EPA-453/R-00-002

April 2000

http://www.epa.gov/ttn/ua

National Emission

Standards for

Hazardous Air Pollutants

for Source Categories:

Paper and Other Web

Coating Operations ---

Background Information for

Proposed Standards

United States

Environmental

Office of Air Quality 

Planning and Standards

EPA-453/R-00-002

National Emission Standards for

Hazardous Air Pollutants for Source Categories:

Paper and Other Web Coating Operations -

Background Information for Proposed Standards

Emission Standards Division

U.S. Environmental Protection Agency

Office of Air Quality Planning and Standards

Research Triangle Park, North Carolina 27711

April 18, 2000
ii

Disclaimer

This report has been reviewed by the U.S. Environmental

Protection Agency, Office of Air Quality Planning and Standards,

Emission Standards Division and approved for publication. Mention of

trade names of commercial products does not constitute endorsement or

recommendation for use.

Copies of this report are available through the

U.S. Environmental Protection Agency

Library Services Office (MD-35)

Research Triangle Park, North Carolina 27711

or it may be ordered from the

National Technical Information Services

5285 Port Royal Road

Springfield, Virginia 22161

Telephone: (703) 487-4650.
iii

TABLE OF CONTENTS

Page

1.0 INTRODUCTION .................... 1-1

1.1 OVERVIEW ................... 1-1

1.2 PROJECT HISTORY ................ 1-2

1.2.1 Background ............... 1-2

1.2.2 Data Gathering ............. 1-4

1.2.3 Emissions and Control Data ....... 1-5

1.3 DOCUMENT ORGANIZATION ............. 1-6

1.4 REFERENCES .................. 1-7

2.0 THE PAPER AND OTHER WEB COATING INDUSTRY ...... 2-1

2.1 INTRODUCTION ................. 2-1

2.2 OVERVIEW OF THE COATING PROCESS ........ 2-3

2.2.1 Coating Operations ......... 2-3

2.2.2 Coating Process ........... 2-4

2.2.2.1 Coating Applicators ....... 2-4

2.2.2.2 Coating Ovens .......... 2-17

2.2.2.3 Inert Ovens ........... 2-18

2.2.3 Coating Types ............ 2-19

2.2.3.1 Solventborne Coatings ...... 2-20

2.2.3.2 Waterborne Coatings ....... 2-20

2.2.3.3 Hot-melt Coatings ........ 2-21

2.2.3.4 Reactive Coatings ........ 2-22

2.2.3.5 Radiation-Cure Coatings ..... 2-22

2.3 INDUSTRY PROFILE ............... 2-24

2.3.1 Pressure-sensitive Tapes and Labels . 2-27

2.3.1.1 Baseline Emissions ....... 2-29

2.3.1.2 Types of Coatings and Applicators 

Used .............. 2-29

2.3.1.3 Pressure-sensitive Tapes and Labels 

Coating Process ......... 2-32

2.3.2 Flexible Vinyl ........... 2-33

2.3.2.1 Baseline Emissions ....... 2-34

2.3.2.2 Types of Coatings and Applicators 

Used .............. 2-35

2.3.2.3 Flexible Vinyl Coating Process . 2-36

2.3.3 Photographic Film ............ 2-38

2.3.3.1 Baseline Emissions ....... 2-39

2.3.3.2 Types of Coatings and Applicators 

Used .............. 2-39

2.3.3.3 Photographic Film Coating Process 2-40

2.3.4 Decorative and Industrial Laminates . 2-42

2.3.4.1 Baseline Emissions ....... 2-42

2.3.4.2 Types of Coatings and Applicators 
iv

Used .............. 2-43

2.3.4.3 Decorative and Industrial Laminate Coating

Process ............. 2-44

2.3.5 Miscellaneous Coating Industries . . 2-46

2.3.5.1 Baseline Emissions ....... 2-47

2.3.5.2 Abrasive Products ........ 2-48

2.3.5.3 Specialty Paper Coating ..... 2-50

2.4 REFERENCES .................. 2-52

3.0 EMISSION CONTROL TECHNIQUES ............ 3-1

3.1 INTRODUCTION ................. 3-1

3.2 CAPTURE SYSTEMS ................ 3-1

3.3 CONTROL DEVICES ................ 3-5

3.3.1 Oxidizers .............. 3-8

3.3.1.1 Thermal oxidizers ........ 3-8

3.3.1.2 Catalytic oxidizers ....... 3-10

3.3.2 Adsorption ............. 3-12

3.3.3 Condensation ............ 3-15

3.4 PREVENTIVE MEASURES .............. 3-18

3.4.1 Product Substitution/Reformulation . 3-18

3.4.2 Work Practice Procedures ...... 3-19

3.5 REFERENCES .................. 3-21

4.0 MODEL PLANTS, CONTROL OPTIONS, AND ENHANCED MONITORING 4-1

4.1 INTRODUCTION ................. 4-1

4.2 MODEL PLANTS ................. 4-1

4.3 CONTROL OPTIONS ................ 4-3

4.4 ENHANCED MONITORING .............. 4-8

4.5 REFERENCES .................. 4-10

5.0 ENVIRONMENTAL AND ENERGY IMPACTS OF CONTROL OPTIONS 5-1

5.1 INTRODUCTION ................. 5-1

5.2 ENERGY IMPACTS ................ 5-2

5.3 AIR IMPACTS .................. 5-5

5.4 WATER IMPACTS ................. 5-8

5.5 SOLID WASTE IMPACTS .............. 5-9

5.6 REFERENCES .................. 5-10

6.0 MODEL PLANT CONTROL OPTION COSTS .......... 6-1

6.1 INTRODUCTION ................. 6-1

6.2 CAPTURE AND CONTROL APPROACH ......... 6-2

6.3 MODEL PLANT CAPITAL AND ANNUAL COSTS - EXISTING

SOURCES .................... 6-5

6.3.1 Permanent Total Enclosures--Cost Related

Background ............. 6-6
v

6.3.2 PTEs for the Model Plants ...... 6-9

6.3.3 New Thermal Oxidizers ........ 6-9

6.3.4 Increasing Destruction Efficiency of

Existing Thermal Oxidizers ..... 6-12

6.3.5 Monitoring, Reporting, and

Recordkeeping ............ 6-15

6.4 TOTAL COSTS AND COST EFFECTIVENESS ...... 6-17

6.5 MODEL PLANT CAPITAL AND ANNUAL COSTS - NEW SOURCES6-21

6.6 REFERENCES .................. 6-23
vi

LIST OF TABLES

Page

Table 2-1. Types of Coating Applicators Used by 

Respondents of the POWC Survey ........... 2-5

Table 2-2. The 18 SIC Codes of the Paper 

and Other Web Coating Industry ........... 2-25

Table 2-3. Primary Products of the Pressure-sensitive 

Tapes and Labels Survey Respondents ........ 2-28

Table 2-4. Types of Coating Applicators Used by Survey

Respondents in the Pressure-sensitive Tapes and 

Labels Industry Segment .............. 2-32

Table 2-5. Types of Coating Applicators Used by Survey 

Respondents in the Flexible Vinyl Film Industry 

Segment ...................... 2-36

Table 2-6. Types of Coating Applicators Used by Survey Respondents in

the Photographic Film Industry Segment ....... 2-41

Table 2-7. Types of Coating Applicators Used by Survey Respondents

in the Decorative and Industrial 

Laminates Industry Segment ............. 2-44

Table 2-8. 1996 TRI Facilities and Emissions for the

Miscellaneous POWC Industry Segment ........ 2-48

Table 3-1. Common Control Devices and Associated

HAP Control Device Efficiency Ranges ........ 3-6

Table 3-2. Examples of Work Practice Standards ..... 3-20

Table 4-1. Specifications for Model Plants Representing 

the POWC Industry ................. 4-4

Table 4-2. Control Options for the POWC Industry .... 4-5

Table 5-1. POWC Model Plants and Their Estimated 

Correspondence to the National POWC Industry .... 5-2

Table 5-2. Energy Impacts of Control Option 1 

for the POWC Model Plants ............. 5-3

Table 5-3. Total Estimated Energy Impacts of 

Control Option 1 for the National POWC Industry . . 5-4

Table 5-4. Air Impacts of Control Option 1 

for the POWC Model Plants ............. 5-7

Table 5-5. Total Estimated Air Impacts of Control Option 1 

for the National POWC Industry ........... 5-7

Table 6-1. Specifications for Model Plants Representing 

the POWC Industry ................. 6-3

Table 6-2. Capture and Control Approach for the POWC Model Plants

with Control Option 1 ............... 6-4

Table 6-3. Capital Costs of Permanent Total Enclosures

for the POWC Model Plants ............. 6-10
vii

Table 6-4. Annual Costs Associated with Installation 

and Operation of Permanent Total Enclosures (PTE) 

for the POWC Model Plants ............. 6-11

Table 6-5. Regenerative Thermal Oxidizer Capital and 

Annual Operating Costs for POWC Model Plants .... 6-13

Table 6-6. Capital and Annual Costs of Increasing 

Destruction Efficiency of Existing T.O.s in the POWC

Industry ..................... 6-14

Table 6-7. Capital and Annual Operating Costs Associated 

with Monitoring, Recording, and Recordkeeping (MR&R) 

Requirements for the POWC Model Plants ....... 6-16

Table 6-8. Total Model Plant Capital Costs for Complying 

with Control Option 1 ............... 6-18

Table 6-9. Total Model Plant Annual Costs for Complying 

with Control Option 1 ............... 6-19

Table 6-10. Cost Effectiveness of Capture and Control 

Approaches to Control Option 1 for the POWC Model 

Plants ....................... 6-20

Table 6-11. Annual and Capital Costs of Achieving New Source MACT

Floor level of Control ............... 6-22
viii

LIST OF FIGURES

Page

Figure 2-1. Gravure coating unit ............ 2-6

Figure 2-2. Three-roll reverse-roll coater ....... 2-8

Figure 2-3. Knife coater ................ 2-10

Figure 2-4. Dip and squeeze coater ........... 2-13

Figure 2-5. Extrusion coater .............. 2-15

Figure 2-6. Calendering process ............ 2-16

Figure 3-1. Thermal recuperative oxidizer. ....... 3-9

Figure 3-2. Two-bed carbon adsorber. .......... 3-13

Figure 3-3. Shell-and-tube surface condenser. ..... 3-16
1-1

1.0 INTRODUCTION

1.1 OVERVIEW

Section 112 of the Clean Air Act (Act) requires that the U.S.

Environmental Protection Agency (EPA) establish emission standards

for all categories of sources of hazardous air pollutants (HAP). 

These national emission standards for hazardous air pollutants

(NESHAP) must represent the maximum achievable control technology

(MACT) for all major sources. The Act defines a major source as:

...any stationary source or group of stationary sources

located within a contiguous area and under common control

that emits or has the potential to emit, in the aggregate,

10 tons per year or more of any hazardous air pollutant or

25 tons per year or more of any combination of hazardous

air pollutants.

In July 1992, the initial list of source categories for

regulation under section 112 of the Act was published. "Paper and

Other Webs (Surface Coating)" was included as a source category. To

more clearly define the source category, the EPA subsequently decided

to call the source category "Paper and Other Web Coating Operations." 

The NESHAP for the paper and other web coating (POWC) industry will

establish standards for major sources in this source category.

The POWC source category can be described as processes that

apply a uniform layer of material (coating) across essentially the

entire length and/or width of a continuous substrate (web) to provide
1-2

a covering, finish, or functional or protective layer to a substrate,

to saturate a substrate or to provide adhesion between two substrates

for lamination. This definition serves to distinguish the POWC

source category from the printing and publishing source category,

which can be described as processes that apply words, designs, or

pictures to a substrate. Web coating is done in the manufacture of

some major product types such as: pressure-sensitive tapes and

labels; photographic film; industrial and decorative laminates;

flexible vinyl products; flexible packaging; abrasive products; and

folding paperboard boxes. Because this source category is defined by

the broad web coating operation, other product types may be included

under the POWC source category.

The purpose of this document is to summarize the background

information gathered during the development of the POWC NESHAP.

1.2 PROJECT HISTORY

1.2.1 Background

The POWC industry can be divided by technology, substrate, or

type of product. Further divisions and industry segments can be

identified in each of the major industry divisions. Many

manufacturing processes include web coating operations as one step in

the production process. It is estimated that more than

400 establishments in the U.S. have web coating operations. 

Surface coatings usually provide a covering, a finish, or

decorative, functional, or protective layer to a substrate. Coatings

for lamination purposes provide adhesion for the case where two

substrates are pressed together. For example, polyvinyl chloride

film may be coated with an adhesive and then laminated to (pressed

onto) fabric to manufacture wall coverings. In some processes, the

web is formed on the coating line where it is then coated and wound.
1-3

The coating industry can be divided by technology into

segments, such as gravure coaters, roll coaters, dip coaters,

extrusion coaters, etc. While the industry manufactures a wide range

of products, the manufacturing process varies little by product. The

coating industry can also be divided by the type of substrate coated. 

The primary substrates coated by the industry are paper, film, and

foil. The industry uses a range of films including polyester,

polyethylene, polypropylene, polyvinyl chloride, and cellulose

acetate. Other substrates coated by the industry include foam and

fabric.

The coating industry can additionally be divided by the type of

product. The types of products manufactured by the industry include

but are not limited to: pressure-sensitive tapes and labels;

photographic film; coated vinyl; wall coverings; sandpaper and other

abrasives; paperboard boxes; vinyl flooring; industrial and

decorative laminates; carbon paper and carbonless paper; circuit

boards; and business forms.

The development of NESHAP for the POWC industry must take into

account areas of overlap with other industries and NESHAP for other

source categories. Potential areas of overlap are printing, fabric

coating, and coil coating.

Many products manufactured by the POWC industry are printed and

coated, often on the same production line. The printing and

publishing NESHAP,1 promulgated in May 1996, allows facilities that

print and coat different materials on the same line, or print and

coat the same substrate on different lines, to cover their coating

operations under the printing and publishing NESHAP. Stand-alone

coating equipment can be included as part of the affected source

under the printing and publishing NESHAP if it is similar to the

printing presses in any of the following ways: it applies solids-
1-4

containing materials to the same web or substrate; it applies a

common solids-containing material; or it uses a common control device

for control of organic HAP emissions. Therefore, many facilities

whose coating operations could be covered under the POWC NESHAP may

instead opt to cover their coating operations under the printing and

publishing NESHAP. Also, although facilities coating fabric will be

primarily covered under fabric coating, printing and dyeing NESHAP,

facilities will likely be given the option of covering their fabric

coating operations under the POWC operations NESHAP. 

Some segments of the POWC industry are already subject to

regulations limiting their volatile organic compound (VOC) emissions. 

In 1978, the EPA developed a control technique guidelines (CTG)

document for surface coating of paper and fabric.2 The EPA

promulgated new source performance standards (NSPS) for pressuresensitive tape manufacturers, flexible vinyl coating and printing

operations, and polymeric coating of supporting substrates.3,4,5

While none of these regulations were specifically directed at

reducing HAP emissions, many HAP used by the POWC industry are also

VOC. Examples of HAP that are frequently used by this industry and

are also volatile organic compounds (VOC) are formaldehyde, methyl

ethyl ketone, methanol, toluene, and xylene. Therefore, many control

devices installed by the industry to reduce VOC emissions also reduce

HAP emissions.

1.2.2 Data Gathering

The POWC NESHAP project began in March 1996. In late 1996, a

questionnaire was developed and distributed by the EPA, with the help

of the Pressure Sensitive Tape Council (PSTC), to determine HAP use

and control in the pressure-sensitive tape and label segment of the

POWC industry. In 1997, the EPA developed and distributed a

questionnaire, with the help of the Chemical Fabrics & Film
1-5

Association (CFFA) and the National Association of Photographic

Manufacturers (NAPM), to determine HAP use and control by film

formation and coating operations. Also in 1997, the EPA developed

and distributed a questionnaire to determine HAP use and control in

the manufacture of industrial and decorative laminates, with the help

of the Laminating Materials Association (LMA), the National

Electrical Manufacturers Association (NEMA), and the Association of

Industrial Metallizers, Coaters, and Laminators (AIMCAL). 

The EPA questionnaires were designed to evaluate HAP emissions

from the industry and the current level of control of HAP emissions

by the industry. The questionnaires were included with information

collection requests (ICR) sent out under the authority of section 114

of the Act. Questionnaire responses were solicited from

104 companies that manufacture pressure-sensitive tapes and labels,

40 companies that operate film formation and coating equipment, and

49 companies that manufacture industrial or decorative laminates.

