  SEQ CHAPTER \h \r 1 MEMORANDUM

DATE:	February 18, 2009

SUBJECT:	Overview of the Paints and Allied Products Manufacturing Area Source Category

FROM:	Bradley Nelson, EC/R Inc.

TO:		Melissa Payne, EPA/OAQPS/RDPAG   SEQ CHAPTER \h \r 1

1.0	INTRODUCTION

This memorandum presents an overview of the Paints and Allied Products Manufacturing area source category and a summary of control technologies used by the industry to reduce the emissions of volatile and particulate hazardous air pollutant (HAP) emissions.  This information is in support of the development of National Emission Standards for Hazardous Air Pollutants (NESHAP) for the Paints and Allied Products Manufacturing category.  The first section of this memorandum contains a brief background of the Urban Air Toxics Area Source Program and the listing of the Paints and Allied Products Manufacturing category.  The following sections provide a brief introduction to the paints and allied products manufacturing industry processes, emission sources, and associated control techniques to reduce HAP emissions.

2.0	URBAN AIR TOXICS AREA SOURCE PROGRAM

Section 112 of the Clean Air Act (CAA) outlines the statutory requirements for the EPA’s stationary source air toxics program.  Section 112(k) requires the development of standards for area sources which account for 90% of the emissions of the 33 urban HAPs listed in the Integrated Urban Air Toxics Strategy (UATS).  These area source standards can require control levels which are equivalent to either maximum achievable control technology (MACT) or generally available control technology (GACT), as defined in the CAA under section 112(d)(3) and section 112(d)(5), respectively.

EPA discussed the legal basis for using GACT for area sources in (National Air Toxics Program:  The Integrated Urban Strategy( (64 FR 38706, July 19, 1999):

We read section 112(d)(5) to authorize promulgation of at least two types of rules:  rules that set emission levels based on specific controls or management practices (analogous to MACT standard setting), and rules that establish permitting or other regulatory processes that result in the identification and application of GACT.  As long as the result of section 112(d)(5) rulemaking is that sources use enforceable generally available control technologies or management practices, section 112(d)(5) appears to give us flexibility in choosing between the adoption of numerical emission limits and the promulgation of other requirements that result in sources applying GACT.

The general procedure used to evaluate emission control methods as possible candidates for GACT involve: (1) identifying and characterizing emissions streams for the source category, (2) identifying control measures applicable to these emission streams, (3) determining the level of use of these control measures in the sector, (4) estimating the cost of these control measures, and (5) estimating the emission reductions achieved by the control measures.  Once these steps were completed, we calculated the cost per ton of emission reduction achieved (cost effectiveness) by each emission control method.

The Paints and Allied Products Manufacturing category was added to the categories being listed pursuant to section 112(c)(3) and 112(k)(3)(B)(ii) in November 2002 (67 FR 70427).  The portion of the 1990 112(k) inventory pertinent to paint and allied products manufacturing was compiled using the 2002 North American Industry Classification System (NAICS) codes.  These manufacturing sectors included NAICS codes 325510 (Paint and Coating Manufacturing), 325520 (Adhesive Manufacturing), 325910 (Printing Ink Manufacturing) and 325998 (All Other Miscellaneous Chemical Product and Preparation Manufacturing- Writing and Stamp Inks).  The Paints and Allied Products Manufacturing source category was listed based on the urban HAP emissions of benzene, cadmium, chromium, lead, methylene chloride, and nickel.

The HAP emissions from this category can be broadly characterized by two types of emission streams: volatiles and particulate.  Volatile HAP emissions are a result of solvents that evaporate during the manufacturing process, and include benzene and methylene chloride.  Particulate HAP emissions occur from the handling of solid materials, such as pigments, during the manufacturing process.  The particulate HAPs for this listing are cadmium, chromium, lead, and nickel.  A summary of the 1990 baseline emissions for the listed urban HAP for the paints and allied products manufacturing industry in tons per year (TPY) is presented in Table 1.

Table 1.  Urban Air Toxics Strategy HAP Emissions

Pollutant	1990 Baseline Area Source Urban HAP Listing (tpy)

Benzene	9.50

Cadmium	0.25

Chromium	6.73

Lead	10.8

Methylene Chloride	93.7

Nickel	0.131

Number of Facilities

The 2002 Economic Census for the Paint and Coating Manufacturing, Adhesive Manufacturing, Printing Ink Manufacturing, and the Miscellaneous Chemical Product and Preparation Manufacturing – Writing and Stamp Inks categories listed a total of 1,409 Paint and Coating Manufacturing, 585 Adhesive Manufacturing, and 508 Printing Ink Manufacturing establishments operating in the U.S.  For the Miscellaneous Chemical Product and Preparation Manufacturing category, the census only provided the number of writing and stamp ink manufacturing facilities that had shipments over $100,000, which was listed as 4 facilities.  To estimate the total number of writing and stamp ink manufacturing facilities, we looked at the printing ink census information and found that 51% of the facilities in that category had shipments greater than $100,000.  We used this same percentage to estimate the total number of writing and stamp ink manufacturing sector and estimated 8 facilities in the stamp and writing ink category.  Therefore the total inventory of paints and allied products manufacturing facilities operating in the U.S. was estimated to be 2,510.  It was estimated that 2,190 of these facilities are area sources, based on data obtained from the 2002 NEI database. The area source total includes: 1,185 paint and coating manufacturing facilities, 509 adhesive manufacturing facilities, 488 printing ink manufacturing facilities, and 8 writing and stamp ink manufacturing facilities.

3.0	DESCRIPTION OF THE MANUFACTURING PROCESS

The Paints and Allied Products Manufacturing source category includes establishments primarily engaged in the production of paints, inks, stains, varnishes, shellacs, putties, sealers, caulks, adhesives and other coatings, the intended use of which is to leave a dried film of solid material on a substrate.  The manufacturing process may include, but is not limited to, any combination of the following steps: weighing, mixing, grinding, tinting, thinning, heating, cooking, flushing, and packaging.  The coatings may be manufactured in liquid or solid form.  The source category does not include the following: (1) products that do not leave a dried film of solid material on the substrate, such as thinners, paint removers, brush cleaners, and mold release agents; (2) electroplated and electroless metal films; and (3) the manufacture of the raw materials, such as resins, pigments, and solvents, used in the production of paints and coatings.

Paints and coatings manufacturing can be classified as a batch process and generally involves the blending and mixing of resins, pigments, solvents, and additives.  This manufacturing process consists of four major steps:

•	Preassembly and premix;

•	Pigment grinding, milling, and dispersing;

•	Product finishing and blending; and

•	Product filling and packaging.

A diagram of the process is shown in Figure 1 below, and the steps are described in more detail in the following sections.

3.1	Preassembly and Premix

In the preassembly and premix step, raw materials are added to a high speed dispersion tank to form an intermediate product referred to as the base or mill base.  This high speed dispersion tank type may be fixed or portable, depending on the batch size and type of coating produced.  The raw materials added include resins, organic solvents, plasticizers, dry pigment, and pigment extenders for solvent-based coatings, and water, ammonia, dispersant, pigment, and pigment extenders for water-based coatings.

Ink manufacturing typically uses oils, resins, solvents, and driers as raw materials.  The type of equipment used in the premix step depends on the batch size and the type of coating being produced.  Drums equipped with a portable mixer may be used for drum-sized batches; these mixers normally have an impeller with three or four blades.  Other materials made in portable mix tanks may be blended using larger, permanent high-speed dispersers or variable-speed mixers fitted with paddle, propeller, turbine, or disc-type agitators.  Coating manufacturing facilities may use typical grinding equipment for premix operations.  This approach, common with water-based paints and inks, eliminates the need to transfer the material to another type of equipment for the grinding/milling step described below.

Figure 1.  Basic Flow Sheet for Paints and Allied Products Manufacturing Processes

3.2	Pigment Grinding or Milling

In this step, pigment is added to the liquid intermediate coating product to yield fine particle dispersion via three stages: wetting, grinding, and dispersion.  In the wetting step, a surfactant is used to wet the pigment particles by displacing air, moisture, and gases that are adsorbed on the surface of the pigment particles.  The grinding step involves the mechanical breakup and separation of pigment clusters into small particles.  This is normally done using pebbles, balls, or beads.  The dispersion step mixes the wetted particles to form a particle suspension.  The equipment depends on the type of pigment used in the coating, and includes attritors, sand mills, bead and shot mills, high-speed stone and colloid mills, high-speed dispersers, high-speed impingement mills, and horizontal media mills.  High-speed dispersion is the most common method of mixing in the paints and allied products manufacturing industry.  Roller and ball mills are sometimes used; however this equipment has become outdated because of high emissions of volatile organic compounds (VOC) due to its more open design.  The use of roller mills is normally used by manufacturers of very high quality paint and inks and viscous pigmented products that require fine dispersion and clean color.

3.3 	Product Finishing

In this step, the final product specifications for color, viscosity, and other coating characteristics are met.  This generally consists of thinning, tinting, and blending.  For solvent-based coatings and inks this may involve the addition of various combinations of pigments, organic solvents, and resins.  For water-based coatings, this typically involves the addition of an antifoaming agent, a polyvinyl acetate emulsion, and water.  Additional ingredients may be blended in to meet product specifications through additional milling in a ball mill or mixing and dispersing in a portable mix tank/high-speed disperser setup.

