed that
nearly 91 percent of HAP emissions occur during the product
manufacturing process.  A summary is presented in Table 2.  

			

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

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

Product Manufacturing	1,406  (1,275)	90.7

Combustion Processes	1.60  (1.45)	0.103

Raw Material Storage	14.9  (13.5)	0.961

Equipment Cleaning and Fugitive Emissions	40.5  (36.7)	2.61

Other Miscellaneous Processes	63.8  (57.9)	4.12

Coating Application Testing	22.0  (20.0)	1.42

	Source:  2002 NEI Database

4.0	MODEL PLANTS

	To provide the best possible estimate of control technology costs, the
paints and allied products manufacturing facilities were divided by size
into two different model plant categories, “small” and “large.” 
The small model plant was assumed to have 19 employees or less, and was
estimated to produce 167,000 gallons of paint and allied products per
year.  The large model plant was assumed to have 20 or more employees
and was estimated to produce 1,050,000 gallons of coatings per year. 
The model plants are discussed in more detail in the memorandum, Model
Plants for Paints and Allied Products Manufacturing Area Sources.  This
memorandum also estimated the emissions of particulate matter (PM),
particulate matter less than 2.5 microns (PM2.5), volatile organic
compounds (VOC), HAP, volatile HAP, and particulate HAP for each of the
model plants using the estimated production rates.  A summary of these
estimated uncontrolled pollutant emissions for each of these model
plants is presented in Table 3. 

Table 3.  Summary of HAP, PM, and VOC Uncontrolled Emissions from the 

Paints and Allied Products Manufacturing Model Plants

Model Plant	Estimated Plant Production (Gal/yr)	PM Emissions

(Tons/yr)	PM2.5 Emissions

(Tons/yr)	VOC Emissions (Tons/yr)	HAP Emissions (Tons/yr)	Volatile HAP
Emissions (Tons/yr)	Particulate HAP Emissions (Tons/yr)

Small	167,000	5.58	2.64	15.7	1.549	1.545	0.004

Large	1,050,000	35.1	16.6	98.4	9.733	9.710	0.023



5.0	HAP REDUCTION OVERVIEW

As shown in Table 2, the product manufacturing process step is the
largest source of HAP emissions from the paints and allied products
manufacturing sector.  This step involves the addition and mixing of
components in a process vessel into the final product.  Emissions of HAP
occur from splash loading of volatile organic chemicals into the process
vessel, evaporation of volatile organic chemicals during the mixing
process, and fugitive particulate emissions from the addition of dry
pigments to the process vessel.  The data indicate that control
technology for volatile HAP was used only sparingly on process vessels,
as reported in both the state permits and the NEI database.  Paint
industry representatives indicated that most paints and allied products
manufacturing facilities use covers on their process vessels to reduce
the loss of volatiles.  Data from State permits and site visits indicate
that management practices and housekeeping measures appear to be more
prevalent in the industry for control of volatile HAP emissions.  

Particulate HAP emissions occur during the addition of pigments or other
solids to the process vessel.  These pigments or solids are typically in
a powder form, however many manufacturers are now using these solids in
a cake or paste medium.  The data analysis showed that add-on controls
for particulate HAP emissions from process vessels are widespread
throughout the industry.  The state operating permits that were obtained
indicated that 79 percent (23 of 29) of the area source and synthetic
minor source facilities used add-on controls for particulate emissions. 


6.0	HAP EMISSION REDUCTION COSTS

Costs for reducing emissions of volatile and particulate HAP were
calculated using information from the Miscellaneous Organic Chemical
Manufacturing NESHAP (MON), information obtained from vendors, EPA's Air
Compliance Advisor (Version 7.5), and the EPA Air Pollution Control Cost
Manual.  In this section, the control technology costs are separated
into two categories; control technology for volatile HAP, and control
technology for particulate HAP.  

