      MEMORANDUM


DATE: 	May 25, 2018

SUBJECT:	Technology Review for Surface Coating Operations in the Printing, Coating, and Dyeing of Fabrics and Other Textiles Category

FROM:	Eastern Research Group, Inc.

TO:		Paula Hirtz, OAQPS/SPPD/MMG


1.0	INTRODUCTION

Section 112 of the Clean Air Act (CAA) requires the U.S. Environmental Protection Agency (EPA) to establish technology-based standards for listed source categories of hazardous air pollutants (HAP). These technology-based standards are often referred to as maximum achievable control technology (MACT) standards. The Printing, Coating, and Dyeing of Fabrics and Other Textiles NESHAP (40 CFR part 63, subpart OOOO), hereafter referred to as the Fabric Coating NESHAP, regulates organic HAP emissions from operations performed on fabric and other textile substrates. The Fabric Coating NESHAP requires the use of MACT to reduce HAP emissions from the following subcategories:
 Coating and printing subcategory includes any operation that coats or prints fabric or other textiles; where coating means the application of a semi-liquid coating material to one or both sides of a textile web substrate. Coated and printed substrates are used in products including, but not limited to, architectural structures, apparel, flexible hoses, hot-air balloons, lightweight liners, luggage, military fabric, rainwear, sheets, tents, threads and V-belts.
 Slashing subcategory includes any operation with slashing operations. Slashing means the application of a chemical sizing solution (or size) to the vertical (or warp) yarns to bind the fibers and stiffen them for protection prior to weaving. Slashing operation means the equipment used to mix and prepare size for application and the slasher, which is the equipment used to apply and dry size on warp yarn.
 Dyeing and finishing subcategory includes any operation that dyes or finishes fabric or other textiles. Dyes are applied to yarn, fiber, cord, or fabric in aqueous solutions and dried before or after finishing, depending on the process. Dyed and finished textiles are used in a wide range of products including, but not limited to, apparel, carpets, high-performance industrial fabrics, luggage, military fabrics, outer wear, sheets, towels, and threads.

Section 112 of the CAA also contains provisions requiring the EPA to periodically revisit these standards. Specifically, section 112(d)(6) states:

      (6) REVIEW AND REVISION.  -  The Administrator shall review, and revise as necessary (taking into account developments in practices, processes, and control technologies), emissions standards promulgated under this section no less often than every 8 years.

To comply with this CAA requirement, the EPA conducted a technology review for the Fabric Coating NESHAP standard for major sources. This memorandum addresses the technology review for all coating and printing; slashing; dyeing and finishing. For this exercise, we considered any of the following to be a "development":


 Any add-on control technology or other equipment that was not identified and considered during MACT standard development;
 Any improvements in add-on control technology or other equipment (that was identified and considered during MACT standard development) that could result in additional emission reductions;
 Any work practice or operational procedure that was not identified and considered during development of the original MACT standard;
 Any process change or pollution prevention alternative that could be broadly applied to the industry and that was not identified or considered during development of the original MACT standard; and
 Any significant changes in the cost (including cost effectiveness) of applying controls (including controls the EPA considered during the development of the original MACT standard).

In addition to reviewing the practices, processes, and control technologies that were considered during the development of the 2003 NESHAP, we reviewed a variety of data sources in our investigation of potential practices, processes, or controls to consider. Among the sources we reviewed were the NESHAP for various industries that were promulgated after the Fabric Coating NESHAP. We reviewed the regulatory requirements and/or technical analyses associated with these regulatory actions to identify any practices, processes, and control technologies considered in these efforts that could be applied to emission sources in the Printing, Coating, and Dyeing of Fabrics and Other Textiles Surface Coating source category, as well as the costs, non-air impacts, and energy implications associated with the use of these technologies. Finally, we reviewed information from other sources, such as state and/or local permitting agency databases and industry-supported databases.

Section 2 of this memorandum presents a summary of the sources of data that were used to conduct the technology review and Section 3 presents the technology review for fabric printing, coating, finishing, slashing, and dyeing operations. 

2.0	SOURCES OF AVAILABLE CONTROL TECHNOLOGY INFORMATION

To identify any developments in practices, processes, or control technologies that could be applicable to the fabric printing, coating, and dyeing industry, we researched the following sources of information: RACT/BACT/LAER Clearinghouse, regulatory actions promulgated subsequent to the Fabric Coating NESHAP, site visits, and industry information. Each is described in the following sections.


2.1	RACT/BACT/LAER Clearinghouse Database

Under the EPA's New Source Review (NSR) program, if a company is planning to build a new plant or modify an existing plant such that criteria air pollution emissions will increase by a certain amount (in tons per year, depending on pollutant), then the company must obtain an NSR permit. The NSR permit is a construction permit which generally requires the company to minimize air pollution emissions by changing the process to prevent air pollution and/or installing air pollution control equipment. 

The terms "RACT," "BACT," and "LAER" are acronyms for different program requirements relevant to the NSR program. RACT, or Reasonably Available Control Technology, is required on existing sources in areas that are not meeting national ambient air quality standards (non-attainment areas). BACT, or Best Available Control Technology, is required on new or modified major sources in clean areas (attainment areas). LAER, or Lowest Achievable Emission Rate, is required on new or modified major sources in non-attainment areas. 

BACT and LAER (and sometimes RACT) are determined on a case-by-case basis, usually by State or local permitting agencies. The EPA established the RACT/BACT/LAER Clearinghouse, or RBLC, to provide a central database of air pollution technology information (including past BACT and LAER decisions contained in NSR permits) to promote the sharing of information among permitting agencies and to aid in future case-by-case determinations. However, data in the RBLC are not limited to sources subject to RACT, BACT, and LAER requirements. Noteworthy pollution prevention and control technology decisions and information may be included even if they are not related to past RACT, BACT, or LAER decisions. 

