White Paper – Surface Coating
Strategy Evaluation
Portland Air Toxics Solutions
Table of Contents
Introduction ............................................................................................................................................... 3
I.
SOURCE CATEGORY: Surface Coating ...................................................................................... 4
A.
Source Category Description ......................................................................................................................4
A.1.
Surface Coating in the PATS area ........................................................................................................4
A.2.
Surface Coating Devices.......................................................................................................................5
B. Modeling Results: Degree of Contribution and Emission Reductions Needed. .....................................6
B.1.
Description of emissions/2017 modeling results from surface coating ................................................6
B.2.
Main risk drivers ...................................................................................................................................7
C. Source Category Effect on Distribution of Emissions ..............................................................................7
II.
A.
III.
A.
B.
C.
IV.
SUMMARY OF EXISTING EMISSION REDUCTION STRATEGIES ............................... 8
Measures for the surface coating source category ....................................................................................8
SUMMARY OF POTENTIAL NEW EMISSION REDUCTION MEASURES .................. 12
Narrative Overview of Strategies Evaluated........................................................................................... 12
Summary of Strategies Evaluated ............................................................................................................ 13
Other Measures Considered ..................................................................................................................... 19
DETAILS FOR EACH POTENTIAL NEW EMISSION REDUCTION MEASURE ........ 20
A. Strategy: Substitute Lower Emitting Components (Coatings) (Strategies #1, 3, 5, 8, 9, 10, and 13) .20
B. Strategy: Increase Operation of Existing RTO Add-on Controls (Strategy #2) ..................................22
C. Strategy: Upgrade Capture and Destruction Efficiency of Existing Catalytic and Thermal Oxidizers
(Strategy #4)........................................................................................................................................................ 23
D. Strategy: Improved Application Techniques to Minimize Coating Consumption (Strategies #6 and
14) 23
E. Strategy: Perform All Spray Applied Rail Coating in a Filtered Spray Booth (Strategy #7) and
Upgrade Existing Water Wash Spray Booths to Dry Filter Booths (Strategy #11) .....................................24
F. Strategy: Install Thermal Oxidation on Spray Booth Exhausts (Strategies #12) ................................25
V.
ATTACHMENTS ....................................................................................................................... 27
Attachment A: Considerations.......................................................................................................................... 27
Attachment B: Response from Oregon Metals Industry Council (OMIC) ...................................................32
Tables
Table 1: 2017 Projected HAP Emissions for Surface Coating Category (pounds/year) ............................ 5
Table 2: Reduction Targets for Surface Coating ........................................................................................ 6
Table 3: Blueprint and Brainstorm List Strategies ................................................................................... 13
Table 4: PATS Pollutants Emission Reductions from Each Strategy....................................................... 14
Table 5: Other Pollutants Reduced by Each Strategy ............................................................................... 16
Table 6: Summary of Strategies Evaluated: Timeframe, Technical Feasibility, and Cost ....................... 18
Table 7: Blueprint and Brainstorm List Strategies ................................................................................... 27
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Table 8: Effectiveness ............................................................................................................................... 28
Table 9: Implementation/Feasibility Barriers ........................................................................................... 29
Table 10: Cost Considerations .................................................................................................................. 30
Table 11: Benefits and Distribution of Benefits and Cost ........................................................................ 31
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Surface Coating White Paper
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Introduction
This White Paper is intended solely to provide initial background and survey-level findings for potential
emissions reduction measures for the specific source category. The White Paper may contain prepared
written statements in the Attachments that represent those group or individual positions only. Not all
participants in the PATSAC process submitted comments to the White Papers. The content included in
this White Paper was developed to inform future stakeholder work and may be further investigated and
refined.
The purpose of this document is to evaluate potential emission reduction strategies for point source
surface coating operations in the PATS study area. For the surface coating source category, 14
strategies were evaluated.
Section I describes the surface coating source category, the magnitude and type of emissions from each
surface coating process operation type, summarizes the modeling conclusions regarding degree of
contribution of surface coating to times above benchmark, describes the emission reductions needed,
and describes the spatial extent.
Section II summarizes existing emission reduction measures.
Section III provides three tables that summarize the strategy evaluation, provides an overview of
emission reduction measures evaluated, and lists strategies that were considered, but not evaluated.
Section IV provides a detailed narrative of the strategy and describes the strategies’ impact on the
primary considerations as requested by the advisory committee: magnitude, timeframe, other pollutants,
technical feasibility, and cost.
Section V contains additional details on the full range of considerations for each strategy as requested
by the advisory committee.
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I.
SOURCE CATEGORY: Surface Coating
A. Source Category Description
The surface coating source category includes point source facilities that apply coatings in the
manufacture of products. Facilities in this source category are generally classified under the SIC and
NAICS based on the type of product being manufactured. The PATS study area includes sources
performing paper coating, metal can coating, wood furniture coating, barge coating, rail car coating,
heavy duty truck coating, and drum coating.
A.1.
Surface Coating in the PATS area
This source category included projected 2017 emissions from 8 surface coating surface coating facilities
emitting 10 PATSAC species, including 6 organic species and 4 inorganic (heavy metal) species. The
reduction strategies for this source category can provide emission reductions for both the organic and
inorganic HAP species.
The 2017 inventory includes the following facilities that are emitting the PATS HAP from surface
coating operations:
• Two performing paper coating (Dynea Overlays, Inc., and Graphic Packaging International, Inc.)
• One performing metal can coating (Crown Cork and Seal Company (USA), Inc.)
• One performing wood furniture coating (DMH, Inc.)
• One performing surface coating of rail cars and barges (Gunderson, Inc.)
• One performing surface coating of heavy duty trucks (Freightliner, Inc.)
• One performing miscellaneous metal part surface coating as part of electronic equipment
assembly (Tektronix, Inc.)
• One performing steel drum coating (IMACC Corporation).
Several of these are subject to NESHAP as major source rules for HAP:
• Dynea Overlays, Inc., subject to the NESHAP for paper and other web coating (40 CFR 63,
subpart JJJJ)
• DMH, Inc., subject to the NESHAP for wood furniture manufacturing (40 CFR 63, subpart JJ)
• Gunderson, LLC, subject to the NESHAP for shipbuilding and repair (40 CFR 63, subpart II),
and the NESHAP for miscellaneous metal parts and products surface coating (40 CFR 63,
subpart MMMM).
One facility (Crown Cork and Seal Company (USA), Inc.) is a synthetic minor source and is not subject
to the major source NESHAP for can coating (40 CFR 63, subpart KKKK).
Several of the sources are also subject to reasonably achievable control technology (RACT) limits for
VOC emissions because they exceed the 100 ton/year major source threshold for VOC emissions:
• Dynea Overlays, Inc.
• Graphic Packaging International, Inc.
• Crown Cork and Seal Company (USA), Inc.
• Gunderson, LLC (only for the rail car coating operations, RACT does not apply to the barge
coating operations)
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Surface Coating White Paper
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•
•
Freightliner, LLC
IMACC Corporation
The 2017 projected emissions from surface coating are presented in Table 1.
A.2.
1.77
Trichloroethylene
Perchloroethylene
Nickel
Napthalene
Methylene Chloride
Manganese
184
Lead
Formaldehyde
Diesel PM2.5
1,4-Dichlorobenzene
Chromium VI
Cadmium
1,3-Butadiene
Benzene
Arsenic
Acrolein
0.15
0.58
506
135
1.55
636
26.9
4,390
20.3
3,290
368
135
Total –
Ethylbenzene
A – Paper
Coating
B – Metal
can Coating
C – Wood
Furniture
D – Rail Car
and Barge
Coating
E – Misc.
