  SEQ CHAPTER \h \r 1 MEMORANDUM

DATE:	February 16, 2009

SUBJECT:	Regulatory Alternative Impacts for 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 the estimated impacts of regulatory
alternatives and generally available control technology (GACT) options
considered by EPA in the development of National Emission Standards for
Hazardous Air Pollutants (NESHAP) for the Paints and Allied Products
Manufacturing area source category. The memorandum contains a brief
summary of the background for the rulemaking, the general approach for
developing the impacts of the regulatory alternatives, identification of
the control measures, and the impacts of the control measures and
regulatory alternatives.

2.0	BACKGROUND

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 in urban areas 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 GACT, as defined
in the CAA under section 112(d)(3) and section 112(d)(5), respectively. 


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 Paints 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.  

3.0  	GENERAL APPROACH

	This section provides a summary of the general approach that was used
to develop the impacts for the Paints and Allied Products Manufacturing
category.  The general approach provides the steps that were used to
evaluate the HAP emission reductions and cost for each control measure
that was evaluated.

3.1	Steps

The general approach used to evaluate emission control methods as
possible candidates for GACT involved using the following steps:

Identify baseline emission levels,

Identify control measures applicable to the emission streams,

Identify saturation of existing control levels, 

Estimate the impacts of control measures, 

Identify regulatory alternative, and 

Estimate the impacts of regulatory alternative.  

The information and data used for these steps were collected from
literature searches, census statistics, AP-42 emissions factors, state
operating permits, and the National Emission Inventory (NEI) database.  

3.2	Model Plants

  Model plants were developed to estimate the impacts of the control
options for the Paints and Allied Products Manufacturing sector.  Using
production data and employee size from the census, two model plants were
developed; small and large.  Small model plants were assumed to have
less than 19 employees and produce approximately 167,000 gallons of
product per year.  Large model plants were assumed to have 20 or more
employees and produce approximately 1,050,000 gallons of product per
year.  Based on the data from the census, which estimated there is a
total of 2,190 area source facilities operating in the U.S., we
estimated that there are 1,572 small model plant area source facilities,
and 618 large model plant area source facilities.  Using these model
plants, AP-42 emission factors for particulate matter (PM) and volatile
organic compounds (VOC) could be used to determine facility emission
rates for the two model plants.  More detailed information on the
development of these model plants is available in a separate memorandum.
 A summary of the model plant production rates and the estimated
emissions for PM, PM2.5, VOC. volatile HAP and particulate HAP are
presented in Table 1.  

Table 1.  Summary of HAP, PM, and VOC Emissions from the 

Paints and Allied Products Manufacturing Model Plants

Model Plant	Estimated Plant Production (Gal/yr)	Estimated Pigment Usage
(Tons/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	558	5.58	2.64	15.7	1.549	1.545	0.004

Large	1,050,000	3,507	35.1	16.6	98.4	9.733	9.710	0.023



4.0	BASELINE EMISSIONS

Census data and the NEI database were used to estimate the baseline
emissions from the Paints and Allied Products Manufacturing area source
sector.  In this memorandum, the population of area source Paints and
Allied Products Manufacturing were estimated to be 2,190 facilities. 
This memorandum also estimated the baseline HAP emissions from the area
source facilities using HAP emission data from the NEI database.  The
baseline HAP emissions level for the Paints and Allied Products
manufacturing area source category was estimated to be 4,761 tons per
year (Ton/yr).  The total listed urban HAP (benzene, cadmium, chromium,
lead, methylene chloride, and nickel) emissions were estimated to be 221
Ton/yr.  

The baseline emissions were also estimated using AP-42 emission factors,
the model plant data, and the following assumptions:

 

95 percent of the existing facilities use process vessel covers;

79 percent of the existing facilities use a particulate control device;
and

7 percent of the existing facilities use a thermal oxidizer.

We also assumed that facilities that use a thermal oxidizer will also
use a particulate control device and process vessel covers to control
HAP emissions, and facilities that use a particulate control device also
use process vessel covers.  Using these assumptions the baseline HAP
emissions using the model plant emission factors are calculated to be
4,891 tons per year (Ton/yr), whereas the baseline HAP emissions using
the 2002 NEI data was estimated to be 4,761 Ton/yr.  Therefore, we
believe that the model plant emission factors accurately represent the
HAP emissions from the Paints and Allied Products Manufacturing
industry.  