6.1	Volatile HAP Control Costs

A review of control technology used by paints and allied products
manufacturing facilities showed that only a few facilities use add-on
control technology (e.g., condenser, carbon absorber, thermal oxidizer)
to reduce the emissions of volatile HAP.  From the information gathered,
volatile emissions streams from process vessels in this industry have a
very low concentration of volatiles, typically less than 300 parts per
million by volume (ppmv), and may consist of a mixture of several
volatile compounds.  Because of this low concentration, many control
devices applicable to volatile emission streams would not be technically
feasible because of the drop off in removal efficiency at these lower
concentrations, excessive energy requirements to achieve high reduction
efficiency, or problems with reducing a mixture of volatile compounds. 
For example, EPA documentation states that condensers are used as air
pollution control devices for treating emission streams with high VOC
concentrations (usually > 5,000 ppmv) in applications involving
gasoline bulk terminals, storage, etc.  Carbon adsorbers generally are
not effective on emission streams containing a mixture of volatile
compounds because VOCs with lower vapor pressures will displace those
with higher vapor pressure already adsorbed by the carbon.  Therefore it
was concluded that for these low concentration streams, the most
feasible choice for add-on control is a thermal oxidizer, and we limited
our cost calculations for volatile HAP emission streams to this control
device.  

6.1.1	Thermal Oxidation Cost

The EPA's Air Compliance Advisor (Version 7.5) was used to estimate the
annual cost of using thermal oxidation.  The inlet stream
characteristics were derived from information provided by the National
Paint and Coatings Association (NPCA) in their comments on the draft
miscellaneous organics NESHAP (MON).  In these comments, NPCA provided
stack test data that included HAP concentration and flow rates for 36
emission streams at 10 paints and allied products manufacturing
facilities of various sizes in the form of a histogram.  Based on this
histogram, the majority of emission streams had a HAP concentration of
no more than 300 parts per million volume (ppmv) and a flow rate of
1,750 cubic feet per minute (cfm), the midpoint of the range 1,000 to
2,500 cfm as shown on the histogram.  This midpoint was used as the
exhaust flow rate in the Air Compliance Advisor program for both the
small and large model plants.  The concentration of the exhaust stream
was calculated using the VOC emissions from each of the model plant
facilities.  The VOC emissions were used to provide a better estimate of
the heating value of the exhaust stream.  For the small plant, the
annual VOC emissions are 15.7 tons per year (Ton/yr).  Assuming 250 days
per year and 8 hours per day, the hourly VOC emissions were calculated
to be 15.7 pounds per hour (lb/hr).  This hourly VOC emission rate was
converted to 626 ppmv using the 1,750 cfm exhaust flow rate and using
the molecular weight of toluene.  Toluene was used because it is a
represents the HAP with the highest emission rate for the paints and
allied products manufacturing sector.  For the large model plant, the
annual VOC emissions are 98.4 Ton/yr.  Using the same assumptions for
the small model plants, the hourly VOC emission rate was calculated to
be 98.4 lb/hr and the VOC concentration was calculated to be 3,921 ppmv.
 The VOC concentrations for each of the model plants and the exhaust
flow rate were used to calculate the control technology costs.  A
summary of the capital cost, annual cost, and cost per ton for each of
the thermal oxidation control technologies are presented in Table 4. 

Table 4.  Summary of Thermal Oxidation Cost per Ton for

Paints and Allied Products Manufacturing Facilities

Model Plant	Control Technology	Total Capital Investment	Annual Cost	HAP
Cost per Ton ($/Ton HAP reduced)1

Small	Fixed Bed Catalytic Incinerator	$172,162	$47,553	$31,407

	Fluidized Bed Catalytic Incinerator	$218,584	$56,120	$37,065

	Recuperative Thermal Incinerator	$281,953	$70,121	$46,312

Large	Fixed Bed Catalytic Incinerator	$205,368	$51,721	$5,435

	Fluidized Bed Catalytic Incinerator	$256,985	$61,078	$6,419

	Recuperative Thermal Incinerator	$297,228	$66,728	$7,012

1 Assumes 98% reduction of HAP.  

Note: Capital and annual costs were escalated from February 2003 dollars
to 2006 dollars using the Marshall & Swift Equipment Cost Index (2003
– 1,123.6, 2006 – 1,302.3).