The RBLC contains over 5,000 air pollution control permit determinations that can help identify appropriate technologies to mitigate most air pollutant emission streams. It was designed to help permit applicants and reviewers make pollution prevention and control technology decisions for stationary air pollution sources, and includes data submitted by several U.S. territories and all 50 States on over 200 different air pollutants and 1,000 industrial processes. 

The RBLC provides several options for searching the permit database on-line to locate applicable control technologies. We conducted a search of the RBLC for processes in the fabric coating, printing, and dyeing category, with permits dating back to 1970. The search results included the following data fields:
 
       RBLC ID;
       Facility Name, and State;
       Permit Date;
       Process name;
       Pollutant;
       Control technology; and
       Percent efficiency of control.

The EPA's RBLC included seven facility records (with a total of 9 coating lines) for the fabric printing, coating, and dyeing process code. Each record pertained to a determination for a VOC emission limit and no records pertained to a HAP limit. Six of the seven determinations required facilities to meet VOC limits using solvent substitution, solvent reformulation, low VOC adhesives, or condensation controls. None of these control techniques are considered to be a "development" in MACT standard practices, processes, and control technologies. The seventh record was an overall VOC annual emission limitation determination for a Boeing facility. 

The results of the RBLC search for this source category are summarized in Appendix A to this memo. It should be noted that only one RBLC record was from a permit issued after promulgation of the final Fabric Coating NESHAP in 2003.

2.2	Subsequent Regulatory Actions

Regulatory actions promulgated subsequent to the May 5, 2003 Fabric Coating NESHAP have been identified for similar surface coating operations. These regulatory actions, listed in Table 1, were reviewed for developments in practices, processes and control technologies.
                                          
Table 1. Subsequent Regulatory Actions for Sources Similar to Fabric Printing, Coating and Dyeing Operations

                            Major Source  Standards
                                    Subpart
                               Date Promulgated
           Practices, Processes, and Control Technologies Evaluated
           Surface Coating of Miscellaneous Metal Parts and Products
                                     MMMM
                                   1/2/2004
Emission limit as mass HAP per volume solids used. Add-on control devices: low-HAP coatings (Ultraviolet (UV) curable, electron beam-curable), powder coatings
                 Surface Coating of Plastic Parts and Products
                                     PPPP
                                  04/19/2004
Emission limit as mass HAP per mass solids used, add-on control devices, low-HAP coatings (Ultraviolet (UV) curable, electron beam-curable)
             Surface Coating of Automobiles and Light-Duty Trucks
                                     IIII
                                   4/26/2004
Emission limit as mass HAP per volume solids used. Develop and implement a work practice plan to minimize organic HAP.
                 Risk and Technology Review for MACT Standards
                                    Subpart
                               Date Promulgated
   Practices, Processes, and Control Technologies Identified as Developments
                                 Magnetic Tape
                                      EE
                                   4/7/2006
                                No developments
                            Printing and Publishing
                                      KK
                                   4/21/2011
          Permanent total enclosures installed on controlled presses
                         Shipbuilding and Ship Repair
                                      II
                                  11/21/2011
Concentrator/RTO installed on spray booths to achieve 95% control efficiency for modules in new ship construction (was not applicable for fully assembled ships); lower VOC coating limits based on California regional rules.
                         Wood Furniture Manufacturing
                                      JJ
                                  11/21/2011
RTO; Lower VOC coating limits based on California regional rules; more efficient spray guns.
                                       
Bans conventional spray guns except when the overspray is routed to a control device.
                 Aerospace Manufacturing and Rework Facilities
                                      GG
                                   7/26/2016
                                No developments

Developments identified in the regulatory actions listed in Table 1 will be discussed in Section 3 (Technology Review for Surface Coating Operations).

2.3	State Rules and State Operating Permits

As part of this technology review, we researched state VOC rules that were developed in response to control technique guidelines (CTGs) developed by EPA and state permits. The CTGs established VOC limits to control VOC emissions. The technologies recommended by the CTGs to control VOC also provide control of HAP emissions. Therefore, as part of this review we reviewed the state operating permits to compare the VOC and HAP limits to the CTG and NESHAP limits. 

State Rules

In 1977, the EPA published a CTG to control VOC emissions from fabric coating. The CTG recommended separate limits for fabric coating lines (0.35 kg per liter (2.9 lbs per gal), less water) and vinyl coating lines (0.45 kg per liter (3.8 lbs per gal), less water). The CTG described a "fabric coating" to include all types of coatings applied to fabric, a large portion of which is rubber used for rainwear, tents, and industrial purposes such as gaskets and diaphragms. "Vinyl coating" referred to any printing or decorative or protective topcoat applied over vinyl coated fabric or vinyl sheets; it did not include the application of vinyl plastisol to the fabric, the emissions of which the CTG stated were near zero.

The 1977 CTG stated that the limitations for both were based on use of an add-on control device to recover or destroy 81 percent of the VOC introduced in the coating, based on capturing 90 percent of the VOC and delivering it to a control device having an efficiency of 90 percent.

The 1977 CTG reported that the limitation for fabric coating could also be achieved by use of an organic-borne coating which is about 60 volume percent solids or a water-borne coating with a solids content of about 24 volume percent and an organic solvent-to-water ratio of 20:80, but neither of these coatings were known to be in routine use by the industry at that time.