Metal Parts
Coating
F – Drum
Coating
Acetaldehyde
Subcategory
15-PAH
Table 1: 2017 Projected HAP Emissions for Surface Coating Category (pounds/year)
1.55
116
36.7
18,440
10,666
240
24,340
10,898
240
1.55
2.79
2,357
3,290
38.5
2,475
1.55
0.58
Surface Coating Devices
Surface coating is the application of a material (such as paints, sealants, caulks, adhesives) to a substrate
for decorative, protective, or functional purposes.
In paper coating, the coating is applied to a continuous web of paper using a roll, knife, or die. In other
coating operations included in the PATC study area, the coatings are applied by spray equipment. The
spray coating operations may be performed in a spray booth or other enclosure to capture the coating
overspray and to remove flammable vapors from the coating area. However, in some cases, such as for
very large objects (like barges or rail cars), coatings may be applied in open yard or shop environment.
Emissions of volatile organic pollutants occur from the evaporation of solvents used in the coatings, and
may also occur from the solvents used to clean surfaces before coating, or from solvents used to clean
application equipment. Emissions of inorganic pollutants, including heavy metals, occur from air-borne
overspray from spray applied-coating operations. The inorganic pollutants are found as pigments in the
coatings. It is assumed that inorganic pollutants are emitted only from spray-applied coating operations
and are not emitted from coating operations that apply coatings with rollers, dip tanks, and other nonPage 5 of 33
Surface Coating White Paper
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spray methods. However, inorganic HAP emissions may result from the abrasive blasting, grinding, or
sanding of dried coatings that contain inorganic HAP pigments.
If coating operations are performed in a spray booth, the exhaust from the spray booth is typically
filtered in some way to capture paint particles to prevent them from building up on the ventilation
equipment and on surrounding property. The emissions from the coating operation in a spray booth may
be vented to a control device, such as a thermal oxidizer, to reduce VOC and HAP emissions.
B. Modeling Results: Degree of Contribution and Emission Reductions Needed.
B.1.
Description of emissions/2017 modeling results from surface coating
Table 2 shows the various pollutants that are attributed to surface coating in the PATS domain and
identifies the reduction targets for the specific PATS pollutants. The targets represent the reductions
needed to meet ambient benchmark concentrations for surface coating facilities (not considering
background concentrations). The reduction targets were developed based on commensurate reductions
from all source sectors – point, area, and mobile – at the most impacted receptor near each source.
Table 2: Reduction Targets for Surface Coating
Times Above
Benchmark
More than 10
times above
benchmark
Between 1
and 10 times
above
benchmark
Pollutant
15 PAH
Naphthalene
Ethylbenzene
Formaldehyde
Range of Reduction
Targets
in lbs & (percent)
117
(86)
2103
(74-86)
10391
(15-76)
10843
(92-97)
Projected 2017 emissions from
surface coating contributing to
benchmark exceedances (lbs)
135
2472
21272
10009
A data quality analysis was performed for all source categories. The data quality rating for surface
coating was determined to be an A rating (Excellent).
To see details on each of the pollutants, please see October 27, 2010 presentation at the advisory
committee meeting, available at:
http://www.deq.state.or.us/aq/toxics/docs/pats/armitageIntroPATS.pdf
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B.2.
Main risk drivers
Some pollutants emitted by surface coating facilities may be risk drivers for the PATS study area as a
whole, but the facilities only contribute significantly to risk in their immediate vicinity.
Naphthalene is a pollutant that has an exceedance more than 10 times above the benchmark. The point
source sector collectively contributes about 9% of the total projected naphthalene emissions in 2017. At
the highest impacted receptor for naphthalene, one surface coating facility contributes less than 25% of
total projected naphthalene emissions.
C. Source Category Effect on Distribution of Emissions
The emissions of 15-PAH, ethylbenzene, and formaldehyde contribute to the exceedances in localized
impact areas near surface coating facilities. While their contribution may be significant to these
pollutants in the area immediately surrounding the facilities, these pollutants are dominated by other
sources that are dispersed throughout the study area.
To see details on each of the pollutants, please see January 25, 2011 presentation at the advisory
committee meeting, available at
http://www.deq.state.or.us/aq/toxics/docs/pats/1_25_11analysisPresentation.pdf
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II. SUMMARY OF EXISTING EMISSION REDUCTION STRATEGIES
Emissions from surface coating generally originate from the evaporation of the solvents (containing
VOC and organic HAP) used in the coatings, and from the inorganic used as pigments in the coatings in
coating overspray from spray-applied coating operations. Control measures for surface coating
operations fall into the following general categories:
•
•
•
•
Reduce the HAP or VOC content of the coatings and solvents used.
Switch to coating materials that do not contain particular target HAP species of concern.
Perform coating operations in an enclosure so emissions can be captured and treated. Emission
treatment will include thermal oxidation to reduce VOC and organic HAP emissions, and
filtering to reduce inorganic HAP emissions.
Employ work practices to reduce the amount of coating or solvent that needs to be applied to
complete a specific job, thereby reducing the potential for emissions. These practices include:
o Use high efficiency spray guns to minimize the amount of coating overspray and increase
the fraction of coating that reaches the intended part substrate. This minimizes coating
consumption to minimize solvent emissions and inorganic HAP emissions from
overspray.
o Using automated gun washers to reduce the amount of solvent needed to clean
application equipment and prevent evaporation of cleaning solvents.
o Using covered solvent containers and other housekeeping measures to minimize solvent
emissions.
A. Measures for the surface coating source category
Federal
Paper and Other Web Coating:
• Paper and other web coating NESHAP (40 CFR 63, subpart JJJJ, compliance date December 5,
2005). Organic HAP emission limits based on emission capture and control technology that can
reduce total organic HAP emissions by 95 percent at existing affected sources and 98 percent at
new affected sources.
• CTG for Paper Film and Foil Coating (September 2007). Recommends an overall VOC control
efficiency of 90 percent for each coating line, or alternative emission limits equivalent to 90
percent overall control (0.40 lb VOC/lb solids, or 0.08 lb VOC/lb coating, based on an average
of all materials used on a line). Recommends applying the control recommendations only to
individual surface coating lines with the potential to emit, prior to controls, at least 25 tpy of
VOC from coatings.
• NSPS for pressure sensitive tape and label manufacture (40 CFR 60, subpart RR, applies to new
sources constructed or reconstructed after December 30, 1980). VOC limits equal to VOC
emission reduction of 90 percent on sources using 50 tpy or more of VOC.
Metal Can Coating:
• Metal can surface coating NESHAP (40 CFR 63, subpart KKKK, compliance date November 13,
2006). Organic HAP emission limits based on a combination of add-on controls and low HAP
coatings.
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•
•
NSPS for the beverage can surface coating industry (40 CFR 60, subpart WW, applies to sources
that commenced construction, modification or reconstruction after November 26, 1980). VOC
limits on volume-weighted calendar-month average for different beverage can surface coating
operations (0.29 kg VOC/L coating solids from each two-piece can base coating operation; 0.46
kg VOC/L coating solids from each clear base coating and each overvarnish coating operation;
0.89 kg VOC/L coating solids from each two-piece can inside spray coating operation).
Beverage cans include soft drinks, beer and malt liquor cans, but not fruit or vegetable juice
containers.
CTG for Cans, Coils, Paper, Fabrics, Automobiles, and Light-duty Trucks (May 1977).
Recommends VOC limits based on reducing the amount of organic solvents in coating
formulations. Expressed in kg VOC/L of coating solids, the recommended limits are as follows:
0.34 for sheet basecoat, 0.51 for interior body spray and two-piece can exterior end (spray or roll
coat), 0.66 for three-piece can side-seam spray, and 0.44 for end sealing compound.