3.4 	Product Filling

The final step in the paint and allied products manufacturing process is product filling.  Filtration removes impurities and catches small particles of grinding media.  The product end use determines the type of filtration required.  The most common methods include filtering through a cloth bag filter or the use of equipment such as strainers or sieves.  Once the coating has been filtered, it can be transferred into pails, drums, totes, tank wagons, or other containers for shipment.  This process may be completed either manually or mechanically depending on the number and size of containers being filled.

3.5	HAP Emission Points

The majority of volatile and particulate HAP emissions occur during the four steps discussed above.  Volatile HAP is emitted through evaporation and can occur any time during the manufacturing process.  Particulate HAP emissions occur during the grinding, milling, and dispersing processes.  Other sources of HAP emissions are raw material storage, wastewater treatment operations, and equipment leaks.  The process operations that generate the highest HAP emissions include: loading of materials into the mixing tanks; heat-up losses during operation of the high speed dispersers and mixers; surface evaporation during mixing, blending, and dispersing; and filling losses that occur during transfer into the receiving container.  In addition, miscellaneous operations that can generate HAP emissions include: solvent reclamation; process equipment cleaning; wastewater treatment of contaminated water generated during the manufacturing process; storage of solvents, pigments, and resins; equipment leaks; and accidental spills.

Data obtained from the 2002 NEI database was used to determine the source of HAP emissions from the paint and allied products manufacturing process.  Using the source classification code (SCC) and the process identification field, HAP emissions were broken into five process categories.  The categories include;

Product manufacturing,

Combustion processes,

Raw material storage,

Equipment cleaning and fugitive emissions, and

Other miscellaneous processes.

Table 2 shows the percent of emissions from the major categories in the manufacturing process.

The product manufacturing category comprises the four major steps discussed earlier in this section.  The combustion process includes emissions from boilers and process heaters used to produce heat and steam for the manufacturing process.  The raw material storage category includes emissions from fixed roof and floating roof storage tanks.  The equipment cleaning and fugitive emissions category includes emissions from equipment cleaning operations and fugitive emissions from the facility.  The other miscellaneous processes category includes emissions that were not identified in the SCC or process description.  These emissions are believed to be either fugitive or wastewater HAP emissions.

The area source HAP emissions identified in the 2002 NEI database totals 1,406 Mg/year (1,550 tons/year).  A summary of the area source HAP emissions by category is presented in Table 2.  The main source of HAP emissions from the Paints and Allied Products Manufacturing sector occurs during the manufacturing processes.  The majority of HAP emissions from the area sources identified in the 2002 NEI database are volatile HAP emissions, which comprise 1,403 Mg/year (1,546 tons/year) of the total 1,406 Mg/year of HAP emissions.  Accordingly, the particulate HAP totals 4.4 Mg/year (4 tons/year).

Table 2.  Paints and Allied Products Manufacturing Area Source HAP Emissions

Category	HAP Mg/year (Ton/year)	Percentage of Total

Product Manufacturing	1,275  (1,406)	90.7

Combustion Processes	1.5  (1.6)	0.1

Raw Material Storage	13.5  (14.9)	1.0

Equipment Cleaning and Fugitive Emissions	36.7  (40.5)	2.6

Other Miscellaneous Processes	57.9  (63.8)	4.1

Paint Testing	20.0  (22.0)	1.4

	Source:  2002 NEI Database

EMISSION CONTROL TECHNIQUES

This section details techniques that are currently utilized by the paints and allied products manufacturing industry to control organic HAP and volatile organic compound (VOC) emissions.

4.1 	Pollution Prevention- Common Practices

Common pollution prevention practices used in the Paints and Allied Products Manufacturing category include;

Reformulation of coatings to water-based or low solvent products

Elimination of heavy metals and chlorinated compounds

Materials management

Use of sandmills instead of ballmills.

Distillation and re-use of waste solvents

Cleaning tanks with wipers and squeegees rather than solvents

Process tank covers

Many coating manufacturers now produce water-based, high solids, powder, and radiation curable coatings that contain less solvent than traditional coatings, thereby reducing HAP emissions.  Water-based coatings may contain up to 80 percent water and 20 percent solids.  These coatings emit less organic HAP and VOCs than conventional solvent-based coatings, although they still contain 5 to 20 percent solvent for wetting, viscosity control, and pigment dispersion.  Coatings that contain greater than 60 percent solids by volume and require some solvent to induce flow are generally considered high solids coatings.  Powder coatings are produced from dry synthetic resins pigments, solid additives and as much as 10 percent volatile compounds.  Powder coatings contain no liquid solvents and typically do not produce volatile emissions.

In addition to reformulation, other pollution prevention practices center around the re-use and management of materials used to manufacture coatings.  Coating manufacturers reduce waste by minimizing stock, returning unused materials to the supplier, using materials on a first-in/first-out basis, and dating materials to avoid spoilage.

Changes in manufacturing equipment have also reduced the emissions of HAP from paint and allied products manufacturing processes.  The most common change is to cover process and storage tanks to reduce material addition, evaporative, and mixing losses.  Closed system and other process equipment have also reduced the emissions of HAP.  Sandmills, for example, are more efficient than the traditional ballmills and require less solvent for cleaning.  In addition, new cleaning methods have been established to reduce the use of solvents; for example, equipment can be dedicated to a specific color or color ranges and does not have to be cleaned as often.

4.2 	Pollution Prevention Opportunities

Some of the pollution prevention opportunities in the Paints and Allied Products Manufacturing sector include;

Materials tracking

High-pressure wash systems

Counter-current rinsing

Automated tank cleaning

Some manufacturers use software to more efficiently track and manage raw materials.  These software programs can record raw material usage, production, and generate hazardous waste and emission reports.  Using material management software can also allow manufacturers to exchange or sell unused resins, pigments, and raw materials to other manufacturers.

A number of new cleaning techniques are becoming adopted in the paints and allied products manufacturing industry, including high-pressure wash systems and counter-current rinsing.  High-pressure wash systems use pressurized water to remove product coating from the tank wall.  The high pressure reduces the amount of cleaning liquid used, and therefore the liquid waste generated.  Counter-current rinsing uses various levels of spent solvent to clean process equipment.  The first rinse uses a nearly spent solvent solution, followed with a second rinse of slightly cleaner solvent, ending with a final rinse of clean solvent.  Automated tank cleaning systems also reduce chemical and water consumption, along with their related disposal costs.

4.3 	Add-on Control Devices

Organic HAP and VOC emissions from paints and allied products manufacturing operations can be reduced through the use of add-on control technology, including;

Capture devices

Oxidation control devices

Absorption control devices

Adsorption control devices

Condensation

UV oxidation

Filtration devices

4.3.1 	Capture Devices

Emissions from process areas can be captured using a total or partial enclosure system.  Total enclosure systems completely enclose the process area and duct all emissions to a control device or stack.  These systems are common in facilities that use automated equipment to produce coatings.  Partial enclosure systems are similar to total enclosures except that the capture efficiency is less than 100 percent.

Capture systems can be designed to capture emissions from a particular piece of processing equipment rather than the entire room by using flexible duct work or a hood attached to a capture device.  The hood or flexible duct can be moved from equipment to equipment during the coating manufacturing process.

4.3.2 	Oxidation

HAP, VOC, carbon monoxide, and condensable organic particulate matter emissions in an air stream may be destroyed by exposure to an oxidizing atmosphere at high temperatures.  Oxidizers may be of thermal or catalytic design and may use primary or secondary heat recovery to reduce energy consumption.  Catalytic oxidizers employ a catalyst to aid in the oxidation reaction, which helps lower the required combustion temperature relative to that achieved in thermal oxidizers.  In general, thermal oxidizers achieve destruction efficiencies of greater than 95 percent as applied to coating manufacturing operations with high and constant concentrations of organic emissions.  Primary heat recovery ranges from approximately 55 to 95 percent.

4.3.3 	Absorption

The absorption process consists of contact between a gas stream and a liquid so that one or more of the components of the exhaust stream will dissolve in the liquid.  Water is the most common absorbent, but organic solvents are also used. Removal efficiency can be enhanced by adding reactive chemicals to the absorbent to either increase solubility of the absorbed pollutant or to change the equilibrium. Some particulate matter may also be removed by the liquid, although excessive particulate matter can lead to plugging.

4.3.4	Adsorption

In adsorption, the unbalanced molecular forces on a solid surface attract and retain gases and particulate matter that come in contact with it. Several materials are widely used as the adsorbent, including activated carbon, organic resin polymer, and inorganic materials; each has substantial surface area per unit of volume.  Adsorption is used for coating application operation exhaust streams at ambient temperature to approximately 38°C (100°F).  Carbon adsorption removal efficiency is dependent upon several factors, including the flow rate of the inlet air stream, the inlet concentration of the pollutant, the chemical and physical characteristics of the pollutant, and the bed design. Existing systems have generally been designed for efficiencies between 90 to 95 percent, although efficiencies of up to 99 percent can be achieved in some cases.