6.1.2	Process Vessel Cover Cost

Process vessel covers used at paints and allied products manufacturing
facilities can be: metal, plastic, and wood.  Each type of material
offers the same volatile emissions reduction capabilities, and the only
differences are cost and expected life of material.  The most economical
choice of material to use is wood.  Plywood was used to determine the
process vessel cover HAP reduction costs for the model plants.  The
equipment cost of a 4 feet x 8 feet, ¾” BC exterior plywood was
obtained from a local lumber supply store and was found to be $32.44. 
Assuming no direct installation cost, indirect installation costs, or
contingencies, the capital cost of a single sheet of plywood was
calculated to be $38.28.  This cost was comparable to other lumber
supply stores around the U.S. for similarly sized and grade plywood
sheets.  The next step was to determine what size process vessels that a
sheet or sheets of plywood could cover.  The maximum diameter of process
vessel that a single sheet of plywood could cover was determined by
assuming a 1 inch overhang of the plywood on the process vessel and
using the shortest side of the plywood (i.e., 4 feet).  Using these
assumptions, the maximum diameter of process vessel that could be
covered using a single sheet of plywood was determined to be 46 inches. 
Assuming the process vessel is approximately 3 feet in height, the
volume of the process vessel was estimated to be 259 gallons.  The
maximum diameter of process vessel that two sheets of plywood could
cover was determined by assuming a 1 inch overhang of the plywood on the
process vessel and using the longest side of the plywood (i.e., 8 feet).
 Using these assumptions, the maximum diameter of process vessel that
could be covered using two sheets of plywood was determined to be 94
inches.  Using a height of 4 feet, the volume of the process vessel was
estimated to be 1,441 gallons.  

Using this process vessel size and plywood cost information; two plywood
process vessel cover costs were estimated.  For small process vessels,
the capital and annual costs for a 46 inch diameter (4 feet by 4 feet)
plywood process vessel cover were estimated to be $19.14 and $2.73
respectively.  For large process vessels, the capital and annual costs
were estimated to be $75.56 and $10.90 respectively for a 94 inch
diameter (8 feet x 8 feet) process vessel cover.   Annual costs were
calculated assuming a 10-year equipment life, 7 percent interest rate,
and a capital recovery factor of 0.142.

Information on the number of process vessels was obtained from the
Paints and Allied Products Manufacturing model plant memorandum.  The
memorandum listed an average of 17 mixing process vessels for minor
source facilities and 129 mixing process vessels for major source
facilities.  The mixing process vessels from these facilities range from
50 gallons to 2,000 gallons in size, with a median size in the 500-1000
gallon size range.  For this analysis, the small model plants will be
assumed to have 17 mixing process vessels, and the large model plants
will be assumed to have 129 mixing process vessels.  The number of
process vessels that are in use and would need to covered at any given
time was estimated to be approximately 15 percent, using information
provided by the NPCA.  Therefore, the number of process vessel covers
needed was estimated to be 3 for a small model plant and 19 for a large
model plant.  The size of the process vessels were assumed to be evenly
distributed, therefore 50 percent of the process vessels would use 46
inch size process vessel covers and 50 percent of the process vessels
would use 96 inch size process vessel covers.   

Previous studies by the EPA indicated that process vessel covers can
reduce volatile emissions from process vessels by about 40 percent.  The
NPCA concurred with this estimate for paint manufacturing mixing tanks
in their comments on the proposed major source NESHAP.  Therefore, this
percentage was used to estimate the volatile HAP reductions associated
with adding covers to process vessels.  A summary of the annual costs
and the calculated cost per ton of using process vessel covers are
presented in Table 5.

Table 5.  Summary of Costs for Adding Covers to Process Vessels to
Model Plants

Model Plant	Uncontrolled Facility VOC Emissions (Ton/yr)	Uncontrolled
Facility Volatile HAP Emissions (Ton/yr)	Total Facility Capital Cost of
Process Vessel Covers	Total Facility Annual Cost of Process Vessel
Covers	Cost Effectiveness ($/Ton VOC reduced)2	Cost Effectiveness ($/Ton
volatile HAP reduced)2

Small	15.7	1.545	$122	$17	$2.77	$28.11

Large	98.4	9.710	$926	$132	$3.35	$33.94

1 The total facility capital and annual cost is the total annual cost
for applying covers to the mixing process vessels in use at the model
plant (e.g. small – 3 , large – 19).