Wood Furniture
•
•
•
Wood Furniture Manufacturing Operations NESHAP (40 CFR 63, subpart JJ, promulgated
December 7, 1995). Contains emission limits for organic HAP for finishing operations, cleaning
operations, and contact adhesives. For finishing operations, limits are based on any combination
of a weighted average volatile HAP (VHAP) content across all coatings used at the facility, use
of low VHAP (“compliant”) finishing materials, or a control device. Cleaning operations are
based on a maximum VOC content of the strippable spray booth material. Contact adhesives
allow for either add-on control devices or use of compliant contact adhesives.
There is no NSPS for the wood furniture surface coating source category.
CTG for control of VOC emissions from Wood Furniture Manufacturing Operations (April
1996). Investigated the use of add-on control devices (incineration, recovery, adsorption,
collection and volume reduction), lower VOC finishes, emerging technologies (mobile zone
spray booth, biofiltration, three-dimensional ultraviolet curing), and pollution prevention work
practices for controlling VOC emissions from surface coating operations in wood furniture
manufacturing. The recommended controls consist of VOC content limits for the various types
of coatings employed in wood furniture manufacturing, along with work practices to reduce
emissions from coating and cleaning operations. Work practices include covering VOCcontaining coatings and solvent containers when not in use, leak inspection and repair programs
for coating transfer equipment, training in measures to reduce overspray, and discontinuing use
of conventional air spray guns. Recommends applying the control recommendations only to
sources located in nonattainment areas with the potential to emit at least 25 tpy of VOC.
Miscellaneous Metal Parts
• Surface Coating of Miscellaneous Metal Parts and Products (40 CFR 63, subpart MMMM,
promulgated January 2, 2004). Applicable to major sources of HAP, this NESHAP contains
organic HAP emission limits for major sources of HAP. Organic HAP emission limits based on
a combination of add-on controls and low HAP coatings. Note that this NESHAP includes drum
surface coating sources but not metal cans which are covered in the metal can NESHAP (40 CFR
63, subpart KKKK).
• There is no NSPS for the miscellaneous metal parts surface coating source category.
• CTG for Miscellaneous Metal and Plastic Parts Coatings (September 2008). Recommended to
apply to sources where the total actual VOC emissions equal or exceed 15 lb/day, or 2.7 tons per
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•
12-month rolling period. The CTG recommends three options for VOC control: 1) VOC content
limits for coatings based on low-VOC content and application methods; 2) combination of lowVOC coatings, application methods, and add-on controls; or 3) using solely add-on controls with
an overall control efficiency of 90 percent.
Miscellaneous Surface Coating and Paint Stripping Operations at Area Sources (40 CFR 63,
subpart HHHHHH, promulgated January 9, 2008). Applicable to area sources with spray applied
surface coating operations that use coatings containing target inorganic HAP. Requires work
practices (operator training) and equipment practices (high efficiency spray guns and filtered
spray booths) to reduce inorganic HAP emissions.
Ship Building and Repair
• Ship Building and Ship Repair (Surface Coating) NESHAP (40 CFR 63, subpart II, promulgated
December 15, 1995). This NESHAP applies to major sources with a minimal annual marine
coating usage of 1,000 liters. Organic HAP limits are established for general use and specialty
grades of coatings, specified in grams per liter coating solids. These limits appear to be similar
to those of the CTG, only specified for volatile organic HAP in the NESHAP and volatile
organic compounds in the CTG. The standards also contain work practices on storage, transfer
and application of coatings.
• There is no NSPS for ship building and repair surface coating operations.
• CTG for Shipbuilding and Ship Repair Operations Surface Coating (August 1996).
Recommends lower-VOC coatings, specified in grams per liter coating solids, for general and
specialty grades of coatings. Add-on controls were investigated in developing the CTG, but
were determined to require case-by-case determination of feasibility.
State of Oregon
•
•
•
The following NSPS area adopted by reference in OAR 340-238-0060:
o 40 CFR Part 60, subpart RR – Pressure sensitive tape and label surface coating
operations, is adopted at OAR 340-238-0060(3)(vv).
o 40 CFR Part 60, subpart WW – Beverage can surface coating industry, is adopted at
OAR 340-238-0060(3)(bbb);
The following major source NESHAP are adopted by reference in OAR 340-244-0220:
o 40 CFR Part 63, subpart JJJJ – Paper and other web coating, is adopted at OAR 340-2440220(5)(qqqq).
o 40 CFR Part 63, subpart KKKK – Surface coating of metal cans, is adopted at OAR 340244-0220(5)(qqq).
o 40 CFR Part 63, subpart MMMM – Surface coating of miscellaneous metal parts and
products, is adopted at OAR 340-244-0220(5)(rrr)
o 40 CFR Part 63, subpart JJ – Wood furniture manufacturing operations, is adopted at
OAR 340-244-0220(5)(aa)
o 40 CFR Part 63, subpart II – Shipbuilding and ship repair (surface coating), is adopted at
OAR 340-244-0220(z)
The area source NESHAP (40 CFR Part 63, subpart HHHHHH) has been incorporated in the
state codes under OAR 340-244-0220(4)(mmmm); however, no area miscellaneous surface
coating sources are included in the inventory that emit inorganic HAP.
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Local
These sources are located in the Portland Air Quality Maintenance Area (AQMA), which has VOC
emission limits in OAR 340-232-0160, Surface Coating in Manufacturing, that affect paper coating,
can manufacturing (including drum manufacturing), and miscellaneous metal part manufacturing
(including rail car and heavy duty truck manufacturing), but not wood furniture or barge (ship)
manufacturing:
•
•
•
Limits coatings used in paper coating to a VOC content of 2.9 lb/gallon coating applied, less
water and exempt compounds.
Limits the VOC content of coatings used in can coating (including drum coating):
o Sheet basecoat (exterior and interior) and over-varnish; two-piece can exterior (basecoat
and over-varnish) – 2.8 lb/gal
o Two- and three-piece can interior and exterior body spray, two-piece can exterior end
(spray or roll coat) – 4.2 lb/gal
o Three-piece can side-seam spray – 5.5 lb/gal
o End sealing compound – 3.7 lb/gal
o End sealing compound for fatty foods – 3.7 lb/gal
Limits the VOC content of coatings used in Miscellaneous Metal Parts and Products (this would
include rail car and heavy duty truck coating, but not ship or barge coating):
o Clear coatings – 4.3 lb/gal
o Force air dried or air dried – 3.5 lb/gal
o Extreme performance coatings – 3.5 lb/gal
o Other coatings (i.e., powder, oven dried) – 3.0 lb/gal
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III.
SUMMARY OF POTENTIAL NEW EMISSION REDUCTION MEASURES
DEQ has evaluated 14 strategies for reducing emissions from surface coating. The strategies and results
of the evaluation are summarized in this section. Detailed strategy descriptions and evaluations can be
found in sections IV and V.
A. Narrative Overview of Strategies Evaluated
DEQ evaluated the following types of strategies:
• Substituting lower emitting coatings and solvents (components) for those containing the PATS
HAPs, including both organic and inorganic HAP.
• Establishing emission standards to require a higher overall capture and control efficiency on existing
capture and control systems (e.g., spray booths and catalytic or thermal oxidizers), and requiring
existing sources without those controls to install and operate equivalent controls.
• Improving the efficiency of spray applied surface coating operations by requiring more efficient
spray guns and operator training to improve coating transfer efficiency and reduce emissions
associated with coating application and use.
• Requiring up-grades in existing spray booths so that water wash type spray booths are retro-fitted
with dry filters, which can achieve 98 percent filter efficiency, compared to the unknown efficiency
of water wash spray booths.