4.3.5	Condensation

Volatile compounds can be removed from gas streams by cooling the gas to a temperature less than the dew point of the volatile compounds.  The gas can be cooled using either direct or indirect heat exchangers, and the typical coolant is cold water.  Refrigerant coolant is used for low concentrations streams (i.e., less than 1 percent, or 10,000 ppmv).  Condensation systems are typically not cost effective for low concentration streams of varied composition.

4.3.6	UV Oxidation

An air stream is mixed with oxidants such as ozone and peroxide and irradiated with ultraviolet (UV) light to produce highly reactive hydroxy and oxygen radicals.  These radicals then react with the organics in the air stream, converting them into carbon dioxide and water.  The chemistry of this process is similar to that by which sunlight degrades organics in the atmosphere.  UV/ozone oxidation technology has been successfully demonstrated for controlling coating manufacturing operation emissions.  This technology can achieve VOC destruction efficiencies of greater than 95 percent.

4.3.7	Filtration Devices

Baghouses are the most commonly used control device for airborne dust and particulate matter in the paint and allied products manufacturing industry.  The baghouses are used with a capture device and typically control emissions in the pigment loading area.  In addition to baghouses, some facilities also use cartridge filters or cyclones.

5.0 	DATA SOURCES

An important consideration when determining GACT emission control measures is prevalence of use in the industry.  To determine this, we examined state permits, data from the 2002 NEI database, the Miscellaneous Organics NESHAP (MON), and other sources (e.g., conversations with industry representatives).  When possible, the information was separated by area source and major source status.  A summary of the facilities and facility information provided in the state permits is presented in Table 1 of the Appendix.

5.1	Process Vessels - Volatile HAP Emission Streams

5.1.1  	State Permit Data

Add-on Controls.  Add-on controls were listed for 9 facilities, and are summarized in the Appendix in Table 2.  Only one true area source reported an add-on control for volatile emissions, which was used on a varnish mixing tank.  Two synthetic minor facilities reported using add-on controls for volatile emissions.  One uses a thermal oxidizer to control unspecified process emissions, the other uses a condenser to control processing and holding tanks.  The other six facilities that reported controls on volatile emission streams were major sources.  Two of the major sources reported the use of a thermal oxidizer to control emissions from paint manufacturing operations.  Another major source used a thermal oxidizer on paint manufacturing operations and also used a stripping column on wastewater treatment operations.  A major source that produces both resins and paints reported the use of a thermal oxidizer only on the resin manufacturing operations, which are not in this source category.  One major source facility reported using a condenser, although it is only used for resin manufacturing.  The final major source used a carbon adsorber to control emissions from raw material storage tanks.

Assuming that both synthetic minor and area sources will be subject to the area source rule, about 10 percent (3 out of a total of 29 area and synthetic minor sources) of these facilities for which permits were obtained reported controls on volatile emission streams.  If all of the permit data is considered without regard to area source status, about 18 percent (9 out of a total of 50 facilities) of the facilities used add-on controls on volatile emissions streams.

Management Practices and Housekeeping Measures.  Many of the permits also listed various management practices and housekeeping measures, such as covering tanks and solvent containers when not in use.  Management practices and housekeeping requirements were specified in the permits for 16 facilities and are summarized in Table 3 in the Appendix.  Management practices or housekeeping measures were reported for 28 percent of the area source and synthetic minor facilities and for 38 percent (8 of 21 facilities) of the major sources.

5.1.2  	2002 NEI Data

Add-on Controls.  Add-on control devices for HAP emissions were reported for 52 facilities, 12 area source and 40 major source.  Some of the control devices listed for these facilities are typically used for particulate matter control and have little or no effect on volatile HAP emissions, but only those technologies that apply to volatile HAP emissions were counted for this section.  Only 8 of the 665, or 1.2 percent, of the area source facilities used control equipment for volatile HAP control.  A summary of the descriptions is provided in Table 4 in the Appendix.  For major source facilities, 23 of 326 facilities (7.1 percent) used control technology that reduces volatile HAP.  A summary of the volatile control descriptions for major sources is shown in the Appendix in Table 5.

Management Practices and Housekeeping Measures.  The NEI database did not include any management practices or housekeeping measures for the control of volatile HAP from these sources.  Therefore, no information can be provided on the prevalence of these measures for reducing HAP emissions.

5.2	Process Vessels - Particulate HAP Emission Streams

5.2.1  	State Permit Data

Add-on Controls.  Add-on control devices for particulate HAP emissions were reported by a total of 35 out of 50 facilities (70 percent) for which permits were obtained.  For area source and synthetic minor facilities, about 79 percent (23 out of 29 facilities) of the facilities used add-on controls for particulate HAP emissions.  Major sources used particulate HAP control at a rate of about 57 percent (12 out of 21 facilities).  This information is summarized in Table 6 of the Appendix.

According to the permit data, not all process vessels where particulate HAP emissions may originate, or storage silos where solid raw materials are stored, are equipped with particulate HAP controls.  An attempt was made to determine whether there was a minimum tank size that was controlled, but there were not sufficient data to ascertain any trends.

Management Practices and Housekeeping Measures.  The permits did not provide any specific information for management practices or housekeeping measures for reducing emissions of particulate HAP.  However, many of the management practices and housekeeping measures used to reduce the emissions of volatile HAP are appropriate for reducing emissions of particulate HAP.

We also examined the State permits for particulate HAP emission rate information after control.  Although many of the permits provided an equation for allowable particulate emissions in terms of the process weight rate, there was very little information on the process weight rates themselves.  Therefore, particulate HAP emission rate data for use in the GACT analysis could not be established.

5.2.2.  2002 NEI Data

Add-on Controls.  Only 31 of the 665 paint manufacturing facilities identified in the NEI database listed a particulate HAP control device (4 area sources, 27 major sources).  A summary of the facilities and add-on particulate control is presented in the Appendix in Table 7.  This reported use directly contradicts that listed in the permits.  One possible explanation is that the particulate control devices are not typically used for regulatory compliance purposes.  The facilities may simply be trying to avoid worker exposure and reduce potentially hazardous inorganic emissions (e.g., chromium, cadmium, and lead compounds), and did not list the particulate controls in the reports compiled for the NEI.  For these reasons, we believe that the permit data provide a more accurate depiction of particulate control device use in the paints and allied products manufacturing industry.

Management Practices and Housekeeping Measures.  The NEI database did not include any management practices or housekeeping measures for the control of particulate HAP from these sources.  Therefore, no information can be provided on the prevalence of these measures for reducing HAP emissions.

5.3	Storage Vessels – Volatile and Particulate HAP

Data from State permits were reviewed for information on volatile and particulate HAP controls for storage vessels.  No controls were reported for any of the facilities (area or major sources) for paint manufacturing operations.  In general, however, the permits were found to contain little usable information regarding controls on storage vessels.  Consequently, the background information for the storage vessel MACT floor analysis for the major source paint manufacturing NESHAP was reviewed to determine if there are controls that may be applicable to area sources.  This documentation stated that the MACT floor for storage vessels at major sources was no control, and above the floor options were considered to have (reasonable( cost effectiveness values only for storage vessels above 20,000 gallons.  According to the available permit data, all of the storage vessels at area source facilities were below 10,000 gallons.

5.4	Wastewater Treatment Operations – Volatile and Particulate HAP

The State permits and NEI database were reviewed for information related to air emission controls for wastewater treatment operations.  None were found.  To look at options, we therefore reviewed the background information for the major source paint manufacturing NESHAP.  According to this documentation, the MACT floor was established to be controls on wastewater streams with a HAP concentration of at least 4,000 ppmw.  The cost effectiveness of this level of control was estimated to be $28,700/Mg.  No information on the HAP concentration in wastewater streams at area source paint manufacturing facilities was available; therefore, no assessment can be made on whether the major source level of control may be applicable to area sources.

5.5	Equipment Leaks – Volatile HAP

According to the information reported in the State permits, none of the area source facilities reported leak detection and repair (LDAR) programs.  One major source reported an LDAR program, but it was limited to railcar unloading operations.  The background information for the major source paint manufacturing NESHAP states that a visual inspection program equivalent to the bulk gasoline terminal NESHAP was determined to be the MACT floor, with a cost effectiveness of $1,690/Mg.  Because there is no information on the number and type of piping connections at area source facilities, we cannot make a determination on whether this level of control and cost effectiveness is applicable to area source paints and allied products manufacturing facilities.

6.0	HAP CONTROL TECHNOLOGY SUMMARY

The data indicate that controls to reduce volatile HAP were used only sparingly on process vessels, as reported in both the State permits and the NEI database.  This is probably due to the absence of federal regulation of this industry and a lack of specific State or local rules other than general VOC and air toxics rules.  Another factor that may contribute to the lack of existing volatile HAP control may be the generally high capital investment needed for add-on control devices.  Taken together, these factors have produced little incentive to control these emissions, and may explain why volatile HAP controls are not prevalent in the industry.

The data analysis showed that add-on controls for particulate HAP emissions from process vessels are widespread throughout the industry.  The permits indicated that 7 of 8 area source and 15 of 20 synthetic minor source facilities used add-on controls for particulate emissions.  However, there are neither federal regulations for particulate emissions from paints and allied products manufacturing operations nor concerted State or local regulatory efforts to explain the difference in the level of control between particulate emissions and volatile emissions.  The analysis showed that both the total capital investment and the annual costs of particulate HAP controls are far less than volatile HAP controls, which helps explain this difference.  However, we assume that the use of particulate HAP controls is driven by factors other than just costs.  Concerns such as workplace safety the environmental effects of inorganic HAP emissions, and in some cases OSHA regulations, probably override simple cost considerations.