State Operating Permits

The relevant details from the permits collected by EPA are summarized in Appendix 2.

2.4 Site Visits

The EPA is planning to conduct site visits to fabric printing, coating, and dyeing facilities for this technology review.

2.4 Industry Information

Coating and Printing

Coating is a specialized chemical finishing technique to produce textiles that meet high performance requirements. Once the coating is dried (and cured, if necessary), it bonds with the material to impart elasticity and/or resistance to one or more elements such as abrasion, water, chemicals, heat, fire, and oil. The material itself provides strength (such as tear strength) and can include woven fabrics, nonwoven fabrics, knitted fabrics, yarn, cord, and thread, although woven fabrics are the most commonly used.

Printing is the application of color to a fabric in a design or pattern, usually in the form of a paste. In some cases, the printing material is chemically the same as coating material but thinned to a lower viscosity. Typically, four types of printing are used for mass production: rotary screen, engraved roller, flat-bed screen, and heat transfer. After application of the printing material, the substrate is treated with steam, heat, or chemicals to fix the color.

Dyeing and Finishing

Dyeing is the application of color to the whole body of a textile material with some degree of color fastness (i.e., the ability to maintain its color without fading or washing away). Dyes and finishes are applied to yarn, fiber, cord, thread, or fabric in aqueous solutions and then dried. Textiles are dyed using continuous and batch processes and dyeing may take place at any of several stages in the manufacturing process (i.e., prior to fiber extrusion, fiber in staple form, yarn, fabric, garment). Most of textile dyeing is done in the finishing departments of basic textile manufacturing facilities, although there are also several commission dye houses who perform dyeing and finishing, but no weaving or knitting. From an environmental perspective, dyeing has typically been viewed as a wastewater issue due to large quantities of water, chemicals, and auxiliaries (such as salt) used.

Finishing refers to any process operation performed after bleaching, dyeing, or printing that improves the appearance and/or usefulness of a textile substrate. Finishing encompasses any of several mechanical (e.g., texturizing, napping) and chemical processes (e.g., optical finishes, softeners, urea-formaldehyde resins for crease resistance) performed on fiber, yarn, or fabric to improve its appearance, texture, or performance. The fabric is usually dried prior to chemical finishing. Chemical finishing is commonly done continuously; fabric is passed through an aqueous solution containing the finishing chemical(s). After treatment, the fabric is typically passed through an oven to drive off water and activate/cure the finishing chemicals. There is no set recipe for the chemical finishes or mechanical finishing processes applied to any given substrate. Finishing methods are used according to desired characteristics of the end product (which vary widely and are market driven) and firms have some flexibility in the specific processes or chemicals they choose.

Slashing

The slashing subcategory includes the yarn preparation process performed on warp yarns (i.e., yarns which run vertically or lengthwise in woven goods) prior to weaving. The objectives of slashing are to strengthen, smooth the outer surface, and lubricate the yarn. Warp yarns need to sustain their elongation and flexibility during the weaving process, which necessitates the slashing process. Slashing is the application of a chemical solution (known as sizing) to a yarn in a water solution followed by squeezing and drying. The chemical nature of the size applied is dependent on the yarn substrate and the type of weaving being used. The three main types of size currently used are natural products (starch), fully synthetic products (e.g., polyvinyl alcohol or PVA), and semisynthetic blends (e.g., modified starches and carboxymethyl cellulose or CMC). Starch is principally used on cotton and does not work well on synthetic fabrics.

3.0	TECHNOLOGY REVIEW FOR SURFACE COATING OPERATIONS

As defined in the Printing, Coating, and Dyeing of Fabrics and Other Textiles NESHAP, coating means the application of a semi-liquid coating material to one or both sides of a textile web substrate. Once the coating material is dried (and cured, if necessary), it bonds with the textile to form a continuous solid film for decorative, protective, or functional purposes. Coating does not include finishing where the fiber is impregnated with a chemical or resin to impart certain properties, but a solid film is not formed. Such materials include, but are not limited to, coatings, sealants, inks, and adhesives. Decorative, protective, or functional materials that consist only of acids, bases, or any combination of these substances are not considered coating material for the purposes of this subpart.

The principal HAP emitted by the fabric coating and printing, dyeing and finishing, and slashing affected sources (accounting for about 97% of HAP emissions) include toluene, phenol, methanol, n,n-dimethyl formamide, xylenes, trichloroethylene, and formaldehyde. The operations associated with each subcategory and HAP emissions from those operations are described below.

Coating and Printing
Coating and printing material application and curing are the largest contributors of HAP emissions at coating and printing affected sources. Other operations and activities that may create HAP emissions associated with coating/printing include storage tanks, substrate preparation, coating and printing material mixing/thinning operations, equipment cleaning, and waste and wastewater operations.

Dyeing and Finishing
Dyeing and finishing HAP emissions are a function of site specific conditions, i.e., the fabric that passes through in the process range, the types of equipment used for the process, the dye or finish chemistry, and the process conditions (e.g., where the fabric is heated). 

Dyestuffs and auxiliary chemicals, as purchased, are the sources of HAP emissions from dyeing. The HAP constituents are needed to impart characteristics to the dyed substrate (e.g., certain colors can only be attained through the use of HAP-containing dyestuffs or auxiliaries). In 2002, it was estimated that the fraction of HAP contained in dye materials that is emitted to the atmosphere is generally estimated to range from zero to 10 percent, with the exception of one source, who reported their fraction of HAP emitted was 19 percent. 