• Require sources without filtered spray booths to install and operate filtered spray booths and enclose
all spray applied coating operations in booths, with the exception of barge coating operations.
The single measure with the greatest impact on PATS HAP emissions for the surface coating source
category would focus on a single facility that performs drum coating, which currently does not have any
VOC or organic HAP controls. This single facility accounts for about 80 percent of the PATS HAP
emissions from the surface coating source category in the inventory. Emissions from this facility could
be reduced by about 95 percent through the installation and operation of a thermal oxidizer or similar
device on the exhaust from the drum coating operation.
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B. Summary of Strategies Evaluated
Table 3: Blueprint and Brainstorm List Strategies
Blueprint Level Strategy
Substitute lower emitting
components
Emission standards
Substitute lower emitting
components
Emission standards
Substitute lower emitting
components
Improved application techniques
Emission standards
Substitute lower emitting
components
Substitute lower emitting
components
Substitute lower emitting
components
Emission standards
Emission standards
Substitute lower emitting
components
Improved application techniques
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Surface Coating White Paper
Brainstorm List Strategy
#1 – Web/Paper Coating and Printing Switch coatings and inks
#2 – Web/Paper Coating and Printing –
Continual operation of regenerative
thermal oxidizer
#3 – Metal Can Coating/Lithography –
Switch coatings
#4 – Metal Can Coating/Lithography –
Upgrade capture and destruction
efficiency of existing catalytic and thermal
oxidizers from 81% to 98%
#5 – Wood Furniture – Switch coatings
#6 – Wood Furniture – Switch to more
efficient spray guns
#7 – Rail Car and Barge Coating –
Perform all spray applied rail coating in
filtered spray booths
#8 – Rail Car and Barge Coating – Switch
rail coatings
#9 – Rail Car and Barge Coating – Switch
barge coatings
#10 – Miscellaneous Metal Parts Coating
– Switch to alternative solvents for
electronics cleaning
#11 – Drum Coating – Upgrade spray
booths from water wash to dry fabric
filters (from 60% to 98% filter efficiency)
#12 – Drum Coating – Install thermal
oxidation on spray booth exhaust (e.g.,
catalytic or regenerative thermal oxidizer)
#13 – Drum Coating – Switch coatings
#14 – Drum Coating – Switch to more
efficient spray guns
Portland Air Toxics Solutions
Table 4: PATS Pollutants Emission Reductions from Each Strategy
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0.135
(90)
166
(90)
1.77
(100)
0.58
(100)
0.135
(90+)
166
(90+)
1.59
(90)
0.52
(90)
455
(90)
455
(90)
572
(90)
382
(60)
24.2
(90)
16.1
(60)
1.52
(98)
Portland Air Toxics Solutions
3,224
(98)
114
(98)
Trichloroethylene
Perchloroethylene
Nickel
Napthalene
Methylene Chloride
Manganese
Lead
Formaldehyde
Ethylbenzene
Diesel PM2.5
Chromium VI
1,4Dichlorobenzene
Cadmium
1,3-Butadiene
Benzene
Arsenic
Acrolein
Acetaldehyde
Strategy
#1 – Web/Paper Coating and
Printing - Switch coatings
and inks
#2 – Web/Paper Coating and
Printing – Continual
operation of regenerative
thermal oxidizer
#3 – Metal Can
Coating/Lithography –
Switch coatings
#4 – Metal Can
Coating/Lithography –
Upgrade capture and
destruction efficiency of
existing catalytic and thermal
oxidizers from 81% to 98%
#5 – Wood Furniture –
Switch coatings
#6 – Wood Furniture –
Switch to more efficient
spray guns
#7 – Rail Car and Barge
Coating – Perform all spray
15-PAH
Emissions Reduced from Each Strategy
In lbs and (percent)
Page 15 of 33
135
(100)
1.55
(100)
3,951
(90)
18.3
(90)
3,290
(100)
116
1.55
(100) (100)
135
(100)
1.55
(100)
3,951
(90)
18.3
(90)
3,290
(100)
116
1.55
(100) (100)
Surface Coating White Paper
331
(98)
36.7 2.79
(100) (100)
228 (95)
17,518 10,133
(95)
(95)
16,596 9,599
(90)
(90)
9920
5333
(50)
(50)
Portland Air Toxics Solutions
2,239
(95)
240
(100)
120
(50)
2,357
(100)
1,178
(50)
Trichloroethylene
Perchloroethylene
Nickel
Napthalene
Methylene Chloride
Manganese
Lead
Formaldehyde
Ethylbenzene
Diesel PM2.5
Chromium VI
1,4Dichlorobenzene
Cadmium
1,3-Butadiene
Benzene
Arsenic
Acrolein
Acetaldehyde
Strategy
applied rail coating in filtered
spray booths
#8 – Rail Car and Barge
Coating – Switch rail
coatings
#9 – Rail Car and Barge
Coating – Switch barge
coatings
#10 – Miscellaneous Metal
Parts Coating – Switch to
alternative solvents for
electronics cleaning
#11 – Drum Coating –
Upgrade spray booths from
water wash to dry fabric
filters (from 60% to 98%
filter efficiency)
#12 – Drum Coating – Install
thermal oxidation on spray
booth exhaust (e.g., catalytic
or regenerative thermal
oxidizer)
#13 – Drum Coating –
Switch coatings
#14 – Drum Coating –
Switch to more efficient
spray guns
15-PAH
Emissions Reduced from Each Strategy
In lbs and (percent)
Table 5: Other Pollutants Reduced by Each Strategy
#2 – Web/Paper Coating and Printing – Continual operation of
regenerative thermal oxidizer
#3 – Metal Can Coating/Lithography – Switch coatings
(90+)
#4 – Metal Can Coating/Lithography – Upgrade capture and
(90+)
destruction efficiency of existing catalytic and thermal oxidizers from
81% to 98%
#5 – Wood Furniture – Switch coatings
#6 – Wood Furniture – Switch to more efficient spray guns
#7 – Rail Car and Barge Coating – Perform all spray applied rail
coating in filtered spray booths
#8 – Rail Car and Barge Coating – Switch rail coatings
#9 – Rail Car and Barge Coating – Switch barge coatings
(60)
(60)
(98)
Greenhouse
Gases
Fine Particulate
(PM2.5)
Strategy
#1 – Web/Paper Coating and Printing - Switch coatings and inks
Ozone
Precursors
Emissions Reduced
from Each Strategy
In lbs and (percent)
Notes
No change, assuming that there is no change in
VOC content of coatings.
Increase Increased RTO operation will increase GHG
emissions from fuel combustion.
No change, assuming that there is no change in
VOC content of coatings.
Increase Increased RTO temperature will increase GHG
emissions from fuel combustion.
No change, assuming that there is no change in
VOC content of coatings.
Reduced overspray will reduce PM emissions;
increased efficiency will decrease coating use and
VOC emissions.
Captured overspray in booth will decrease PM
emissions from spray coating.
No change, assuming that there is no change in
VOC content of coatings.
No change, assuming that there is no change in
VOC content of coatings.
No change, assuming that there is no change in
VOC content of solvents.
#10 – Miscellaneous Metal Parts Coating – Switch to alternative
solvents for electronics cleaning
#11 – Drum Coating – Upgrade spray booths from water wash to dry
(95)
fabric filters (from 60% to 98% filter efficiency)
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#12 – Drum Coating – Install thermal oxidation on spray booth
exhaust (e.g., catalytic or regenerative thermal oxidizer)
#13 – Drum Coating – Switch coatings
(95+)
#14 – Drum Coating – Switch to more efficient spray guns
(50)
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Surface Coating White Paper
(50)
Increase Increased GHG emissions from fuel combustion for
thermal oxidation
No change, assuming that there is no change in
VOC content of coatings.