Besides information obtained from these questionnaires, the EPA

made several site visits to POWC facilities. Also, the EPA met

and/or conversed with many trade associations and industry

representatives. Other sources of information obtained for the

project include emission data from the 1996 Toxic Release Inventory6

(TRI) database, trade organization surveys, the Aerometric

Information Retrieval System7 (AIRS) database, and the literature.

1.2.3 Emissions and Control Data

The available emissions and control information for the POWC

industry are summarized in Chapters 2 and 3. Most of the information

collected from POWC surveys is based on calendar year 1996, but

represents current practices in the industry. Control efficiency

data are also representative of current conditions. In some segments
1-6

of the industry, there has been a shift away from HAP use to either

nonHAP VOC or waterborne materials.

1.3 DOCUMENT ORGANIZATION

This document is organized into six chapters designed to

explain the background information collected for the paper and other

web coating NESHAP. Following this introduction, Chapter 2 presents

a profile of the paper and other web coating processes and industry. 

Chapter 3 describes the emission control techniques used by the POWC

industry. Model plants developed to represent major sources in the

POWC industry are presented in Chapter 4, along with control options

and enhanced monitoring for the industry. In Chapter 5, the

environmental and energy impacts of the control options for the POWC

industry are presented. The cost impacts of these control options

developed for the model plants are presented in Chapter 6. 
1-7

1.4 REFERENCES

1. U.S. Environmental Protection Agency. National Emission

Standards for the Printing and Publishing Industry. 40 CFR 63,

Subpart KK, May 1996.

2. U.S. Environmental Protection Agency. Control of Volatile

Organic Emissions from Existing Stationary Sources -Volume II:

Surface Coating of Cans, Coils, Paper, Fabrics, Automobiles,

and Light-Duty Trucks. EPA-450/2-77-008. Research Triangle

Park, North Carolina. May 1977.

3. U.S. Environmental Protection Agency. Standards of Performance

for Pressure Sensitive Tape and Label Surface Coating

Operations. 40 CFR 60, Subpart RR (48 FR 48375), October 18,

1983.

4. U.S. Environmental Protection Agency. Standards of Performance

for Flexible Vinyl and Urethane Coating and Printing. 40 CFR

60, Subpart FFF (49 FR 26892), June 29, 1984.

5. U.S. Environmental Protection Agency. Standards of Performance

for Polymeric Coating of Supporting Substrates. 40 CFR 60,

Subpart VVV (54 FR 37551). September 11, 1989.

6. U.S. Environmental Protection Agency. Toxic Release Inventory

System (TRI) Database. Office of Pollution Prevention and

Toxics, Washington, DC. 1996.

7. U.S. Environmental Protection Agency. Aerometric Information

Retrieval System (AIRS) Database. Office of Air Quality

Planning and Standards, Research Triangle Park, North Carolina.

1997.
2-1

2.0 THE PAPER AND OTHER WEB COATING INDUSTRY

2.1 INTRODUCTION

The paper and other web coating (POWC) industry consists of the

application of various coatings onto web substrates to manufacture a

wide range of products, including, but not limited to, pressuresensitive tapes and labels, vinyl film, photographic paper and film,

flexible packaging, industrial and decorative laminates, sandpaper

and other abrasives, and wall coverings.

Although the industry manufactures an extensive list of

products, the coating processes used by the different segments of the

industry are very similar. Typically, the substrate (web) is

unwound, coated, rewound and/or cut to size, and packaged. 

Alternatively, a web may be unwound, coated, and then combined with

another material by lamination (either before or instead of being

rewound). 

Emission sources are also similar throughout the different

industry segments. Coating application and drying/curing are the

largest emission sources for all segments of the industry, with

minimal HAP emissions from cleaning, coating mixing, coating and

solvent storage, and wastewater. Coating line emissions can

represent up to 96 percent of the total HAP emissions from coating

operations.1 Some segments of the industry also manufacture

substrates onsite. In the flexible vinyl industry segment of the

POWC industry, 38 percent of the facilities responding to an EPA
2-2

survey stated that flexible vinyl substrates were formed onsite.2 In

the photographic film industry segment, 20 percent of the respondents

indicated that they formed flexible vinyl substrates onsite.3

Many industrial facilities perform both coating and printing

operations. Within the printing industry, the rotogravure and wideweb flexography product and packaging printing industry segment (that

includes the flexible packaging industry as a major subsector) does

the most coating, with material use distributed almost equally

between inks and coatings.4,5 Printing operations are covered under

EPA's promulgated National emission standards for hazardous air

pollutants (NESHAP) for the printing and publishing industry.6 The

printing and publishing NESHAP covers all types of printing

operations and includes an option for facilities that perform both

printing and coating to cover certain coating operations under the

printing and publishing NESHAP. Therefore, many of the facilities

whose coating operations could be covered under the NESHAP for the

POWC industry may opt to cover these operations under the printing

and publishing NESHAP. A detailed discussion of the printing and

publishing industry is included in the background information

document for that industry.7 

In the responses from the POWC survey of the pressure sensitive

tape and label, flexible vinyl, photographic film, and decorative and

industrial laminates industry segments, 8 percent of all (824)

coating application stations were printing stations. In the

individual segments, the flexible vinyl industry segment had the

highest percentage of printing stations at 30 percent. The other

industry segments had much lower percentages of printing stations:

decorative and industrial laminates and photographic film both had 2

percent, and pressure-sensitive tapes and labels had 0.7 percent.8
2-3

Section 2.2 includes a discussion of the typical coating

processes used by the POWC industry. Section 2.3 contains a POWC

industry profile that includes a discussion of the major segments of

the POWC industry, and the types of coatings and operations that are

specific to those segments of the industry. References may be found

in Section 2.4. Appendix A lists the facilities that responded to

the EPA survey of the POWC industry.

2.2 OVERVIEW OF THE COATING PROCESS

Section 2.2.1 provides a definition of a "web coating

operation." In Section 2.2.2, the typical components of the coating

process are explained with detailed descriptions of coating

applicators and ovens. The types of coatings used in the POWC

industry are described in Section 2.2.3. 

2.2.1 Coating Operations

A web coating operation may be defined as a process that

applies a uniform layer of material (coating) across essentially the

entire length and/or width of a continuous (web) substrate to provide

a covering, finish, or functional or protective layer to a substrate,

to saturate a substrate or to provide adhesion between two substrates

for lamination. Some coatings actually form part of all of the

substrate, such as photographic, x-ray, and microfiche film; vinyl

for wall and window coverings; the back side of carbonless paper; and

reactive resins used in the manufacture of decorative and industrial

laminates.9 These materials may or may not be further coated,

printed, or processed. Coatings for lamination can also provide

adhesion between two substrates.10

The distinction between a printing operation and a coating

operation may not always be obvious. Printing may be described as a

process that applies words, designs, or pictures to a substrate. 
2-4

Although printing and coating are distinct operations for regulatory

purposes, they have many similarities. 

2.2.2 Coating Process

Components of a typical coating line in the POWC industry

include an unwind roll, one or more coating applicators and drying

ovens, a rewind roll or cutting/slitting operation, and flash-off

area. Each coating application station may use the same type of

coating applicator or different types of applicators. Typically, an

oven immediately follows each application station. The coating

applicator and the oven are the main emission sources on the coating

line.

2.2.2.1 Coating Applicators. Several different types of

applicators may be used to apply the coatings. The most common types

of applicators used by the industry include (roto)gravure, reverse

roll, slot die, knife, flexography, Mayer rod, dip and squeeze, and

extrusion/calendering. Other types of applicators may be used for

selected coating operations, but these are the primary types of

applicators used by the POWC industry. 

Table 2-1 shows the breakdown of coating applicators used by

respondents of the POWC survey.11 From these data it can be seen

that gravure coating applicators were used the most (at 32 percent of

the coating stations), with roll and/or reverse roll coaters used

second most (at 20 percent), and slot die used third most (at

10 percent), together accounting for almost two-thirds of the coating

application stations. The eight remaining coating applicator types

together account for approximately one-third of the coating

applicators in the surveys.

2.2.2.1.1 Rotogravure. Rotogravure (web-fed gravure) coaters

are used extensively by the printing industry, but they are also used
2-5

Table 2-1. Types of Coating Applicators Used by 

Respondents of the POWC Survey

Application Method

Percentage of 

Application Stations

Gravure 32

Roll, Reverse Roll 20

Slot Die 10

Knife 9

Flexography 8

Mayer Rod 7

Dip 5

Extrusion/calendering 3

Rotary Screen 3

Printing 2

Flow 1

Total 100

for coating. The coating materials (or inks) are picked up in the

recessed areas of the roll and transferred directly to the substrate. 

The gravure coater can print patterns on the substrate or coat some

or all of the substrate. Figure 2-1 shows a diagram of a gravure

coating unit; several of these may be combined on one coating line.

In gravure coating, the coatings include both solvent and waterbased

systems, with the solvents including aromatic, aliphatic, and

oxygenated hydrocarbons. About 60 percent of the coatings are

petroleum-based waxes and hot melts, 35 percent are extrusion

coatings, and 5 percent water-based.12

2-7

Among the POWC survey respondents, gravure was the most common

type of coating application station, at 32 percent of all coating

stations, and also the most common coating technique in

the pressure-sensitive tapes and labels industry segment (at

33 percent) and flexible vinyl industry segment (at 40 percent). In

the decorative and industrial laminates industry segment, gravure

coating was the second-most common (after dip), at 34 percent of the

coating stations.

2.2.2.1.2 Reverse Roll. The reverse roll coater applies a

constant thickness of coating to the substrate, usually by means of

three rollers--a metering roller, a backing roller, and an applicator

(transfer) roller. A metering roller picks up the 

coating solution from a trough and transfers it to an applicator

roller. (Sometimes there is no metering roller and the coating 

is pumped directly onto an applicator roller.) The web is supported

by a backing roller where the applicator roller contacts the paper. 

The applicator roller then transfers the coating to the substrate, as

the web passes between the backing roller and the applicator roller. 

The applicator roller turns in a direction opposite to that of the

paper, hence the name reverse roll coater. This reverse direction of

the applicator roller reduces striations in the coating that can form

if the applicator 

roller is turned in the same direction as the paper web. Figure 2-2

depicts a three-roll reverse roll coater.

Among the POWC survey respondents, roll and/or reverse roll was

the second-most common type of coating application station, at

20 percent of all coating stations, with 28 percent of the

photographic film stations, 26 percent of the pressure-sensitive

tapes and labels coating stations, and 20 percent of stations in the 

2-9

decorative and industrial laminates industry segment using roll

and/or reverse roll coater coaters.

2.2.2.1.3 Slot Die. The slot die coater is similar to an

extruder but is less heavy-duty than an extruder since less viscous

materials are used with a slot die coater (see Section 2.2.2.1.8 for

a discussion of extruders). In a slot die coater, the coating is

extruded through an adjustable-width orifice onto the substrate and

is sometimes followed by a smoothing roller. Slot die coaters are

typically used for application of hot-melt coatings and adhesives,

but may also be used to apply aqueous coatings.14

Among the POWC survey respondents, slot die coating was the

third-most common coating technique, at 10 percent of all coating

stations; and was the most common technique in the photographic film

industry segment (at 44 percent). It was also a common technique in 

the pressure-sensitive tapes and labels industry segment (at 12

percent). No decorative and industrial laminates facilities among

the survey respondents used slot die coaters.

2.2.2.1.4 Knife. A knife coater consists of a blade that

scrapes off excess coating from the substrate. The tray or trough of

coating is located behind the knife blade. A continuous sheet of

substrate is drawn between the knife blade and the support roller. 

As coating is deposited on the substrate, the knife blade spreads it

across the substrate to the desired thickness. The position of the

knife relative to the substrate surface can be adjusted to control

the thickness of the coating. Some knife coaters use high velocity

air as the knife blade, these are known as air-knife coaters. A

diagram of a floating knife coater is shown in Figure 2-3.

Knife coaters can apply solutions of much higher viscosity than

roll coaters, thus less solvent is emitted per pound of coating

applied. Knife coaters handle coatings with viscosity up to 

2-11

10,000 centipoise (cp), while reverse roll coaters operate best with

coatings that have a viscosity ranging from 300 to 1500 cp. Knife

coaters, however, usually operate at lower speeds than roll coaters

and show a greater tendency to break the web.16

Among the POWC survey respondents, knife coating was the

fourth-most common type of coating application station at 

9 percent of all coating stations, with 11 percent of the flexible

vinyl coating stations, 11 percent of the photographic film coating

stations, 9 percent of the pressure-sensitive tapes and labels

coating stations, and 5 percent of the decorative and industrial

laminates industry stations having knife coaters.

2.2.2.1.5 Flexography. In flexographic coating, the area to be

coated is delineated by a raised surface on a flexible plate that is

usually made of rubber or other elastomeric materials.17 Because of

the ease in plate preparation, flexography is more suited to short

production runs than gravure.18

Coating materials applied with flexography must be very fluid

to work properly and include waterborne and solvent-based 

systems. The solvents used must be compatible with the rubber or

polymeric plates; thus aromatic solvents are not used. Some of 

the components of solvent-based flexographic coatings include ethyl,

n-propyl, and isopropyl alcohol; glycol ethers; aliphatic

hydrocarbons; and esters.20 Flexography is performed both on wide

web (<18 inches) and narrow web (<18 inches), and on sheets as well

as web.21

Among the POWC survey respondents, flexographic coating was the

fifth-most common type of coating application station at 8 percent of

all coating stations, with 20 percent of the flexible vinyl industry

segment and 4 percent of the pressure-sensitive tapes and labels

industry segment coating stations having flexographic coaters. No
2-12

decorative and industrial laminates facilities among the survey

respondents used flexographic coating applicators.

2.2.2.1.6 Mayer Rod. The Mayer rod (or wire-wound rod) coater

is a metering device used to control the thickness of an 

applied coating. Typically, the coating is applied via a roller, and

the excess coating is removed by a rod covered by a spiral-wound

stainless steel wire. The rod wipes the coating off the substrate

except for the portion which escapes through the spaces between the

wires. Larger wire diameters result in larger spaces, and therefore

heavier coatings.22

Among the POWC survey respondents, Mayer rod coating was used

most often in the pressure-sensitive tapes and labels industry

segment, with 11 percent of the coating stations having Mayer rod

coaters, and was used by 5 percent of the decorative and industrial

laminates, 3 percent of the flexible vinyl, and 

2 percent of the photographic film industry segment coating stations.

2.2.2.1.7 Dip and Squeeze. The dip and squeeze coater, also

called a dip coater, impregnates or saturates the substrate rather

than applying a coating to the web surface.23 Figure 2-4 shows a

diagram of a dip and squeeze coater. The substrate is fed and dipped

into a coating-filled pan by a system of rollers. 

The saturated web is then passed through nip rollers that squeeze off

any excess coating. 

Among the POWC survey respondents, dip and squeeze coating was

the most-common coating station in the decorative and industrial

laminates industry segment, at 36 percent of the coating stations. 

Overall, only 5 percent of the coating stations from the entire

survey respondents used dip and squeeze, with 3 percent of the

flexible vinyl industry segment and 1 percent of the pressuresensitive tapes and labels industry segment.

2-14

2.2.2.1.8 Extrusion/calendering. The extrusion coater creates

a web substrate or applies coating materials to a preformed web

substrate by forcing it through a die. A typical extrusion coater

forms a plastic film or coating of the hot-melt type by forcing a

molten polymer resin through a die as the web or conveyor passes

below the die. The extruded web is then cooled to restore the

coating to a solid state.25 Nearly all extrusion coatings are made

of low-density polyethylene (LDPE). They account for a large portion

of the coatings used in the printing product and packaging industry,

divided about evenly between cartons/cardboard and flexible

materials.26 Figure 2-5 shows a diagram of an extrusion coater.

In calendering, a process similar to extrusion, material is

pressed by a roller or between rollers to form a web such as vinyl

sheeting. Calendering may also be used to apply a coating to a

substrate, as in the manufacture of duct tape.27 Prior to

calendering, resins, plasticizers, and pigments are blended together

in a series of blenders, mixers, and mills. Plasticizers are used to

improve the flexibility of the coating/material.28 After mixing, the

mixture is conveyed to the calender. In a typical four-roll

calender, the molten coating is rolled into a continuous sheet, which

is then cooled. Figure 2-6 shows the calendering process. 

Among the POWC survey respondents, extrusion/calendering was

used most often in the pressure-sensitive tapes and labels industry

segment, at 3 percent of the coating stations, with 2 percent of the

coating stations in the photographic film industry segment using

extrusion/calendering occurring. No coating stations were reported

to use extrusion/calendering in the decorative and industrial

laminates industry segment. 