2 Assumes 40% reduction of VOC and HAP.

	Another type of process vessel cover is the disposable “shower cap”
type cover.  The disposable cover is equipped with elastic around the
outside edge of the cover which allows the cover to be secured to the
process vessel.  The cover also has a center hole with elastic to allow
the mixing shaft to be put through during mixing.  The disposable cover
cost ranges from $1.56 (30” diameter) to $3.60 (80” diameter).  To
estimate the annual cost of using the disposable covers, we assumed the
facility operates 250 days out of the year, $3.37 cost per cover (60”
diameter), 15 percent of the process vessels are used during the day,
and the disposable covers are used for 2 days.  Using these assumptions,
the annual cost of using disposable covers at a small model plant is
$1,074, and the annual cost of using disposable covers for a large model
plant is $8,151.  This calculates to a HAP cost per ton of $1,738 per
ton of volatile HAP reduced for a small model plant, and $2,099 per ton
of HAP reduced for a large model plant.  The cost per ton of VOC was
calculated to be $171 and $1,298 per ton of VOC reduced for the small
and large model plants respectively.

6.2	Particulate HAP Emission Control Costs

Two types of particulate HAP control methods are currently being used in
the Paints and Allied Products Manufacturing industry.  The first is a
mechanical collection device that removes the particulate matter from
the exhaust stream.  Typical particulate collection devices used by the
industry include; baghouses, venturi scrubbers, and electrostatic
precipitators (ESP).  The second type of particulate HAP control used by
the industry is the substitution of wetted or paste pigments for dry
pigments.  The wetted or paste pigments are in a solid or semi-solid
format and do not emit particulate HAP emissions when handled. 
Generally, baghouses and vent systems are used at facilities that use
powdered or dry pigments in their coatings formulations to protect
workers from exposure to hazardous materials in the pigments.  

6.2.1	Add-on Control Technology Cost

Vendors of particulate control technologies were contacted to provide
equipment cost estimates for a particulate capture system for a paints
and allied products facility.  The vendors recommended the following
factors to size the particulate control device: 200 feet per minute
(ft/min) face velocity, 16 inch diameter flexible duct size, and a duct
length of 150 feet.  Using these factors, the treated exhaust flow rate
was calculated to be 279 cubic feet per minute (cfm).  A summary of the
contact reports and the cost calculations are provided in Appendix B for
the fabric filter particulate control system, and Appendix C for the
cartridge particulate control system.    

The cost for two types of particulate control devices were obtained from
the vendors.  The first system is a 1,000 cfm baghouse, equipped with 6
pleated bags and 150 feet of flexible duct to capture the fugitive
particulate matter.  The equipment cost of the system was estimated to
cost $12,400.  The second system is a 1,000 cfm cartridge particulate
control system that uses 2 cartridge filters to capture the particulate.
 The equipment cost for this cartridge system equipped with two flexible
ducts was $8,000.    

The EPA Air Pollution Control Cost Manual was used to estimate the
capital and annual cost for the pleated bag particulate control system
and the cartridge particulate control system.  The cost per ton of
particulate removed was calculated using the estimated particulate
emissions for each of the model plants.  A summary of the estimated
particulate emission rates for the small and large model plants are
shown in Table 3.  The capital cost, annual cost, and cost per ton of
the pleated bag and cartridge particulate control systems are presented
in Table 6.

6.2.2	Pigment Substitution Cost

Another option for reducing the emission of particulate HAP is the
substitution of wetted or paste pigments in place of dry pigments. The
wetted or paste pigments eliminate fugitive emissions when pigments are
added to the paint formulation in the mixing process vessel.  The NPCA
and their members stated that wetted or paste pigments are typically two
times the cost of dry pigments.  However, based on information obtained
from a manufacturer of pigments that is provided in Appendix D, and cost
information obtained from the Internet, we found no price difference
between wetted and dry pigments.  Because there is no cost increase in
substituting from dry to wetted pigments, the cost per ton for switching
to wetted pigments would be $0 per megagram of HAP removed.  It should
be noted that not all pigment is available or can be used in a wetted or
paste form.

7.0	SUMMARY OF CONTROL OPTIONS

	In this analysis, two types of control options were investigated.  The
first type looked at potential control options for controlling volatile
HAP.  The second type looked at potential control options for
controlling particulate HAP.  Costs for these options were developed for
two model plants that are typical of the paints and allied products
manufacturing industry.  A summary of these control options are
presented in Table 7.