In finishing, unlike in dyeing, the fraction of HAP contained in finishes that is emitted to the atmosphere is generally assumed to be 100 percent with the exception of HAP that cross-link to the fiber, such as formaldehyde. This is because finished textiles are generally dried and cured at relatively high temperatures (i.e., over 300[o]F). 

Slashing
The primary source of HAP emissions from slashing is methanol from PVA size (i.e., chemical solution), typically applied to synthetics (although it is also used for natural fibers). The methanol is present in the PVA size as a contaminant and is not needed for the slashing process. The methanol emissions are from the size cooking operation and from the application or slashing process -- the distribution of emissions from these two sources depends upon the temperature at which the size is cooked, the cooking time, and how often mixing containers (cookers) are opened. In 1999, the American Textile Manufacturers Institute (ATMI) demonstrated that the majority of the domestic market used PVA with less than 1 percent methanol as purchased. 

3.1	Summary of Existing MACT Level of Control

The Fabric Coating NESHAP, promulgated in 2003 and most recently amended in 2006, limits emissions of HAP from fabric printing, coating, and dyeing operations that are major sources of HAP.

Affected Sources
The coating and printing subcategory includes all web coating and printing equipment; the dyeing and finishing subcategory includes all dyeing and finishing equipment used to apply dyeing or finishing materials; and the slashing subcategory includes all slashing equipment used to apply and dry size on warp yarn. Independent of subcategory, the following emission sources are also part of the affected source:

 All storage containers and mixing vessels in which regulated materials are stored or mixed; 
 All manual and automated equipment and containers used for conveying regulated materials;
 All storage containers and all manual and automated equipment and containers used for conveying waste materials; and
 All manual and automated equipment, structures, and devices used to convey, treat, or dispose of wastewater streams or residuals.

Exemptions/Exclusions
The NESHAP does not regulate cleaning materials and preparation materials in the slashing or the dyeing and finishing subcategories. Slashing and dyeing and finishing operations are aqueous processes (i.e., water is by far the largest solvent used), and therefore, the cleaning materials and preparation activities used in these operations do not contain HAP.

The Fabric Coating NESHAP does not apply in the following situations:

 Any web coating operation that is part of the affected source of subpart JJJJ of part 63 (NESHAP for paper and other web coating). This would include any web coating line that coats both a paper and other web substrate and a fabric or other textile substrate for use in flexible packaging, pressure sensitive tape and abrasive materials, or any web coating line laminating a fabric substrate to paper.
 Any web coating operation that is part of the affected source of subpart XXXX of part 63 (NESHAP for tire manufacturing). This would include any web coating line that applies coatings to both tire cord and to textile cord used in the production of belts and hoses.
 Coating, slashing, dyeing, or finishing operations at a synthetic fiber manufacturing facility where the fibers are the final product of the facility.
 Any web coating line that coats or prints fabric or other textiles for use in flexible packaging and that is included in an affected source under subpart KK of part 63 (NESHAP for the printing and publishing industry).
 Web coating lines engaged in the coating of both fabric and other webs on the same web coating line where the fabric substrate is less than 10 percent by mass of the substrate coated.
 If coating, printing, slashing, dyeing, finishing, thinning materials contain no organic HAP.
 If coating, printing, slashing, dyeing or finishing that occurs as part of a research or laboratory operation, or that is part of janitorial, building, and facility maintenance operations.
 Coating, printing, slashing, dyeing, or finishing operations used by a facility and not for commerce, unless organic HAP emissions from the coating, printing, slashing, dyeing or finishing operations are as high as the major source HAP emission levels.
 If web coating and printing operations dry at ambient temperatures (i.e., do not involve drying or curing equipment such as ovens, tenter frames, steam cans, or dryers).
 Coating, printing, slashing, dyeing, or finishing operations performed on-site at installations owned or operated by the Armed Forces of the United States (including the Coast Guard and the National Guard of any State).

NESHAP Compliance Options and Emission Limits

Affected fabric printing, coating, and dyeing sources have several compliance options: 
1) Comply through a pollution prevention approach by applying regulated materials that meet the emission rate limits, either individually (compliant material option) or collectively (emission rate without add-on controls option), during each monthly compliance period. 
2) Use a capture system and add-on control device to meet either the applicable organic HAP overall control efficiency limit or emission rate limit. 
3) Use a 100 percent efficient capture system (a permanent total enclosure) and a thermal oxidizer that reduces organic HAP emissions to no more than 20 parts per million by volume (ppmv).

The NESHAP includes a provision to account for reactive materials in multi-component coatings that are not emitted to the atmosphere. Sources may use EPA Method 24 of 40 CFR part 60 Appendix A on the reactive coating as applied (see section 11.2 of Method 24) to determine the mass fraction of non-aqueous volatile matter and use that value as a substitute for the mass fraction of organic HAP in each coating component. Sources may also submit an alternative technique for approval by the Administrator to quantify the organic HAP actually emitted from the coating process. 

The HAP emission limits for each subcategory are presented in the table below.

