MEMORANDUM


DATE:	April 2022

SUBJECT:	Estimated Costs/Impacts 40 CFR Part 60 Subpart TTTa 

FROM:	Lisa Sutton, OAQPS/SPPD/MMG

TO:	Docket for NSPS for Surface Coating of Plastic Parts for Business Machines

Background
The focus of this memo is to measure the impact of BSER regulatory options that are more stringent than the current NSPS on spray booths at affected facilities that commence construction, modification, or reconstruction after January 8, 1986. Further, we have evaluated regulatory options in terms of 1) impacts on affected facilities--cost, environmental, and energy impacts, as well as 2) cost effectiveness of control options.
Model Plant
We expect no new, modified, or reconstructed sources to become subject to NSPS subpart TTTa over the next 8 years. However, we opted to evaluate impacts on a model plant basis. 
Through a detailed analysis of the Enforcement and Compliance History Online (ECHO) database and by contacting individual facilities and reviewing their air permits, we determined that three facilities currently perform surface coating of plastic parts for business machines. To define the size of the model plant we looked at the VOC emissions of the active stationary sources. The table below presents the annual VOC emissions of these active facilities.
These facilities are largely job shops. Job shops are typically small manufacturing systems that handle job production such as small- to medium-size customer orders or batch jobs. Job shops typically move on to different jobs when each job is completed. 

Table 1. Stationary sources that currently perform surface coating under Subpart TTT.
Stationary Source Name
                                   Location
                                  Booth Count
                            (Count Subject to TTT)
                                  Stationary 
                                  Source Type
                               (Material Coated)
                     Annual VOC Emissions Mg/yr (tons/yr)

                                       
                                       
                                       
                                 Potential [a]
                                  Actual [b]
FM Structural Plastic Technology, Inc.
Rogers,
AR
                                      14
                                      (8)
Job Shop
(Medical Office Equipment)
                                     86.2
                                  (95.0) [c]
                                       d
Universal Plastics  -  Middlefield
Middlefield, OH
                                      10
                                     (10)
Job Shop
(Medical Office Equipment)
                                     24.4
                                    (26.9)
                                      6.3
                                    (6.98)
Xerox Corporation  -  Wilson Center
Webster,
NY
                                       4
                                      (1)
Original Equipment Manufacture
(Refurbish Production Equipment)
                                      9.3
                                  (10.3) [c]
                                      6.2
                                    (6.78)
Average
                                     40.0
                                    (44.1)
                                      6.2
                                    (6.88)
Notes
a  -  Potential emissions are characterized from the air permits. 
b  -  Actual emissions are characterized from the 2017 National Emissions Inventory (NEI).
c  -  Emission includes activities not regulated under NSPS subpart TTT.
d  -  The State Agency reported annual emissions for FM Structural Plastic in the Emissions Inventory System (EIS) non-point inventory.

For the annual emissions of the TTTa model plant we selected a value of 27.2 Mg per year (30 tons per year) as a value between the average potential emissions represented by the active facilities air permits and the average actual emissions represented by the 2017 National Emissions Inventory (NEI).
Below is the historical basis we used to quantify the model plant volume of coating materials:
 The EPA's 1985 Background Information and Draft Environmental Impact Statement (BID) "small model plant" was estimated to be applying 1,730 liters of coating solids per year to plastic parts; 250 of that is for EMI-RFI shielding coatings, leaving 1,480 as exterior coating. Subpart TTTa will not have separate limits for EMI/RFI coatings.
 The 1988 NSPS provided a model plant with 1,480 liters of coating solids applied and a calculated VOC release of 2.67 Mg VOC. It is assumed that this ratio of coating deposited to VOC emissions is representative of other facilities. 

As discussed above, we selected for the TTTa model plant a release of 27.2 Mg of VOC annually. Using the 1988 ratio of Mg VOC to liter solids applied, we estimate that the model plant will consume 15,100 liters of coating solids applied.
Control Options
Control techniques used to reduce VOC emissions from general surface coating processes include: 1) the use of more efficient coating application techniques, 2) low-VOC-content coatings, and 3) add-on controls. In reviewing the NSPS for surface coating of plastic parts for business machines, we considered each of these emission reduction techniques.
Application techniques options are limited for surface coating of plastic parts for business machines. First, plastic parts are mostly spray applied. Dip coating is uncommon because although it has a high transfer efficiency (TE), it is color specific and the customer (i.e., job shop) cannot easily switch colors. Dip coating may be used by original equipment manufacturers for large runs (Sherwin-Williams, 12/7/2021). Further, owners and operators are constrained in the extent to which TE can be improved. The type of plastic being coated affects the choice of coating, which in turn affects the choice of and efficiency of the spray application technique. Low-VOC-content coatings have been developed for surface coating of plastic parts for business machines and we determined that all three facilities currently subject to the 1988 NSPS at 40 CFR part 60, subpart TTT, use low-VOC-coatings in combination with the TE specified in the rule for each spray application technology to comply with the emission limitations in the NSPS.
Consistent with these control techniques, we evaluated three regulatory options for control of VOC emissions from new (or modified or reconstructed) affected facilities. Options 1 and 2 rely on coating reformulation for low VOC coatings and are more stringent than the current NSPS. Option 3 is the use of add-on control. 