Reduced overspray will reduce PM emissions;
increased efficiency will decrease coating use and
VOC emissions.
Portland Air Toxics Solutions
Table 6: Summary of Strategies Evaluated: Timeframe, Technical Feasibility, and Cost
Blueprint level
Strategy
Substitute lower
emitting components
Emission standards
Substitute lower
emitting components
Emission standards
Substitute lower
emitting components
Improved
application
techniques
Emission standards
Substitute lower
emitting components
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Timeframe to
Reduce Emissions
#1 – Web/Paper Coating
and Printing - Switch
coatings and inks
#2 – Web/Paper Coating
and Printing – Continual
operation of regenerative
thermal oxidizer
#3 – Metal Can
Coating/Lithography –
Switch coatings
1 year
Technical
Feasibility
Immediate
Very feasible.
1 year
Feasible
#4 – Metal Can
Coating/Lithography –
Upgrade capture and
destruction efficiency of
existing catalytic and
thermal oxidizers from 81%
to 98%
#5 – Wood Furniture –
Switch coatings
2 years
Systems with higher
overall capture and
destruction efficiency are
in use.
1 year
#6 – Wood Furniture –
Switch to more efficient
spray guns
#7 – Rail Car and Barge
Coating – Perform all spray
applied rail coating in
filtered spray booths
#8 – Rail Car and Barge
Coating – Switch rail
coatings
1 year
U.S. EPA is proposing to
require major source
wood furniture mfrs to
reduce formaldehyde in
coatings. (75 FR 80220)
Ethylbenzene is
commonly found in
commercial xylene, which
is a common coating
solvent. Reducing
ethylbenzene may require
replacing xylene with
other solvents.
Very feasible. Already
being done in most
coating industries.
Rail car sized spray
booths are in use at other
facilities.
Surface Coating White Paper
2 years
1 year
Feasible. Ethylbenzene is
commonly found in
commercial xylene, which
is a common coating
solvent. Reducing
ethylbenzene may require
replacing xylene with
other solvents.
Cost Summary
Increased electricity
and fuel cost to
operate RTO for more
hours per year.
Can coating NESHAP
estimated cost increase
of low-HAP coatings
could be $2-$5/gallon.
Costs could be on the
order of $100,000 per
year, but not all
coatings should need
to be replaced, so costs
should be lower.
Engineering and
modification may cost
several $10,000.
U.S. EPA estimated
the annual cost for the
proposed risk
reduction measures to
be about $7,000 per
year per facility. (75
FR 80220)
Low cost (e.g., few
thousand dollars).
Costs may be on the
order of $100,000 per
booth; plus operating
costs.
Costs are on the order
of about $40,000 per
year per facility, based
on MMPP NESHAP.
Portland Air Toxics Solutions
Blueprint level
Strategy
Timeframe to
Reduce Emissions
Substitute lower
emitting components
#9 – Rail Car and Barge
Coating – Switch barge
coatings
1 year
Substitute lower
emitting components
#10 – Miscellaneous Metal
Parts Coating – Switch to
alternative solvents for
electronics cleaning
1 year
Emission standards
#11 – Drum Coating –
Upgrade spray booths from
water wash to dry fabric
filters (from 60% to 98%
filter efficiency)
1 year
Emission standards
2 years
Substitute lower
emitting components
#12 – Drum Coating –
Install thermal oxidation on
spray booth exhaust (e.g.,
catalytic or regenerative
thermal oxidizer)
#13 – Drum Coating –
Switch coatings
Improved
application
techniques
#14 – Drum Coating –
Switch to more efficient
spray guns
One year
1 year
Technical
Feasibility
Cost Summary
EPA did not identify any
feasible options to
propose for reducing
residual risk for major
sources subject to the
shipbuilding NESHAP
(75 FR 80220.)
Very feasible. DoD, for
example, has investigated
replacement solvents for
similar operations at DoD
maintenance facilities.
Very feasible. DoD, for
example, has investigated
retrofit of waterwash
booths with dry filters for
similar operations at DoD
maintenance facilities.
Very feasible. Systems
are commercially
available.
Costs are on the order
of about $40,000,
based on low VOC
coatings for Ship
Building and Repair
CTG.
Formaldehyde is a
reactant in the production
of amino resins used to
produce baked
thermosetting coatings for
drum coating. Some
coating suppliers may be
able to achieve lower
formaldehyde contents by
controlling the amino
resin manufacturing
process.
Very feasible. Already
being done in most
coating industries.
Unknown
Low cost (e.g., few
thousand dollars).
Low cost (e.g., few
thousand dollars).
System may cost
several $100,000,
depending on flow
rate.
Low cost (e.g., few
thousand dollars).
C. Other Measures Considered
No other measures were considered that are not discussed in this paper.
The use of bio-filters in surface coating applications could be considered as a reduction strategy, but was not
evaluated in this White Paper.
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IV. DETAILS FOR EACH POTENTIAL NEW EMISSION REDUCTION MEASURE
The five primary considerations below are from the PATSAC Considerations List.
(reference: http://www.deq.state.or.us/aq/toxics/docs/pats/3_2_11regroupedConsideraton.pdf)
A. Strategy: Substitute Lower Emitting Components (Coatings) (Strategies #1, 3, 5, 8, 9, 10, and 13)
Narrative Overview
The source of potential organic HAP and inorganic HAP emissions from surface coating operations are the
coatings themselves. Reducing or eliminating those emissions can be accomplished by switching to
coatings that contain reduced amounts of the HAP, or that are free of that HAP. Several of the recent
surface coating NESHAP for major sources have been based on coating substitution (switching to low HAP
or non-HAP coatings) as the basis for emissions standards to reduce organic HAP emissions. These major
source NESHAP have tended to limit only total HAP emissions, rather than emissions of individual HAP.
However, EPA has begun conducting residual risk analyses for the surface coating NESHAP that have
focused on the risks presented by individual HAP. The EPA has recently proposed standards that would
require wood furniture manufacturers to reduce the formaldehyde content of coatings (see 75 FR 80220,
December 21, 2010).
To reduce organic HAP emissions, switching to lower or non-HAP coatings may involve switching to
different coating technologies (e.g., from solventborne to waterborne coatings), or to different resin systems
in order to take advantage of different solvents that are lower in HAP content, or to avoid HAP that are
found in the resin itself.
15-PAHs are associated with coatings that use coal tar as part of the resin, where the coal tar is the source of
the 15-PAHs. Coal tar epoxy coatings have been used as marine coatings and may also be used in coating
of rail cars where extreme durability is needed. They can be replaced with epoxy coatings that do not use
coal tar resins.
Emissions of ethylbenzene are most likely associated with the solvents used in the coatings. Ethylbenzene
is commonly found as a few percent in commercial grade xylene used as a solvent in coatings.
Emissions of formaldehyde are most likely associated with the type of resin used in the coating, specifically
thermosetting (baked) coatings that contain amino resins. These are often used for wood furniture coating
and drum coating, and the formaldehyde may be present at residual amounts (e.g., less than 0.5 percent by
weight) in the finished coating.
Emissions of naphthalene may be linked to either the solvents or the resins used in coatings. Naphthalene
may be present at a few percent in aromatic solvents used in coatings. It is also a precursor in the
production of phthalic anhydride, which is used in the production of plasticizers and alkyd and unsaturated
polyester resins used in various types of coatings; naphthalene may be present in residual amounts. MSDS
for finished coatings and solvents may show very small amounts (e.g., less than 0.5 percent by weight) of
naphthalene.