2-17

2.2.2.2 Coating Ovens. Like the applicator, the oven is a primary

piece of equipment on the coating line. The major functions of the

oven are to dry the coating by evaporating the solvent and/or finish

the curing of a polymeric coating.31 The oven exhaust is the largest

source of HAP emissions in the coating process.

The important properties of a drying/curing oven include the

source of heat, operating temperature, residence time, allowable

hydrocarbon concentration, and oven air circulation.32 There are two

basic types of heating used in drying ovens, direct and indirect. 

Direct heating routes the hot products of combustion (blended with

ambient air to the proper temperature) directly into the drying zone. 

The fuels used for a direct-fired oven are usually limited to natural

gas or propane because of the requirements for clean burning. Fuel

oil, or other heavier fuels, can produce enough soot and other

particulates to adversely affect the coating.

In an indirect-heated oven, the incoming air stream exchanges

heat with steam or combustion products but does not physically mix

with them. The heat transfer may occur in any of several types of

heat exchangers, such as shell-and-tube or plate type.

Direct-fired ovens are more common because of their higher

thermal efficiency. Indirect-heated ovens lose efficiency both in

the production of steam and in the heat transfer from steam to oven

air.33 Indirect heating is usually limited to small ovens, cases

where product contamination cannot be tolerated, and where surplus

steam is available.

The average oven temperature is important to both the process

and the costs of installing add-on control equipment. For drying

purposes, the oven must be at a temperature above the boiling point

of the solvent(s). If the coating cures by polymerization rather

than solvent evaporation, the temperature may have to be even higher. 
2-18

The average temperature affects the amount of cooling required if the

exhaust stream is directed to a carbon adsorber and the amount of

preheating required if the exhaust stream is directed to a thermal

oxidizer.

The oven temperature profile is also important to product

quality. If the initial drying is too fast, flaws in the coating

such as craters or fish-eyes may result.34 If the drying is too slow

at lower temperatures, a longer oven will be needed to dry the

coating. The solution to this problem is multizoned ovens, where the

oven is physically divided into several sections, each with its own

hot air supply and exhaust. By using a lower temperature in the

first zone and then gradually increasing the temperature in

subsequent zones, uniform drying can be achieved in a reasonably

sized oven.35

For safety, most facilities in the industry try to maintain air

flow through their ovens so that the solvent concentration is no

greater than 25 percent of the lower explosive limit (LEL). However,

newer oven styles safely allow higher solvent concentrations, up to

40 to 50 percent of the LEL. The higher solvent concentrations are

allowable due to the increasing use of continuous LEL monitors that

sound alarms or shut down the line if the LEL reaches too high a

level. With the higher allowable solvent concentrations, the amount

of air flow needed through the oven is decreased, resulting in lower

energy costs. The higher solvent concentrations also reduce the

costs of add-on control devices, which increase in cost as the air

flow increases. The exhaust flow rates from ovens used by the

industry vary from 5,000 to 35,000 standard cubic feet per minute

(scfm). Typical oven exhaust rates are 10,000 to 20,000 scfm.36

2.2.2.3 Inert Ovens. An inert oven is a coating drying method

that uses an inert gas (e.g., nitrogen) to replace oxygen in the air
2-19

space in the oven. In an inert oven, solvent vapors can be

concentrated at levels higher than the LEL to enable efficient

collection via condensation. The ovens are also found to be useful

with coatings that otherwise would be difficult to apply without

forming air bubbles under the coating surfaces.37 

There is no oven vent to the atmosphere in an inert oven. 

Instead, a small diameter pipe conducts superconcentrated exhaust at

flow rates of only 100-200 ft3/min to condensation coils. Solvent

concentrations may be 100,000 to 200,000 ppm in an inert oven’s

exhaust, which is above the upper explosive limit (UEL) for most/all

solvents. After the solvent condenses out of the gas in the coils,

the cleaned gas is returned to the oven; this cycle is a closed loop

in terms of the oven gas.38

For proper operation, there must be an oxygen-free dead-zone of

air space after the inert oven and before the condenser, where the

air flow is balanced between the air pulled in vs. the air pushed

out. This situation complicates the use of total enclosures around a

coating line with an inert oven. Unfortunately, air flow as little as

200 ft/min can disturb the web in an inert oven and cause a web to

break, especially one made of paper. Because of issues such as

solvent concentrations above the UEL and static electricity in film

coating, safety is another concern with totally enclosing the air

space around inert ovens.39

2.2.3 Coating Types

The basic coating types, by composition, used in the POWC

industry are solventborne, waterborne, hot-melt, and radiation-cure

coatings. These coating types are described in this section, below.

Coatings typically consist of a fluid portion (i.e.,

solvent(s)), resins, pigments, and additives. The solvents and

resins together form the vehicle, which maintains the coating in
2-20

liquid form for application; once the coating is deposited on the

substrate, the solvents of the vehicle evaporate leaving the resin,

and the pigments and additives. The solvent portion of the vehicle

transfers the solid portion of the coating to the substrate surface

in a uniform layer and typically plays no role further role in the

coating process.40 Coatings can range from 0 to 99 percent solvent. 

The nonsolvent portions of coatings are called “solids.”

The HAP from the coatings may be emitted as fugitive emissions

(unless the facility is equipped with a permanent total enclosure) at

the point of application and in flash-off areas. The HAP from the

coatings are also emitted via exhaust stacks/vents from the ovens

used to dry the coatings.

2.2.3.1 Solventborne Coatings. Solventborne coatings are widely

used in the POWC industry.41 The content of the coating vehicle is

highly variable in solventborne coatings, and depends primarily on

the type of coating applicator used. For solventborne coatings,

coating formulations typically range from 40 to 80 percent solvents

by weight, as supplied. For use, the solventborne coatings may be

diluted with additional solvents. The primary solvents in

solventborne coatings that are HAP include methanol, methyl ethyl

ketone, toluene, and xylene. Other primary solvents (not HAP)

include acetone and ethanol.

Knife coaters, reverse roll coaters, and gravure coaters are commonly

used to apply solventborne coatings.42

2.2.3.2 Waterborne Coatings. In waterborne coatings, a

significant part of the fluid is made up of water, although some

organic solvents may be used at up to 30 percent of the fluid. The

EPA Reference Test Method 24 considers a waterborne coating to be one

with more than 5 percent water by weight in its volatile fraction.43

Most coating equipment used for solventborne coatings can also be
2-21

used for waterborne coatings. However, troughs or trays containing

waterborne coatings may have to be mixed more often than with

solventborne coatings because waterborne coatings are more

susceptible to coagulation or agglomeration of their solids.44 Knife

coaters and gravure coaters are also particularly well suited to

application of waterborne coatings.45 

Oven temperatures are typically higher with waterborne coatings

because water has a higher boiling point and higher heat of

vaporization than most organic solvents. However, energy usage may

still be lower for waterborne coatings because less dilution air is

required.46

2.2.3.3 Hot-melt Coatings. Hot-melt coatings are probably the

most environmentally friendly of all the coating formulations used by

the POWC industry because they contain no solvent, being 100 percent

solids in composition.47 Unlike solventborne coatings and waterborne

coatings, which typically are formulated with some organic solvent,

hot-melt coatings emit no volatile organic compounds (VOC). Energy

usage with hot-melt coatings is substantially lower than with either

waterborne or solventborne coatings. Fire and explosion dangers are

also minimized because there are no volatile hydrocarbons.48

The application of hot-melt coatings is fairly simple. The

solid coating material is heated and delivered to the coater head in

a molten state. It is then metered onto the web by a heated gravure

coater, a heated roll coater, or an extrusion coater. The coated web

is then chilled and the coating restored to its solid state.49

However, despite its simplicity, application of hot-melt coatings may

have several problems. Controlling the coating weight can be

difficult with hot-melt coatings. The coater head is more

susceptible to streaking due to plugging or dirt accumulation. 
2-22

Cleaning the coater head with hot-melt coatings is also more

difficult and time consuming.50

The use of hot-melt coatings, although growing, is still

limited by several factors. Hot-melt adhesives do not have the

strength or resistance to environmental stresses such as heat or cold

as do solventborne adhesives.51 The hot-melt adhesives are typically

a darker color and, therefore, are not used on transparent surfaces. 

Hot-melts also cannot be used on film substrates that are sensitive

to heat because the substrate could melt during the coating

process.52

2.2.3.4 Reactive Coatings. Reactive coatings are coatings that

cure via a chemical (usually polymeric) reaction which forms other

compounds that are either not HAP’s and/or stay with the substrate as

a residual HAP which is not emitted with or without drying. 

Reactive coatings are frequently used in the decorative and

industrial laminates industry segment of the POWC industry and the

abrasive subsector of the miscellaneous industry segment, and include

styrene formaldehyde, phenolic, melamine, and epoxy resins. In the

POWC survey responses in the decorative and industrial laminates

industry segment, seven facilities provided test or engineering data

on the amount of residual HAP left in the substrate with the use of

reactive coatings. These data indicate that anywhere from zero to

50 percent of the coating (by weight) reacts and stays with the

substrate/product.53

2.2.3.5 Radiation-Cure Coatings. A special case of reactive

coatings, radiation-cure coatings (also called prepolymer coatings54)

include coatings that are cured by exposure to electron beam (EB) or

ultraviolet (UV) radiation. Radiation-cure coatings are solventless

and are almost entirely composed of the resins that make up the

coating. They are applied in a liquid state via some typical coating
2-23

application methods (e.g., gravure and flexography), and polymerize

into a solid state upon exposure to UV or EB radiation. Ultraviolet-cured coatings require addition of a photoinitiator to

catalyze the polymerization reaction; EB-cured coatings do not,

because the highly exited electrons emitted by the EB source are

capable of initiating the polymerization reaction.55

Benefits of radiation-cured coatings extend beyond decreased

solvent usage and the associated emission reductions. The

instantaneous nature of the curing process eliminates the need for

drying ovens on the production line, which often leads to production

increases56 and may allow direct integration of ancillary operations

(e.g., cutting, slitting, folding) into the production line.57

Because no drying ovens are used, energy usage is greatly reduced as

is the space required for a coating line.58 Since the coatings will

not cure unless exposed to the proper type of UV or EB radiation,

they will not cure on the production equipment during operation or

during process downtime. As a result, it is not necessary to clean

application devices at the end of each shift or during breaks, and

cleaning is easier when it is performed.59

Although industry generally perceives UV coating usage as

expensive because it may be costly to switch a coating line from

solvent-based coating equipment to radiation-cured systems, there are

often savings with the use of radiation-cured coatings due to the

above-mentioned benefits that can offset capital costs. Another

industry perception is that the coatings themselves are more

expensive. This may be true on a volume-to-volume basis comparison,

however, a radiation-cured coating will cover a much greater area of

substrate (2 to 4 times) than an equal volume of a solvent-based

coating because the radiation-cured coating is 100 percent solids and

has no loss of volume due to evaporation of solvent.60
2-24

There are, however, several real limitations to the use of

radiation-curable systems. The extent of cure penetration can be a

problem if the coating is very thick or heavily pigmented.61 Because

low viscosity solvents are not used, application of the relatively

higher viscosity radiation-cured coatings can be problematic; this

factor is less important in the application to web substrates than in

spray coating.62 Also, skin contact with UV-cured coatings should be

minimized by the use of gloves because of the potential for

irritation and/or allergic reaction with the use of these coatings.63

This is especially true when cleaning is performed, since the

combination of cleaning solvents and inks and coatings increases

dramatically the level of irritation to the skin.64

2.3 INDUSTRY PROFILE

The POWC industry includes the manufacture of a wide range of

products. Table 2-2 presents a listing of 18 Standard Industrial

Classification codes (SIC) codes for industries that include products

or processes that are likely to be manufactured or used,

respectively, by the POWC industry. As shown in the table, the POWC

industry is thought to encompass a large number of SIC codes. 

However, there may be facilities operating under other SIC codes not

included in Table 2-2 that also apply coating to web substrates, such

as paper, plastic, film, foil, and foam. In addition, all facilities

operating under these SIC codes are not necessarily members of this

source category; many of the 18 SIC codes cover only one or two

products that are manufactured with web coating. Some of the 18 SIC

codes include facilities that primarily print rather than coat the

substrate, that may choose to cover their limited coating operations

under the printing and publishing NESHAP. Consequently, while the

list of SIC codes presented in Table 2-2 can serve as a guide to

identifying many of the facilities in the POWC industry, it should 
2-25

Table 2-2. The 18 SIC Codes of the Paper 

and Other Web Coating Industry

SIC Code Description

2653 Corrugated and solid fiber boxes

2657 Folding paper board boxes, including sanitary

2671 Packaging paper and plastics film, coated and

laminated

2672 Coated and laminated paper, not elsewhere

classified

2673 Plastics, foil, and coated paper bags

2674 Bags: uncoated paper and multi wall

2675 Die-cut paper and paperboard and cardboard

2679 Converted paper and paper board, not elsewhere

classified

2754 Commercial printing, gravure

2761 Manifold business forms

3074 Plastic aseptic packaging

3081 Unsupported plastics film and sheet

3083 Laminated plastics plate, sheet, and profile

shapes

3291 Abrasive products

3497 Laminated aluminum (metal) foil and leaf,

flexible packaging

3861 Photographic equipment and supplies

3955 Carbon paper and inked ribbons

3996 Linoleum, asphalted-felt-base, and other hard

surface floor coverings, not elsewhere

classified

Note: There are likely a number of facilities in each SIC that do not do

coating and these 18 SIC’s are not necessarily an exhaustive list of

facilities that may do coating. 
2-26

not be used to completely define the industries subject to the POWC

NESHAP.

Based on emissions estimates from the Toxic Release Inventory

(TRI) system65 for these SIC’s, the POWC data gathering efforts

focused on the four largest segments of the POWC industry that were

defined by their product and process types: pressure-sensitive tapes

and labels (SIC 2672), flexible vinyl (SIC 3081), photographic film

(SIC 3861), and decorative and industrial

laminates (SIC 3083). Therefore, much of the information in this

section focuses on these four industry segments. A fifth segment,

called “Miscellaneous Coating,” is also discussed that includes a

number of industries that are identifiable as having some web coating

operations associated with their product manufacturing, such as those

facilities that do both printing and coating.

Within 1996 TRI data for the 18 POWC SIC's, the four major POWC

SIC's (2672, 3081, 3861, 3083) had the greatest percentages 

of major source HAP emissions, and together represent 79 percent of

the TRI emissions and 82 percent of the facilities (if the six

Printing and Publishing SIC codes are excluded from the analysis). 

The POWC data gathering efforts focused on identifying the

activities within the major industry segments that generated HAP and

on variations in the coating processes and control techniques. It

was found that the web coating operations (described in Section 2.2)

and control techniques (described in

Chapter 3) do not vary significantly among the segments of the POWC

industry. 

Most segments of the industry have some operations that are

unique to those segments. The discussion below includes information

on the types of coatings and coating applicators used by each major

segment, and the primary HAP emitted by each industry segment. It
2-27

also includes a discussion of operations that are specific to each

industry segment. 

2.3.1 Pressure-sensitive Tapes and Labels

The pressure-sensitive tape and label industry segment is one

of the largest segments of the POWC industries, based on 1996 TRI

emissions.66 It includes the manufacture of all types of tapes and

labels, including masking tape, strapping tape, duct tape,

transparent tape, electrical tape, and medical tapes and labels. It

also includes the manufacture of metallized labels and self-adhesive

labels.67 Demand for pressure-sensitive labels has increased as the

demand for glue-applied labels has decreased. One pressure sensitive

label product, blank roll labels (such as for computer data

processing), is viewed as a fast-growing label market. As of 1989,

pressure-sensitive labels accounted for as much as 22 percent of all

labels.68

Survey responses from the pressure-sensitive tapes and labels

industry segment, showed that in terms of primary products, bonding

and mounting tapes and labels were reported most often (18 percent),

with carton sealing, abrasion resistant, and application/pre-mask

tapes and/or labels next highest (at 12, 10, and 10 percent,

respectively).69 Table 2-3 shows the 29 primary products listed in

the pressure-sensitive tapes and labels survey responses.70

In a survey conducted by the Pressure Sensitive Tape Council in

1994, 39 percent of the responding facilities indicated they

manufactured film tape, 25 percent label stock, 15 percent paper

tape, 5 percent cloth tape, 2 percent filament tape, and 15 percent

other types of tape.71 Backing materials (substrates) used by the

pressure-sensitive tape and label industry segment include paper, a

variety of films, foam, metal foil, and fabric. Medical tapes and

duct tapes are made with fabric backings.72
2-28

Table 2-3. Primary Products of the Pressure-sensitive 

Tapes and Labels Survey Respondents

Primary Product

Percent of 

Respondents

bonding and mounting 18

carton sealing 12

abrasion resistant 10

application/pre-mask 10

double side 9

identification/safety, warning 4

anti-skid 3

anti-stick 3

book binding 3

bundling 3

label 3

coated textile for care labels 1

correction/cover-up 1

electrical 1

electronic applications 1

fastening 1

freezer 1

office/stationery 1

packaging 1

printable 1

protective - long term 1

pressure-sensitive adhesive-coated films 1

silicone 1

specialty fabric tapes 1

surface protection 1

trainer tapes - cotton based 1

transfer 1

vibration/sound damping 1

vinyl graphics film 1

Total 100
2-29

2.3.1.1 Baseline Emissions. In the POWC data gathering

effort, information was collected from 91 facilities in the pressuresensitive tapes and labels industry segment, of which 44 were

determined to be major sources of HAP. The total number of

facilities and HAP emissions in the pressure-sensitive tapes and

labels industry segment were estimated to be 96 facilities and

8,063 tons per year (tpy) HAP emissions, representing 22 percent

of the total number of facilities and 17 percent of total HAP

emissions estimated for the POWC source category.73 

The total number of major sources and HAP emissions in the

pressure-sensitive tapes and labels industry segment were 

estimated to be 47 facilities and 7,780 tpy HAP emissions,

representing 11 percent of the total number of facilities and 

16 percent of the total HAP emissions estimated for the POWC source

category.