The area source facilities appear to use little if any controls on storage vessels, wastewater treatment operations, and equipment leaks.  The background information for the major source rule provided some insight into emission controls for these operations.  However, the information could not be directly transferred to the area source analysis due to a lack of specific data (e.g., concentration of pollutants in wastewater streams and number and type of fittings at area source facilities).

APPENDIXTable 1.  Summary of Facility Information as Reported in State Permits

Facility Name and Location	Status	SIC Code	Emission Streams Controlled?

	Volatiles	Particulate

U.S. Ink

Jacksonville, FL	Area	2893	No	Yes

ChemRex, Inc.

Ft. Wayne, IN	Area	2851	No	Yes

A.F. Wolke Paint Co.

Corydon, IN	Area	2851	Insufficient information	Insufficient information

Iowa Paint Manufacturing Co.

Des Moines, IA	Area	2851	No	Yes

Vogel Paint & Wax Co.

Orange City, IA	Area	2851	No	Yes

Sun Chemical

Hopkinsville, KY	Area	2893	Yes	Yes

Textured Coatings of America

Panama City, FL	Area	2851	No	Yes

American Inks and Coatings

Pine Bluff, AR	Area	2893	No	Yes

Jellico Chemical Co.

Louisville, KY	Area	2851	No	No

Matthews Paint

Pleasant Prairie, WI	Area	2851	Yes	Yes

Engineered Polymer Solutions

Elkhart, IN	Synthetic Minor	2851	No	Yes

Engineered Polymer Solutions

Indianapolis, IN	Synthetic Minor	2851	No	Yes

Plasti-Kote Co.

Medina, OH	Synthetic Minor	2851	No	No

DAP, Inc.

Tipp City, OH	Synthetic Minor	2851	Yes	Yes

Table 1.  Summary of Facility Information as Reported in State Permits

(Continued)

Facility Name and Location	Status	SIC Code	Emission Streams Controlled?

	Volatiles	Particulate

Red Devil, Inc.

Pryor, OK	Synthetic Minor	2891	No	Yes

Delta Laboratories

Ocala, FL	Synthetic Minor	2851	No	No

Baker Paint Mfg.

St. Petersburg, FL	Synthetic Minor	2851	No	Yes

Ameron International

Little Rock, AR	Synthetic Minor	2851	No	Yes

NCP Coatings

Mishawaka, IN	Synthetic Minor	2851	No	Yes

Morton International

Warsaw, IN	Synthetic Minor	2851	No	Yes

H.B. Fuller Co.

Elkhart, IN	Synthetic Minor	2891	No	Yes

Elpaco Coating Corp.

Elkhart, IN	Synthetic Minor	2851	No	No

Davie Imperial Coatings

Hammond, IN	Synthetic Minor	2851	No	Yes

HyKlas Paints

Louisville, KY	Synthetic Minor	2851	No	No

Progress Paint Co.

Louisville, KY	Synthetic Minor	2851	No	Yes

PPG Architectural Finishes, Inc.

(Courtaulds Coatings)

Louisville, KY	Synthetic Minor	2851	No	Yes

Blatz Paint Co.

Louisville, KY	Synthetic Minor	2851	No	No

Marcus Paint Co.

Louisville, KY	Synthetic Minor	2851	No	Yes

Table 1.  Summary of Facility Information as Reported in State Permits

(Continued)

Facility Name and Location	Status	SIC Code	Emission Streams Controlled?

	Volatiles	Particulate

PPG Architectural Finishes, Inc.

(Porters Paints)

Louisville, KY	Synthetic Minor	2851	No	Yes

Color Corporation of America

(Valspar Corp)

Louisville, KY	Synthetic Minor	2851	No	Yes

Engineered Polymer Solutions

Ft. Wayne, IN	Major	2851	No	Yes

CP Inc.

Connersville, IN	Major	2851	No	No

Color Converting Industries

Des Moines, IA	Majora	2893	No	Yes

Sherwin-Williams Auto Finishes

Richmond, KY	Major	2851	Yes	Yes

PPG Industries

Delaware, OH	Major	2851	Yes	Yes

PPG Industries

Cleveland, OH	Major	2851	Yes	Yes

Sherwin-Williams

Bedford Heights, OH	Majorb	2851	Yes	No

BASF Corp.

Greenville, OH	Majorc	2851	Yes	No

Star Bronze, Inc.

Alliance, OH	Majord	2851	No	No

Siegwerk, Inc.

Lynchburg, VA	Major	2893	No	No

DuPont

Front Royal, VA	Majore	2851	Yes	Yes

Table 1.  Summary of Facility Information as Reported in State Permits

(Continued)

Facility Name and Location	Status	SIC Code	Emission Streams Controlled?

	Volatiles	Particulate

Coronado Paint Co.

Edgewater, FL	Major	2851	No	Yes

Valspar Industries

Little Rock, AR	Major	2851	No	Yes

Bondo Corp.

Atlanta, GA	Majorf	2851	No	Yes

PPG Industries

East Point, GA	Major	2851	No	Yes

Worwag Coatings

Lafayette, IN	Major	2851	No	No

Uniroyal Technology Corp.

South Bend, IN	Major	2891	No	Yes

Red Spot Paint & Varnish Co.

Evansville, IN	Major	2851	No	No

Patriot Paint Co.

Portland, IN	Major	2851	No	No

IVC Industrial Coatings

Indianapolis, IN	Major	2851	No	No

Flint Ink

Warsaw, IN	Major	2893	No	Yes

a No HAP emissions listed in the permit.  Major source status based on VOC PTE of 250 tpy.

b No HAP emissions listed in the permit.  Major source status based on VOC PTE of 125 tpy.

c No HAP emissions listed in the permit.  Major source status based on VOC PTE of 295 tpy.

d No HAP emissions listed in the permit.  Major source status based on VOC PTE of 95 tpy.

e No HAP emissions listed in the permit.  Major source status based on VOC PTE of 175 tpy.

f No HAP emissions listed in the permit.  Major source status based on VOC PTE of 49 tpy.

Table 2.  Summary of Add-on Controls for Volatile Emissions Used by

Paints and Allied Products Manufacturing Facilities as Reported in State Permits

Facility

Major or Area Source

Controlled Operation

Control Measure

Comments

Sun Chemical

Hopkinsville, KY

Area

Varnish mixing tanks

Condenser followed by water scrubber

Matthews Paint

Pleasant Prairie, WI

Area

Manufacturing operations

Thermal oxidizer

Oxidizer used to limit emissions to synthetic minor levels

DAP, Inc.

Tipp City, OH

Synthetic Minor

Adhesive processing and holding tanks

Condenser

Sherwin-Williams

Richmond, KY

Major

Steam heated resin reactor tanks and thinning tanks for resin manufacturing

Condenser

Resin manufacturing is not part of the source category

PPG

Delaware, OH

Major

Resin reactor tanks; solvent recovery distillation

Thermal oxidizer

Resin manufacturing is not part of the source category

PPG

Cleveland, OH

Major

Mills; process tanks; mixers; lab operations

Thermal oxidizer

Sherwin-Williams

Bedford Heights, OH

Major

Propellant filling and propellant line purging operations

Thermal oxidizer

Table 2.  Summary of Add-on Controls for Volatile Emissions Used by

Paints and Allied Products Manufacturing Facilities as Reported in State Permits

(Continued)

Facility

Major or Area Source

Controlled Operation

Control Measure

Comments

BASF

Greenville, OH

Major

Resin reactor tanks; wastewater treatment (process water from resin manufacturing); clearcoat manufacturing; solvent recovery; wastewater storage tank; fuel oil storage tank

Stripping column (wastewater treatment)

Thermal oxidizer (all other operations)

Resin manufacturing and fuel oil storage are not part of the source category

DuPont

Front Royal, VA

Major

Raw material storage tanks

Carbon adsorber

	Table 3.  Summary of Management Practice and Housekeeping Measures as Reported in State Permits

Company/Location

Status

Management Practices and Housekeeping Measures

Textured Coatings of America

Panama City, FL

Area

1. VOC storage containers must be kept covered.

2. Minimize leaks, fugitives, and spills.

Matthews Paint

Pleasant Prairie, WI

Area

1. All portable mixing tanks must be covered except to add ingredients or take samples.  Lids must extend ( inch past outer rim and be maintained in good condition such that contact is maintained along 90% of rim.  Can allow for clearance for mixer shaft.

2. All stationary tanks covered except to add ingredients or to take samples.

Engineered Polymer Solutions

Indianapolis, IN

Synthetic minor

Waste solvent kept in closed containers

PlastiKote Co.

Medina, OH

Synthetic minor

Dispersers and mixers must be covered

DAP, Inc.

Tipp City, OH

Synthetic minor

Tanks must be covered

Red Devil, Inc.

Pryor, OK

Synthetic minor

Containers with VOC must be kept tightly closed when not in use.  Rags must be placed in covered containers.