Low-VOC-Content Coatings 
Regulatory Options 1 and 2 rely on coating reformulation and are more stringent than the current NSPS. To evaluate Options 1 and 2, we estimated costs and emission reductions by assuming that all coatings are prime and color coating/top coating because they represent the majority of coating and have the same emission limits, and we did not include texture and touchup coatings in the impacts analysis. 

Option 1
Option 1 is based on the 2008 Control Techniques Guidelines (CTG) level of control. Specifically, the option 1 VOC emission limit both for primer and for topcoat (which the EPA believes to be equivalent to color coat) is, upon conversion to the NSPS format, 1.4 kg VOC/l (12 lb VOC/gal) coating solids applied. If the model plant used 15,100 l/yr (4,000 gal/yr) of coating solids applied, then the estimated reduction in VOC emissions is 1.5 Mg/yr (1.7 tpy). The calculations are shown in Table 2 below.

Table 2. Control Option 1 Reductions.
                                 NSPS Baseline
                              Option 1 (2008 CTG)
                                   Reduction
                             Primer and Color Coat
                        kg VOC/l coating solids applied
                                 (lb VOC/gal)
                            Primer and Topcoat, [a]
                            kg VOC/l coating solids
                                 (lb VOC/gal)
                            Primer and Topcoat, [a]
                     kg VOC/l coating solids applied [b] 
                                 (lb VOC/gal)
                                   Emission 
                                   Reduction
                       kg VOC/l coatings solids applied
                                 (lb VOC/gal)
                      Model Plant, Emission Reduction [c]
                                   VOC Mg/yr
                                   (tons/yr)
                                      1.5
                                    (12.5)
                                     0.57
                                    (4.80)
                                      1.4
                                     (12)
                                      0.1
                                     (0.8)
                                      1.5
                                     (1.7)
Notes
a  -  The CTG emission rate limits specified in Table 9 did not include a color coat; topcoat is assumed to be an equivalent type (page 43 of 142).
b  -  An assumed transfer efficiency of 0.40 is necessary to convert the coating concentration from kg VOC /liter coating solids to kg VOC/liter coating solids applied.
c  -  Assumes 15,100 liters of coating solids applied.

New York State Regulations are equivalent to the 2008 CTG content limits. Therefore, all business machine plastic parts coatings in New York shall comply with these more stringent VOC emission limits. Thus, coatings manufacturers have been successful in reformulating coating products to meet more stringent limits. A Xerox facility in Webster NY is actively engaged in the surface coating of plastic parts for business machines and is complying with air permit limits that are more stringent than the VOC emission limits of the 1988 NSPS. As described later in this memorandum, we drew from compliance data collected from two sources to develop a representative list of compliant coatings currently available, and we identified those we found to be currently in use at one or both sources. Because at least one stationary source is already achieving this level of control entirely through use of currently available coating formulations, we assume the cost effectiveness of option 1 for the representative coating to be $0 per ton of VOC reduction, on expectation that new, modified, and reconstructed sources will be able to achieve that option's level of control entirely through use of currently available coating formulations at the same cost. We lack information sufficient to determine the incremental costs that sources may incur to make necessary substitutions of current coatings with lower-VOC-content coatings. However, we expect the costs to be minimal because we expect compliance can be achieved through substitution with reformulated coatings that are currently available. We recognize that there are aspects of coatings substitution for which we do not have cost comparison data. Multiple factors could affect both direct and indirect costs as well as coating performance; these include consideration of application method, durability, and color. 

Option 2
Option 2 is based on the 1994 Alternative Control Techniques (ACT) level of control. Specifically, the option 2 VOC emission limits for primer and color coat are, upon conversion to the NSPS format, 0.43 kg VOC/l (3.6 lb VOC/gal) and 1.0 kg VOC/l (8.4 lb VOC/gal) coating solids applied, respectively. The average VOC emission limit for those two types is 0.72 kg VOC/l (6.0 lb VOC/gal) coating solids applied and is considered representative of the ACT level of control. If option 2's representative coating comprised the entirety of the stationary sources 15,100 l/yr (4,000 gal/yr) of coating solids applied, then the estimated reduction in VOC emissions is 11.8 Mg/yr (13.0 tpy). The calculations are shown in Table 3 below.