5.0	HAP CONTROL MEASURES

This section describes the potential control options for reducing
emission of HAP from the Paints and Allied Products Manufacturing
industry.  Because the control options are different for the different
types of urban HAP that are addressed by this rulemaking, the impacts
and control options are broken down into two groups; volatile HAP and
particulate HAP.  Volatile HAP is the largest component of the total HAP
emitted by the industry.  Volatile HAP comprised of 99.76 percent of the
total HAP listed in the 2002 NEI database.  Volatile HAP emissions occur
from splash loading of volatile organic chemicals into the process
vessel, and evaporation of volatile organic chemicals during the mixing
process.  Particulate HAP emissions occur from the addition of dry
pigments and other solids to the process vessel and during the pigment
milling or grinding manufacturing process.  Control options for each of
these types of HAP are discussed in the following sections.

5.1	Volatile HAP Control Measures

To determine the volatile HAP control measures for the Paints and Allied
Products Manufacturing sector, information was obtained from state
operating permits and the NEI database.  In addition, recommended
management practices from the NPCA Coatings Care program were also
reviewed.

5.1.1	Identification of Controls

Information obtained from the 2002 NEI database, state permits, and
industry groups provided the following control options for reducing
volatile HAP:

Process Vessel Covers;

Add-on Control Technology.

Process vessel covers reduce the emissions of HAP by limiting the
exposure of volatile compounds to the atmosphere.  By covering the
process vessel, the solvent fugitive emissions loss in the coatings
product during the manufacturing process is reduced, which therefore
reduces the volatile HAP emissions from the process vessel. Previous
studies by EPA indicated that process vessel covers can reduce the
emissions from process vessels by approximately 40 percent.

Add-on control technology can be used to capture or oxidize volatile HAP
from the coating manufacturing process.  The use of add-on control
technology involves the use of a volatile HAP capture device to capture
the fugitive emissions, which are then routed to an add-on control
device.  Because of the low volatile HAP concentration of the fugitive
stream, the most feasible choice of add-on control technology is a
thermal oxidizer.  Thermal oxidizer can generally reduce volatile HAP
emissions by 98 percent.

5.1.2	Saturation of Controls

Data from State permits and the NEI database indicate that volatile HAP
add-on control technology was used only sparingly on process vessels. 
Based on the information published in the State permits, only 3 of the
29 (10%) area source facilities used some type of volatile HAP add-on
control.  The 2002 NEI data listed only 8 of the 665 facilities (1.2%)
used an add-on control technology for the reduction of volatile HAP.   

Information from the industry and visits to coating manufacturing
facilities show that process vessel cover are prevalent in the Paints
and Allied Products Manufacturing industry.  The Miscellaneous Organic
NESHAP (MON) estimated that approximately 95 percent of the facilities
use process vessel covers. 

5.2	Particulate HAP Regulatory Alternatives

Particulate HAP emissions occur during the grinding of pigments process
step, and during the addition of pigments to the process vessel. 
Control options for reducing these fugitive particulate HAP emissions
were obtained from state operating permits and the NEI database.  

5.2.1	Identification of Controls

Add-on particulate HAP control was identified as a control option for
reducing emissions of particulate HAP.  A fugitive emission capture
device is used to capture the fugitive particulate emissions, which are
then routed to a particulate control device where the particulate is
filtered from the exhaust stream.  Typical particulate control add-on
control options used in the Paints and Allied Products Manufacturing
industry include a filtered bag particulate control system and a
cartridge filter particulate control system

The filtered bag particulate control system uses a series of bags that
filter the particulate HAP from the exhaust stream.  These systems are
commonly used by many different sources and are designed to reduce
particulate emissions by 98 percent.  The cartridge particulate control
device uses cartridge filter to capture the particulate from the exhaust
stream.  These systems are also designed to achieve 98 percent reduction
in particulate emissions.

5.2.2	Saturation of Controls

The data analysis showed that add-on controls for particulate HAP
emissions from process vessels are widespread throughout the industry. 
The State permits indicated that 23 of 29 (79%) area source use add-on
controls for particulate emissions.  Discussions with industry groups
also confirmed that particulate control devices are commonly used in the
Paints and Allied Products Manufacturing industry. 