Table 2. Emission Limits for New or Reconstructed and Existing Affected Sources in the Printing, Coating and Dyeing of Fabrics and Other Textiles Source Category [Table 1 from 40 CFR 63 Subpart OOOO]
If your affected source is a
And it conducts
Then this is the organic HAP emission limit for each compliance period
1. New or reconstructed coating and printing affected source
Coating operations only, or Printing operations only, or Both coating and printing operations
You may choose any one of the following limits:
  Reduce organic HAP emissions to the atmosphere by achieving at least a 98 percent organic HAP overall control efficiency; 
  Limit organic HAP emissions to the atmosphere to no more than 0.08 kg of organic HAP per kg of solids applied; or 
  If you use an oxidizer to control organic HAP emissions, operate the oxidizer such that an outlet organic HAP concentration of no greater than 20 ppmv on a dry basis is achieved and the efficiency of the capture system is 100 percent.
2. Existing coating and printing affected source
Coating operations only, or Printing operations only, or Both coating and printing operations
You may choose any one of the following limits:
  Reduce organic HAP emissions to the atmosphere by achieving at least a 97 percent organic HAP overall control efficiency;
  Limit organic HAP emissions to the atmosphere to no more than 0.12 kg of organic HAP per kg of solids applied; or
  If you use an oxidizer to control organic HAP emissions, operate the oxidizer such that an outlet organic HAP concentration of no greater than 20 ppmv on a dry basis is achieved and the efficiency of the capture system is 100 percent.
3. New, reconstructed or existing dyeing finishing affected source
a. Dyeing operations only
You must limit organic HAP emissions to the atmosphere to no more than 0.016 kg of organic HAP per kg of dyeing materials applied.

b. Finishing operations only
You must limit organic HAP emissions to the atmosphere to no more than 0.0003 kg of organic HAP per kg of finishing materials applied.

c. Both dyeing and finishing operations
You must limit organic HAP emissions to the atmosphere to no more than 0.016 kg of organic HAP per kg of dyeing and finishing materials applied.
4. New, reconstructed or existing slashing affected source
Slashing operations only
You must limit organic HAP emissions to the atmosphere to no more than zero kg organic HAP per kg of slashing materials as determined according to §63.4321(e)(1)(iv). 

If a facility reduces emissions from coating or printing operations by using a capture system and add-on control device (other than a solvent recovery system for which you conduct a liquid-liquid material balance), then the facility must also comply with operating limits that apply to the emission capture system and add-on control device. These operating limits are site-specific parameter limits that are determined by the facility during the initial performance test of the capture system and add-on control device. These limits are presented in Table 3.

Table 3. Operating Limits if Using Add-On Control Devices and Capture Systems [Table 2 from 40 CFR 63 Subpart OOOO]

Control Device
                                Operating Limit
1. Thermal oxidizer
a. The average combustion temperature in any 3-hour period must not fall below the combustion temperature limit established according to §63.4363(a)
2. Catalytic oxidizer
a. The average temperature measured just before the catalyst bed in any 3-hour period must not fall below the limit established according to §63.4363(b); and either

b. Ensure that the average temperature difference across the catalyst bed in any 3-hour period does not fall below the temperature difference limit established according to §63.4363(b)(2); or

c. Develop and implement an inspection and maintenance plan according to §63.4363(b)(4).
3. Emission capture system
Submit a monitoring plan to the Administrator that identifies operating parameters to be monitored according to §63.4364(e)

Additionally, the NESHAP sets work practice standards for any coating operation or group of coating operations for which you demonstrate compliance using:

 The emission rate with add-on controls option, 
 The organic HAP overall control efficiency option, or 
 The oxidizer outlet organic HAP concentration option for a web coating/printing operation; or 
 The emission rate with add-on controls option for a dyeing/finishing operation.

Additional details on work practices are provided in section 3.2.3. 

MACT Floor Determination
In 1998, the EPA surveyed fabric printing, coating and dyeing facilities to determine which add-on controls were in use as part of the NESHAP development process. Surveyed facilities were asked to provide detailed information on coating line emissions and controls. The results of that survey are summarized below for each subcategory.

Coating and Printing: For the coating and printing subcategory, the MACT analysis considered both add-on controls and lower HAP coating and printing materials, as described below. The lower HAP materials include waterborne coatings and higher-solids coatings.

Add-on Controls: The EPA survey results showed that of the 21 coating facilities, thirteen operated controls on their coating lines. In aggregate, there were 29 controlled coating lines: 16 lines used thermal oxidizers, 3 lines used catalytic oxidizers, 9 lines used carbon adsorbers to control VOC and organic HAP; and one controlled line used an electrostatic precipitator to control particulate matter. The technology basis for existing sources was emission capture and add-on control with an overall control efficiency (OCE) of 97 percent, and for new sources the OCE was 98 percent.

Analysis of the survey results for capture efficiency showed that not all determinations were performed in the same manner. Of the six facilities claiming that the enclosures were Permanent Total Enclosures (PTE), only three were classified in the MACT floor database as actually meeting the EPA Method 204 criteria of a PTE. One facility reported the basis for the capture efficiency was PTE as determined by Method 204 and for two facilities who claimed 100 percent capture, the EPA confirmed that Method 204 criteria had been met.

Emission reduction efficiencies greater than 98 percent were considered during MACT development, but the additional costs incurred did not justify the incremental reduction in HAP. Also, vendors could not guarantee the higher efficiencies over the life of the equipment.  As a result, the EPA did not accept a higher OCE as a "beyond-the-floor" option for MACT in the development of the original NESHAP.

Waterborne coating and higher-solids coatings: Waterborne coatings generally produce lower levels of organic HAP and VOC emissions, as compared to uncontrolled solvent borne coatings, but their applicability is limited in that, for some products, these coatings are not able to achieve the desired final product characteristics. Similarly, low organic HAP or waterborne printing materials are not able to achieve the desired final product characteristics for certain products (e.g., designer and fashion apparel) that require the use of higher organic HAP printed materials. Higher solids coatings (e.g., ultraviolet (UV) cured coatings, electron beam (EB) cured coatings, and thermally applied polyurethane coatings) also have lower HAP contents than conventional solvent borne fabric coatings, but they are not universally applicable for all fabric coating needs.  Given the limited applicability of waterborne, UV-curable, EB-curable, and thermal (a.k.a., hot-melt) coatings, waterborne and higher solids coating and printing materials were rejected by the EPA as a beyond-the-floor option in the development of the original NESHAP. 