For small model plants the cost per ton for using plywood process vessel
covers was estimated to be $28.11 per ton of HAP reduced for a small
model plant, and $33.94 per ton of HAP reduced for a large model plant. 
Reductions of particulate HAP can be achieved by either substituting the
dry pigments for wetted or paste pigments at a cost per ton of $0 per
ton of particulate HAP removed, or installing an add-on control device
at a cost of $282,000 per ton of particulate HAP removed for a large
model plant and $1.6 million per tom of particulate HAP removed for a
small model plant.  The reduction of particulate matter would improve
workplace safety and reduce the cross contamination of coating products.

Table 6.  Summary of Add-on Particulate Control Technology Cost per Ton
for

Paints and Allied Products Manufacturing Facilities

Control Technology	Total Capital Cost	Annual Cost	PM Cost per Ton
($/Ton)1	PM2.5 Cost per Ton ($/Ton)1	Particulate HAP Cost per Ton
($/Ton)1

Small Model Plant

Pleated Bag Particulate Control System	$23,537	$7,463	$1,365	$2,885
$1,903,911

Cartridge Particulate Control System	$15,198	$6,362	$1,163	$2,459
$1,622,942

Large Model Plant

Pleated Bag Particulate Control System	$23,537	$7,463	$217	$459	$331,115

Cartridge Particulate Control System	$15,198	$6,362	$185	$391	$282,251

1 Assumes 98% reduction of PM, PM2.5, and particulate HAP.

	

	

Table 7.  Summary of HAP Control Options for the Paints and Allied
Products Manufacturing Industry

Type Of HAP	Control Option	UncontrolledHAP Emission (Ton/yr)	HAP
Emission Reduction (Ton/yr)	Annual Cost ($/yr)	HAP Cost Effectiveness
($/Ton of HAP removed)

Small Model Plant (167,000 gal/yr)

Volatile HAP	Fixed Bed Catalytic Incinerator	1.545	1.514	$47,553	$34,536

	Fluidized Bed Catalytic Incinerator	1.545	1.514	$56,120	$40,758

	Recuperative Thermal Incinerator	1.545	1.514	$70,121	$50,927

	Plywood Process Vessel Covers	1.545	0.618	$17	$28.11

Particulate HAP	Pleated Bag Particulate Control	0.004	0.0039	$7,463
$1,903,911

	Cartridge Particulate Control	0.004	0.0039	$6,362	$1,622,942

	Pigment Substitution	0.004	0.004	$0	$0

Large Model Plant (1,260,000 gal/yr)

Volatile HAP	Fixed Bed Catalytic Incinerator	9.710	9.516	$51,721	$5,977

	Fluidized Bed Catalytic Incinerator	9.710	9.516	$61,078	$7,058

	Recuperative Thermal Incinerator	9.710	9.516	$66,728	$7,711

	Plywood Process Vessel Covers	9.710	3.884	$132	$33.94

Particulate HAP	Pleated Bag Particulate Control	0.023	0.0225	$7,463
$331,115

	Cartridge Particulate Control	0.023	0.0225	$6,362	$282,251

	Pigment Substitution	0.023	0.023	$0	$0



Appendix A

Summary of HAP Total Emissions by SCC

2002 NEI Database















Appendix B

Particulate Control Vendor Contact Report

Fabric Filter Particulate Control System

CONTACT REPORT

Date/Time	Project Name	Project Number

February 5, 2009  1:00pm	Paints and Allied Products Manufacturing
CCC-204



EC/R Originator	Contact	Phone Number

Bradley Nelson	Aaron Lehman – Air Dynamics Industrial Systems
Corporation	(717) 854-4050

General Subject



The purpose of the telephone call was to obtain control cost information
for a fabric filter dust collection system for a paints and allied
products manufacturing facility.  Mr. Lehman stated for this application
he would recommend a particulate filtration system with a 200 ft/min
face velocity to capture fugitive particulate emissions.  Assuming a
16” diameter duct to capture the particulate emissions, the fabric
filter would need to treat 279 cfm of exhaust gas.  For that amount of
exhaust gas, Mr. Lehman recommended a 1,000 cfm fabric filter system
equipped with 6 pleated bags.  Mr. Lehman said the cost for this system
ranges from $7,000 to $9,000, depending on the auxiliary equipment that
is required.  Mr. Lehman stated that the system generally requires the
replacement of the pleated bags annually.  The cost for replacing one
pleated bag is approximately $22-23 per bag.  Cost of the flexible duct
is not included in the equipment cost for the fabric filter system.