6.0	CONTROL MEASURES AND IMPACTS

The impacts are divided into two sections: the impacts for volatile
control options, and the impacts of particulate control options.  The
impacts were estimated using the model plant emission factors for
volatile and particulate HAP.  To determine the number of existing area
source facilities that are currently controlled, we used the percentages
of area source facilities using control devices obtained from the state
permits.  

6.1	Volatile HAP Control Measures

	The control options that were identified for reducing emissions of
volatile HAP were determined to be a thermal oxidizer and process vessel
covers.  For purposes of estimating the impacts, the thermal oxidizer
was assumed to reduce volatile HAP emissions by 98 percent, and the
process vessel covers were assumed to reduce volatile HAP emissions by
40 percent.

6.1.1	Model Plant Impacts of Volatile HAP Control Measures

	Using capital and annual cost estimates and the estimated model plant
VOC and volatile HAP emissions, the cost effectiveness of each of the
volatile control options were calculated.  A summary of the costs and
cost effectiveness values are presented in Table 2.  Process vessel
covers provide a HAP cost effectiveness of $28 per ton of volatile HAP
removed for small model plants and $34 per ton of volatile HAP removed
for large model plants.  The thermal oxidizer HAP cost effectiveness
values for the small and large model plants were calculated to be
$31,400 and $5,400 per ton of volatile HAP removed respectively.

6.1.2	Nationwide Impacts

The nationwide impacts for the volatile control options were calculated
assuming that 7 percent of the 2,190 area source facilities are
currently using a thermal oxidizer, and 95 percent of the 2,190 area
source facilities are using process vessel covers.  The model plant
memorandum estimated that 1,572 of the area source facilities are small
model plants and 618 of the area source facilities are large model
plants.  A summary of the nationwide impacts is presented in Table 3. 
The total annual cost of requiring the use of process vessel covers to
reduce volatile HAP was estimated to be $5,435 with a total volatile HAP
reduction of 169 Tons/yr.  The total annual cost of requiring the use of
a thermal oxidizer to control volatile HAP is $96 million with a total
volatile HAP reduction of 7,433 Tons/yr.

Table 2.  Summary of Volatile Control Option Impacts for the Model
Plants

Volatile HAP Control Option	Total Facility Capital Cost of Process
Vessel Covers	Total Facility Annual Cost of Process Vessel Covers	VOC
Cost Effectiveness ($/Ton VOC reduced)	HAP Cost Effectiveness ($/Ton
volatile HAP reduced)

Small Model Plants

Process Vessel Coversa	$122	$17	$3	$28

Thermal Oxidationb	$122	$17	$3,091	$31,407

Large Model Plants

Process Vessel Coversa	$926	$132	$3	$34

Thermal Oxidationb	$926	$132	$536	$5,435

a Assumes 40% reduction of VOC and HAP.

b Assumes 98% reduction of VOC and HAP.

6.2	Particulate HAP Control Measures

	The control options that were identified for reducing emissions of
particulate HAP were determined to be a add-on particulate control
device.  Two types of particulate control devices were identified: a
pleated bag particulate control device and a cartridge particulate
control device.  Each of these particulate control devices can achieve
98 percent reduction in particulate HAP emissions. 

  

Table 3.  Summary of the VOC and Volatile HAP Control Measure Impacts
for the

Paints and Allied Products Manufacturing Industry

Regulatory Option	Number of Facilities to Apply Control Technology	Total
Annual Cost	Volatile Organic Compounds	Volatile Hazardous Air Pollutants



	Uncontrolled  Emissions

(Ton/yr)	 Emissions Reduction (Ton/yr)	VOC Cost Effectiveness ($/Ton)
Uncontrolled Emissions

(Ton/yr)	 Emissions Reduction (Ton/yr)	HAP Cost Effectiveness ($/Ton)

Small Model Plant (1,572 Area Source Facilities)

Process Vessel Covers	79	$1,343	1,240	496	$3	122	48.8	$28

Thermal Oxidation	1,415	$67,287,495	22,216	21,771	$3,091	2,186	2,142
$31,407

Large Model Plant (618 Area Source Facilities)