The primary HAP emitted by the pressure-sensitive tapes and

labels industry segment are toluene, xylene, methyl ethyl ketone, and

methanol. 

2.3.1.2 Types of Coatings and Applicators Used. The pressuresensitive tape and label industry segment primarily uses five

classes of coatings: adhesives; release coatings; primers; coloring

agents; and saturants. Adhesives are used on all pressure-sensitive

tapes and labels. 

The pressure-sensitive tape and label industry segment uses a

range of coating formulations. According to a survey conducted by

the Pressure Sensitive Tape Council,74 84 percent of the facilities

responding to the survey indicate they used solventborne coatings,

60 percent waterborne coatings, 43 percent hot-melts, 13 percent

calendered adhesives, 8 percent radiation- cured coatings, 8 percent
2-30

two-part reactive coatings, and 6 percent other types of coating

formulations. 

Solventborne coatings are used as adhesives, release coatings,

primers, coloring agents, and saturants. They can also be used on

all types of backing materials. For some applications--particularly

special purpose applications requiring high performance from the

adhesive, or applications where the tape is exposed to extreme

environmental conditions--solventborne coatings are often the only

coatings available that can achieve the performance and durability

required.

Waterborne coatings are also used by the pressure-sensitive

tape and label industry segment for adhesives and release coatings. 

Waterborne adhesives are comparable in performance to many

solventborne adhesives. They are currently being used for many

applications within the industry segment and, as technology continues

to improve, the number of waterborne coating applications in the

pressure-sensitive tapes and labels industry should increase. In

some applications where high performance is required or in extreme

environmental conditions, solventborne adhesives may still be

required, but eventually waterborne adhesives may also be able to be

used for these applications. Drawbacks of using water-based

adhesives may include what one company75 found was that waterbased

adhesives need closer control of process variables and coater

conditions, which can lower line speeds and raise cost to the

consumer. Waterbased adhesives are thought to be more suited to

gravure or slot die coating application techniques than reverse roll

in this aspect. Clean-up operations are also reportedly more

difficult with waterbased adhesives. In addition, waterbased

adhesive-coated products may need to be remoisturized after drying to
2-31

reduce curl and to ease laminating, top coating, and finishing

operations.

Waterbased release coatings are already being used extensively

by the pressure-sensitive tape and label industry segment.76 In most

cases, the performance of the release coating is not as critical as

that of the adhesive, so the pressure-sensitive tape and label

industry segment has made more progress in converting to waterborne

release coatings.

Hot-melt coatings, especially, adhesives, are used extensively

by the pressure-sensitive tape and label industry segment.77 Hotmelt coatings are generally considered to be 100 percent solids, and

essentially pollution free. The POWC survey responses indicate that

of the 21 coatings identified as hot-melt adhesives, 17 were 100

percent solids.78 The remaining four hot-melt adhesive coatings had

solids contents ranging from 99.90 to 99.96 percent. Only one of

these four, however, contained any HAP (naphthalene), at a

concentration of 0.04 weight percent.

Although hot-melt adhesives are solvent-free, the possibility

exists for the evaporative loss of some of the lighter components in

the coating formulation. Most of the applicable coatings are high

molecular weight polymers, which may contain trace amounts of

unreacted monomers and/or low molecular weight polymers. Some of

these may be volatilized at the coating temperatures experienced in

hot-melt coating operations. The EPA conducted limited tests to

measure evaporative losses from hot-melt coatings. Weight losses of

from 0.1 to 12.6 percent occurred.79

The types of coating applicators used by survey recipients in

the pressure-sensitive tapes and labels industry segment are shown in

Table 2-4.80 This table shows that 33 percent of the coating

stations in the pressure-sensitive tapes and labels survey industry 
2-32

Table 2-4. Types of Coating Applicators Used by Survey

Respondents in the Pressure-sensitive Tapes and 

Labels Industry Segment

Application Method

Percentage of 

Application Stations

Gravure 33

Roll, Reverse Roll 26

Slot Die 12

Mayer Rod 11

Knife 9

Flexography 4

Extrusion/calendering 3

Dip 1

Flow 1

Total 100

Note: Seventy-five percent of the flexography coating stations are

flexography printing.

segment use gravure coaters, 26 percent use roll and/or reverse roll,

12 percent use slot die, and 11 percent use Mayer rod, with the

remaining 19 percent of the stations using five other applicator

types.

2.3.1.3 Pressure-sensitive Tapes and Labels Coating Process. 

The coating of pressure sensitive tapes and labels is called a

“converting” operation, in which some backing material (paper, 

cloth, cellophane, etc.) is coated one or more times to create a tape

or label that will stick on contact for the consumer’s purposes. In

the pressure-sensitive tape process, the web is unrolled, coated,

dried, chilled, and then rolled up. The coating processes may add

pre-coats, adhesives, or release coatings.81
2-33

Each pressure sensitive tape and label coating line typically

undergoes a minimum of two coating operations. These 

may be done separately on discrete coating lines, or a single 

tandem coating line may be used where the web undergoes a sequence of

coating and drying steps without being rewound between steps. Tandem

coating lines are usually used for large volume products with

relatively long runs times, since the flexibility of a coating line

is reduced with a tandem set-up.82

With most pressure-sensitive tapes and labels, release coatings

are applied to the backside of the tape or the mounting paper for

labels. The labels may be pre-printed. The function of the release

coating is to allow smooth and easy unrolling of the tape or removal

of the label from the mounting paper. In some cases, primers are

applied to the backing material before the adhesive is applied. The

primer improves the bond between the backing material and the

adhesive. Coloring agents may be coated onto the backing or in some

cases may saturate the backing for decorative purposes. For some

applications, the backing may be saturated with various materials to

modify the properties of the backing. For example, a paper backing

may be saturated with synthetic rubber to increase its tensile

strength and flexibility.

2.3.2 Flexible Vinyl

This segment of the POWC industry includes facilities

manufacturing a range of products from flexible vinyl. Polyvinyl

chloride (PVC) is the primary substrate used to manufacture flexible

vinyl products. Products manufactured by the flexible vinyl products

industry segment include wall coverings, automotive upholstery,

furniture upholstery, tablecloths, luggage, and shower curtains.83

Most products are manufactured from PVC film supported by fabric,

paper, or foam. The PVC is used as a substrate and as a dispersion
2-34

coating layer in the manufacture of wall coverings. Unsupported

vinyl products include shower curtain liners, pool liners, and some

window shades.84

According to an estimate by the Gravure Association of America,

nearly 50 percent of the 1981 value of supported vinyl products was

attributable to wall coverings. According to the Adhesives and

Sealant Council, more than 75 percent of residential wall coverings

are pre-pasted strippable products. Another 20 percent are fabricbacked vinyl, and the remaining 5 percent are specialty items

(metallics, grass cloth, rice paper, or other unusual substrates).85

Production of vinyl products has been declining since the 1980s,

especially for automotive upholstery and trim. A further decline in

automotive vinyls production is likely.86

In the responses to the EPA POWC survey, among 47 flexible

vinyl segment facilities, 38 percent indicated that they perform

substrate formation at their facility. 

2.3.2.1 Baseline Emissions. In the POWC data gathering effort,

information was collected from 47 facilities in the flexible vinyl

industry segment, of which 20 were determined to be major sources of

HAP’s. The total number of facilities and HAP emissions in the

flexible vinyl industry segment were estimated to be 112 facilities

and 13,878 tpy HAP emissions, representing 26 percent of the

facilities and 28 percent of the total HAP emissions estimated for

the POWC source category.87 

The total number of major sources and HAP emissions in the

flexible vinyl industry segment were estimated to be 49 facilities

and 13,257 tpy HAP emissions, representing 11 percent of the total

facilities and 27 percent of the total HAP emissions estimated for

the POWC source category.88 
2-35

2.3.2.2 Types of Coatings and Applicators Used. The flexible

vinyl industry segment primarily uses a number of functional types of

coatings: base coats, primers, topcoats, photo-reactive, laminating

(for support), adhesion, and substrate forming. The flexible vinyl

industry segment uses a range of coating formulations: solventborne,

waterborne, hot melt, and UV-cured.

Solventborne, waterborne, and high-solids coatings are used for

laminating flexible vinyl products where adhesives are required. 

However, in some cases, an adhesive is not used for bonding the vinyl

to fabric; instead, the vinyl sheet is bonded to the fabric by either

compression between two rollers or by casting directly onto the

fabric.

The use of waterborne and high-solids primers and topcoats is

still limited in the flexible vinyl industry. For example,

waterborne topcoats cannot be used for automotive parts such as

dashboards and vinyl roofs that are exposed to the sun as they do

not provide the same resistance to ultraviolet light as solventborne

topcoats.89,90 Most of the coatings and inks used to coat a PVC web

are solvent solutions of vinyl chloride/vinyl acetate copolymers and

PVC resins. A typical ink or coating used in the manufacture of

flexible vinyl products is 85 percent solvent and 15 percent

solids.91 

The types of coating applicators used by survey recipients in

the flexible vinyl industry segment are shown in Table 2-5.92 

Table 2-5 shows that for the flexible vinyl industry segment,

40 percent of the coating stations used gravure coating, 20 percent

used flexographic coating, 11 percent use knife or air knife,

9 percent used a roll or reverse roll coater, and 7 percent used

rotary screen coating. The remaining 13 percent 
2-36

Table 2-5. Types of Coating Applicators Used by Survey 

 Respondents in the Flexible Vinyl Film Industry Segment 

Application Method

Percentage of

Application Stations

Gravure 40

Flexography 20

Knife/Air Knife 11

Roll/Reverse Roll 9

Rotary screen 7

Dip 3

Die 3

Mayer Rod 3

Othera 4

Total 100

a Including flow coater, spray, squeeze, calender, and electrostatic.

are distributed among ten different coating application types.

2.3.2.3 Flexible Vinyl Coating Process. The process used to

produce flexible vinyl products consists of web formation, finishing

(which may include both printing and coating), and embossing. 

The vinyl web formation process consists of vinyl coating

preparation, vinyl coating formation or application to the web, and,

in some cases, expansion of the web. Vinyl substrates are formed by

calendaring, extruding, casting, and knife/roll 

coating.93 All except knife/roll coating use plasticizers, which

improve the flexibility of the coating/material. 

Extruding, calendaring, and knife/roll coating techniques were

discussed above in Section 2.2.2. In the casting process, a vinyl

web is cast or coated onto a paper carrier web using roll coating or

knife coating. This paper is ultimately removed and reused. The

vinyl web surface next to the paper becomes the finished product
2-37

surface. The paper carrier may impart a mirror-like finish or a

textured surface to the vinyl web.

Most resins used in vinyl web formation are composed primarily

of polymers of high molecular weight. These polymers are generally

not volatile, and, therefore, VOC and HAP emissions are negligible.94

Traces of solvent may be emitted from the ovens; some of these vapors

are captured by the ovens and controlled. 

The emissions from vinyl web formation are mostly high

molecular weight organic compounds which condense into aerosols. 

These compounds are primarily vaporized plasticizers from the heated

materials as it is blended, mixed, conveyed, calendared, and cooled. 

Some of these plasticizers may be HAP. The compound DEEP, which is a

HAP, is often used as a plasticizer. For the reasons discussed

above, emissions from vinyl web formation processes, which are

primarily aerosol, were not considered in the flexible vinyl NSPS.95

In the POWC survey responses, HAP emissions were zero or low in

substrate formation in the flexible vinyl industry.96 

The primer used in the flexible vinyl industry provides an

extra-smooth surface for the printing step which often follows. 

After primer application, the web may be printed, and then a final

topcoat is applied. The topcoat provides protection against wear.

Flexible vinyl products are sometimes embossed to improve their

appearance or wearability. Most flexible vinyl substrates are

embossed as part of the finishing operation that may include

laminating or printing. The exception is calendared products, which

are embossed as they exit the calendar. The embossing line consists

of a support roller and an embossing cylinder. The image pattern is

formed in the surface of the cylinder by mechanical or chemical

means. The web is heated and continuously drawn between the
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embossing and supporting rollers. As it passes through the cooled

roller, the image or pattern is set in the hot web surface.97

Volatile emissions from the process of embossing are likely to

be relatively low. The emissions from the embossing process depend

primarily on the type of material and coatings on the web being

heated. In embossing of a newly-calendared flexible vinyl substrate,

the emissions are high molecular weight organic compounds which

condense as they exit the stack gases. These emissions are primarily

plasticizers from the heated web. Based on information collected by

the EPA from 100 plants in 1980, aerosol emissions from the embossing

operation of an average plant were estimated to by 8 tpy; VOC

emissions from embossing were estimated to be 10 tpy, or 1.3 percent

of the total plant VOC emissions.98

A PVC web may be coated, printed, or both. Both coating and

printing are typically done with gravure coaters. In the production

of vinyl products, printing, coating, embossing, and other finishing

processes are almost always performed on a single line (often

referred to as "imaging equipment"). Some products are printed by

flexography or screen printing and then coated by gravure.99 In the

manufacture of flexible vinyl products, there is little distinction

between the printing and coating operations.

2.3.3 Photographic Film

The photographic film industry segment manufactures film for

diverse products such as still cameras and moving pictures,

microfiche film, x-ray film, intensifying screens, and decorative

window coverings.100 Both cellulose acetate film and polyester film

are used for photographic film, although cellulose acetate is used

more than polyester. Facilities manufacturing photographic film may

also coat paper for use as photographic paper or as backing material

for photographic film.101 These facilities may also coat some
2-39

pressure-sensitive tape, which is used at the end of a film roll to

hold the roll in place.

In the responses to the EPA POWC survey, among the

15 facilities that responded in the photographic film industry

segment, 20 percent reported that they perform film substrate

formation on site. 

2.3.3.1 Baseline Emissions. In the POWC data gathering effort,

information was collected from 15 facilities in the photographic film

industry segment, of which 11 were determined to be major sources of

HAP’s.102 

The total number of facilities and HAP emissions in the

photographic film industry segment were estimated to be 36 facilities

and 5,306 tpy HAP emissions, representing 8 percent of the total

facilities and 11 percent of the total HAP emissions estimated for

the POWC source category.103 The total number of major sources in the

photographic film industry segment were estimated to be 27 facilities

and 5,254 tpy HAP emissions, representing 6 percent of the total

facilities and approximately 11 percent of the total HAP emissions

estimated for the POWC source category.

The primary HAP’s emitted by the (photographic) film

manufacturing industry segment are methyl ethyl ketone, methylene

chloride, and methanol. Methylene chloride is primarily emitted from

the formation and coating of cellulose acetate film and polyester

film.104

2.3.3.2 Types of Coatings and Applicators Used. The photographic

film industry segment primarily uses a number of functional types of

coatings: base coats, primers, topcoats, photo-reactive, laminating

(for support), adhesion, and substrate forming. The photographic

film industry segment uses a range of coating formulations:

solventborne, waterborne, hot melt, and UV-cured.
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The base coatings, or sublayers, of photographic film are

typically solventborne coatings. These coatings act as an antistatic

and provide lubricity. The coatings are formulated with a number of

solvents, but methanol is the most commonly used solvent.105 Some

formaldehyde and dimethyl formamide are also used.106 The number of

layers of photosensitization materials that are applied varies

according to the complexity of the film. Twelve or more layers may

be applied to the more complex films.107 Unlike most coating

processes, multiple layers may be applied simultaneously at the same

coating station to photographic film. At some facilities, multiple

waterbased coating layers are applied at the same station. The

coatings do not mix because each coating has a different viscosity.108

All coating of photosensitization materials is done in the absence of

light.109 The coatings used in the photosensitization process are

waterborne emulsions. Some of these coatings may contain small

concentrations of methanol, but water is the primary solvent.