Methylene chloride and perchloroethylene emissions are probably not associated directly with the use
coating and solvents, but are probably used in cleaning parts prior to assembly, soldering, or coating.
Reducing emissions of these HAP would involve finding alternative solvents.
Chromium VI, lead, manganese, and nickel are commonly used as pigments in coatings to achieve certain
types of corrosion protection and color characteristics. To reduce inorganic HAP emissions, switching to
non-HAP coatings (e.g., ones that are free of chromium VI, lead, manganese, and nickel) may involve
switching to coatings with alternative pigments to achieve the same corrosion protection and color
characteristics.
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Primary Considerations
a. Magnitude of Reductions.
To control organic HAP emissions, switching coatings may achieve emission reductions of up to 100
percent, depending on the source of the emissions and the nature of the HAP in the coating or solvent.
For 15-PAHs, switching from coal tar epoxy coatings to alternative epoxy coatings can probably achieve a
100 percent emissions reduction, or 135 lbs/year.
For ethylbenzene, one would need to switch to coatings that do not use xylene as a solvent in order to
achieve a 100 percent emission reduction. The actual degree of emission reduction would likely be
determined from the degree to which coatings could be found that did not use xylene as a solvent, or as a
component in the solvent. Facilities may need to switch to either waterborne coatings or to high-solids,
two-component epoxy coatings. These two strategies could achieve 100 percent emission reductions for
those coatings that can be switched. It is more likely that not all coatings could be switched, or that some
residual ethylbenzene remains in levels that are below a reportable threshold (e.g., less than 0.1 percent on
MSDS). Therefore, a maximum reduction of about 90 percent is more likely, for a total reduction of 21,900
lbs/year (10.95 tons/year).
Formaldehyde emissions could be reduced by nearly 100 percent by switching to coatings that do not
contain formaldehyde, by switching to different coating resin technologies. Smaller reductions would be
achieved by switching to coatings within the same technology that have smaller residual amounts of
formaldehyde. It is more likely that not all coatings could be switched, or that some residual formaldehyde
remains in levels that are below a reportable threshold (e.g., less than 0.1 percent on MSDS). Therefore, a
maximum reduction of about 90 percent is more likely, for a total reduction of 9,800 lbs/year (4.9
tons/year).
Naphthalene emissions could be reduced from the coating resin by switching to different resin technologies,
similar to formaldehyde, and from solvents by reducing the use of aromatic solvents and switching to
solvents that contain a smaller percentage of naphthalene. Reductions would depend on the degree to which
coatings could be identified that have reduced amounts of naphthalene. It is most likely that not all coatings
and solvents could be switched, or that some residual naphthalene remains in levels that are below a
reportable threshold (e.g., less than 0.1 percent on MSDS). Therefore, a maximum reduction of about 90
percent is likely, for a total reduction of 2,200 lbs/year (1.1 tons/year).
Methylene chloride and perchloroethylene emissions could be reduced by up to 100 percent by replacing
these compounds with alternative solvents, for a reduction of 39 lbs for both HAP.
Emissions of inorganic HAP (chromium VI, lead, manganese, and nickel) could be reduced by up to 100
percent by substituting coatings that do not contain these pigments. Coatings that are free of these pigments
are becoming more readily available as a result of EPA area source NESHAP for miscellaneous surface
coating operations (40 CFR 63, subpart HHHHHH). Compounds of these metals are among those that are
regulated as target inorganic HAP under subpart HHHHHH. Total emission reductions from all four
inorganic HAP would be about 3,500 lbs/year (1.75 tons/year).
b. Timeframe to Implement.
As there are no current regulations that limit the content of coatings and solvents in these industries with
respect to the individual PATS HAP. Therefore, ample time would be needed to consider regulation, and
for sources to investigate alternative coatings and solvents. In similar situations for existing major and area
source surface coating operations, the NESHAP allow three years for compliance with the standards.
Considering this action would be a regulatory requirement beyond those adopted and implemented by the
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state, there would likely be additional implementation time required for regulatory development and public
comment.
c. Other pollutants reduced.
Other pollutants (VOC and HAP) would likely be reduced by specifically targeting the content of these
HAP in coatings and solvents, if the users switch coating technologies (e.g., to waterborne coatings). If the
user simply switches to coatings that are lower in only the target HAP, there would be no change in other
HAP or VOC.
d. Technical feasibility.
Lower HAP coatings should be available for nearly all subcategories. Some subcategories may have
particular challenges that could limit the use of alternative coatings. For example, drum coatings may need
to have particular properties to be compatible with drum contents.
e. Cost.
The cost of switching coatings will vary with the type of current and new technology. Switching from
waterborne to solventborne coatings, or from one component to two component coatings, would also require
a switch in coating application equipment.
B. Strategy: Increase Operation of Existing RTO Add-on Controls (Strategy #2)
Narrative Overview
One source performing paper coating has a regenerative thermal oxidizer (RTO) that is only operated during
the ozone season. The source could reduce emissions by operating the RTO year round.
Primary Considerations
a.
Magnitude of Reductions.
The source could reduce emissions by about 90 percent, or by 166 lb/yr of formaldehyde and ethylbenzene
by operating the RTO year round.
b. Timeframe to Implement.
Once a regulation is in place to require year round operation of the RTO, compliance could begin
immediately.
c. Other pollutants reduced.
Emissions of VOC and other HAP would be reduced by about 90 percent. Emissions that are a byproduct of
natural gas combustion in the RTO would increase.
d. Technical feasibility.
Once a regulation is in place to require year round operation of the RTO, compliance could begin
immediately.
e. Cost.
The source would have increased (doubled) natural gas and operation and maintenance costs from increased
operation of the RTO.
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C. Strategy: Upgrade Capture and Destruction Efficiency of Existing Catalytic and Thermal
Oxidizers (Strategy #4)
Narrative Overview
One source (can coating) has an emission capture and destruction efficiency system that achieves an overall
efficiency of 81 percent, as specified in the permit. We assume this is based on capture efficiency of 90
percent and destruction efficiency of 90 percent. Improvements in the emission capture system could be
made to increase capture efficiency so that it qualifies as a permanent total enclosure (PTE) rated at 100
percent efficiency. Efficiency of the catalytic oxidizers could be increased from 90 to 95 percent efficiency.
Primary Considerations
a. Magnitude of Reductions.
Emissions would be further reduced by an additional 90 percent with upgrades to the capture system and
catalytic oxidizer, or a reduction of ethylbenzene emissions of about 455 lbs/year.
b. Timeframe to Implement.
Once a regulation is in place to require increased performance of the capture and destruction system,
additional time may be needed by the source to implement those changes. Some engineering and
fabrication may be needed, requiring up to two years to complete.
c. Other pollutants reduced.
Emissions of VOC and other HAP would be reduced by about 90 percent. Emissions that are a byproduct of
natural gas combustion in the RTO would increase.
e. Technical feasibility.
Emission capture systems and catalytic oxidizers with higher efficiency are currently available, so option is
technically achievable.
f. Cost.
Engineering and fabrication could cost several $10,000. However, increased efficiency of PTE could
reduce air flow to oxidizer and increase VOC concentration, resulting in greater destruction efficiency at
lower supplemental fuel cost.
D. Strategy: Improved Application Techniques to Minimize Coating Consumption (Strategies #6 and
14)
Narrative Overview
Most sources that are performing spray applied coating operations are already likely using high efficiency
spray guns (e.g., high volume, low pressure spray guns or airless spray guns). This is especially true in the
rail car and barge coating operations. Operator training has also been shown to improve transfer efficiency
and reduce coating usage in most operations, even above and beyond that achieved by using high efficiency
spray equipment.