Process Vessel Covers	31	$4,092	3,050	1,220	$3	301	120	$34

Thermal Oxidation	556	$28,756,876	54,710	53,616	$536	5,399	5,291	$5,435

Total (2,190 Area Source Facilities)

Process Vessel Covers	110	$5,435	4,290	1,716	$3	423	169	$32

Thermal Oxidation	1,971	$96,044,371	76,926	75,387	$1,274	7,585	7,433
$12,921



6.2.1	Model Plant Impacts of Particulate HAP Control Measures

	Using capital and annual cost estimates and the estimated model plant
PM, PM2.5, and particulate HAP emissions, the cost effectiveness for
each of the particulate control options were calculated.  A summary of
the costs and cost effectiveness values are presented in Table 2.  The
pleated bag and cartridge particulate control systems provide a
particulate HAP cost effectiveness of $1.6 million and $1.9 million,
respectively for small model plants, and $331,000 and $282,000,
respectively for large model plants.  

Table 4.  Summary of Particulate Control Option Impacts for Model Plants

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.

6.1.2	Nationwide Impacts

The nationwide impacts for the volatile control options were calculated
assuming that 79 percent of the 2,190 area source facilities are
currently using a particulate control device.  The model plant
memorandum estimated that 1,572 of the area source facilities are small
model plants and 618 of the area source facilities are large model
plants.  A summary of the nationwide impacts is presented in Tables 5,
6, and 7.  The total annual cost of requiring the use of a pleated 

Table 5.  Summary of PM Control Measure Impacts for the

Paints and Allied Products Manufacturing Industry

Regulatory Option	Number of Facilities to Apply Control Technology	Total
Annual Cost	Particulate Matter



	Uncontrolled Emissions

(Ton/yr)	 Emissions Reduction (Ton/yr)	PM Cost per Ton ($/Ton)

Small Model Plant (1,572 Area Source Facilities)

Pleated Bag Particulate Control	330	$2,462,899	1,841	1,805	$1,365

Cartridge Particulate Control	330	$2,099,438	1,841	1,805	$1,163

Large Model Plant (618 Area Source Facilities)

Pleated Bag Particulate Control	130	$970,233	4,563	4,472	$217

Cartridge Particulate Control	130	$827,051	4,563	4,472	$185

Total (2,190 Area Source Facilities)

Pleated Bag Particulate Control	460	$3,433,132	6,404	6,276	$547

Cartridge Particulate Control	460	$2,926,489	6,404	6,276	$466



Table 6.  Summary of PM2.5 Control Measure Impacts for the

Paints and Allied Products Manufacturing Industry

Regulatory Option	Number of Facilities to Apply Control Technology	Total
Annual Cost	Particulate Matter less than 2.5 Microns



	Uncontrolled Emissions

(Ton/yr)	 Emissions Reduction (Ton/yr)	PM2.5 Cost per Ton ($/Ton)

Small Model Plant (1,572 Area Source Facilities)

Pleated Bag Particulate Control	330	$2,462,899	871	854	$2,885

Cartridge Particulate Control	330	$2,099,438	871	854	$2,459

Large Model Plant (618 Area Source Facilities)

Pleated Bag Particulate Control	130	$970,233	2,158	2,115	$459

Cartridge Particulate Control	130	$827,051	2,158	2,115	$391

Total (2,190 Area Source Facilities)

Pleated Bag Particulate Control	460	$3,433,132	3,029	2,969	$1,156

Cartridge Particulate Control	460	$2,926,489	3,029	2,969	$986



Table 7.  Summary of Particulate HAP Control Measure Impacts for the

Paints and Allied Products Manufacturing Industry

Regulatory Option	Number of Facilities to Apply Control Technology	Total
Annual Cost	Particulate Hazardous Air Pollutants



	Uncontrolled Emissions

(Ton/yr)	 Emissions Reduction (Ton/yr)	Particulate HAP Cost per Ton
($/Ton)

Small Model Plant (1,572 Area Source Facilities)

Pleated Bag Particulate Control	330	$2,462,899	1.32	1.29	$1,903,911

Cartridge Particulate Control	330	$2,099,438	1.32	1.29	$1,622,942

Large Model Plant (618 Area Source Facilities)