Table 3. Control Option 2 Reductions.
                                 NSPS Baseline
                              Option 2 (1994 ACT)
                                   Reduction
                            Primer and Color Coat 
                        kg VOC/l coating solids applied
                                 (lb VOC/gal)
                         kg VOC/l coating, less water 
                            and exempt solvents [a]
                                 (lb VOC/gal)
                                       
                              kg VOC/l solids [b]
                                 (lb VOC/gal)
                      kg VOC/l coating solids applied [c]
                                 (lb VOC/gal)
                                   Emission
                                   Reduction
                       kg VOC/l coatings solids applied
                                 (lb VOC/gal)
                      Model Plant, Emission Reduction [c]
                                   VOC Mg/yr
                                   (tons/yr)
                                      1.5
                                    (12.5)
                                 Primer: 0.14
                                     (1.2)
                                 Primer: 0.17
                                     (1.4)
                                 Primer: 0.43
                                     (3.6)
                                     0.78
                                     (6.5)
                                     11.8
                                    (13.0)
                                       
                               Color Coat: 0.28
                                     (2.3)
                               Color Coat: 0.40
                                     (3.4)
                               Color Coat: 1.00
                                     (8.4)
                                       
                                       
                                       
                                   Avg: 0.21
                                     (1.8)
                                   Avg: 0.29
                                     (2.4)
                                   Avg: 0.72
                                     (6.0)
                                       
                                       
Notes
a  -  The ACT emission rate limits specified in Table 4-1 level 2 reformulation (page 134 of 207).
b  -  An assumed VOC density of 0.88 kg/l is necessary to convert the coating VOC concentration from "kg VOC/liter coating less water and exempt solvents" to "kg VOC/liter coating solids."
c  -  An assumed transfer efficiency of 0.40 is necessary to convert the coating concentration from kg VOC /liter coating solids to kg VOC/liter coating solids applied.
d  -  Assumes 15,100 liters of coating solids applied.

We examined compliance demonstration records collected from two active facilities and the "plastic substrate" coatings available from Sherwin-Williams. The available coatings are presented in Table 4 below. Records show that of the 13 unique coatings, all but four can achieve the option 2 level of control without reformulation. 

Table 4. Identified Coatings, Capable of Complying with Option 2 Limits.
User or 
Vendor
Coating Details
Coating 
Type
VOC content. Coating solids applied (kg/liter) [a]
Compliant with option 2 (1994 ACT)
Xerox [b]
1. Sherwin-Williams POLANE 
W2 Celestial Blue (Paint No. F73L1502)
                                     color
                                     0.96
                                      Yes
Xerox [b]
2. Sherwin-Williams POLANE 
W2 Matte Black (Paint No. F83B1018)
                                     color
                                     0.94
                                      Yes
Xerox [b]
3. KEM AQUA 600T and 600S, 
xerox x-7 (Paint No. F73WXR2504-4366)
                                     color
                                     0.82
                                      Yes
Xerox [b]
4. KEM AQUA 600T and 600S, 
xerox x-2 (Paint No. F73WXA8573-4366)
                                     color
                                     0.77
                                      Yes
Xerox, [b] Universal Plastics [c]
5. Sherwin-Williams POLANE 
W2 Quartz White (Paint No. F73WC506)
                                     color
                                     0.95
                                      Yes
Xerox, [b] Universal Plastics [c]
6. KEM AQUA 600T and 600S, 
Cosmic Blue (SP)(C/G) (Paint No. F73WXL13158-4366)
                                     color
                                     0.78
                                      Yes
Xerox, [b] Universal Plastics [c]
7. KEM AQUA 600T and 600S, 
VUDU Blue 25/30 (Paint No. F73WXL11457-4366)
                                     color
                                     0.75
                                      Yes
Universal Plastics [c]
8. Sherwin-Williams POLANE 
700T with Kem Aqua Colorants, BLACK (Paint No. F63WX)
                                     color
                                     0.70
                                      Yes
Universal Plastics, [c] Sherwin-Williams [d]
9. KEM AQUA
Bonding Primer for Plastic, White
                                     prime
                                     0.45
                                                                             No
Sherwin-Williams [d]
10. Sherwin-Williams POLANE 
2.8T Plus- Becton White F63WC111
                                     color
                                     1.21
                                                                             No
Sherwin-Williams [d]
11. Sherwin-Williams POLANE 
700T White F63W522
                                     color
                                     0.64
                                      Yes
Sherwin-Williams [d]
12. Sherwin-Williams POLANE 
8880 High Gloss- White F63W280
                                     color
                                     1.86
                                                                             No
Sherwin-Williams [d]
13. Sherwin-Williams POLANE 
8910- High Gloss White F63W200
                                     color
                                     1.13
                                                                             No
Notes
a  -  Assumed a TE of 0.40 to calculate, in the format of the NSPS, a conservatively low VOC emission rate for each coating.
b  -  Email from stationary source contact, Danelle Giannini (12/2/2021 3:23 PM). "I am also attaching records showing the calculations we use to calculate the content of VOCs in our coatings to show that they are compliant with both NSPS Subpart TTT requirements and NY's 6NYCRR Part 228 requirements."
c  -  Email from State inspector, Tracy Gu (11/4/2021 12:29 PM). Records collected for Dec. 2020 inspection.
d  -  Menu of Sherwin-Williams coatings general industrial website: https://industrial.sherwin-williams.com/na/us/en/general-industrial/catalog/category/products-by-industry/electronics/business-machines.10656533.html 