Dyeing and Finishing: The EPA survey results showed that there were no emission controls used to reduce organic HAP emissions from dyeing operations; the few controls used on finishing operations were to reduce opacity and were not efficient at reducing organic HAP emissions. Therefore, the MACT floors for dyeing and finishing were evaluated based on the HAP content of the purchased materials used in the dyes and finishes applied at a facility and no beyond-the-floor technology was identified.

It should be noted that seven stakeholders (Dan River Inc., American Yarn Spinners Association, Southern Mill Inc., American & Efird Inc., Textile and Carpet Industry MACT Coalition, WestPoint Stevens, and Springs Industries Inc.) commented on the proposed NESHAP that an add-on control compliance option should be included in the final rule for the dyeing and finishing subcategory. They argued that as the industry moved from large scale goods production to specialized niche production, and as new products and technologies were developed and implemented, flexibility in the production process and in compliance options (including the use of add-on controls) would be the key to the survival of this industry. In response, the EPA included an emission rate with an add-on controls option in the final rule.

Commenters on the proposed NESHAP also argued that organic HAP in the dyeing and finishing materials may be discharged in the wastewater to a publicly owned treatment works (POTW) or onsite secondary wastewater treatment, and not emitted to the atmosphere. In response, the EPA included an equivalent emission rate compliance option in the final rule in which a source must make an initial compliance demonstration that at least 90 percent of the mass of organic HAP contained in dyeing and finishing materials applied in the affected source is discharged to a POTW or onsite secondary wastewater treatment.

Slashing: As discussed above, the primary source of HAP emissions from slashing is methanol (as a contaminant) from polyvinyl alcohol (PVA) size. In 1999, the industry trade group ATMI indicated that the majority of the domestic textile market was using low-HAP PVA for slashing.

The MACT floors for existing sources and new or reconstructed sources in the slashing subcategory was zero organic HAP (which includes methanol). Each organic HAP that is not an OSHA-defined carcinogen that is measured to be present at less than 1 percent is counted as zero. There was no beyond-the-floor technology identified that could achieve a lower organic HAP content in materials "as purchased" than zero percent HAP.

3.2	Identified Control Measures for Printing, Coating, and Dyeing Operations

As discussed in section 2.1, a total of seven facilities, and nine process lines, were identified in the RBLC as having printing, coating, or dyeing operations subject to VOC emission limits. The RBLC indicated that most (i.e., 7 of 9) lines comply with limits by substituting or reformulating solvents and coatings to meet VOC limits. One process line complies with VOC limits using add on condensation control equipment. No control method was specified for one line. None of these control techniques are considered to be a "development" in MACT standard practices, processes, and control technologies.

3.2.1	Add-On Control Technology or Other Measures Not Identified and Considered During MACT Development

Coating and Printing: In this technology review we have not identified any improvements in the add-on controls used in fabric coating and printing that would support revising the MACT emission limits for existing and new sources after a thorough review of: 1) regulatory actions promulgated subsequent to the Fabric Coating NESHAP; 2) other data sources, including the RBLC, state regulations, and industry information. The add-on controls that are now available have essentially the same emission reduction performance as those that were available when the NESHAP was proposed and promulgated.

Dyeing and Finishing: In this technology review we have not identified any improvements in the add-on controls used in dyeing and finishing. The add-on controls that are now available have essentially the same emission reduction performance as those that were available when the NESHAP was proposed and promulgated.

Slashing: Because the emission limitation for the slashing subcategory is already zero-organic HAP, there is no add-on control technology development possible that can achieve a lower emission limitation.

3.2.2	Improvements in Add-On Control Technology or Other Equipment for Organic HAP Emissions That Was Identified and Considered During MACT Development

To aid identification of developments in add-on control technologies, we collected and reviewed state operating permits and calculated the fraction of facilities in each subcategory using add-on controls. The subcategory (i.e., coating and printing, dyeing and finishing, or slashing) was identified using the applicable HAP emission limit included in the permit. However, some permits included all applicable limits from the Fabric Coating NESHAP, and this made it difficult to identify the applicable subcategory and/or the control device at the facility. The results of permit investigation are summarized in Table 4, and the information for each facility is presented in Appendix B.

Table 4. Summary of Process Types and Add-On Controls Determined from Permits
NESHAP Subcategory
                 Fraction of Facilities Using Add-On Controls
Coating and Printing
                                 10 / 17 (59%)
Dyeing and Finishing
                                  1 / 3 (33%)
Slashing
                                  0 / 2 (0%)
Unknown or Multiple Subcategories
                                  9 / 21 (43%)
Total
                                 20 / 43 (47%)


Coating and Printing: In this technology review we have not identified any improvements in the add-on controls used in fabric coating and printing that would support revising the MACT emission limits for existing and new sources after a thorough review of: 1) regulatory actions promulgated subsequent to the Fabric Coating NESHAP; 2) other data sources, including the RBLC, state regulations, and industry information. The add-on controls that are now available have essentially the same emission reduction performance as those that were available when the NESHAP was proposed and promulgated.

