MEMORANDUM
DATE:		December 30, 2021
SUBJECT:	Summary of Data Collected for the Miscellaneous Coatings Manufacturing RTR Inorganic HAP Amendments
FROM: 		Angie Carey
TO:			Docket ID: EPA-HQ-OAR-2018-0747
 PURPOSE
      The purpose of this memo is to present the data collected to develop the Miscellaneous Coatings Manufacturing (MCM) Risk and Technology Review (RTR) proposal. EPA collected information from publicly available title V permits, a control device manufacture, as well as information from the American Coatings Association (ACA) from four area source paint facilities. This memo presents the information that was collected and reviewed for this action. 
2.0 DISCUSSION
      In reviewing the title V permits available for this category, out of the 13 facilities reporting metal HAP in the 2017 National Emissions Inventory (NEI), EPA determined that 11 facilities control metal HAP. The title V permits showed that 23 facilities control PM with dry filters, baghouses, or scrubbers. There are seven permits with PM limits (see Table 1).

                    Table 1: PM Requirements in MCM Permits
                                    Source
                                Limit (gr/dscf)
                                Control device
                                 PPG Oak Creek
                                     0.07
                               Cartridge filters
                                Lord Sagertown
                                     0.04
                                   Baghouses
                                 PPG Delaware
                                     0.03
                                   Baghouses
                                 Von Roll USA
                         0.05  -  0.15 -  average 0.1
                                 Fabric filter
                                 3M Hutchinson
                                      0.1
                               Cartridge filters
                                 3M Knoxville
                                      0.1
                                  Bag filter
                               3M Cottage Grove
                                      0.3
                                   Baghouses

      Additionally, ACA provided EPA with Method 5 PM performance tests from four area source facilities that are coating manufacturers. These four performance tests' results are available in the Docket ID: EPA-HQ-OAR-2018-0747. Emissions reported ranged from 0.003 to 0.0138 gr/dscf. An upper prediction limit (UPL) analysis was completed based on these four performance tests (see Excel file UPL for Area Source Paint.xlsx). Table 2 below shows a summary of this UPL analysis. 
                     Table 2: Summary of the UPL Analysis
Facility
Run 1 (gr/dscf)
Run 2 (gr/dscf)
Run 3 (gr/dscf)
Average (gr/dscf)
UPL (gr/dscf)
UPL New (gr/dscf)
UPL Existing (gr/dscf)
                                  SPPD_FAC_04
                                                                         0.0138
                                                                        0.00830
                                                                         0.0043
                                                                         0.0088
                                                                           0.02
                                                                               

                                  SPPD_FAC_03
                                                                        0.00079
                                                                        0.00057
                                                                        0.00069
                                                                        0.00068
                                                                        0.00131
                                                                         0.0013
                                                                               
                                  SPPD_FAC_01
                                                                         0.0007
                                                                         0.0003
                                                                         0.0005
                                                                         0.0005
                                                                        0.00164
                                                                               

                                  SPPD_FAC_02
                                                                         0.0005
                                                                         0.0008
                                                                         0.0023
                                                                         0.0012
                                                                         0.0048
                                                                               
                                                                          0.014
      
      EPA also had discussions with baghouse and cartridge filter vendor, Donaldson, who service this industry, and they provided performance specifications indicating that some systems could achieve PM emissions on the order of 0.002 to 0.005 gr/dscf within the MCM category. See Docket ID: EPA-HQ-OAR-2018-0747. 
      Based on the fraction of HAP in particulate matter (PM) that has been reported in two independent references (see EPA Springdale Chromium Q.docx in the MCM Docket ID: EPA-HQ-OAR-2018-0747 and Model Plants for Paint and Allied Products Manufacturing Area Sources in the Paints and Allied Products Docket ID: EPA-HQ-OAR-2008-0053), we estimate on average 0.12 weight percent inorganic HAP metal-compounds in PM associated with dust collectors in the source category. Assuming this weight fraction, inorganic HAP emissions from the outlet of a PM control device emitting on the order of 0.003 gr/dscf would result in inorganic HAP emissions approaching or below the detection limit of the analysis method for total selected metals, EPA Method 29. For example, 0.0012 weight percent of 0.003 gr/dscf PM is equivalent to 8 μg/dscm of metal HAP, approximately three times the reference detection level (RDL), See Data and Procedure for Handling Below Detection Level Data in Analyzing Various Pollutant Emissions Databases for MACT and RTR Emissions Limits.pdf in the Docket for this action. Therefore, it is difficult to set a limit based on inorganic HAP because controls achieving low PM loading rates (e.g., the best performers) will likely result in concentrations of inorganic HAP below limits of detection. However, measurement of PM is feasible and also represent the best performers and, therefore, we are using PM as a surrogate. 
      