In coatings used for x-rays and intensifying screens, acetone

(not a HAP), methylene chloride, and methanol are the primary

solvents.110 As with photographic film production, waterborne

coatings are used in the photosensitization coating process. 

The types of coating applicators used by survey recipients in

the photographic film industry segment are shown in 

Table 2-6.111 Table 2-6 shows that for the photographic film industry

segment, 44 percent of the coating stations used a die, 28 percent

used roll or reverse roll coating, 12 percent used gravure coating. 

The remaining 16 percent are distributed among four different coating

application types.

2.3.3.3 Photographic Film Coating Process. The coating process

for photographic film is similar to that for other segments of the

industry. The web is unwound, coated, and then rewound. However, 
2-41

Table 2-6. Types of Coating Applicators Used by Survey Respondents in

the Photographic Film Industry Segment

Application Method

Percentage of

Application Stations

Die 44

Roll/reverse roll 28

Gravure 12

Knife/Air knife 11

Mayer Rod 2

Calender 2

Flow 1

Total 100

different types of coatings may be applied on different lines. For

example, base coatings are applied on one line, and the web is then

rewound and moved to another line where the web is unwound, coated

with photosensitization materials, and then rewound. The coating

process for x-rays and for intensifying screens, which are often used

in place of the traditional x-rays, is similar to that for

photographic film. The intensifying screens are first coated with

three types of solventborne coatings overcoat for protection; and an

anti-curl layer. The substrate is then rewound and transferred to

another line for the application of the photosensitization

materials.112 

Some film facilities manufacture their film onsite. In the

formation of cellulose acetose film, cellulose acetate is dissolved

in methylene chloride and cast onto a wheel. As the methylene

chloride is driven off, this wheel becomes the unwind reel for the

coating line. The formed film is unwound from the wheel, coated, and

then rewound; therefore, formation of the substrate can be considered

a part of the coating line, as in vinyl film formation.113 Film
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formation itself is not likely to be a significant source of HAP

emissions at film manufacturing facilities. In the POWC survey

responses, facilities had little or no HAP emissions solely from the

formation of the film.114

2.3.4 Decorative and Industrial Laminates

Decorative laminates provide an aesthetically pleasing surface

used in products such as kitchen counter tops, and store display

shelving. Laminates may also be used in the manufacture of such

products as floor coverings and finished particle boards.115

Industrial laminates provide a functional surface with special

properties such as fire, electrical, or chemical resistance,116 and

are used to manufacture products such as rigid laminates used in

furniture manufacturing, interior building construction, printed

wiring board (PWB) blanks, industrial tubes, yoke bars, and molded

bearings. Flexible laminates are a type of laminate that is

bendable, often in cable form, and is used by some electronics

manufacturers in automobiles, computers, and radios. 

Laminate production facilities may also manufacture adhesives,

release coatings, and resins. These facilities may also perform

coating operations for production of release paper and printing

operations for production of the decorative paper.

Sources of HAP emissions from the manufacture of decorative and

industrial laminates include mixing/compounding, coating, drying,

curing, pressing, and finishing operations; however, the predominant

emission points are from coating, drying, and curing.

2.3.4.1 Baseline Emissions. In the POWC data gathering effort,117

information was collected from 41 facilities in the decorative and

industrial laminates industry segment, of which 17 were determined to

be major sources of HAP’s. The total number of facilities and HAP

emissions in the decorative and industrial laminates industry segment
2-43

were estimated to be 68 facilities and 8,798 tpy HAP emissions,

representing 16 percent of the total facilities and 18 percent of the

total HAP emissions estimated for the POWC source category.118 The

total number of major sources and HAP emissions in the decorative and

industrial laminates industry segment were estimated to be 28

facilities and 8,489 tpy HAP emissions, representing 7 percent of the

total facilities and 17 percent of the total HAP emissions estimated

for the POWC source category.119

The primary HAP emitted by the decorative and industrial

laminates industry segment are methanol, phenol, and toluene. 

Although release coatings in the past contained chromium, the POWC

survey responses indicate this may no longer be true.120

2.3.4.2 Types of Coatings and Applicators Used. The decorative

and industrial laminates industry segment uses many functional types

of coatings: primers, topcoats, lacquers, substrate forming,

laminating, fire resisting, chemical resisting, releasing,

decorative, and saturating. The coating formulations used are:

solventborne, reactive (resins), release coats, and adhesives.121

Resins used in the laminating process include epoxy, melamine,

phenol-formaldehyde, polyester, polyvinyl acetate (PVAC), polyvinyl

acrylate (PVA), silicone, styrene-formaldehyde, and ureaformaldehyde.122,123,124,125 Laminate producers generally distinguish

resins from adhesives by defining a resin as a substance that

impregnates or saturates the substrate, while an adhesive is a

substance applied to the substrate surface.126 The HAP emitted in

largest amounts are methanol, phenol, and formaldehyde.

The types of coating applicators used by survey recipients in

the decorative and industrial laminates industry segment are shown in

Table 2-7.127 This table shows that 36 percent of the coating 
2-44

Table 2-7. Types of Coating Applicators Used by Survey Respondents

in the Decorative and Industrial 

Laminates Industry Segment

Application Method

Percentage of 

Application Stations

Dip 36

Gravure 34

Roll, Reverse Roll 20

Mayer Rod 5

Knife 5

Total 100

stations are dip, 34 percent are gravure, and 20 percent are roll

and/or reverse roll, with the remaining stations being 

Mayer rod and knife applicators (5 percent of the stations, each).

2.3.4.3 Decorative and Industrial Laminate Coating Process. 

In the manufacture of the decorative and industrial laminates,

the first operation is known as "compounding," and involves

activation of the resins by mixing together precise amounts of the

varnish components in a batch tank. This compounding process is

referred to as the “A-stage.” The amount of each component used is

generally controlled by weight; and precise adherence to specified

amounts, temperatures, mixing times, and sequence is necessary for a

good quality resin. At this point, the varnish is held for a

digestion period so the reactivity can stabilize it to a consistent

and prescribed level appropriate to the next operation.128

After the digestion period, web substrates (e.g., paper or

woven fiberglass) are loaded on the coating line (or treater). 

The web is dipped into a resin tank equipped with metering apparatus,

and then to an oven to evaporate the solvent and achieve partial cure

of the resin. This process is called the “B-stage.” Any decorative

or overlay paper used in the product is also treated in the B-stage,
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usually by impregnation with resins. Release paper used in the

product, if not purchased pre-coated, is dip coated in the B-stage as

well.129

The next stage, or “C-stage” is a press lamination operation. 

First, some B-stage products are cut into sheets, and then multiple

plies of the sheets are collated according to the ultimate core

thickness. With decorative laminates, a decorative overlay (printed

or solid pigmented pattern sheet) is also added used. The laminate

may also include layers of release paper (paper treated with a

release coating) applied during pressing. The release paper allows

separation of layers after pressing, so that several sheets of

laminate can be produced together. Alternatively, some B-stage

products are left uncut to produce continuous laminates. The C-stage

operations are done in batch pressings.130 

The collated laminates are then laid between press plates with

copper foil on the surface of the stack. These "books" or packages

of laminates undergo high temperature and pressure pressing to cure

it to its final form. High-pressure laminates are subject to

pressures of between 1,000 and 1,400 pounds per square inch (psi)

during manufacture.131

After the pressed books are removed from the C-stage press,

they are transported to a tear down station where the laminate is

separated from the press plates. Continuous laminates can be rolled

at this point, but only into large-diameter rolls. The C-stage

products from PWB manufacture may be left in a roll and sold as prepreg bonding;132 it may undergo additional lamination at other

facilities to produce multilayer laminate.133 Other C-stage products

may undergo several finishing steps to prepare them for shipment. 

Preparation for delivery includes labeling and packaging.134
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Laminates are also produced by application of an adhesivecoated roll of paper or vinyl film to panel substrate. The paper or

vinyl film is unwound, coated with a liquid adhesive, and then

combined with a substrate at a combining station. The substrate may

be panels of particle board, fiberboard, hardboard, etc., fed into

the line continuously end to end. Following lamination, the panels

are individually stacked. 

The flexible laminate manufacturing process is somewhat

different than that used by rigid laminate manufacturers. Generally,

flexible laminate manufacturers purchase the plastic substrate, which

is manufactured elsewhere, and use adhesive to attach copper foil. 

The adhesive application process is performed on a web, and often the

shipped product is still in a web form when it is delivered to the

circuit board manufacturer. 

2.3.5 Miscellaneous Coating Industries

This industry segment was created primarily to represent the

remaining sectors of the POWC, such as the major subsectors of

abrasive coating, specialty coaters that coat paper to customer

specifications as it is obtained from paper manufacturers, and

rotogravure and wide-web flexography coating (primarily in the

packaging and product subdivision that produces flexible packaging

for food). Other, minor subsectors of the POWC industry produce the

following products: corrugated and solid fiber boxes; folding

paperboard boxes, including sanitary; die-cut paper and paperboard

and cardboard; converted paper and paperboard, not elsewhere

classified; manifold business forms and related products; plastic

aseptic packaging; and carbon paper and inked ribbons. Because

rotogravure and wide-web flexographic coating has been previously

researched and studied under the printing and publishing NESHAP, this

subsector is not further discussed here.135
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The 1996 TRI emissions for the Miscellaneous POWC industries

are shown in Table 2-8. From the information in Table 2-8, it can be

seen that the abrasives products subsector has the greatest number of

facilities among this group (at 32 percent), and the converted paper

and paperboard products not elsewhere classified (gift wrap, paper

wall paper, cigarette paper) subsector has the highest per-facility

emissions (86 tpy) and highest portion of the emissions (42 percent).

2.3.5.1 Baseline Emissions. Using TRI data from 1996 for SIC

codes 2653, 2657, 2675, 2679, 2761, 3074, 3291, and 3955, the total

number of facilities and HAP emissions in the miscellaneous industry

segment were estimated to be 117 facilities and 13,174 tpy HAP

emissions, representing 27 percent of the total facilities and 27

percent of the total HAP emissions estimated for the POWC source

category. The total number of major sources and HAP emissions in the

miscellaneous industry segment were estimated to be 52 facilities and

12,714 tpy HAP emissions, representing 12 percent of the total

facilities and 26 percent of the total HAP emissions estimated for

the POWC source category.136 2.3.5.2Abrasive Products. Many

abrasive products such as sandpaper are coated products. Paper,

film, cloth, and heavy fiber are all substrates used in the

manufacture of abrasive products. In particular, the use of films,

especially polyester films, is growing. If cloth is used as an

abrasive product substrate, the cloth is pretreated to give it body;

abrasive cloths are called finishing cloths.137

The coating process for abrasive products includes up to three

coatings that are applied to the substrate. For a cloth abrasive, a

seal coat is applied to the cloth. An adhesive coating is then

applied to bind the abrasive to the substrate. The abrasive is 
2-48

Table 2-8. 1996 TRI Facilities and Emissions for the

Miscellaneous POWC Industry Segment(a)

SIC INDUSTRY DESCRIPTION (b)

Number

of

TRI 

Facilities 

Percent

of TRI

Facilities

TRI

Emissions

(tpy)

Percent 

of TRI

Emissions

Per

Facility

Emissions

(tpy)

2679 Misc. Converted Paper ProductsConverted paper and paperboard products,

nec (gift wrap, paper wall paper,

cigarette paper)

38 27% 3,282 42% 86

2653 Paperboard Containers and BoxesCorrugated and solid fiber boxes 19 13% 1,576 20% 83

3291 Misc. Nonmetallic Mineral

Products

Abrasive products 46 32% 1,422 18% 31

2761 Printing and Publishing Manifold business forms 16 11% 847 11% 53

2657 Paperboard Containers and BoxesFolding paperboard boxes, including

sanitary

17 12% 336 4% 20

3955 Pens, Pencils, Office, & Art

Supplies

Carbon paper and inked ribbons 6 4% 272 3% 45

2675 Misc. Converted Paper ProductsDie-cut paper and board 1 1% 81 1% 81

3074 Plastic aseptic packaging 0 0% 0 0% 0

Total 143 7,816

(a) Data is taken directly from TRI and does not account for facilities reporting under multiple SIC codes.

(b) nec = not elsewhere classified.
2-49

applied, and, in some cases, another protective coating is applied

over the abrasive. Adhesives are applied with a roll coater, while

the abrasive is typically applied electrostatically. For some

applications, a pressure-sensitive adhesive backing is applied to the

abrasive product. Printing is also used with abrasives manufacturing

to place the company name on the back of products that include

sandpaper. Grit is applied/printed onto the sandpaper backing with a

flexography roller.138

Most of the coatings and adhesives used by the abrasive

products industry segment are waterborne. Some special purpose

products may still require solventborne coatings and adhesives, but

even these are being reformulated to waterborne. UV-cured coatings

are used in the manufacture of ophthalmic abrasives, that are used to

grind ophthalmic lenses. This product is amenable to the UV process

because of the thinness of the substrate that allows for complete

penetration and curing of the coating by the UV radiation.139

A phenol-formaldehyde resin is used to bind the abrasive to the

substrate. These resins are a source of formaldehyde emissions

because they are formulated with excess formaldehyde. However, the

amount of excess formaldehyde has decreased dramatically over the

years. The resins used to contain as much as 20 percent excess

formaldehyde, but they now have less than 1 percent excess

formaldehyde.140 Phenol and formaldehyde are the primary HAP emitted

by the abrasive products industry segment. 

Based on 1996 TRI data for SIC 3291, the abrasive coating

industry subsector has 46 facilities and emits approximately

1,400 tpy HAP.141 The abrasive coating industry consists of only five

corporations (of which two are the primary participants), each having

facilities at multiple locations. The industry is represented by the

Coating Abrasives Manufacturing Industry (CAMI) trade association.142
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2.3.5.3 Specialty Paper Coating. The term “specialty coating”

evolved as a means to distinguish traditional paper manufacturers,

who use mostly waterbased coatings in the paper making process, from

those facilities (some closely associated with paper manufacturers)

that apply solventbased coatings to paper in order to generate

products, often for other paper converters who interface with the

customers (i.e., consumers or end users). Specialty coating, then,

connotes solvent-based web coating by the latter group of

facilities.143 Specialty-coated products may include some of the

products presented above in the discussion of the pressure-sensitive

tape and label, flexible vinyl, and photographic film industry

segments. However, what differentiates the subset of specialtycoated products from the broad class of web-coated products is the

great extent to which their manufacture depends on customer

specifications. 

The American Forest & Paper Association (AF&PA) represents the

majority of the members of the paper industry and has a constituency

of twelve companies classified as specialty coaters. Information in

this section is largely based on site visits to some of these

specialty coating facilities performed with the cooperation and

coordination of the AF&PA.

Specialty coaters coat paper, in grades varying from tissue

paper to heavy kraft paper, as well as paper/foil laminates,

polyester and other films, aluminum foil, vinyl, canvas and other

fabrics, and possibly other substrates. Specialty-coated products

and/or end-uses include thermal imaging papers (i.e., fax paper,

paper for register receipts), pressure-sensitive labels, microfilm

for data storage, graphic arts papers, paper for finished stationery

products (i.e., notepads, diaries), gift wrap (for sale to

distributors), electronic equipment, photography, and printed circuit
2-51

boards. Thus, as previously mentioned, specialty coated products are

not necessarily products absent from the other web coating industry

segments.

Specialty coating facilities are not necessarily small, with

some having over 10 coating lines. Facilities that conduct more

printing than coating may have longer setup and breakdown periods

than facilities that produce only a few products, because the print

plates are more likely to need to be switched out between different

product runs than coating lines, which can be dedicated to one type

of coating process applying a uniform layer across the web. 

The types of coating applicators used by the specialty coaters

include gravure, roll, rod, slot die, and knife. The types of

coatings include solventbased ,waterborne, UV-cured, and 100 percent

solids. The HAP’s used by specialty coaters include vinyl acetate,

methanol, toluene, glycol ethers, and methyl ethyl ketone (MEK).

Safety issues at specialty coating facilities arise with the

use of some low-HAP coatings, such as the need to use corona

dischargers (which generate ozone) to treat film surfaces before

applying waterbased coatings, and the allergic reactions in some

individuals as a result of working with 100 percent solids,

radiation-cured coatings. Technical issues with regard to replacing

solventborne coatings in specialty coating include the inability to

replace solventborne formulations for applications such as the

metallized coating of paper and the manufacture of microfilm, both of

which currently require solventbased coating chemistries.
2-52

2.4 REFERENCES

1. Docket No. A-99-09. U.S. Environmental Protection Agency,

Washington, DC. 1999. Responses from the paper and other web

coating NESHAP survey.