Dyeing and Finishing: In this technology review we have not identified any developments in dyeing and finishing that would support revising the MACT emission limits for existing and new sources. The current limits are based on the use of low-HAP dyes and finishes. Of the three facilities with permits and identified as dyeing and finishing, only one is using an add-on control to comply with the limits. However, the EPA does not have any data to indicate that the facility using an add-on control could achieve HAP emission rates lower than the current HAP emission limit.

Slashing: Because the emission limitation for the slashing subcategory is already zero-organic HAP, there is no add-on control technology development possible that can achieve a lower emission limitation.

3.2.3	Work Practices and Procedures Not Identified and Considered During MACT Development

No additional work practices or procedures were identified that were not already identified and considered during MACT development.

The current standards require that, if a facility uses add-on controls to comply with the emission limitations, the facility must develop and implement a work practice plan to minimize organic HAP emissions from the storage, mixing, and conveying of coatings, thinners, and cleaning materials used in, and waste materials generated by, those coating operations. These work practices include the following:

 All organic-HAP-containing coatings, thinners, cleaning materials, and waste materials must be stored in closed containers.
 Spills of organic-HAP-containing coatings, thinners, cleaning materials, and waste materials must be minimized.
 Organic-HAP-containing coatings, thinners, cleaning materials, and waste materials must be conveyed from one location to another in closed containers or pipes.
 Mixing vessels which contain organic-HAP-containing coatings and other materials must be closed except when adding to, removing, or mixing the contents.
 Emissions of organic HAP must be minimized during cleaning of storage, mixing, and conveying equipment.

If a facility is not using add-on controls and is using either the compliant material option or the emission rate option, the facility does not need to comply with work practice standards. Under the compliant material option, the materials covered by the work practices would be either non-HAP, or would already be compliant with numerical HAP content limits.

3.2.4	Any process change or pollution prevention alternative that could be broadly applied that was not identified and considered during MACT development.

Coating and Printing: In this technology review we have not identified any developments in waterborne and higher solids coatings that would support revising the MACT emission limits for existing and new sources. The current limits are based on the use of emission capture systems and add-on controls, but facilities have the option to use waterborne and higher solids coatings to comply with those limits. The EPA has found no information to indicate that developments in waterborne or higher solids coatings could achieve lower HAP emissions than the current HAP emission limits.

Dyeing and Finishing: In this technology review we have not identified any developments in dyeing and finishing that would support revising the MACT emission limits for existing and new sources. The current limits are based on the use of low-HAP dyes and finishes.

Slashing: Because the emission limitation for the slashing subcategory is already zero-organic HAP, there is no technology development possible that can achieve a lower emission limitation.

3.2.5 Significant changes in the cost (including cost effectiveness) of applying controls (including controls the EPA considered during the development of the original MACT standards).

In developing the 2003 Printing, Coating, and Dyeing of Fabrics and Other Textiles NESHAP, the EPA assumed that all sources with affected finishing, slashing, and dyeing operations would comply through the use of reformulated finishing, slashing, dyeing, thinning, and cleaning materials, and that these materials could be utilized without the need for capital expenditures. The EPA estimated that total annual costs would be $7.5 million and achieve HAP emission reductions of 748 tons/year. This would correspond to a cost effectiveness of about $10,000 per ton of HAP reduced. The information collected for this technology review has confirmed that facilities have complied with the emission limits for the finishing, slashing, and dyeing subcategories predominantly by using low-HAP reformulated materials. 

In developing the 2003 NESHAP, the EPA estimated the cost of applying emission capture and add-on controls for the coating and printing subcategories. The EPA estimated that the total annual costs would be $5.6 million and achieve HAP emission reductions of 3,182 tons/year. This would correspond to a cost effectiveness of about $1,800 per ton of HAP reduced. The information collected for this technology review has indicated that a majority of facilities have complied with the emission limits for the coating and printing subcategories by using add-on controls. 

The control costs estimated during the Printing, Coating, and Dyeing of Fabrics and Other Textiles NESHAP development have not been revisited or updated.  
Appendix A. Practices, Processes and Control Technologies Identified for Printing, Coating, and Dyeing of Fabrics and Other Textiles Operations in the Query of the RBLC Database [Process Type: 41.005 Fabric Coating/Printing/Dyeing]

                                    RBLCID
                                   Facility
                                     State
                                  Permit Date
                                 Process Name
                                   Pollutant
                      Emission Limitation/Control method
WA-0326
Boeing Commercial Airplane Group
WA
10/12/2005
Aircraft Interiors Manufacturing
                                      VOC
205 ton/year
CA-0967
Garden Prints
CA
6/5/2001
Textile Printing
                                      VOC
15 lb/day from press
127 lb/day from facility
Requirements are met by use of inks with 50 gram/liter or less.
CA-0969
New Age Graphics, Inc.
CA
7/22/1999
Fabric Printing
                                      VOC
30 lb/day
Requirements are met by use of low VOC plastisol and water based inks (i.e., 2.8 lb/gallon) and low VOC adhesives (0.25 lb/gallon).
CA-0970
Giant Merchandising
CA
5/17/1999
Fabric Printing
                                      VOC
900 lb/month
Requirements are met by use of water based and plastisol inks. Inks contain less than 0.625 lb/gallon VOC. BACT requires the use of screen printing materials that comply with South Coast's State Rule VOC levels i.e., 1130.1
RI-0013
Kenyon Industries, Inc.
RI
6/19/1996
Fabric Coater (No. 12)
Fabric Coater (No. 2)
                                      VOC
2.9 lb/gal
Requirements are met by use of low VOC coatings




Fabric Coater
                                      VOC
5.4 lb/gal
Requirements are met by use of add on condensation control equipment
NH-0007
L. W. Packard & Co. Inc.
NH
5/31/1995
Textile Finishing/Dyeing
                                      VOC
0.0456 lb/lb cloth shipped
Requirements are met with solvent substitution.
MA-0019
Brittany Dyeing and Printing
MA
3/16/1994
Textile Dyeing And Printing
                                      VOC
0.5 lb/lb solids
Requirements are met with reformulation.