Delta Laboratories

Ocala, FL

Synthetic minor

1. Close all VOC containers when not in use.

2. Cover tanks, troughs, basins when not in use.

3. Maintain piping, valves, fittings in good condition.

4. Prevent excessive air turbulence across exposed VOC.

5. Immediately confine and clean up VOC spills and place material in closed containers.

Table 3.  Summary of Management Practice and Housekeeping Measures as Reported in State Permits

(Continued)

Company/Location

Status

Management Practices and Housekeeping Measures

Blatz Paint Corp.

Louisville, KY

Synthetic minor

VOC storage tanks 250 - 40,000 gal limited to vapor pressure of less than 1.5 psia or install submerged fill pipe

PPG Industries

Delaware, OH

Major

High speed dispersers covered with lid at all times except when adding ingredients or taking samples.

PPG Industries

Cleveland, OH

Major

1. Stationary process vessels equipped with tightly fitting vented cover when averaging.

2. Subpart HHHHH:  portable and stationary process vessels must be equipped with cover or lid whenever vessel contains HAP.

3. All mixing and blending tanks must be equipped with cover or lid that completely covers opening of tank except for safe clearance of mixing shaft.  Cover must be kept closed except when adding ingredients or taking samples.

Star Bronze, Inc.

Alliance, OH

Major

Mix tanks must be enclosed

DuPont

Front Royal, VA

Major

Open equipment for conveying or transporting materials likely to create objectionable air pollution must be covered

Coronado Paint Co.

Edgewater, FL

Major

1. Close all VOC containers when not in use.

2. Cover tanks, troughs, basins when not in use.

3. Maintain piping, valves, fittings in good condition.

4. Prevent excessive air turbulence across exposed VOC.

5. Immediately confine and clean up VOC spills and place material in closed containers.

Table 3.  Summary of Management Practice and Housekeeping Measures as Reported in State Permits

(Continued)

Company/Location

Status

Management Practices and Housekeeping Measures

Bondo Corp.

Atlanta, GA

Major

1. Portable and stationary mixing tanks must be equipped with covers that completely cover the tank except for safe clearance of mixer shaft.  Must be kept covered at all times except when operator access is necessary.

2. Free fall of VOC materials must be accomplished by utilizing drop tubes, fill pipes, or low-clearance equipment design.

Siegwerk, Inc.

Lynchburg, VA

Major

Open equipment for conveying or transporting materials likely to create objectionable air pollution must be covered

PPG Industries

East Point, GA

Major

1. Portable and stationary mixing tanks must be equipped with covers that completely cover the tank except for safe clearance of mixer shaft.  Must be kept covered at all times except when operator access is necessary.

2. Free fall of VOC materials must be accomplished by utilizing drop tubes, fill pipes, or low-clearance equipment design.

Table 4.  Summary of Add-on Controls for Volatile Emissions Used by Area Source

Paints and Allied Products Manufacturing Facilities as Reported in the 2002 NEI Database

Facility	Controlled Operation(s)	Control Measure	Comments

DeGussa Construction Chemicals Operation

Brighton, CO

Breather Vent of WC100 UST

Xylene UST

Vapor recovery system

System include condensers, hooding, and other enclosures

DeGussa Construction Chemicals Operation

Brighton, CO

HLM packaging line

Activated carbon adsorption

U.S. Polymers

St. Louis, MO

(2) Process tanks

(2) Closed kettle varnish thinning

(3) Resin thinning tank

Tube and shell condenser

Sovereign Pkg Group

Phoenixville, PA

 (2) Mixers

Tube and shell condenser

Engineered Polymer Solutions

Birmingham, AL

Fixed roof VOC tank

Submerged filling

12,000 gallon tank

Engineered Polymer Solutions

Birmingham, AL

Fixed roof VOC tank

Miscellaneous control devices

Not specified in NEI database

NCP Coatings

Mishawaka, IN

Paint mixing line

Miscellaneous control devices

Not specified in NEI database

Lenmar Inc

Baltimore, MD

Paint mixing and handling equipment

Miscellaneous control devices

Not specified in NEI database

Tnemec Company

Baltimore, MD

Paint mixing and handling equipment

Condenser

Table 4.  Summary of Add-on Controls for Volatile Emissions Used by Area Source

Paints and Allied Products Manufacturing Facilities as Reported in the 2002 NEI Database

(Continued)

Facility	Controlled Operation(s)	Control Measure	Comments

Rust-Oleum Corporation

Williamsport, MD

Paint mixing and handling equipment

Afterburner

Flare

Table 5.  Summary of Add-on Controls for Volatile Emissions Used by Major Source

Paints and Allied Products Manufacturing Facilities as Reported in the 2002 NEI Database

Facility	Controlled Operation(s)	Control Measure	Comments

MRX Facility

Brownwood, TX

(4) Tandem maker ovens

Direct flame afterburner

Coating oven

Cook Composites and Polymers

North Kansas City, MO

Resin production

Thermal oxidizer

E I DuPont de Nemours

Front Royal, VA

(3) Paint and resin manufacturing units

Activated carbon adsorption

Ethyl acrylate, methyl methacry, styrene

P D George Co.

St Louis, MO

(2) Thinning tanks

Tube and shell condenser

Kelly-Moore Paint Co

Hurst, TX

(2) Monomer storage tanks

Vapor recovery system

System include condensers, hooding, and other enclosures

Mid-West Industrial Chemical

St. Louis, MO

(4) 10,500 gal storage tank

(3) 4,300 gal storage tank

Bottom filling

Tanks are fixed roof

GE Sealants and Adhesives

Fort Worth, TX

(4) Underground storage tanks

Reactor

Vapor recovery system

System include condensers, hooding, and other enclosures

Foster Products Corp.

Houston, TX

Batch Mixer

Vapor recovery system

System include condensers, hooding, and other enclosures

Eastman Resins

Pleasant Prairie, WI

Resin production

Direct flame afterburner

Table 5.  Summary of Add-on Controls for Volatile Emissions Used by Major Source

Paints and Allied Products Manufacturing Facilities as Reported in the 2002 NEI Database

(Continued)

Facility	Controlled Operation(s)	Control Measure	Comments

Magni Industries

Independence, KY

Paint manufacturing process

Miscellaneous control devices

Not specified in NEI database

Dow Corning

Elizabeth, KY

Not specified

Miscellaneous control devices

Not specified in NEI database

Sherwin Williams Auto Finishes

Richmond, KY

(3) Resin reactors

Vapor recovery system

System include condensers, hooding, and other enclosures

Royston Laboratories

Pittsburgh, PA

 MEK storage tank

Conservation vent

Elmers Products

Bainbridge, NY

Polymerization reactors

Refrigerated condenser

Cytec Engineered Materials

Havre de Grace, MD

Solvent mixing

Condenser

Sherwin-Williams Company

Baltimore, MD

Varnish manufacturing process

Storage tank

Miscellaneous control devices

Not specified in NEI database

DuPont Performance Coatings

Fort Madison, IA

Pigment handling

Condenser

Table 5.  Summary of Add-on Controls for Volatile Emissions Used by Major Source

Paints and Allied Products Manufacturing Facilities as Reported in the 2002 NEI Database

(Continued)

Facility	Controlled Operation(s)	Control Measure	Comments

DuPont Performance Coatings

Fort Madison, IA

(6) Thinner blending tanks

Solvent recovery unit

Product training spray booths

Thinner filling machine

Miscellaneous control devices

Not specified in NEI database

Iowa Paint Tech & Manufacturing Center

Des Moines, IA

(8) Paint mixing tanks

(3) Product finishing

(2) Lab spray paint booths

(3) Storage tanks

Tank washer

Pigment grinding & milling

Sandmill

Oil base dilling line

Miscellaneous control devices

Not specified in NEI database

Poly One Corporation

St. Louis, MO

Ball and sand mill

Process enclosed

Fugitive emissions

Poly One Corporation

St. Louis, MO

Lacquer mixing handling

Submerged filling

Fugitive emissions

Blending Facility

Irving, TX

(7) Mixers

Tray type gas absorption

Blending Facility

Irving, TX

(1) Reactor

(5) Mixers

Gas Scrubber

Blending Facility

Irving, TX

(2) Reactors

Vapor recovery system

System include condensers, hooding, and other enclosures

Table 5.  Summary of Add-on Controls for Volatile Emissions Used by Major Source

Paints and Allied Products Manufacturing Facilities as Reported in the 2002 NEI Database

(Continued)

Facility	Controlled Operation(s)	Control Measure	Comments

Paint Mfg

Garland, TX

Reactor

Resin Building

Direct Flame Afterburner

Watson Standard Company

Pittsburgh, PA

Mixer

Process enclosed

Fugitive emissions

Lymtal International

Lake Orion, MI

Natural gas boiler

Activated carbon adsorption

Table 6.  Summary of Add-on Controls for Particulate Matter Emissions Used by

Paints and Allied Products Manufacturing Facilities as Reported in State Permits

Company/Location

Status

Particulate Controls

Operations Controlled

Size of Tanks Controlled

Emission Limitsa

US Ink

Jacksonville, FL

Area

Portable and stationary dust collectors

Color mixing tanks (portable dust collectors)

Carbon black handling (stationary dust collectors)

Not listed

0.78 lb/hr, 3.4 tpy for each stationary dust collector

No limits on portable dust collectors

ChemRex, Inc.