2. Reference 1.

3. Reference 1.

4. Profile Survey of the U.S. Gravure Industry. Gravure

Association of America, New York, New York. 1996.

5. Docket No. A-92-42. U.S. Environmental Protection Agency,

Washington, DC. 1995. Responses from the printing and

publishing NESHAP survey.

6. National Emission Standards for the Printing and Publishing

Industry. Title 40, Code of Federal Regulations, Part 63,

Subpart KK. U.S. Office of the Federal Register, Washington,

DC. May 1996.

7. National Emission Standards for Hazardous Air Pollutants:

Printing and Publishing Industry, Background Information for

Proposed Standards (EPA-453/R-95-002a). U.S. Environmental

Protection Agency, Research Triangle Park, North Carolina.

February 1995.

8. Reference 1.

9. Reference 1.

10. Source Category Survey Report for Paper, Film & Foil Converting

Industry (Draft). Radian Corporation, Research Triangle Park,

North Carolina. November 1984. p. 4-26.

11. Reference 1.

12. Reference 7, p. 2-19.

13. Reference 10, p. 4-48.

14. The Wiley Encyclopedia of Packaging Technology. Marilyn Bakker,

Ed. John Wiley and Sons, Inc., New York, New York, 1996. p.

189.
2-53

15. Reference 10, p. 4-63.

16. Control of Volatile Organic Compound Emissions from Existing

Stationary Sources - Volume II: Surface Coating of Cans,Coils,

Paper, Fabrics, Automobiles, and Light-duty Trucks (EPA-450/2-

77-008). U.S. Environmental Protection Agency, Research

Triangle Park, North Carolina. 1977. 

pp. 5-1, 5-28.

17. Documentation for Developing the Initial Source Category List

(EPA-450/3-91--030). U.S. Environmental Protection Agency,

Research Triangle Park, North Carolina. December 1991.

18. Reference 7.

19. Reference 10, p. 4-62. 

20. Printing Ink Handbook (fifth edition). National Association of

Printing Ink Manufacturers, Inc., Harrison, New York. 1998. p.

38.

21. Reference 7. 

22. Reference 10, p. 4-62.

23. Reference 14, p. 189.

24. Reference 10, p. 4-59.

25. Reference 10, p. 4-64.

25. Reference 10, p. 4-68.

26. Reference 4, p. INK-13.

27. Improved Equipment Cleaning in Coated and Laminated Substrate

Manufacturing Facilities (Phase I) (EPA-600/R-94-007). U.S.

Environmental Protection Agency, Research Triangle Park, North

Carolina. January 1994. p. 2-33.

28. Reference 10, p. 4-59.

29. Reference 10, p. 4-69.
2-54

30. Adapted From a graphic at http://www.

scana.com/sce&g/business_solutions/technology/ezirpca.htm.

Permission granted by Apogee Graphics - http://www.apogee.net.

31. Reference 27, p. 2-25.

32. Reference 27, pp. 2-25,2-28.

33. Reference 27, p. 2-28.

34. Compilation of Air Pollutant Emission Factors (AP-42). Volume I

(Fifth Edition). U.S. Environmental Protection Agency, Research

Triangle Park, North Carolina. January 1995. p. 4.2.2.9-3.

35. Reference 27, p. 2-29.

36. Reference 1.

37. Memorandum from Sutton, L., EC/R, Inc., Durham, North Carolina

to D. Brown, U.S. Environmental Protection Agency, Research

Triangle Park, North Carolina. December 2, 1998.Minutes of

October 13, 1998, meeting with the Pressure Sensitive Tape

Council.

38. Reference 37.

39. Reference 37.

40. Reference 27, p.2-7.

41. Reference 1.

42. Reference 10, p. 4-59.

43. EPA Test Method 24-Determination of Volatile Matter Content,

Water Content, Density, Volume Solids, and Weight Solids of

Surface Coatings. U.S. Office of the Federal Register,

Washington, DC. Code of Federal Regulations, Title 40, Chapter

1, Pt. 60, Appendix A. July 1, 1997. pp. 930-932.

44. Solvent-Based to Waterbased Adhesive-Coated Substrate Retrofit,

Volume II: Process Overview (EPA-600/R-95-Ollb) U.S.

Environmental Protection Agency, Research Triangle Park, North

Carolina. January 1995. p. 5-2.
2-55

45. Reference 10, p. 4-67.

46. Reference 44, p. 5-6.

47. Reference 10, p. 4-68.

48. New Source Performance Standards for the Pressure-sensitive

Tape and Label Surface Coating Industry, Background Information

for Proposed Standards (EPA-450/3-80-003a). U.S. Environmental

Protection Agency, Research Triangle Park, North Carolina.

September 1980. p. 3-29.

49. Reference 10, p. 4-68.

50. Reference 48.

51. Docket No. A-99-09. U.S. Environmental Protection Agency,

Washington, DC. February 14, 1997. Response to paper and other

web coating NESHAP survey from 3M Bedford Park, Bedford Park,

Illinois.

52. Reference 48, p. 3-31.

53. Memorandum from Bhatia, K., EC/R, Inc., Durham, North Carolina,

to D. Brown, U.S. Environmental Protection Agency, Research

Triangle Park, North Carolina. August 20, 1998. Coating

residual HAP data from decorative and industrial laminates

surveys.

54. Reference 34.

55. Radiation Curable Coatings (EPA-600/2-91-035; PB9l-219550) U.S.

Environmental Protection Agency, Control Technology Center,

Research Triangle Park, North Carolina. 1991.

56. Reference 55. 

57. Griese, E.W. UV, BE, and Aqueous Coatings: Technical Basics.

Graphic Arts Technical Foundation, Pittsburgh, Pennsylvania.

GAFF World Magazine. Vol. 10 (3). May/June 1998.

58. Reference 55.

59. Reference 55. 
2-56

60. Reference 55.

61. Reference 55.

62. Reference 55.

63. Reference 55.

64. Kershner, P. UV Flexo in the Label Industry--Equipment

Suppliers* Experiences: Issues in Implementing UV Flexo.

Presented at the “UV Flexo--The New Printing Technology for

Packaging and Labels” meeting, Chicago, Illinois. February 22

and 23, 1995.

65. Memorandum from Sutton, L., EC/R, Inc., Durham, North Carolina,

to D. Brown, U.S. Environmental Protection Agency, Research

Triangle park, North Carolina. December 14, 1998. Paper and

Other Web Coating NESHAP: Summary of toxic release inventory

data of 1996 for selected standard industrial classification

codes.

66. Reference 65. 

67. Reference 10, p. MAR-68.

68. Reference 10, p. MAR-71.

69. Reference 1. 

70. Reference 1.

71. Letter from Owens, T., MACtac, Stowe, Ohio, to D. Brown, U.S.

Environmental Protection Agency, Research Triangle Park, North

Carolina. July 3, 1996. Overheads used in meeting of April 23,

1996.

72. Reference 27, p. 2-7.

73. Memorandum from Jones, D., EC/R, Inc., Durham, Norht Carolina,

to D. Brown, U.S. Environmental Protection Agency, Research

Triangle Park, North Carolina. March 25, 1999. Paper and

other web coating national estimates. 

74. Reference 71, p. 4.
2-57

75. Reference 44, pp. 3-6 to 3-7.

76. Reference 71, p. 4.

77. Reference 48. 

78. Reference 1.

79. Reference 48.

80. Reference 1.

81. Reference 48.

82. Reference 1.

83. Reference 10, p. SUM-12.

84. Reference 10, p. MAR-93.

85. Reference 10, p. MAR-95.

86. Reference 10, p.MAR-117.

87. Reference 73. 

88. Reference 73.

89. Memorandum from Rasor, S., Midwest Research Institute, Cary,

North Carolina, to POWC Project File. Meeting minutes of June

27, 1996 meeting with Chemical Fabrics and Film Association

(CFFA) July 17, 1996. p. 2.

90. Flexible Vinyl Coating and Printing Operations Background

Information for Proposed Standards (EPA-450/3-81-016a). U.S.

Environmental Protection Agency, Research Triangle Park, North

Carolina. 1981. pp. 3-1 to 3-31.

91. Reference 90, pp. 3-1 to 3-31.

92. Reference 1. 

93. Reference 90, p. 3-5.

94. Reference 10, p. 4-68.
2-58

95. Reference 90, Ch. 3.

96. Reference 1. 

97. Reference 90, Ch.3

98. Reference 90, Ch. 3.

99. Reference 10, p. MAR-97.

100. Reference 1.

101. Memorandum from Shrager, B., Midwest Research Institute, Cary,

North Carolina, to D. Brown, U.S. Environmental Protection

Agency, Research Triangle Park, North Carolina. October 14,

1996. Report of July 16, 1996, site visit to Eastman Kodak

Company, Rochester, New York. p. 6.

102. Reference 1. 

103. Memorandum from Jones, D., EC/R, Inc., Durham, North Carolina,

to D. Brown, U.S. Environmental Protection Agency, Research

Triangle Park, North Carolina. March 25, 1999. Paper and other

web coating national estimates.

104. Memorandum from Shrager, B., Midwest Research Institute, Cary,

North Carolina, to D. Brown, U.S. Environmental Protection

Agency, Research Triangle Park, North Carolina. October 14,

1996. Report of July 16, 1996, site visit to Eastman Kodak

Company, Rochester, New York.

105. Reference 104, p. 4.

106. Reference 104, p. 5.

107. Reference 104, p. 5.

108. Reference 104, p. 5.

109. Reference 104, p. 5.

110. Reference 104, p. 6.

111. Reference 1.
2-59

112. Reference 104, p. 6.

113. Reference 104, p. 4.

114. Reference 1.

115. Memorandum from Sutton, L., EC/R, Inc., Durham, North Carolina,

to D. Brown, U.S. Environmental Protection Agency, Research

Triangle Park, North Carolina. July 21, 1997. Report of May 13,

1997, trip to Wilsonart International Inc., Fletcher, North

Carolina.

116. Reference 10, p. SUM-17.

117. Reference 1.

118. Reference 73. 

119. Reference 73. 

120. Reference 1.

121. Reference 1. 

122. Laminating Materials Association, Inc. Glossary printed out May

5, 1997, from computer website. Flat panel laminating

equipment.

123. Laminating Materials Association, Inc. Glossary printed out May

5, 1997, from computer website. Coating equipment.

124. Telecommunication. Dunston, W., U.S. Environmental Protection

Agency, Research Triangle Park, North Carolina with R.

Greenwood, Iten Industries, Ashtabula, Ohio. August 4, 1995.

125. Laminating Materials Association, Inc. Glossary printed out May

5, 1997, from computer website. Low pressure press.

126. Telecommunication. Sutton, L., EC/R, Inc., Durham, North

Carolina with G. Carter, Laminating Materials Association.

November 24, 1997.

127. Reference 1.
2-60

128. Docket No. A-95-52. U.S. Environmental Protection Agency,

Washington, DC. 1993. Letter to Bruce Jordan, U.S.

Environmental Protection Agency, from Allied Signal Laminate

Systems, Inc. Response to information request for the

reinforced plastics composites NESHAP.

129. Reference 115. 

130. Reference 128.

131. Laminating Materials Association, Inc. Glossary printed out May

5, 1997, from computer website. High pressure laminates.

132. Reference 128. 

133. Telecommunication. Caldwell, M.J., Caldwell Environmental,

Inc., Raleigh, North Carolina, with D. Talbot, GE

Electromaterials, Coshocton, OH. December 9, 1998. Circuit

board laminate manufacturing process.

134. Reference 128.

135. Reference 7. 

136. Reference 73. 

137. Telecommunication. Jones, D., EC/R, Inc., Durham, North

Carolina, with K. Fogarty, Norton, Inc., Worcester,

Massachusetts. November 25, 1998. CAMI*s interest in the POWC

NESHAP.

138. Reference 137.

139. Reference 137.

140. Reference 137.

141. Reference 73. 

142. Telecommunication. Jones, D., EC/R, Inc., Durham, North

Carolina, with S. Young, Coating Abrasives Manufacturing

Industry (CAMI), Cleveland, Ohio. November 17, 1997.

143. Memorandum from Bhatia, K., and D. Jones, EC/R, Inc., Durham,

North Carolina, to D. Brown, U.S. Environmental Protection
2-61

Agency, Research Triangle Park, North Carolina. March 15, 1999.

Summary of specialty coating operations derived from American

Forest & Paper Association trips.
2-62

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3-1

3.0 EMISSION CONTROL TECHNIQUES

3.1 INTRODUCTION

Emission control techniques applicable to the paper and other

web coatings (POWC) industry can be categorized as either:

(1) prevention of emissions (pollution prevention measures); or

(2) control of captured emissions by a control device. Sections 3.2

and 3.3 describe capture systems and control devices, respectively. 

Section 3.4 describes pollution prevention measures.

3.2 CAPTURE SYSTEMS

Capture systems are used in this industry to collect solventladen air containing HAP and direct it to a control device. Often,

facilities combine solvent-laden air captured from several coating

operations, each with its own capture method, and duct it to a single

control device. In heatset coating processes, solvent is removed

from the coated substrate by evaporation in a dryer. The exhaust

from the dryer can be easily ducted to a control device without

additional capture systems in place. Additional capture systems are

often used to collect fugitive emissions from solvents that evaporate

from other parts of the coating line, such as the coating application

and flash-off areas, and exhaust them to a vent or control device.

The design of the capture system, and the choice of control

devices, can greatly contribute to the overall HAP control

efficiency, which is a combination of both capture and control

efficiencies. 
3-2

Capture methods in use by the POWC industry are generally

either hoods or enclosures. They include canopy hoods, floor sweeps,

partial enclosure of coating stations, room enclosures, permanent

total enclosure (PTE), and ovens operated at negative pressure.1,2

Permanent total enclosures (which may include room enclosures) can

achieve 100 percent capture. A HAP capture efficiency of 100 percent

is assumed for systems meeting the EPA's criteria for PTEs described

in EPA test method 204. The other capture methods are not generally

associated with a specific capture efficiency. An efficient vapor

collection system will maximize the capture of fugitive emissions

while minimizing the capture of dilution air.

In responses to POWC surveys sent to the pressure-sensitive

tape and label (PST), flexible vinyl, photographic film, and

decorative and industrial laminates industry segments, estimates of

HAP capture ranged from zero to 100 percent capture, with the average

HAP capture efficiency per process greater than 90 percent for

operations with control devices.3

Capture systems can be improved to collect previously fugitive

solvent in the air surrounding coating lines by construction of

additional hooding and/or coating line enclosures. In theory,

capture can be improved to 100 percent for any coating line or

coating area by retrofitting walls and increasing capture to meet the

requirements of a PTE; in practice, retrofitting some existing

facilities may be prohibitively expensive.4 The installation of a

PTE on an existing line, if not designed properly, could increase

evaporative losses from a coating line through increased airflow and

force the need for additional control devices.5 

It may be economically advantageous to pretreat air collected

by capture systems with solvent concentrator systems. Concentrator

systems are designed to adsorb solvents from dilute air streams. The
3-3

sorbent (activated carbon or zeolite) is regenerated with hot air. 

The regeneration air requirement is only about 10 percent of the air

treated. Thus, the dilute solvent-laden air stream is converted to a

concentrated regeneration air stream, which is exhausted to another

control device. If the exhaust from the concentrator system is

ducted to an existing solvent recovery system, then some increase in

capacity of the existing solvent recovery systems may be required.

A widely used source of information on designing industrial

ventilation systems is the Industrial Ventilation manual published by

the American Conference of Governmental Industrial Hygienists

(ACGIH).6 This manual, revised every few years, provides guidance on

designing hoods to ventilate many general operations, including open

surface tanks (e.g., dip tanks), painting (e.g., spray booths), and

miscellaneous operations such as a Banbury mixers and calender rolls. 

The ACGIH manual also addresses sizing of ducts, selection of fans,

and calculation of exhaust system pressure loss.

To determine volatile organic compound (VOC) capture efficiency

(i.e., the ratio of VOCs entering the control device to the total

VOCs emitted by the process), the EPA has developed a testing

procedure that samples both captured VOC emissions and fugitive

emissions in the gas phase. Captured VOC emissions are sampled from

the process exhaust leading to the control device, and fugitive

emissions samples are taken from the exhaust of an enclosure

surrounding the process. 