Reformulation Costs
The EPA has estimated an annualized cost of $29,300 per reformulation and assumes that the model plant would bear the cost of reformulation--specifically, one product among each of four coating types, totaling $117,306 per year. The basis of this reformulation is the 1996 proposed rule for Volatile Organic Compounds (VOC) emission standards for Architectural Coatings.   

Add-on Control
Option 3 is the use of add-on control. The VOC from the spray booth can be captured and ducted to a control device. Typically, the volume of air is high, and the concentration of VOC is low. A regenerative thermal oxidizer (RTO) will control VOC emissions by combusting them to carbon dioxide and water. Destruction efficiency depends on design criteria (e.g., chamber temperature, residence time) and we estimate that 95 percent of VOC will be destroyed. We assumed that 80 percent of total VOC emissions that are estimated to enter the spray booth exhaust due to coating operations. The balance of the stationary source's VOC emissions is attributed to flash-off areas and ovens. Under option 3 we estimated that the VOC emissions reductions would be 20.7 Mg/yr (22.8 tpy) per facility (i.e., 27.2 Mg x 0.80 x 0.95 = 20.7 Mg).
It should be noted that none of the three facilities that currently perform surface coating of plastic parts for business machines use add-on controls to comply with NSPS subpart TTT. Further, dialogue with individual facilities did not yield an expected VOC concentration in spray booth exhaust. Through a series of operational assumptions (i.e., hours of operation, booth ventilation rate) the VOC concentration in the spray booth exhaust and entering the add on control was back calculated. The operational assumptions and about the model plant are listed below:
 2,000 annual hours of operation; the model plant operates 8 hours per day, 5 days a week, for 50 weeks a year.
 10,000 actual cubic feet/minute spray booth ventilation rate. Characterized in BID Table 6-1 Model Plant Parameters (pg. 95 of 276); consistent for all three models.
 167 ppmv VOC concentration in spray booth exhaust. The EPA used the EPA Air Pollution Control Cost Manual spreadsheet for incinerators and oxidizers to back-calculate the concentration necessary to achieve 20.7 Mg/yr reduction. Further, all VOC is assumed to be a single pollutant, toluene. This assumption is necessary to determine heat content and the supplemental fuel requirements (i.e., natural gas).
We used the EPA cost manual spreadsheets to generate the following costs and energy impacts. We recognize there are other add-on controls that can achieve similar emission reductions at a similar cost, such as a VOC concentrator paired with an RTO.

Table 5. Control Option 3 (RTO) Cost Tool Outputs.
                                       
                               Cost Tool Outputs
Total Capital Investment Costs
                                   $917,808
Direct Annual Costs [a]
                                    $30,776
Total Annual Costs [b]
                                   $142,931
     Auxiliary fuel Energy Input
                                                                 26,240 Btu/min
     Fan Power Consumption
                                                                        46.9 kW
     VOC Destroyed
                                                                 22.7 tons/year
Notes
a  -  Includes electricity, fuel, labor, and maintenance costs.
b  -  Interest rate and equipment life are 4.25% and 20-years, respectively. 

Cost Effectiveness
Cost-effectiveness refers to the annualized cost of implementing an air pollution control option divided by the amount of pollutant reductions realized annually. We consider a cost-effectiveness analysis as a useful metric, and a means of evaluating whether a given control achieves emission reduction at a reasonable cost. The table below presents the cost-effectiveness of each control option.

Table 6. Control Option Cost-Effectiveness.
                                Control Option
                                  Reduction 
                                Mg/yr (ton/yr)
                                    Annual
                                     Cost
                              Cost-Effectiveness
                                    ($/ton)
                                 Annual Impact
Option 1 (2008 CTG)
                                   1.5 (1.6)
                                  $0 [Note 1]
                                       -
                                       -
Option 2 (1994 ACT)
                                   11.8 (13)
                                   $117,306
                                    $9,043
                                       -
Option 3 (RTO)
                                  20.7 (22.7)
                                   $142,931
                                    $6,299
                            Electricity: 93,737 kwh
                            Natural Gas: 3,149 mscf
                               GHG: 167 Mg CO2e
Note 1: The EPA assumes this cost to be $0/ton based on the lack of cost data available and on our understanding of the availability of other low-VOC-content coatings. 