Primary Considerations
a.
Magnitude of Reductions.
Switching to high efficiency spray guns can achieve a 60 percent reduction in the amount of coating that
would be applied by reducing the amount of overspray that is generated. Actual reductions are difficult to
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estimate because it is not known what equipment is currently being used at each facility, but most are
already likely using high efficiency equipment so actual reductions would be small.
Operator training in more efficient spray techniques could achieve additional emission reductions of about
20 percent, even when using efficient spray equipment. For the surface coating categories included here,
emission reductions of about 3.5 tons per year of HAP (organic and inorganic combined) could be achieved
through operator training.
b. Timeframe to Implement.
Once a regulation is in place to require operator training, training could be completed within a year.
Training programs are widely available as a result of implementation of subpart HHHHHH.
c. Other pollutants reduced.
VOC, HAP, and PM emissions would be reduced as a result of decreased coating consumption and
decreased amounts of coating overspray, respectively.
d. Technical feasibility.
High efficiency spray guns and operator training are readily available. They are also compatible with all
spray applied surface coating operations, except that training is not needed for automated robotic coating
operations.
d. Cost.
Initial costs are minimal, and costs can be recovered quickly by the source through reduced coating
consumption costs. If coating is done in a spray booth, costs can also be recovered through reduced spray
booth and filter maintenance.
E. Strategy: Perform All Spray Applied Rail Coating in a Filtered Spray Booth (Strategy #7) and
Upgrade Existing Water Wash Spray Booths to Dry Filter Booths (Strategy #11)
Narrative Overview
Most spray applied coating operations at the sources in the inventory are done in spray booths, except those
for rail car and barge coating operations. Some booths have water-wash filters instead of dry fabric filters.
Dry filters are known to achieve 98 percent efficiency in capturing paint overspray, which can be source of
inorganic HAP emissions. All rail car coating operations could be switched to a booth, if they are not
already performed in a booth, and existing booths could have filters up-graded to dry filters.
It is not feasible to enclose barge coating operations in a booth or other type of enclosure to capture
overspray.
40 CFR 63, subpart HHHHHH currently requires all spray applied coating operations at area sources using
the target HAP to be performed in filtered spray booths. Coating operations that do not use these HAP do
not need to meet this requirement. Subpart HHHHHH does not apply to major sources and they do not need
to meet a similar requirement under any of the major source NESHAP.
Primary Considerations
a. Magnitude of Reductions.
Total reductions are hard to estimate because the actual efficiency of the water-wash filters is not known,
and it is not known what fraction of coating is performed on rail cars versus barges at one sources.
Switching an open spray coating operation to an enclosed operation in a filtered booth would achieve a 98
percent emission reduction in inorganic HAP and PM emissions.
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Up-grading a spray booth from water wash to dry filters would probably achieve about an 80 to 90 percent
emission reduction.
b. Timeframe to Implement.
Designing, permitting, and constructing a rail car spray booth could take about one year. Upgrading
existing booths from water-wash to dry filters would take less than one year.
c. Other pollutants reduced.
PM emissions would be reduced as well as inorganic HAP emissions.
d. Technical feasibility.
Spray booths are already in use at several existing rail car coating operations.
Spray booths are not feasible for barge coating operations. U.S. EPA determined it was not feasible to
require a similar enclosure as part of the ship building and repair NESHAP residual risk review (75 FR
80220, December 21, 2010).
DoD has completed a study showing that waterwash spray booths can be retrofitted with dry filters,
generally using in house fabrication expertise at most manufacturing sites. Little or no change is needed in
the exhaust or air handling system. Dry filters also have fewer operation and maintenance costs than water
wash booths.
e. Cost.
The cost to design, permit, and build a rail car spray booth could be several $100,000.
The cost for retrofitting water wash spray booths to dry filter is minimal, as described under technical
feasibility, above. The increased cost for dry filters is offset by reduced operating and maintenance costs for
wet system.
F. Strategy: Install Thermal Oxidation on Spray Booth Exhausts (Strategies #12)
Narrative Overview
One source in the inventory is known to not have a thermal oxidizer or RTO on the exhaust from a drum
coating operation. This source accounts for a large majority (about 80 percent) of the organic HAP
emissions from the sources in the surface coating source category in the PATS inventory.
Primary Considerations
a. Magnitude of Reductions.
Organic HAP emissions could be reduced by about 95 percent and about 15 tons/year by installing a high
efficiency oxidation system on the exhaust from this source.
b. Timeframe to Implement.
The source may need two years or more to design, fabricate, permit, and install a thermal oxidation system.
Standards based on this level of control have generally allowed three years for existing sources to comply.
c. Other pollutants reduced.
Other HAP and VOC would be reduced by 95 percent.
d. Technical feasibility.
Thermal oxidation is the basis for emission standards for other surface coating source categories and high
efficiency units are commercially available.
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e. Cost.
Initial capital costs could be several $100,000, with substantial annual operating and maintenance costs.
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V. ATTACHMENTS
Attachment A: Considerations
This list of considerations will be used by PATSAC as an informal tool to understand toxics reduction
strategies. If the committee chooses, it may also use these considerations to shape its recommended package
of strategies or implementation steps. The tables below are cross-walked to the Committee’s Considerations
reference (DEQ web link below). For example, in Table 8, consideration 1.c. Effect on Exposure, refers to
consideration 1.c in the Committee’s full considerations list.
Considerations (ref: http://www.deq.state.or.us/aq/toxics/docs/pats/3_2_11regroupedConsideraton.pdf)
Table 7: Blueprint and Brainstorm List Strategies
Blueprint Level Strategy
Substitute lower emitting
components
Emission standards
Substitute lower emitting
components
Emission standards
Substitute lower emitting
components
Improved application techniques
Emission standards
Substitute lower emitting
components
Substitute lower emitting
components
Substitute lower emitting
components
Emission standards
Emission standards
Substitute lower emitting
components
Improved application techniques
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Brainstorm List Strategy
#1 – Web/Paper Coating and Printing Switch coatings and inks
#2 – Web/Paper Coating and Printing –
Continual operation of regenerative
thermal oxidizer
#3 – Metal Can Coating/Lithography –
Switch coatings
#4 – Metal Can Coating/Lithography –
Upgrade capture and destruction
efficiency of existing catalytic and thermal
oxidizers from 81% to 98%
#5 – Wood Furniture – Switch coatings
#6 – Wood Furniture – Switch to more
efficient spray guns
#7 – Rail Car and Barge Coating –
Perform all spray applied rail coating in
filtered spray booths
#8 – Rail Car and Barge Coating – Switch
rail coatings
#9 – Rail Car and Barge Coating – Switch
barge coatings
#10 – Miscellaneous Metal Parts Coating
– Switch to alternative solvents for
electronics cleaning
#11 – Drum Coating – Upgrade spray
booths from water wash to dry fabric
filters (from 60% to 98% filter efficiency)
#12 – Drum Coating – Install thermal
oxidation on spray booth exhaust (e.g.,
catalytic or regenerative thermal oxidizer)
#13 – Drum Coating – Switch coatings
#14 – Drum Coating – Switch to more
efficient spray guns
Portland Air Toxics Solutions
Table 8: Effectiveness
Strategy
1.c. Effect on Exposure 1
1.d. Pollution Prevention 2
#1 – …
1
Effect on exposure: How well does the measure target spatial extent of the emissions? Some reductions may have more pronounced effects on localized concentrations; others
may do more to reduce pollutants area-wide. (OAR 340-246-0170 4(g)). Ability to address short term or acute exposures if relevant.