Appendix B. Permit Process Type and Control Methods.

                                   Facility
                                   Location
                                 Process Type
                                Control method
Industrial Laminates/Norplex, Inc
                                                                  Postville, IA
Existing Coating
RTO
Da Lite Screen Company Llc
                                                                     Warsaw, IN
Existing Coating
PM control only  -  baghouse
Lewcott Corporation
                                                                   Millbury, MA
                                                                              -
Unknown (no permit found)
Pioneer Plastics Corp
                                                                     Auburn, ME
Existing Coating 
RTO
American & Efird Plants #5 & #15
                                                                   Mt Holly, NC
Existing Coating 
RTO
Coveris Advance Coatings Us, LLC
                                                                   Matthews, NC
Existing Coating 
PTE and RTO
Flint Group
                                                                      Arden, NC
                                                                               
RTO (a) (no permit found)
Veyance Technologies Inc
                                                                    Lincoln, NE
Existing Coating 
RTO
Avery Dennison Information and Brand Mgmt Div
                                                                 Orangeburg, NY
Existing Coating 
RTO
Endicott Interconnect Technologies Inc
                                                                   Endicott, NY
Existing Coating
PTE and RTO
Cooley, Inc.
                                                                  Pawtucket, RI
Existing Coating
PTE and RTO
Galey & Lord Society Hill
                                                               Society Hill, SC
Existing Dyeing and Finishing
New Coating
No control
No control
Graniteville Speciality Fabrics
                                                               Graniteville, SC
Existing Coating
RTO on coaters
Highland Industries Inc
                                                                     Cheraw, SC
Slashing
No control
Santee Print Works
                                                                     Sumter, SC
Existing Dyeing and Finishing
No control
Cone Mills Carlisle Finishing
                                                                   Carlisle, SC
Existing Dyeing and Finishing
No control
Flexi Wall Systems
                                                                    Liberty, SC
Existing Coating
no control
Trelleborg Coated Systems US Inc.
                                                                Spartanburg, SC
                                                                              -
Unknown (no permit found)
Mohawk Industries Inc - Lees Carpets Division
                                                                    Glasgow, VA
Coating (hot melt and latex) and Dyeing
No control
Duro Textiles LLC
                                                                 Fall River, MA
Multiple types:
a) Existing Coating and Printing, 
b) Dyeing and Finishing
RTO on coaters
Synthetics Finishing Longview
                                                                   Longview, NC
Multiple types:
a) Existing Coating and Printing, 
b) Dyeing and Finishing
Carbon adsorber on coater
Kenyon Industries, Inc.
                                                                   Richmond, RI
Multiple types:
a) Existing Coating and Printing, 
b) Dyeing and Finishing
no control
Milliken & Co Hillside Coating Plant
                                                                   Lagrange, GA
Coating
no control
HBD Industries, Inc.
                                                                    Chanute, KS
Existing Coating
RTO
Hood Coatings
                                                                 Georgetown, MA
Coating
RTO (a) on coaters
Milliken & Co Valway Plant
                                                                   Lagrange, GA
Dyeing Finishing
PM control only  -  WESP
Coats American - Sevier Plant
                                                                     Marion, NC
Thread bonding (coating)
catalytic oxidizer on thread bonders (coaters)
Hanes Dye and Finishing Co.
                                                              Winston-Salem, NC
Dyeing Finishing
no control
Bradford Industries
                                                                     Lowell, MA
Existing Coating
PTE and RTO
Day International, Inc. A Flint Group Company
                                                               Three Rivers, MI
Existing Coating
carbon adsorber
Belt Service Corp-Earth City
                                                                 Earth City, MO
Existing Coating (adhesives)
no control
Highlands Industries
                                                               Kernersville, NC
Existing Coating
carbon adsorber, thermal oxidizer
Warwick Mills Inc
                                                                New Ipswich, NH
Existing Coating
Boiler
Hollingsworth & Vose-Easton Mill
                                                                  Greenwich, NY
Existing Coating
no control
Von Roll USA Inc
                                                                Schenectady, NY
Existing and New Coating Lines
Thermal Oxidizer
Duracote Corp. 
                                                                    Ravenna, OH
Existing Coating
no control
Excello Fabric Finishers, Inc.
                                                                  Coshocton, OH
Existing Coating
no control
Holliston Mills, Inc.
                                                                Church Hill, TN
Existing Coating
no control
Kinyo Virginia Incorporated
                                                               Newport News, VA
Existing Coating
carbon adsorber for solvent recovery
Worthen Coated Fabrics
                                                               Grand Rapids, MI
New Coating
PTE and RTO
Trelleborg Coated Systems Us, Inc - Grace Advanced Materials
                                                              Rutherfordton, NC
New Coating
Carbon Adsorber and RTO
Milliken & Company - New Holland Plant
                                                                Gainesville, GA
Slashing
no control
Milliken Cedar Hill
                                                                 Jonesville, SC
Slashing
no control
Total
                                                                               
                                                                               
18  -  Uncontrolled; 13  -  RTO; 5  -  Unknown; 4  -  Activated Carbon; 1  -  Catalytic Oxidation; 1  -  Boiler; 1  -  Controlled but device not specified 
Footnote: (a) NEI self-reported control method.



