MEMORANDUM

DATE:		November 6, 2009

SUBJECT:	Estimate of HAP Emission Reductions from the Paints and Allied
Products Manufacturing NESHAP

FROM:	Bradley Nelson, EC/R, Inc.

		

TO:		Melissa Payne, EPA/OAQPS/RDPAG

1.0	PURPOSE

The purpose of this memorandum is to document the hazardous air
pollutant (HAP) emission reductions that are estimated to be impacted by
the final area source Paints and Allied Products Manufacturing NESHAP
(40 CFR part 63 subpart CCCCCCC).  This memorandum outlines the steps
that were used in estimating organic and metal HAP emissions and
provides the expected emission reductions from the implementation of the
requirements in the final area source Paints and Allied Products
Manufacturing NESHAP.  

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 proposed rule determined that it was not practical to establish
emission limits for each of the target HAP.  Instead, EPA established
GACT requirements for organic HAP and metal HAP, and defined organic HAP
as benzene and methylene chloride, and metal HAP as cadmium, chromium,
lead, and nickel.  The use of process vessel covers was determined to be
GACT for organic HAP and the capture and control of metal HAP emissions
using a particulate control device was determined to be GACT for metal
HAP emissions.  NESHAP determined that the use of process vessel cover
for organic HAP controls the target HAP using process vessel covers for
organic HAP and a particulate control device to control metal HAP.

The baseline emissions for the paints and allied products manufacturing
source category were calculated using emission data from the 2002 NEI
database.  The memorandum estimated the total HAP emissions from the
targeted HAP to be 221 tons per year and the total HAP emissions to be
4,761 tons per year.  The proposed NESHAP required the control at all
HAP at the facility if you subject to the rule, therefore the HAP
reductions were calculated from the total HAP emissions.  The impacts
memorandum estimated that the proposed rule would reduce 173 if the
total HAP emission from the area source category.  Based on public
comment, EPA has revised the final requirements to only apply to the
target HAP, which are benzene, methylene chloride, cadmium, chromium,
lead and nickel.  Because the final rule only impacts the emissions of
the target HAP, the emission reductions will be taken from the total
target HAP emissions.  

3.0	DISCUSSION

As stated in the baseline emission memorandum, the total emissions of
the target HAP are 221 tons per year.  This total is comprised of 213.6
tons per year of organic HAP emissions (e.g., benzene, methylene
chloride), and 7.7 tons of metal HAP emissions (e.g., cadmium, chromium,
lead, nickel).  The NESHAP has separate requirements for organic HAP and
metal HAP.  For organic HAP, the final rule requires that process
vessels that contain organic HAP must be equipped with a cover.  The use
of a process vessel cover is assumed to reduce organic HAP emissions by
40 percent.  For metal HAP, the NESHAP requires that fugitive
particulate emission from the addition of pigments and solids that
contain metal HAP be captured and routed to a particulate control
device.  The particulate control device is assumed to reduce the metal
HAP emissions by 98 percent.

The total HAP emissions impact by the final rule was estimated using the
total organic HAP emissions and the total metal HAP emissions, and the
assumed control efficiencies of the each of the HAP control options.  A
summary of the total HAP emission and HAP reduction is presented in
Table 1.  The total organic HAP emissions is estimated to be reduced by
4.3 tons per year and the total metal HAP emissions is estimated to be
reduced by 1.6 tons per year.  It can be assumed that the requirements
will also achieve additional HAP reductions in cases where non-target
HAP are also contained in the process vessel.  However, this value
cannot be estimated because there is not enough information on the
recipes for producing the paint or allied product.  Therefore, only the
listed HAP reductions are shown.

Table 1.  Summary of HAP Reductions for the Final Paints and 

Allied Products Manufacturing NESHAP

Type of HAP	Baseline Target HAP Emissions (Tons/year)	Estimated
Percentage of Uncontrolled Facilities	Estimated HAP Percent Reduction
Total Target HAP Emissions Reduction (Tons/year)

Organic Target HAP	213.6	5%	40%	4.3

Metal Target HAP	7.7	21%	98%	1.6

Total Target HAP	221.3	N/A	N/A	5.9



 Memorandum from Bradley Nelson, EC/R Inc. to Melissa Payne,
EPA/OAQPS/RDPAG, Population and Baseline HAP Emissions for the Paint and
Allied Products Area Source Category, February 5, 2009. 
EPA-HQ-OAR-2008-0053-0070.

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

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