2
Pollution prevention: Where does the strategy fit in the pollution prevention hierarchy? 1. Modify the process, raw materials, or product to reduce the quantity and toxicity of air
contaminants generated. 2. Capture and reuse air contaminants. 3. Treat to reduce the quantity and toxicity of air contaminants released. (OAR 340-246-0050)
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Table 9: Implementation/Feasibility Barriers
Strategy
2.a. Legal Authority 3
2.c. Funding 4
2.d.
Implementation 5
2.e. Acceptance 6
2.f. Non-regulatory
Approaches 7
#1 – …
3
Legal authority: Does the measure fall under existing regulations or are new laws/ rules required? Does federal pre-emption preclude new laws/rules? Is/will the proposed
measure be addressed through other planned Federal, state, or local rulemaking or other processes?
4
Funding: What is the cost to DEQ or other agency to implement the measure? How could the agency cost be funded? How certain is the funding mechanism?
5
Implementation: Is there a ready structure for implementation or ability to coordinate with existing programs?
6
Acceptance: Is there public and stakeholder support for the measure?
7
Non-regulatory approaches: Could the measure be implemented through incentives or education? Is there an opportunity to implement the measure through a community-based
multi-stakeholder collaborative process? Could the measure begin as voluntary and later become mandatory as necessary in a contingency plan?
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Table 10: Cost Considerations
Strategy
3.b. Cost
Effectiveness 8
3.c. Other
Environmental
Impacts 9
3.d. Energy
10
3.e. Public Safety
11
3.f. Indirect Economic
Costs 12
#1 – …
8
Cost effectiveness: What is the cost per unit of air toxics reduced?
Other environmental impacts: Potential for the emission reduction measure to transfer pollutants to soil or water, or cause harm to human health or the ecosystem.
10
Energy: Effect of measure on energy use.
11
Public safety: What is the affect of the measure on public safety? For example, would emission reductions restrict activities related to adequate lighting, heat, ventilation,
signage or access to emergency services?
12
Indirect economic costs: What are the potential indirect costs to communities, the local economy or business sectors?
9
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Table 11: Benefits and Distribution of Benefits and Cost
Benefits
Strategy
#1 – …
4.a. Health 13
4.b. Livability 14
4.c. Indirect
Economic Benefits 15
Distribution of Benefits and Cost
5.a. Risk
5.b. Cost
16
Distribution
Distribution 17
13
Health: What are the health benefits of meeting the benchmarks? This could be measured as the number of cancer cases avoided and/or value of statistical life and medical
costs avoided.
14
Livability: Improved quality of life associated with improved nuisance conditions such as odor or noise.
15
Indirect economic benefits: What are the potential benefits to communities, the local economy or business sectors?
16
Risk distribution: Could the measure change the social distribution of risk in the PATS area, i.e. sensitive populations and environmental justice communities?
17
Cost distribution: Could the measure impose disproportionate costs or economic impacts to environmental justice communities in the PATS study area?
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Attachment B: Response from Oregon Metals Industry Council (OMIC)
June 2, 2011
OMIC Comments on the Solvent – Coating White Paper
Reviewing the surface coating (solvent) white paper, OMIC offers these comments. These are not intended to
be considered complete or all inclusive, nor representative of all industry; however, we believe the following
are important points:
The white paper category description concludes that solvents are typically used to remove paints or other
coatings. Solvents are not just used as paint strippers but are often used to clean or prepare surfaces for other
treatments or coatings or as part of coating formulations. The control alternatives for paint strippers are
different from alternatives that could be used in coating operations or for cleaning operations. The description
also says that some paints contain metals and VOCs and that the main emissions of VOCs are during paint
drying. The paper goes on to discuss methylene chloride and other solvents but concludes that naphthalene is
the main solvent of concern given the uncertain methlyene chloride inventory data. Paint formulations are ever
changing, partly in response to requirements for lower VOC and HAP content. The assumption that naphthalene
is a main component of most of the paints and adhesives in use today needs to be verified. The source of
naphthalene, in solvents and paints should be explored and explained further. Formaldehyde is included in the
discussion, however we understand that most of the formaldehyde in the air is from secondary formation which
also should be better understood before imposing new controls and should consider the likelihood of collateral
regulation such as ozone reduction steps that may be considered. The emission inventories used in the
modeling may not reflect the chemical constituents in the paints and other products currently in use.
The combination of consumer and commercial products in the paper makes discussion of strategies confusing.
Many commercial products are high performance compared to consumer applications so the strategy of
substituting lower HAP materials is problematic when considered together. For example, military, aerospace
and specialty requirements exist in the commercial applications. In addition, there has been substantial effort
over the last few decades to reduce the level of VOCs and toxics nationally and in some states through
regulation of commercial sources. For aerospace, that effort has resulted in substantially lower VOC materials
including some water based products that continue to undergo examination for performance and toxicity to
employees 1819. These lower VOC materials may also pose unique problems when implemented in combination
with other controls, such as thermal oxidizers 20 Due to EPA NESHAP requirements to perform residual risk
analysis, advancements in coating technology are being included into regulation and therefore the permits of the
regulated facilities. Efforts in consumer product research have also progressed where regulation or the market
has driven it, but rarely are consumer products usable in commercial applications. Further, we believe that for
industries such as aerospace, national regulations have driven a common set of VOC content requirements so
the Californian limits are already adopted. Since the primary risk drivers are naphthalene, benzene and ethyl
benzene, more work to understand the source of those toxics is recommended before industry regulatory
strategies are adopted.
The paper also recognizes that NESHAPs like 6H exist and are implemented but keeps them on the list of
strategies. DEQ should evaluate the impact and account for it in the paper and the modeling. More effort
18
NIOSH exploring the toxicology of p-Chlorobenzotrifloride solvent present in water based primers
N-propyl bromide is qualified for some uses to replace chlorinated solvents. Calif and others are considering low exposure levels
due to toxicity concerns with this material
20
p-Chlorobenzotrifloride is known to cause issues with thermal oxidizers
19
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should be given to accounting for the emission reduction measures already being implemented before assuming
more control is required.
The paper also suggests that incentive programs for employee suggested alternatives be considered. Care must
be taken that incentive programs fit with the culture of the company. In some cases there are tax and other
consequences to consider. Companies have generally found that incentive for employee involvement in
improvement can be rewarded in ways that work best for them, case by case. In these areas, conservation of
materials is a goal that all can agree on supporting. Substitution is not a large candidate for incentivizing in
industry since engineering, product specifications, and other restrictions usually constrain the options.
The paper suggests that substitutes often have health benefits. Experience in industry is that they may often
have other health risks or other environmental impacts. Care is needed not to drive adoption of new materials
or processes without understanding those impacts. For example, n-propyl bromide was once a promising
candidate for replacing chlorinated solvent degreasers but recent toxicology information has shown it to have
potentially serious risks.
The paper suggests that adopting California rules for industrial and consumer products is effective, cost limited
for Oregon businesses, feasible within 1-2 years. As we stated, those requirements already exist through
Federal requirements and state implementation programs for industrial and commercial facilities. The best
mechanism to level the playing field and push advances in materials and processes is through Federal regulation
already in place.
DEQ has indicated the Eco Biz and education and outreach program is an option and we support any effort to
conduct outreach and education or grant certifications to businesses and to the consumers. The paper endorses
voluntary sustainability programs like the Natural Step network. DEQ could consider support for businesses
that adopt a sustainability or ISO 14001 type program that drives continual improvement.
Submitted on behalf of the Oregon Metals Industry Council by:
Steve Mason : Senior Manager
EHS / Chemical Value Chain
Boeing Portland
For more information, please contact:
Sarah Armitage
Oregon Department of Environmental Quality
(503) 229-5186
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