  SEQ CHAPTER \h \r 1 MEMORANDUM

DATE:	November 10, 2009

SUBJECT:	Revised Regulatory 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 revised impacts for the National Emission
Standards for Hazardous Air Pollutants (NESHAP) for the Paints and
Allied Products Manufacturing area source category.  The impacts have
been revised based upon changes to the final NESHAP, which now only
requires control of the target HAP (e.g., benzene, methylene chloride,
cadmium, chromium, lead, and nickel), rather than requiring control of
all HAP used at the facility.  Therefore, this memorandum supplants the
impacts document that was developed for the proposed rule.  The
memorandum contains a brief summary of the background for the
rulemaking, the general approach for developing the impacts, and the
impacts of the control measures.    

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 generally
available control technology (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.

3.1	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 organic
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. target organic HAP and target metal HAP
are presented in Table 1.  

Table 1.  Summary of Target 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)	Target Organic HAP Emissions (Tons/yr)
Target Metal HAP Emissions (Tons/yr)

Small	167,000	558	5.58	2.64	15.7	0.0391	0.00141

Large	1,050,000	3,507	35.1	16.6	98.4	0.246	0.00887



3.2	Target HAP Emission Calculations

	The target organic HAP emissions presented in Table 1 were calculated
by dividing the total baseline emissions for organic HAP (e.g., benzene,
methylene chloride) by the total estimated plant production for the
source category as shown below. 

Where;

0.588 = Estimated total area source emissions for benzene in tons/yr,

213 = Estimated total area source emissions for benzene in tons/yr,

167,000 = Estimated plant production for a small model plant in gal/yr,

1572 = Estimated number of small model plants in the area source
category,

1,050,000 = Estimated plant production for a large model plant in
gal/yr,

618 = Estimated number of large model plants in the area source
category.

Multiplying the target organic HAP emission factor calculated above by
the estimated plant production values for the small and large model
plants provides the target organic HAP emissions for each of the model
plants that are presented in Table 1.

	The target metal HAP emissions presented in Table 1 were calculated by
dividing the total baseline emissions for metal HAP (e.g., cadmium,
chromium, lead, nickel) by the total estimated pigment usage for the
source category as shown below. 

Where;

0.0101 = Estimated total area source emissions for cadmium in Tons/yr,

2.28 = Estimated total area source emissions for chromium in Tons/yr,

4.05 = Estimated total area source emissions for lead in Tons/yr,

1.40 = Estimated total area source emissions for nickel in Tons/yr,

558 = Estimated pigment usage for a small model plant in Tons/yr,

1572 = Estimated number of small model plants in the area source
category,

3,507 = Estimated pigment usage for a large model plant in Tons/yr,

618 = Estimated number of large model plants in the area source
category.

Multiplying the target metal HAP emission factor calculated above by the
estimated pigment usage values for the small and large model plants
provides the target metal HAP emissions for each of the model plants
that are presented in Table 1.

4.0	CONTROL MEASURES AND IMPACTS

The impacts are divided into two sections: the impacts for the organic
HAP control options, and the impacts of metal HAP control options.  The
impacts were estimated using the model plant emission factors for
organic and metal 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: 

95 percent of the existing facilities use process vessel covers;

79 percent of the existing facilities use a particulate control device. 


4.1	Organic HAP Control Measures

	Process vessel covers were determined to be GACT for organic HAP
emissions.  For purposes of estimating the impacts, the process vessel
covers were assumed to reduce organic HAP emissions by 40 percent.

4.1.1	Model Plant Impacts of Organic HAP Control Measures 

	Using capital and annual cost estimates and the estimated model plant
VOC and organic HAP emissions, the cost effectiveness of the process
vessel covers was calculated.  A summary of the costs and cost
effectiveness values are presented in Table 2.  Process vessel covers
provide a HAP cost effectiveness of $1,087 per ton of organic HAP
removed for small model plants and $1,341 per ton of organic HAP removed
for large model plants.  



4.1.2	Nationwide Impacts

The nationwide impacts for the organic control options were calculated
assuming that 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 organic HAP was estimated to be
$5,435 with a total organic HAP reduction of 4.29 Tons/yr.  