Three types of enclosures are recommended by the EPA to isolate

VOC sources for capture efficiency testing: temporary total

enclosures; building enclosures; and PTEs. During the last several

years, PTEs have become more popular as a viable, cost-effective

method of demonstrating VOC capture efficiency.7 A case study

involving construction of a PTE at a printing facility to contain VOC
3-4

emissions from two existing flexography presses and a future

additional press was presented at the annual meeting of the Air &

Waste Management Association in 1997.8

A common misconception concerning the installation of PTEs is

the assumption that increased air volumes will need to be handled,

and, therefore, the control device will need to be up sized to handle

the increased airflow. While this is true for some PTE

configurations, a well-designed enclosure can be adequately

ventilated using the existing process exhaust air flow.9,10,11,12,13 By

incorporating airflow reduction techniques, such as cascading the

exhaust air from a lower concentration source to a higher

concentration source, lowering the ceiling/raising the floor, and the

use of closed-loop systems, airflows can be sometimes decreased over

those associated with the process before the installation of the

PTE.14,15,16 One company that has retrofitted PTEs at more than 50

plant sites in ten different industries has found that air flows from

the workplace can be reduced by 25 to 50 percent while simultaneously

enhancing the air quality in the working environment.17

The EPA has published seven test methods for capture

efficiency: Method 204 and Methods 204A through F.18 Following

construction of a temporary or permanent total enclosure, the

enclosure must be tested using EPA Method 204 to verify that it meets

EPA design criteria. If the enclosure meets the test criteria, no

further capture efficiency tests are required because the VOC capture

has been established at 100 percent.

In an EPA technical document entitled, "Guidelines for

Determining Capture Efficiency,"19 details are provided for the EPAapproved test methods for determining capture efficiency performance

of VOC emission control systems. The guidance also presents two
3-5

alternative methods, the data quality objective and lower confidence

limit test methods, which do not require use of a total enclosure.

3.3 CONTROL DEVICES

Add-on control devices can be of two types: combustion

(destruction) and recovery. Combustion devices (e.g.,

oxidizers/incinerators) are more commonly used, because they are

capable of high removal efficiencies for almost any type of organic

vapor. Recovery devices include condensers and adsorbers.20 Design

specifications and limitations of these control devices are provided

in an EPA handbook of control technologies for hazardous air

pollutants.21 Without actual source test data for a specific control

system and emission stream, HAP removal efficiency of the control

devices can be assumed to be equal to VOC removal efficiency.22

The most common HAP control devices used in the POWC industry

are thermal oxidizers (also called oxidizers) and, to a lesser

extent, carbon adsorbers. Based on survey responses, condensers for

solvent recovery are also used at some POWC facilities. These

control devices are discussed in more detail below.

In the POWC survey responses, 387 control devices or recovery

methods were cited; oxidizers (both catalytic and thermal), carbon

adsorbers, and condensers accounted for 92 percent of these devices

or recovery methods.

Liquid absorbers and biofilters were found in use by some

facilities in the POWC surveys. Liquid absorbers take advantage of

the solubility of the HAP in a liquid (such as water). In a liquid

absorber, the gas effluent contacts a circulating absorbing liquid,

in usually a counter-current flow direction, as the liquid passes

through a tower packed with variously-shaped material or divided by

flat plates. The tower’s internal configuration is designed to

maximize gas contact with the liquid. Efficiencies of these devices
3-6

are generally controlled by the following: concentration of the HAP

in the air stream; solubility of the HAP in the liquid; HAP

absorption rate; and absorber design and operating conditions (e.g.,

tower height and/or diameter, number of plates, liquid flow rate).23

Biofilters are control devices made up of microbiological filter

media that use hydrocarbons, such as the HAP, for food and emit

carbon dioxide as waste products.

Other control devices in use by this industry, such as wet

scrubbers and cyclones, are believed to be primarily used for control

of particulate matter and may not affect HAP emissions. 

Table 3-1 presents HAP control efficiency ranges for each of

these control devices, both reported in EPA literature and reported

in POWC survey responses from the POWC industry. Thirty percent of

POWC facilities responding to the POWC survey operate one or more

coating lines without add-on control devices, which corresponds to 29

percent of the coating lines without add-on control devices.

Table 3-1. Common Control Devices and Associated

HAP Control Device Efficiency Ranges (Percent)

Control Device

HAP Control Device

Efficiency Reported

in EPA Literature

HAP Control Device

Efficiency Reported

in POWC Survey

Responses

Thermal oxidizer 98 - 99+24,25 86 - 99.96

Catalytic oxidizer 95 - 9926 25 - 99.5

Carbon adsorber 95 - 9927 40 - 99.9

Condenser 50 - 9028 50 - 99.9

The high control efficiencies from the POWC surveys and

literature are not necessarily indicative of the overall performance
3-7

of control devices in the POWC industry. The high efficiencies in

the surveys are for short term performance tests only and do not

necessarily reflect longer term evaluations; such tests are more

appropriately used to evaluate whether the control device has been

designed and installed properly. Long term performance depends on a

number of additional considerations. Depending on the

conditions of operation during performance tests, e.g., inlet HAP

loading to the control device and ambient temperature, control

efficiencies may not represent overall control device performance. 

When facilities report short term efficiency based on testing, the

test is often conducted at maximum operating conditions that result

in measurement of the highest control efficiencies. 

Also, the batch nature of the coating process (i.e., different

products with different coating specifications produced on the same

line throughout the day) would make it difficult to achieve the high

control levels reported in the surveys all the time. Emission stream

characteristics (flow rate, concentration, temperature) are often not

constant in batch processes and control devices are often designed

only for maximum flow rates and concentrations.29 High control

device efficiencies reported for this industry are usually for short

term performance tests only and do not necessarily reflect longer

term evaluations. Such tests are more appropriately used to evaluate

whether the control device has been designed and installed properly;

long term performance depends on a number of additional

considerations, as discussed above.

Information on the specific test conditions for the control

efficiency data collected through the surveys was not available. 

Real-time emission data from a POWC facility does show that coating

process variabilities contribute to the inability of a facility to

show consistently high levels of control.30 For the reasons
3-8

described above, the likelihood that the POWC survey responses

included only initial compliance determination data should be

considered, and that the data do not necessarily reflect control

levels achievable during all of the various coating operations. 

Many factors are known to affect the performance of carbon

adsorption31 and thermal oxidizer32 control devices. These factors

are discussed in more detail below.

3.3.1 Oxidizers

3.3.1.1 Thermal oxidizers. Thermal oxidizers are control devices in

which solvent-laden air is preheated and then passed to a combustion

chamber. In the combustion chamber, volatile organics in the inlet

air stream are ignited and combusted to carbon dioxide and water. 

Dilute gas streams require auxiliary fuel (generally natural gas) to

sustain combustion. Also, because the oxidizer must be in operation

at times when HAP emissions are very low (e.g., when coating

operations are on standby between jobs), supplemental fuel

requirements will vary.

The two main types of thermal oxidizers used in this industry

are recuperative and regenerative. The recuperative oxidizer employs

a heat exchanger to preheat the inlet air stream. Regenerative

oxidizers operate in a cyclic mode, employing ceramics to obtain

greater energy recovery.33,34 Figure 3-1 is a schematic diagram of a

thermal recuperative oxidizer.

Thermal oxidizers can be operated at a wide range of control

device efficiencies, with efficiencies ranging from 98 to 99

percent.35,36 In the POWC survey responses, 278 out of the 387

control devices (or 72 percent) were thermal oxidizers, with

destruction efficiencies ranging from 86 to 99.96 percent. 

Design parameters critical to successful combustion are

turbulence, temperature, and residence time. The combustion chamber 

3-10

must be designed to provide sufficient turbulence to mix the inlet

air with any auxiliary fuel. Air temperature and residence time in

the combustion chamber must be sufficiently high and long,

respectively, to ensure complete combustion. 

Test results show that thermal oxidizers can achieve 98 percent

destruction efficiency for most VOCs at combustion chamber

temperatures ranging from 700 to 1300°C (1300 to 2370°F) and

residence times of 0.5 to 1.5 seconds.37 In order to achieve 98

percent destruction of nonhalogenated VOC (and organic HAP), the

operating temperature of a thermal oxidizer must be greater than

870°C (1600°F).38 In this temperature range, a residence time of

more than 0.75 seconds must be used to ensure 98 percent destruction

of nonhalogenated organics.39 The maximum achievable VOC destruction

efficiency decreases with decreasing inlet 

concentration because of the much slower combustion reaction rates at

lower inlet VOC concentrations.41 

Oxidizers are equipped with controllers for start-up, to allow

the combustion chamber to reach the proper temperature. These

controllers can be designed to prevent operation of the emission

source (e.g., coating operation) until the oxidizer temperature is

adequate to ensure destruction of volatile organics.

To avoid a fire hazard, the inlet air stream to an oxidizer is

monitored to ensure that its organic concentration is below the lower

explosive limit (LEL). The LEL defines the minimum concentration of

a compound that at ambient conditions can produce more energy than is

needed to raise its temperature to the ignition point.42 The

concentration of VOC in the inlet air stream to an oxidizer is

typically limited by insurance companies to 25 percent of the LEL for

a specific VOC.43

3.3.1.2 Catalytic oxidizers. Catalytic oxidizers, like

thermal oxidizers, are control devices in which solvent-laden air is
3-11

preheated and then passed to a combustion chamber. In the combustion

chamber, volatile organics in the inlet air stream are ignited and

combusted to carbon dioxide and water. In the presence of a

catalyst, combustion will take place at a lower temperature than that

required for thermal oxidizers. Temperatures between 350 and 500°C

are common. The catalysts, supported on ceramic or metallic

substrates, are metal oxides or precious metals. 

Catalytic oxidizers in use by the POWC industry are of the

fixed-bed type, using either a monolithic or packed-bed catalyst. 

The tray type of packed-bed catalytic oxidizer, which uses a

pelletized catalyst, is advantageous where large amounts of

phosphorus or silicone compounds are present.44

Catalytic oxidizers can achieve control device efficiencies of

95 to 99 percent.45 In the POWC survey responses, 20 out of the 387

control devices (or 5 percent) were catalytic oxidizers, with

destruction efficiencies ranging from 25 to 99.5 percent. Compared

with a thermal oxidizer, the lower operating temperature of a

catalytic oxidizer can reduce or eliminate the need for supplemental

fuel during normal operation. Also, the nitrogen oxides formed is

reduced at the lower operating temperature of a catalytic oxidizer.

Chlorinated solvents and some silicone additives in coating

formulations will poison or deactivate certain catalysts. However,

catalysts now exist that are tolerant of chlorine, sulfur, and other

compounds.46 The use of chlorinated solvents, however, has decreased

dramatically in recent times so that they are now seldom used.47

The exhaust from adhesive drying ovens can potentially contain

nonvolatile organic matter such as particles of adhesive resins,

additives, release compounds, etc. An oxidizer designed to combust

volatile organics may not have sufficient residence time to destroy

the particles. The emission rate of these particles is usually very

low. However, particulate matter can reduce combustion efficiency by
3-12

blinding the pores of the catalyst, inhibiting contact between the

catalyst active sites and the pollutant gases due to a particulate

buildup on the catalyst bed. Also, pressure drop is increased when a

particulate buildup occurs, increasing energy requirements of the

blower.48

3.3.2 Adsorption

Adsorbers in use by this industry use activated carbon as the

adsorptive material in a regenerable fixed bed. In a typical carbon

adsorber, solvent-laden air is passed through a fixed bed of granular

activated carbon. Volatile organics in the entering air stream are

adsorbed onto active sites on the surface area of the carbon, until

at some point the capacity of the carbon is exhausted, allowing

organics to pass through unadsorbed (called breakthrough). Adsorber

beds are typically operated in parallel so that when the adsorption

capacity of one bed is exhausted, it can be removed from service and

a second adsorber bed can be put into service. The spent carbon in

the first adsorber bed is then regenerated. A changeover from one

adsorber bed to another is automatically initiated either at a preset

interval or when an outlet concentration of VOC exceeds the

breakthrough setpoint according to a gas monitor on the adsorber

outlet. Figure 3-2 is a schematic diagram of a two-bed carbon

adsorber.

Carbon adsorption systems can achieve control device

efficiencies between 95 and 99 percent for some organic HAP.49 In

the POWC survey responses, 39 out of the 387 control devices (or 10

percent) were carbon adsorbers, with control device efficiencies

ranging from 40 to 99.9+ percent. 

In contrast to combustion, carbon adsorption does not destroy

the HAP it removes from the air stream. Carbon adsorbers in this

industry are thermally regenerated, usually by passing steam through 

3-14

the carbon beds.50 The HAP is thereby removed from the carbon

(desorbed) and transferred to the steam. The HAP-containing steam is

then condensed, and the solvent separates from the water. The

solvent can then be decanted for sale or reuse. Regeneration can

also be achieved with hot air. Hot-air regeneration can be quite

attractive when dealing with water soluble solvents.51 Carbon

adsorption is most easily adaptable to coating lines that use a

single solvent; if solvent mixtures are collected by adsorbers, they

usually are distilled for reuse.52

There are two options for disposing of recovered solvent that

cannot be reused. The first is to sell the material back to the

solvent supplier or an independent firm that specializes in

reclaiming contaminated solvents. The other option is to use the

recovered solvent as a fuel in coating ovens or in boilers. However,

many coating ovens and boilers are gas-fired and would require burner

modifications to burn solvent. Carbon adsorption is generally

economically attractive only if the recovered solvent can be reused

directly.53

Carbon adsorbers are most suitable for solvent systems that are

immiscible with water, such as toluene and xylene, but are not

recommended for ketones such as methyl ethyl ketone and methyl

isobutyl ketone.

The presence of solid particles or polymerizable substances in

the inlet air stream to a carbon adsorber may require pretreatment of

the inlet air. Cooling and dehumidification may also be required as

pretreatment in some cases.55

The concentration of VOC in the inlet air stream to a carbon

adsorber is typically limited by insurance companies to 25 percent of

the LEL. If proper controls and monitors are used, LEL levels of up

to 50 percent may be allowed.56
3-15

3.3.3 Condensation

Condensation is a control technique in which one or more

volatile components of a solvent-laden air stream are separated from

the remaining vapor through saturation followed by a gas-to-liquid

phase conversion (i.e., condensation). The recovered organic

components can be reused or sold. The more volatile a compound, the

lower the temperature required for condensation, so refrigeration is

often employed to obtain the low temperatures required for acceptable

removal efficiencies.57 Removal efficiencies obtained by condensers

usually range from 50 to 90 percent.58 In the POWC survey responses,

15 out of the 387 control devices (or 4 percent) were condensers,

with removal efficiencies ranging from 50 to 99.9 percent. 

The most common types of condensers used are surface and

contact condensers. In surface condensers, the coolant does not

contact the gas stream. Most surface condensers in refrigerated

systems are of the shell-and-tube type, where coolant is circulated

through tubes and the volatile organics condense on the outside of

the tubes. Surface condensers allow for direct recovery of volatile

organics from the gas stream.59 Figure 3-3 is a schematic diagram of

a shell-and-tube surface condenser. Contact condensers, unlike

surface condensers, cool through 

direct contact of the coolant with the gas stream. The contact

condenser coolant is a liquid, at ambient or chilled temperature,

sprayed into the gas stream. In a contact condenser, the condensed

volatile organics are contaminated with coolant, so they cannot

usually be reused directly or recovered without further processing.61

Based on the survey responses, condensers with solvent recovery

units are used more commonly by manufacturers of pressure-sensitive

tapes and labels than by other industry sectors. Most if not all

condensers used in the pressure-sensitive tapes and labels industry

sector are surface condensers.62

3-17

To achieve extremely low outlet organic concentrations,

condensation alone is usually inadequate.63 In the POWC survey

responses, one facility used a condenser in combination with carbon

adsorbers to achieve >99 percent control of HAP.Condensers can

usually be used alone successfully if emission streams contain high

inlet concentrations of volatile organics. Condenser removal

efficiencies greater than 85 percent usually require volatile

organics concentrations of 10,000 ppmv 

or greater.64 In the POWC survey responses, there were three

facilities that used condensers alone to achieve greater than

90 percent control efficiency; all three of these facilities were in

the pressure-sensitive tape industry segment.Condensers are also

used with coating lines that use inert ovens. An inert oven is a

coating drying method that uses an inert gas (e.g., nitrogen) to

replace oxygen in the air space in the oven. Inert ovens are used

with coatings that otherwise would be difficult to apply without

forming air bubbles under the coating surfaces.65 There is no oven

vent to the atmosphere in an inert oven. Instead, a small diameter

pipe conducts superconcentrated exhaust at flow rates of only 100-200

ft3/min to condensation coils. Solvent concentrations may be 100,000

to 200,000 ppm in an inert oven’s exhaust, which is above the upper

explosive limit (UEL) for most/all solvents. After the solvent

condenses out of the gas in the coils, the cleaned gas is returned to

the oven; this cycle is a closed loop in terms of the oven gas.66

For proper operation, there must be an oxygen-free dead-zone of

air space after the inert oven, where the air flow is balanced

between the air pulled in vs. the air pushed out. This situation

complicates the use of total enclosures around a coating line with an

inert oven. Also, air flow within the oven would need to be

increased to achieve total enclosure. Unfortunately, air flow as

little as 200 ft/min can disturb the web in an inert oven and cause a
3-18

web, especially one made of paper, to break. Because of issues such

as solvent concentrations above the UEL and static electricity in

film coating, safety is another concern with totally enclosing the

air space around inert ovens.67

3.4 PREVENTIVE MEASURES

3.4.1 Product Substitution/Reformulation

Many facilities in the POWC industry have adopted air pollution

control strategies that have included substitution of lower-solvent

coatings for higher-solvent coatings, or a conversion from

solventborne coatings to waterborne coatings. For some products,

substitute coatings have not been developed to meet performance

requirements, therefore, substitution or reformulation of coatings is

not presently an option. Also, it may be the case that a single

coating line could be used with a low-solvent coating for one

product, but may need to use a higher-solvent coating for another

product because an alternative coating is not available for this end

use. 