Pleated Bag Particulate Control	130	$970,233	2.99	2.93	$331,115

Cartridge Particulate Control	130	$827,051	2.99	2.93	$282,251

Total (2,190 Area Source Facilities)

Pleated Bag Particulate Control	460	$3,433,132	4.31	4.22	$812,806

Cartridge Particulate Control	460	$2,926,489	4.31	4.22	$692,857

bag particulate control device was estimated to be $3.4 million with a
total particulate HAP reduction of 4.22 Tons/yr.  The total annual cost
of requiring the use of a cartridge particulate control device to
control particulate HAP is $2.9 million with a total particulate HAP
reduction of 4.22 Tons/yr.

7.0	REGULATORY ALTERNATIVE COSTS

	Nationwide costs and impacts were estimated for the regulatory
alternatives of requiring covers for control of volatile HAP and add-on
technology for particulate HAP control.  These impacts were calculated
assuming the use of process vessel covers for uncontrolled volatile HAP
facilities, cartridge particulate control devices for uncontrolled
particulate HAP small facilities, and pleated bag particulate control
devices for uncontrolled particulate HAP large facilities.  I summary of
the total capital and annual costs, and the volatile and particulate HAP
reductions are presented in Table 8.

Table 8.  Summary of Regulatory Alternative Costs for the

Paints and Allied Products Manufacturing Industry

Regulatory Option	Number of Uncontrolled Facilities	Total Capital Cost
($)	Total Annual Cost ($/yr)	Total HAP Reduction (Tons/yr)

Process Vessel Covers (Small)	79	$9,639	$1,372	49

Process Vessel Covers (Large)	31	$28,702	$4,087	120

Cartridge Particulate Control	330	$5,015,472	$2,099,438	1

Pleated Bag Particulate Control	130	$3,059,761	$970,233	3

Total	570	$8,113,574	$3,075,130	173



8.0	OTHER AIR POLLUTION IMPACTS

8.1	Water Pollution Impact

	The generation of water pollution occurs from the addition of HAP
pollutants to the process water used at the facility.  Neither of the
control measures requires process water to operate, and neither control
generates any wastewater from their operation.  Therefore, there are no
water pollution impacts from the operation of these control measures. 

8.2	Solid Waste Impact

	Solid waste impacts consist of the disposal of solid waste generated
from the particulate control system.  The solid waste consists of the
filter bags or cartridges and the collected particulate captured from
pigment grinding and pigment addition processes.  The collected
particulate contains metals, including the listed HAP metals.  Depending
on the concentration levels of these metals, the collected particulate
may be considered hazardous waste.  The particulate should be tested to
quantify the metal concentrations and local waste disposal regulations
should be reviewed prior to disposal of the filters and collected
particulate.  The disposal of the particulate materials is assumed to
occur annually, and the cost of testing and disposal is included in the
annual cost of the particulate control systems.

	

8.3	Energy Impacts

	Energy impacts consist of the fuel (natural gas) needed to operate the
combustion-based control device (thermal oxidizer) that is used to
comply with the regulatory alternatives.  It also includes the amount of
electricity to operate the control devices.  The estimated electricity
and fuel impacts are already included in the annual cost of the control
technologies.  No additional energy is required for the process vessel
covers or the replacement of dry pigments with wetted pigments.

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

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

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

 Memorandum from Bradley Nelson, EC/R to Melissa Payne, EPA/OAQPS/RDPAG,
Overview of the Paints and Allied Products Manufacturing Area Source
Category, February 18, 2009.

 National Paint & Coatings Association, Coatings Care® — Providing
for a Cleaner, Safer, Coatings Industry,

  HYPERLINK "http://www.paint.org/cc/"  http://www.paint.org/cc/  

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

 Memorandum from Bradley Nelson, EC/R Inc. to Melissa Payne
EPA/OAQPS/RDPAG, Development of HAP Reduction Costs for the Paints and
Allied Products Manufacturing Area Source Category, February 16, 2009.

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

 Memorandum from Bradley Nelson, EC/R Inc. to Melissa Payne
EPA/OAQPS/RDPAG, Development of HAP Reduction Costs for the Paints and
Allied Products Manufacturing Area Source Category, February 16, 2009.

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

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