Ft. Wayne, IN

Area

Baghouse

Storage silos

Mixing and filling line

Silos - 45 and 85 tons

Mixing tanks - 50 to 2,500 gals.

E = 4.10P0.67

Iowa Paint Manufacturing Co.

Des Moines, IA

Area

Baghouse

Mixers and dispersers

Dispersers - 1,250 gal

Mixers - not listed

0.1 gr/scf, 3.21 lb/hr, 14.08 tpy

Vogel Paint & Wax Co.

Orange City, IA

Area

Dust collector

Pigment silo

Mixing tanks

Not listed

0.1 gr/scf each dust collector

Textured Coatings of America

Panama City, FL

Area

Dust collector

Paint manufacturing

Not listed

Not listed

Table 6.  Summary of Add-on Controls for Particulate Matter Emissions Used by

Paints and Allied Products Manufacturing Facilities as Reported in State Permits

(Continued)

Company/Location

Status

Particulate Controls

Operations Controlled

Size of Tanks Controlled

Emission Limitsa

American Inks and Coatings

Pine Bluff, AR

Area

Dust collectors

Not listed

Not listed

0.1 lb/hr, 0.1 tpy

Sun Chemical

Hopkinsville, KY

Area

Dust collector

Resin dump station

Not listed

E = 3.59P0.62

Matthews Paint

Pleasant Prairie, WI

Area

Dust collector

Paint manufacturing

Not listed

1.0 lb/hr

Engineered Polymer Solutions

Elkhart, IN

Synthetic minor

Baghouse

Gelcoat mixing

1 tank - 1,000 gal

7 tanks - 1,100 gal

2 tanks - 1,200 gal

2 tanks - 2,400 gal

E = 4.10P0.67

Engineered Polymer Solutions

Indianapolis, IN

Synthetic minor

14 Portable baghouses

2 Stationary baghouses

Dry ingredient handling

Raw material loading

Not listed

E = 4.10P0.67

DAP, Inc.

Tipp City, OH

Synthetic minor

Fabric filters

Mixing tanks

3 - 350 gal

0.069 lb/hr each mixer (AP-42)

Red Devil, Inc.

Pryor, OK

Synthetic minor

Baghouse

Powdered material silos, Mixers

Mixers - 5 to 1,000 gal

Overall - 2.0 tpy

Table 6.  Summary of Add-on Controls for Particulate Matter Emissions Used by

Paints and Allied Products Manufacturing Facilities as Reported in State Permits

(Continued)

Company/Location

Status

Particulate Controls

Operations Controlled

Size of Tanks Controlled

Emission Limitsa

Baker Paint Manufacturing

St. Petersburg, FL

Synthetic minor

Baghouse

Pigment handling

Not listed

Not listed

Ameron International

Little Rock, AR

Synthetic minor

Dust collector

Mills

Mixers

Tanks

Not listed

5.4 lb/hr, 68.2 tpy

NCP Coatings

Mishawaka, IN

Synthetic minor

Dust collector

Mixing tanks

Holding tanks

Not listed

11.3 lb/hr each mixing line

Morton International

Warsaw, IN

Synthetic minor

Cyclone and dust collector

Dust collection system

Mills

Weigh-up and blending

Extrusion area

Not listed

Mills - 4.76 lb/hr, 1.64 tpy

Weigh-up and blending - 8.6 lb/hr, 0.34 tpy

Extrusion - 8.6 lb/hr, 0.21 tpy

H.B. Fuller Co.

Elkhart, IN

Synthetic minor

Baghouse

Mixers

Not listed

0.68 to 5.38 lb/hr

E = 4.10P0.67

Davies Imperial Coatings

Hammond, IN

Synthetic minor

Bag filter

Bag dump operations

Not listed

Overall - 10.8 lb/h

Table 6.  Summary of Add-on Controls for Particulate Matter Emissions Used by

Paints and Allied Products Manufacturing Facilities as Reported in State Permits

(Continued)

Company/Location

Status

Particulate Controls

Operations Controlled

Size of Tanks Controlled

Emission Limitsa

Progress Paint Co.

Louisville, KY

Synthetic minor

Baghouse

Mixers

Not listed

Not listed

PPG Architectural Finishes, Inc. (Courtaulds Coatings)

Louisville, KY

Synthetic minor

Baghouse

Cartridge filter

Coating manufacturing

Not listed

Not listed

PPG Architectural Finishes (Porters Paints)

Louisville, KY

Synthetic minor

Bag filters

Dust collector

Dispersers

Latex manufacturing

Not listed

Not listed

Color Corporation of America (Valspar Corp.)

Louisville, KY

Synthetic minor

Bag filter

Premix

Not listed

Not listed

Marcus Paint Co.

Louisville, KY

Synthetic Minor

Dust collector

Paint manufacturing

Not listed

Not listed

Table 6.  Summary of Add-on Controls for Particulate Matter Emissions Used by

Paints and Allied Products Manufacturing Facilities as Reported in State Permits

(Continued)

Company/Location

Status

Particulate Controls

Operations Controlled

Size of Tanks Controlled

Emission Limitsa

Engineered Polymer Solutions

Ft. Wayne, IN

Major

Baghouse

15 Premix tanks

2 Portable mixers

2 Dispersion mixers

Not listed

Paint manuf. - 4.28 lb/hr

Paint fill line - 2.0 lb/hr

Bentone mixing - 3.4 lb/hr

Color Converting Industry

Des Moines, IA

Major

Dust collector

Mixing operations

Waterbased product mixing

Not listed

3.9 lb/hr, 16.89 tpy

Sherwin-Williams Auto Finishes

Richmond, KY

Major

Dust collector

Dry base weigh and mix

Small batch mixers

Mixers, dispersers

Small batch - 5 to 120 gal

Mixers - 5 to 8,000 gal

Dispersers - 250 to 1,400 gal

39.9 lb/hr

PPG

Delaware, OH

Major

Fabric filters

Baghouse

Resin reactor system

Dispersers

Not listed

Resin reactors - 2.13 lb/hr, 2.1 tpy

Dispersers - 0.003 to 2.24 lb/hr

PPG

Cleveland, OH

Major

Dust collector

Baghouses

Paint manufacturing

Not listed

1.4 lb/hr, 6.0 tpy

Table 6.  Summary of Add-on Controls for Particulate Matter Emissions Used by

Paints and Allied Products Manufacturing Facilities as Reported in State Permits

(Continued)

Company/Location

Status

Particulate Controls

Operations Controlled

Size of Tanks Controlled

Emission Limitsa

DuPont

Front Royal, VA

Major

Fabric filters

Paint manufacturing

Resin manufacturing

Not listed

E = 4.10P0.67

Coronado Paint

Edgewater, FL

Major

Baghouse

Paint manufacturing

Not listed

Not listed

Valspar Industries

Little Rock, AR

Major

Dust collectors

Not listed

Not listed

2.1 lb/hr, 1.8 tpy

Bondo Corp.

Atlanta, GA

Major

Baghouses

Storage silos

Dispersers

Mixers

Putty line

Dynaglass line

Elgin line

Simplex line

Packaging line

Primer mix line

Not listed

E = 4.10P0.67

Uniroyal Technology Corp.

South Bend, IN

Major

Dust collectors

Mixing tanks

55 to 2,000 gal (total of 16 tanks)

Not listed

Table 6.  Summary of Add-on Controls for Particulate Matter Emissions Used by

Paints and Allied Products Manufacturing Facilities as Reported in State Permits

(Continued)

Company/Location

Status

Particulate Controls

Operations Controlled

Size of Tanks Controlled

Emission Limitsa

Flint Ink

Warsaw, IN

Major

Baghouse

Dry material handling

Not listed

E = 4.10P0.67

PPG Industries

East Point, GA

Major

Dust collectors

Paint manufacturing

Not listed

E = 4.10P0.67

a E=allowable emission rate, P=process weight rate.

Table 7.  Summary of Add-on Controls for Particulate HAP Emissions Used by

Paints and Allied Products Manufacturing Facilities as Reported in the 2002 NEI Database

Company/Location

Status

Particulate Controls

Operations Controlled

EPS Inc.