  HYPERLINK "http://www.airdynamics.net/"  http://www.airdynamics.net/  







Appendix C

Particulate Control Vendor Contact Report

Cartridge Filter Particulate Control System

CONTACT REPORT

Date/Time	Project Name	Project Number

February 5, 2009  3:00pm	Paints and Allied Products Manufacturing
CCC-204



EC/R Originator	Contact	Phone Number

Bradley Nelson	Tom Carter – American Air Filter	(803) 366-2141

General Subject



The purpose of the telephone call was to obtain control cost information
for a cartridge filter dust collection system for a paints and allied
products manufacturing facility.  Mr. Carter stated that they had the
cost for a cartridge filter system generally costs $2-3 per cfm of
exhaust gas to treat.  For a paints and allied products manufacturing
facility, Mr. Carter recommended a 2,000 cfm particulate control system
equipped with 2 flexible ducts.  He stated this system costs
approximately $7,000 - $8,000.  This system can be equipped with 2 to 4
cartridges depending on the particulate loading rate, but believed the 2
cartridge particulate system would be sufficient in removing the
particulate from the exhaust stream.  Mr. Carter stated that the
cartridges are generally replaced every 2-4 years, and cost
approximately $75 per cartridge to replace.  

  HYPERLINK "http://www.aafintl.com/"  http://www.aafintl.com/ 







Appendix D

Pigment Vendor Contact Report

CONTACT REPORT

Date/Time	Project Name	Project Number

February 15, 2008  10:00pm	Paints and Allied Products Manufacturing
CCC-107



EC/R Originator	Contact	Phone Number

Bradley Nelson	Tom Lavieri – Lansco Colors	(888) 452-6720

General Subject



The purpose of the telephone call was to discuss the available forms of
pigments and their associated cost.  I spoke with Frank Lavieri, General
Manager / Executive VP of Lansco Colors.  His company produces a wide
range of organic and inorganic pigments for the paints and allied
products manufacturing industry.  Mr. Lavieri stated that most of the
pigments that they sell are available in powder or cake form.  The
pigment cake virtually eliminates fugitive emissions of pigment dust by
compressing the pigments particles into a solid cake.  The cake can be
cut to provide the desired amount for the paint or allied coating
recipe.  He stated there was no cost difference between the cost of
pigment in the powder form and pigment in the cake form, and they sell
roughly the same amount of each form of pigment to the industry.

  HYPERLINK "http://www.pigments.com/"  http://www.pigments.com/ 





 Memorandum from Bradley Nelson, EC/R to Melissa Payne, EPA/OAQPS/RDPAG,
Population and Baseline HAP Emissions for the Paint and Allied Products
Area Source Category, February 5, 2009.

 Memorandum from Bradley Nelson, EC/R to Melissa Payne, EPA, Model
Plants for Paint and Allied Products Manufacturing Area Sources, October
28, 2008.

 Memorandum from David Darling, National Paint and Coatings Association,
to  Eric Haxthausen, EPA OMB,  September 13, 2000.  Miscellaneous
Organic NESHAP (MON) MACT OMB Meeting Follow-up.  Air Docket No.
A-96-04, Item No. II-D-453.

 EPA Air Pollution Control Cost Manual, EPA/452/B-02-001, Chapter 2,
Refrigerated Condensers, December 1995.

 EPA Air Pollution Control Cost Manual, EPA/452/B-02-001, Chapter 1,
Carbon Adsorbers, September 1999.

 Memorandum from Bradley Nelson, EC/R to Melissa Payne, EPA, Model
Plants for Paint and Allied Products Manufacturing Area Sources, October
28, 2008.

 Email from Dave Darling, NCPA to Melissa Payne, EPA, Process Vessel
Covers, February 9, 2009.

 Control of Emissions from Ink and Paint Manufacturing Processes.  U.S.
Environmental Protection Agency, Research Triangle Park, North Carolina.
 April 1992.  p. 4-3.

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