Table 2.  Summary of Organic Control Measure Impacts for the Model
Plants

Organic HAP Control Option	Total Facility Capital Cost of Process Vessel
Covers	Total Facility Annual Cost of Process Vessel Covers	VOC Cost
Effectiveness ($/Ton VOC reduced)	Target Organic HAP Cost Effectiveness
($/Ton target organic HAP reduced)

Small Model Plants

Process Vessel Coversa	$122	$17	$2.71	$1,087

Large Model Plants

Process Vessel Coversa	$926	$132	$3.35	$1,341

a Assumes 40% reduction of VOC and target organic HAP.

4.2	Metal HAP Control Measures

	A particulate control device was determined to be GACT for metal HAP
emissions.  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 metal HAP emissions. 

  

Table 3.  Summary of the VOC and Organic 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	Organic 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	$2.71	3.09	1.24	$1,083

Large Model Plant (618 Area Source Facilities)

Process Vessel Covers	31	$4,092	3,050	1,220	$3.35	7.63	3.05	$1,342

Total (2,190 Area Source Facilities)

Process Vessel Covers	110	$5,435	4,290	1,716	$3.18	10.7	4.29	$1,267



4.2.1	Model Plant Impacts of Metal HAP Control Measures

	Using capital and annual cost estimates and the estimated model plant
PM, PM2.5, and metal 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 metal HAP cost
effectiveness of $5.4 million and $4.6 million, respectively for small
model plants, and $859,000 and $732,000, respectively for large model
plants.  

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

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

Small Model Plant

Pleated Bag Particulate Control System	$23,537	$7,463	$1,365	$2,885
$5,400,926

Cartridge Particulate Control System	$15,198	$6,362	$1,163	$2,459
$4,604,140

Large Model Plant

Pleated Bag Particulate Control System	$23,537	$7,463	$217	$459	$858,546

Cartridge Particulate Control System	$15,198	$6,362	$185	$391	$731,887

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

4.2.2	Nationwide Impacts

The nationwide impacts for the metal HAP 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 Target Metal 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)	Metal HAP Cost per Ton ($/Ton)

Small Model Plant (1,572 Area Source Facilities)

Pleated Bag Particulate Control	330	$2,462,899	0.465	0.456	$5,401,094

Cartridge Particulate Control	330	$2,099,438	0.465	0.456	$4,604,031

Large Model Plant (618 Area Source Facilities)

Pleated Bag Particulate Control	130	$970,233	1.15	1.13	$858,613

Cartridge Particulate Control	130	$827,051	1.15	1.13	$731,904

Total (2,190 Area Source Facilities)

Pleated Bag Particulate Control	460	$3,433,132	1.62	1.59	$2,159,203

Cartridge Particulate Control	460	$2,926,489	1.62	1.59	$1,840,559

bag particulate control device was estimated to be $3.4 million with a
total metal HAP reduction of 1.59 Tons/yr.  The total annual cost of
requiring the use of a cartridge particulate control device to control
metal HAP is $2.9 million with a total metal HAP reduction of 1.59
Tons/yr.

5.0	REGULATORY ALTERNATIVE COSTS

	Nationwide costs and impacts were estimated for the regulatory
alternatives of requiring covers for control of organic HAP and add-on
technology for metal HAP control.  These impacts were calculated
assuming the use of process vessel covers for uncontrolled organic HAP
facilities, cartridge particulate control devices for uncontrolled metal
HAP small facilities, and pleated bag particulate control devices for
uncontrolled metal HAP large facilities.  I summary of the total capital
and annual costs, and the organic and metal 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 Target HAP Reduction (Tons/yr)

Process Vessel Covers (Small)	79	$9,639	$1,372	1.24

Process Vessel Covers (Large)	31	$28,702	$4,087	3.05

Cartridge Particulate Control	330	$5,015,472	$2,099,438	0.456

Pleated Bag Particulate Control	130	$3,059,761	$970,233	1.13

Total	570	$8,113,574	$3,075,130	5.88



6.0	OTHER AIR POLLUTION IMPACTS

6.1	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. 

6.2	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.

	

6.3	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.

 Memorandum from Bradley Nelson, EC/R Inc. to Melissa Payne,
EPA/OAQPS/RDPAG, Regulatory Alternative Impacts for the Paints and
Allied Products Manufacturing Source Category, February 16, 2009. 
EPA-HQ-OAR-2008-0053-0073.

 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 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. 

E C/R Incorporated	Providing Environmental Technical Support Since 1989



	

501 Eastowne Drive, Suite 250  (  Chapel Hill, North Carolina  27514

Telephone:  (919)484-0222  (  Fax:  (919) 484-0122

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