Elkhart, IN

Area

Mat or panel filter

(2) Spray booth

Alpha Systems

Elkhart, IN

Area

Mat or panel filter

(2) Mold prep operations

INX International Ink Company

Charlotte, NC

Area

Fabric filter – Medium temperature

Organic dyes and pigments

Chemcraft International

Winston-Salem, NC

Area

Fabric filter – Low temperature

Paint manufacturing mixing and handling

MRX Facility

Brownwood, TX

Major

Gravel bed filter

(4) Drum mixers

(2) Kettle mixers

Quad/Greenfield LLC

Greenfield, IA

Major

Single cyclone

(3) Dispersion unit

Valspar Corporation

Garland, TX

Major

Fabric filter – Medium temperature

Latex paint manufacturing

Paint mixing building

Not specified

Mineral Wells, TX

Major

Fabric filter – Medium temperature

Powder addition process

Macco Adhesive Glidden

Temple, TX

Major

Fabric filter – Medium temperature

Adhesive mixing

Table 7.  Summary of Add-on Controls for Particulate HAP Emissions Used by

Paints and Allied Products Manufacturing Facilities as Reported in the 2002 NEI Database

(Continued)

Company/Location

Status

Particulate Controls

Operations Controlled

Sherwin-Williams Company

Garland, TX

Major

Fabric filter – Medium temperature

(2) High speed dispersion mills

Kelly-Moore Paint Company

Hurst, TX

Major

Fabric filter – Medium temperature

Paint plant building fugitives

International Paint Inc

Houston, TX

Major

Fabric filter – Medium temperature

(2) Paint mixing and handling areas

Not specified

Houston, TX

Major

Fabric filter – Low temperature

(2) Paint booths

Ici Paints

Carrollton, TX

Major

Fabric filter – Medium temperature

(10) Raw material storage areas

Poly One Corporation

St Louis, MO

Major

High efficiency particulate air filter (HEPA)

Plastisol manufacturing fugitives

Vogel Paint & Wax

Orange City, IA

Major

Single cyclone

Pigment grinding

Silo

E I DuPont de Nemours

Front Royal, VA

Major

Fabric filter – Low temperature

Paint & resin manufacturing

Not specified

Fort Worth, TX

Major

Fabric filter – Low temperature

Tote tank booth

Table 7.  Summary of Add-on Controls for Particulate HAP Emissions Used by

Paints and Allied Products Manufacturing Facilities as Reported in the 2002 NEI Database

(Continued)

Company/Location

Status

Particulate Controls

Operations Controlled

Not specified

Fort Worth, TX

Major

Fabric filter – Medium  temperature

Paint mixing area

Mixing building

Valspar Coatings

Grand Prairie, TX

Major

Fabric filter – Medium temperature

Mixing process

Champion Coatings

Houston, TX

Major

Fabric filter – Medium temperature

Coatings production building

Eastman Resins

Pleasant Prairie, WI

Major

Fabric filter – Low temperature

Mixing and handling process

Pigment handling

Sheboygan Paint Company

Sheboygan, WI

Major

Mat or panel filter

Mixing and handling process

Ceramic Industrial Coatings

Osseo, MN

Major

Fabric filter – Low temperature

(4) Storage tanks

Chemical Coatings Inc

Hudson, NC

Major

Baghouse

Paint mixing/blending areas

Sherwin-Williams Company

Greensboro, NC

Major

Baghouse

Paint manufacturing

Engineered Polymer Solutions

Statesville, NC

Major

Baghouse

Latex paint manufacturing

Table 7.  Summary of Add-on Controls for Particulate HAP Emissions Used by

Paints and Allied Products Manufacturing Facilities as Reported in the 2002 NEI Database

(Continued)

Company/Location

Status

Particulate Controls

Operations Controlled

Blending Facility

Irving, TX

Major

Fabric filter – Medium temperature

Slurry mixer

DuPont Performance Coatings

Fort Madison, IA

Major

Baghouse

(5) Thinner blend tanks

Solvent recovery unit

Lab spray booths

Thinner filling machine

Latex resin production

DuPont Performance Coatings

Fort Madison, IA

Major

Fabric filter

Latex resin production

PM dust collector

DuPont Performance Coatings

Fort Madison, IA

Major

Single cyclone

(7) Thinner blend tanks

Solvent recovery unit

Lab spray booths

Thinner filling machine

PM dust collector

DuPont Performance Coatings

Fort Madison, IA

Major

Water sprays

PM dust collector

Table 7.  Summary of Add-on Controls for Particulate HAP Emissions Used by

Paints and Allied Products Manufacturing Facilities as Reported in the 2002 NEI Database

(Continued)

Company/Location

Status

Particulate Controls

Operations Controlled

Iowa Paint Tech & Manufacturing Center

Des Moines, IA

Major

Baghouse

(12) Mixing tanks

(3) Product finishing lines

(2) Lab spray booth

Sandmill

Oil base dilling line

(3) Resin storage tanks

Latex filling line

(2) Tank washer

Lightning mixers

Pigment grinding

Iowa Paint Tech & Manufacturing Center

Des Moines, IA

Major

Single cyclone

(5) Mixing tanks

(2)  Lab spray booth

Lightning mixers

Pigment grinding

Iowa Paint Tech & Manufacturing Center

Des Moines, IA

Major

Water sprays

Cowells mixing tank

Table 7.  Summary of Add-on Controls for Particulate HAP Emissions Used by

Paints and Allied Products Manufacturing Facilities as Reported in the 2002 NEI Database

(Continued)

Company/Location

Status

Particulate Controls

Operations Controlled

Iowa Paint Tech & Manufacturing Center

Des Moines, IA

Major

Spray dryer

(9) Mixing tanks

 (2) Lab spray booth

Sandmill

Oil base dilling line

Latex filling line

Lightning mixers

Pigment grinding

Color Converting Industries

Des Moines, IA

Major

Spray dryer

(7) Product finishing mix tank and dispersers

(3)  Mixers

 The 2002 NAICS codes and industry descriptions were obtained from the U.S. Census website, http://www.census.gov/epcd/www/naics.html.

 Paint and Coating Manufacturing: 2002, U.S. Department of Commerce, Economics and Statistics Administration, February 2005.

 Adhesive Manufacturing: 2002, U.S. Department of Commerce, Economics and Statistics Administration, December 2004.

 Printing Ink Manufacturing: 2002, U.S. Department of Commerce, Economics and Statistics Administration, December 2004.

 All Other Miscellaneous Chemical Product and Preparation Manufacturing: 2002, U.S. Department of Commerce, Economics and Statistics Administration, December 2004.

 Emission Inventory Improvement Program, Volume II: Chapter 8, Methods for Estimating Air Emissions from Paint, Ink, and Other Coating Manufacturing Facilities, February 2005

 Emission Inventory Improvement Program, Volume II: Chapter 8, Methods for Estimating Air Emissions from Paint, Ink, and Other Coating Manufacturing Facilities, February 2005

 Although not specifically listed in all of the permits for the major sources, the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Miscellaneous Coating Manufacturing (40 CFR 63, subpart HHHHH) specifies certain work practice standards that apply to all major sources.

 For example, an equation seen in several permits was E = 4.10P0.67, where E is the allowable PM emission rate and P is the process weight rate.

 Memorandum from David Randall and Jennifer Fields, Midwest Research Institute, to MON Project File.  February 15, 2000.  MACT Floor, Regulatory Alternatives, and Nationwide Impacts for Storage Tanks at Coating Manufacturing Facilities.

 Memorandum from Brenda Shine, North State Engineering, and David Randall, Midwest Research Institute, to MON Project File.  March 1, 2000.  MACT Regulatory Alternatives and Impacts for Wastewater at Surface Coating Facilities.

  PAGE   \* MERGEFORMAT  1

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[Federal Register Volume 87, Number 209 (Monday, October 31, 2022)]
[Rules and Regulations]
[Pages 65529-65531]
[FR Doc No: 2022-23340]

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DEPARTMENT OF HOMELAND SECURITY

Coast Guard

33 CFR Part 165

[Docket Number USCG-2022-0883]
RIN 1625-AA00

Safety Zone; Upper Mississippi River Mile Markers 125-126, Sainte
Genevieve, MO

AGENCY: Coast Guard, DHS.

ACTION: Temporary final rule.

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SUMMARY: The Coast Guard is establishing a temporary safety zone for
all navigable waters of the Upper Mississippi River extending from mile
marker (MM) 125 to MM 126 near Sainte Genevieve, MO. The safety zone is
needed to protect personnel and vessels from potential hazards due to
shoaling in the area. Entry of vessels or persons into this zone is
prohibited unless specifically authorized by the Captain of the Port
Sector Upper Mississippi River or a designated representative.

DATES: This rule is effective without actual notice from October 31,
2022 through November 3, 2022. For the purposes of enforcement, actual
notice will be used from October 20, 2022, until October 31, 2022.

ADDRESSES: To view documents mentioned in this preamble as being
available in the docket, go to https://www.regulations.gov, type USCG-
2022-0883 in the search box and click ``Search.'' Next, in the Document
Type column, select ``Supporting & Related Material.''

FOR FURTHER INFORMATION CONTACT: If you have questions on this rule,
call or Chief Nathaniel Dibley, Waterways Management, Sector Upper
Mississippi River, U.S. Coast Guard; telephone<PHONE_NUMBER>, email
[email protected].

SUPPLEMENTARY INFORMATION:

I. Table of Abbreviations

CFR Code of Federal Regulations
DHS Department of Homeland Security
FR Federal Register
MM Mile marker
NPRM Notice of proposed rulemaking

Sec.  Section
U.S.C. United States Code

II. Background Information and Regulatory History

    The Coast Guard is issuing this temporary rule without prior notice
and opportunity to comment pursuant to authority under section 4(a) of
the Administrative Procedure Act (APA) (5 U.S.C. 553(b)). This
provision authorizes an agency to issue a rule without prior notice and
opportunity to comment when the agency for good cause finds that those
procedures are ``impracticable, unnecessary, or contrary to the public
interest.'' Under 5 U.S.C. 553(b)(B), the Coast Guard finds that good
cause exists for not publishing a notice of proposed rulemaking (NPRM)
with respect to this rule because would be impracticable. On October
14, 2022 a vessel grounded due to shoaling in the navigation channel.
Surveys were then conducted and the shoaling was confirmed in the
navigation channel of the Upper Mississippi River between MM 125 and MM
126, causing a hazard to navigation. The safety zone must be
established immediately to protect people and vessels from hazards
associated with operating in the vicninity of dangerous shoaling areas
during low water conditions. It is impracticable to publish an NPRM
because this safety zone must be established immediately.
    Under 5 U.S.C. 553(d)(3), the Coast Guard finds that good cause
exists for making this rule effective less than 30 days after
publication in the Federal Register. Delaying the effective date of
this rule would be impracticable because immediate action is needed to
respond to the potential safety hazards associated with the shoaling in
the navigation channel.

III. Legal Authority and Need for Rule

    The Coast Guard is issuing this rule under authority in 46 U.S.C.
70034 (previously 33 U.S.C. 1231). The Captain of the Port (COTP)
Sector Upper Mississippi River has determined that potential hazards
associated with shoaling in the navigation channel during low water
conditions will be a safety concern for anyone transiting the Upper
Mississippi River between MM 125 and MM 126. This rule is needed to
protect personnel, vessels, and the marine environment from the
potential hazards of operating near shoaling in low water conditions.

IV. Discussion of the Rule

    This rule establishes a temporary safety zone from October 20,
2022, until November 3, 2022, or the until the hazard has been
mitigated. The safety zone will cover all navigable waters of the Upper
Mississippi River between MM 125 to MM 126. The COTP will terminate the
enforcement of this temporary safety zone before November 3, 2022, if
the hazards associated with the shoaling have been resolved and surveys
indicate that it is safe to transit. No vessel or person will be
permitted to enter the safety zone without obtaining permission from
the COTP or a designated representative. The COTP may be contacted via
telephone at<PHONE_NUMBER>.

V. Regulatory Analyses

    We developed this rule after considering numerous statutes and
Executive orders related to rulemaking. Below we summarize our analyses
based on a number of these statutes and Executive orders, and we
discuss First Amendment rights of protestors.

A. Regulatory Planning and Review

    Executive Orders 12866 and 13563 direct agencies to assess the
costs and benefits of available regulatory alternatives and, if
regulation is necessary, to select regulatory approaches that maximize
net benefits. This rule has not been designated a ``significant
regulatory action,'' under Executive Order 12866. Accordingly, this
rule has not been reviewed by the Office of Management and Budget
(OMB).
    This regulatory action determination is based on on size, duration,
and location of the temporary safety zone. This temporary safety zone
will restrict vessel traffic within a 1 mile area of navigable waters
on the Upper Mississippi River between MM 125 and MM 126. This zone
will remain in effect only while the hazards associated with the
shoaling are present. Vessels seeking to enter or pass through the zone
may seek permission from the COTP Sector Upper Mississippi River.

B. Impact on Small Entities

    The Regulatory Flexibility Act of 1980, 5 U.S.C. 601-612, as
amended, requires Federal agencies to consider the potential impact of
regulations on small entities during rulemaking. The term ``small
entities'' comprises small businesses, not-for-profit organizations
that are independently owned and operated and are not dominant in their
fields, and governmental jurisdictions with populations of less than
50,000. The Coast Guard certifies under 5 U.S.C. 605(b) that this rule
will not have a significant economic impact on a substantial number of
small entities.
    While some owners or operators of vessels intending to transit the
safety zone may be small entities, for the reasons stated in section
V.A above, this rule will not have a significant economic impact on any
vessel owner or operator.
    Under section 213(a) of the Small Business Regulatory Enforcement
Fairness Act of 1996 (Pub. L. 104-121), we want to assist small
entities in understanding this rule. If the rule would affect your
small business, organization, or governmental jurisdiction and you have
questions concerning its provisions or options for compliance, please
call or email the person listed in the FOR FURTHER INFORMATION CONTACT
section.
    Small businesses may send comments on the actions of Federal
employees who enforce, or otherwise determine compliance with, Federal
regulations to the Small Business and Agriculture Regulatory
Enforcement Ombudsman and the Regional Small Business Regulatory
Fairness Boards. The Ombudsman evaluates these actions annually and
rates each agency's responsiveness to small business. If you wish to
comment on actions by employees of the Coast Guard, call 1-888-REG-FAIR
(1-888-734-3247). The Coast Guard will not retaliate against small
entities that question or complain about this rule or any policy or
action of the Coast Guard.

C. Collection of Information

    This rule will not call for a new collection of information under
the Paperwork Reduction Act of 1995 (44 U.S.C. 3501-3520).

D. Federalism and Indian Tribal Governments

    A rule has implications for federalism under Executive Order 13132,
Federalism, if it has a substantial direct effect on the States, on the
relationship between the National Government and the States, or on the
distribution of power and responsibilities among the various levels of
government. We have analyzed this rule under that Order and have
determined that it is consistent with the fundamental federalism
principles and preemption requirements described in Executive Order
13132.
    Also, this rule does not have tribal implications under Executive
Order 13175, Consultation and Coordination with Indian Tribal
Governments, because it does not have a substantial direct effect on
one or more Indian tribes, on the relationship between the Federal
Government and Indian tribes, or on the distribution of power and

responsibilities between the Federal Government and Indian tribes.

E. Unfunded Mandates Reform Act

    The Unfunded Mandates Reform Act of 1995 (2 U.S.C. 1531-1538)
requires Federal agencies to assess the effects of their discretionary
regulatory actions. In particular, the Act addresses actions that may
result in the expenditure by a State, local, or tribal government, in
the aggregate, or by the private sector of $100,000,000 (adjusted for
inflation) or more in any one year. Though this rule will not result in
such an expenditure, we do discuss the effects of this rule elsewhere
in this preamble.

F. Environment

    We have analyzed this rule under Department of Homeland Security
Directive 023-01, Rev. 1, associated implementing instructions, and
Environmental Planning COMDTINST 5090.1 (series), which guide the Coast
Guard in complying with the National Environmental Policy Act of 1969
(42 U.S.C. 4321-4370f), and have determined that this action is one of
a category of actions that do not individually or cumulatively have a
significant effect on the human environment. This rule involves a
temporary safety zone for all navigable waters of the Upper Mississippi
River from MM 125 to MM 126. The safety zone will last from October 20,
2022, until November 3, 2022, or until all hazards associated with the
shoaling have been resolved. It is categorically excluded from further
review under paragraph L60(d) of Appendix A, Table 1 of DHS Instruction
Manual 023-01-001-01, Rev. 1. A Record of Environmental Consideration
supporting this determination is available in the docket. For
instructions on locating the docket, see the ADDRESSES section of this
preamble.

G. Protest Activities

    The Coast Guard respects the First Amendment rights of protesters.
Protesters are asked to call or email the person listed in the FOR
FURTHER INFORMATION CONTACT section to coordinate protest activities so
that your message can be received without jeopardizing the safety or
security of people, places or vessels.

List of Subjects in 33 CFR Part 165

    Harbors, Marine Safety, Navigation (water), Reporting and
recordkeeping requirements, Security measures, Waterways.

    For the reasons discussed in the preamble, the Coast Guard amends
33 CFR part 165 as follows:

PART 165--REGULATED NAVIGATION AREAS AND LIMITED ACCESS AREAS

0
1. The authority citation for part 165 continues to read as follows:

    Authority:  46 U.S.C. 70034, 70051; 33 CFR 1.05-1, 6.04-1, 6.04-
6, and 160.5; Department of Homeland Security Delegation No.
00170.1, Revision No. 01.2.

0
2. Add Sec.  165.T08-0883 to read as follows:

Sec.  165.0883  Safety Zone; Upper Mississippi River MM 125-126, Sainte
Genevieve, MO.

    (a) Location. The safety zone will cover all navigable waters of
the Upper Mississippi River between mile markers (MM) 125 and MM 126.
    (b) Enforcement period. This section will be enforced from October
20, 2022, and will continue until November 3, 2022, or until the
hazards associated with the shoaling have been resolved.
    (c) Regulations. (1) In accordance with the general regulations in
Sec.  165.23 of this part, entry of vessels or persons into the zone
are prohibited unless specifically authorized by the Captain of the
Port Sector Upper Mississippi River (COTP) or designated
representative. A designated representative is a commissioned, warrant,
or petty officer of the U.S. Coast Guard assigned to units under the
operational control of USCG Sector Upper Mississippi River.
    (2) If permission is granted, all person and vessels must comply
with the instructions of the COTP or designated representative while
proceeding through the zone.
    (d) Informational broadcasts. The COTP or a designated
representative will inform the public of the effective period for the
safety zone as well as any changes in the dates and times of
enforcement, through Local Notice to Mariners (LNMs), Broadcast Notices
to Mariners (BNMs), and/or Safety Marine Information Broadcast (SMIB)
as appropriate.

    Dated: October 20, 2022.
A.R. Bender,
Captain, U.S. Coast Guard, Captain of the Port Sector Upper Mississippi
River.
[FR Doc. 2022-23340 Filed 10-28-22; 8:45 am]
BILLING CODE 9110-04-P