In the POWC surveys, the use of low-HAP coatings, such as

waterborne, ultraviolet cured, hot-melt, and reactive resins were

reported in use by many facilities. In the flexible vinyl and film

industry segment, 74 percent (40 out of 58) of the facilities cited

the use of low-HAP coatings. In the pressure-sensitive tape industry

segment, low HAP coatings were used in 54 percent (49 out of 91) of

the facilities. In the decorative and industrial laminates sector,

12 percent (5 out of 41) of the facilities cited the use of low-HAP

coatings.

One problem with lower-solvent coatings is that, although there

are nonzero HAP emissions from these coatings, the concentration of

HAP in the coating oven/area exhaust is too low to be efficiently

controlled in a normally-sized add-on control device. Also, since

the exhaust contains a relatively high water content along with a low
3-19

HAP concentration, there is too little heat value for combustion of

the exhaust. Consequently, HAP standards developed for the industry

will provide alternatives to a percentage emission reduction;

otherwise, a facility might be prevented from switching from a

solventborne coating to a waterborne coating when the substitution is

possible.

3.4.2 Work Practice Procedures

Work practice procedures are physical actions intended directly

to affect emission reductions. Because work practice procedures are

specifically tailored to an industry, they may vary from a few manual

operations to a complex program.

For situations where an emission standard for control of a HAP

is not feasible, then design standards, equipment standards,

operational standards, and/or work practice standards can be

promulgated instead of an emission standard. As described in

section 112(h) of the CAA, situations where an emission standard is

not feasible are when a HAP cannot be directed through a capture

device (or when use of the capture device would be inconsistent with

Federal, State, or local law) or when the application of measurement

methodology to a class of sources is not practicable due to

technological and economic limitations.

 For the POWC industry, work practice procedures may be

appropriate for some activities, such as the following: solvents in

maintenance operations; solvent handling and transfer; spraying

operations and booths; drying and squeegee operations; and open

vessels. Examples of such work practice standards are provided in

Table 3-2.
3-20

Table 3-2. Examples of Work Practice Standards

Activity Example Work Practice Standard

Solvents use in

cleaning

--Used cleaning solvents must be put into an

enclosed container.

--During atomized cleaning of a spray gun,

the cleaning solvent must be directed into a

waste container fitted with a capture

device.

Solvent handling and

transfer

--Handling and transfer of solvents must be

conducted in such a manner to reduce spills. 

Spills must be wiped up immediately and the

wipe rags stored in covered containers.

Open vessels --Waste solvent will be stored in closed

containers that may have an opening for

pressure relief but do not allow for liquid

to drain.
3-21

3.5 REFERENCES 

1. Docket No. A-99-09. U.S. Environmental Protection Agency,

Washington, DC. 1999. Responses from the paper and other web

coating NESHAP survey.

2. Pressure Sensitive Tape and Label Surface Coating Industry--

Background Information for Proposed Standards (EPA-450/3-80-

003a). U.S. Environmental Protection Agency, Research Triangle

Park, North Carolina. September 1980. pp. 3-14 to 3-15.

3. Reference 1. 

4. National Emission Standards for Hazardous Air Pollutants:

Printing and Publishing Industry--Background Information for

Proposed Standards (EPA-453/R-95-002a). U.S. Environmental

Protection Agency, Research Triangle Park, North Carolina.

February 1995. p. 3-2.

5. Memorandum from Sutton, L., E.C./R, Inc., Durham, North

Carolina to D. Brown, U.S. Environmental Protection Agency,

Research Triangle Park, North Carolina. February 9, 1998.

Minutes of January 28, 1998, meeting with the Pressure

Sensitive Tape Council.

6. Industrial Ventilation: A Manual of Recommended Practice. 18th

ed. American Conference of Governmental Industrial Hygienists,

Cincinnati, Ohio. 1984.

7. VOC Capture Efficiency Testing Using Permanent Total

Enclosures. The Air Pollution Consultant: November/December

1997. Elsevier Science, Inc. pp. 1.13 through 1.17.

8. D. Bemi, et al. Demonstrating VOC Capture Efficiency Using

Permanent Total Enclosure Technology: Common Practices,

Challenges and Rewards. Proceedings of the Air & Waste

Management Association*s 90th Annual Meeting and Exhibition,

Toronto, Canada. June 1997.

9. Bemi, D. “Demonstrating VOC Capture Efficiency using Permanent

Total Enclosure Technology: Common Practices, Challenges and

Rewards.”Paper No. 97-TA4B.04. Presented at Air and Waste

Management Association 1997 Annual Meeting, Toronto, Ontario,

Canada. June 8-13, 1997. pg. 7.
3-22

10. Lukey, M. “Permanent Total Enclosures needed in Response to

Subpart KK and Changes in Test Procedures.” Paper No. 97-

TA4B.05. Presented at Air and Waste Management Association 1997

Annual Meeting, Toronto, Ontario, Canada. June 8-13, 1997. pg.

3.

11. Lukey, M. “Five Design Options for Permanent Total Enclosures.”

Paper No. VIP-69. Presented at Air and Waste Management

Association Specialty Conference “Emerging Solutions to VOC and

Air Toxics Control,” San Diego, California. February 26-28,

1997. pg. 281.

12. Turner, T. “Local capture or Total Enclosure? The Answer is

Yes!” Paper No. 94-RA11l.0l. Presented at Air and Waste

Management Association 1994 Annual Meeting, Cincinnati, Ohio.

June 19-24, 1994. pg. 7.

13. Oiestad, A. “Fugitive VOC Capture Systems Using the ‘Total

Permanent Enclosure Concept*.” Paper No. 93-TA-33.0. Presented

at Air and Waste Management Association 1993 Annual Meeting,

Denver, Colorado. June 13-18, 1993. pg. 2.

14. Reference 12, pg. 6.

15. Reference 10, pg. 3.

16. Reference 13, pg. 2.

17. Reference 13, pg. 2.

18. Appendix M, Test Methods 204, 204A-204F: Preparation, Adoption,

and Submittal of State Implementation Plans, Final Rule.

Federal Register. 40 CFR Part 51, Volume 62, Number 115. June

16, 1997. pp. 32500-32536.

19. Guidelines for Determining Capture Efficiency. U.S.

Environmental Protection Agency, Office of Air Quality Planning

and Standards, Emission Monitoring and Analysis Division,

Research Triangle Park, North Carolina. January 9, 1995.

20. Handbook: Control Technologies for Hazardous Air Pollutants

(EPA-625/6-91-014). U.S. Environmental Protection Agency,

Cincinnati, Ohio. June 1991. p. 3-1.

21. Reference 20.
3-23

22. Reference 20, p. 3-3.

23. Reference 20, p. 4-44.

24. Guideline Series: Control of Volatile Organic Compound

Emissions from Reactor Processes and Distillation Operations

Processes in the Synthetic Organic Chemical Manufacturing

Industry (EPA-450/4-91-031). U.S. Environmental Protection

Agency, Research Triangle Park, North Carolina. August 1993.

p. 3-12.

25. Reference 20, p. 3-3.

26. Reference 20, p. 4-11.

27. Reference 20, p. 3-4.

28. Reference 20, p. 3-3.

29. Control of Volatile Organic Compound Emissions from Batch

Processes - Alternative Control Techniques Information Document

(EPA/R-94-020). U.S. Environmental Protection Agency, Research

Triangle Park, North Carolina. February 1994.

30. Memorandum from Bhatia, K. and D. Jones, E.C./R, Inc., Durham,

North Carolina, to D. Brown, U.S. EPA, Research Triangle Park,

North Carolina. September 30, 1998. Summary of Continuous

Emission Monitoring Study for the EPA*s Coatings and Consumer

Products Group.

31. Carbon Adsorption for Control of VOC emissions: Theory and Full

Scale System Performance (EPA-450/3-88-012). U.S. Environmental

Protection Agency, Research Triangle Park, North Carolina. June

1988.

32. Memorandum (and attachments) from Farmer, J. R., U.S.

Environmental Protection Agency, Research Triangle Park, North

Carolina, to distribution. August 22, 1980. Thermal incinerator

and flare removal efficiency.

33. Reference 20, p. 4-2.

34. OAQPS Control Cost Manual, 4th ed. (EPA-450/3-90-006). U.S.

Environmental Protection Agency, Research Triangle Park, North

Carolina. January 1990. p. 3-7.
3-24

35. Reference 24, p. 3-12.

36. Reference 20, p. 3-3.

37. Reference 24, p. 3-12.

38. Reference 29, p. 4-31.

39. Reference 34, p. 3-8.

40. Reference 34, pp. 3-5 to 3-6.

41. Reference 20, p. 3-3.

42. Reference 34, p. 3-16.

43. Reference 20, p. 4-11.

44. Reference 2, p. 4-14.

45. Reference 24, p. 3-12

46. Reference 34, p. 3-14.

47. Reference 2, p. 4-22.

48. Reference 2, pp. 4-22, 4-23.

49. Reference 20, p. 3-4.

50. Reference 2, pp. 4-3, 4-6.

51. Reference 2, p. 4-6.

52. Compilation of Air Pollutant Emission Factors (AP-42), Volume I

(Fifth Edition). U.S. Environmental Protection Agency, Research

Triangle Park, North Carolina. January 1995. p. 4.2.2.6-3.

53. Reference 2, p. 4-8.

54. Reference 2, p. 4-4.

55. Handbook: Control Technologies for Hazardous Air Pollutants

(EPA-625/6-91-014). U.S. Environmental Protection Agency,

Cincinnati, Ohio. June 1991. pp. 3-4 to 3-5.
3-25

56. Reference 20, p. 3-5.

57. Reference 34, p. 8-3.

58. Reference 20, p. 3-5.

59. Reference 34, p. 8-5.

60. Reference 34, p. 8-5.

61. Telecommunication. Sutton, L., E.C./R, Inc., Durham, North

Carolina, with T. Godonis, American Biltrite, Inc., Moorestown,

New Jersey. March 19, 1998. Question regarding condensers.

62. Reference 20, p. 3-5.

63. Reference 20, p. 3-5.

64. Reference 34, p. 8-7.

65. Memorandum from Sutton, L., E.C./R, Inc., Durham, North

Carolina to D. Brown, U.S. Environmental Protection Agency,

Research Triangle Park, North Carolina. December 2, 1998.

Minutes of October 13, 1998, meeting with the Pressure

Sensitive Tape Council.

66. Reference 65. 

67. Reference 65.
3-26

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4-1

4.0 MODEL PLANTS, CONTROL OPTIONS, AND ENHANCED MONITORING

4.1 INTRODUCTION

This chapter describes model plants, control options, and

enhanced monitoring options for the paper and other web coating

(POWC) industry. Model plants were developed to evaluate the effects

of the control options on major sources in the POWC source category. 

Control options were selected based on the application of currently

available control devices and levels of capture consistent with the

levels of overall achievable control. Enhanced monitoring options

are specified to ensure the consistent performance of control

devices.

4.2 MODEL PLANTS

Model plants have been specified to represent the range of

capacity and overall control efficiency (OCE) at major sources in the

POWC industry, as determined primarily by responses to EPA surveys of

four POWC industry segments: pressure sensitive tapes and labels;

flexible vinyl; photographic film; and decorative and industrial

laminates industries. According to one estimate, based on a

comparison of POWC survey efforts and Toxic Release Inventory (TRI)

data, these four industry segments represent approximately 80 percent

of the major sources and HAP emissions of the TRI facilities in the

nonprinting portion of the POWC industry.1 

In the POWC survey responses, it was found that HAP OCE was a

function of control device operation and capture efficiency. The

overall level of control was distributed in the surveyed facilities
4-2

from zero to more than 95 percent, with approximately 20 percent of

the facilities reporting zero control, 50 percent reporting between

zero and 90 percent, and the remaining 30 percent reporting more than

90 percent control.

It was also found in the POWC survey responses that HAP usage

varied widely among facilities. Six facilities reported zero HAP

usage. On the average in the surveyed facilities, more than

80 percent of the HAP emitted was from the coating lines and

associated processes. The other sources of HAP emissions include

mixing, cleaning, and storage. These sources are mostly

uncontrolled, with the unenclosed processes not as amenable to

capture and control as enclosed processes. Little data were

available on the control of these sources. Consequently, HAP usage

for sources of HAP other than coating lines was not addressed in the

model plants. 

Model plants were developed from the 89 identifiable major

sources in the POWC survey responses. While these model plants

represent the sources that will be regulated, they are not

necessarily representative of all plants in the entire industry,

since major sources are only the highest emitters of HAP emissions by

the industry. 

The two parameters used to develop the model plants were the

coating line HAP OCE and the coating line HAP emissions after

control. These parameters were chosen because they were the plant

parameters that best differentiated the plants into groups, and

because they are the most important parameters in cost and impact

analyses. 

Five separate coating line OCE groups corresponding to 0, 50,

80, 90, and 95 percent OCE are represented by the POWC model plants. 

Within each OCE group, the controlled coating line HAP emissions were

examined and subcategories were created where the HAP emissions
4-3

within each OCE group covered too wide a range to be represented by a

simple average. For model plants with OCE’s of 0, 50, and 80 percent

OCE (Model Plant groups 1, 2, and 3), two subcategories were created

for this purpose. In each case, the “a” group had controlled HAP

emissions less than 200 tons per year (tpy) and the “b” group had HAP

emissions greater than 200 tpy. It was also the case that the “a”

groups had fewer coating lines than the “b” groups, with the “a”

groups having five or fewer coating lines. For Model Plant group 1,

a third “c” category was created to represent the facilities that are

likely using compliant coatings; facilities in this group had coating

HAP emissions less than or equal to 0.2 pounds (lb) HAP emitted per

lb of coating solids applied. Specifications for the POWC model

plants are given in Table 4-1. 

4.3 CONTROL OPTIONS

Table 4-2 presents the three control options for the POWC

industry that include ranges in capture system and add-on control

performance, and the use of low-HAP coatings. For add-on controls,

any combination of capture and control device efficiency that

produces an OCE of 95 percent is equivalent to the control option. 

For low-HAP coatings, the control option is a level of 0.2 pounds

(lb) of HAP emitted per lb of coating solids applied.

The add-on control systems of demonstrated control

effectiveness in the POWC industry are composed of a HAP capture

system achieved by permanent total enclosures (PTEs) and a HAP

destruction or recovery system achieved by thermal or catalytic

oxidizers, or carbon adsorbers, condensers, and other solvent

recovery systems. These devices are discussed in Chapter 3.
4-4

Table 4-1. Specifications for Model Plants Representing the POWC Industrya

Model

Plant 

No.

Coating Line

Overall HAP

Control

Efficiency,

percent

Controlled

Coating Line 

HAP

Emissions, 

tpy

Coating Use,

tpy

Average

Number of

Coating

Lines

Average

Number of

Coating

Stations

Uncontrolled

Coating Line 

HAP

Emissions, 

tpy

HAP Capture

Efficiency,

percent

HAP

Destruction

Efficiency,

percent

Percent of

Database

Major

Sources

1a 0 99 2,108 2 5 99 0 0 20

1b 0 1,765 7,521 12 9 1,765 0 0 3

1cb 0 48 6,597 3 17 48 0 0 10

2a 50 138 8,607 5 11 276 55 90 25

2b 50 1,261 369,929 31 154 2,522 53 95 1

3a 80 183 7,518 3 8 915 89 90 11

3b 80 1,378 14,516 8 15 6,890 84 95 1

4 90 99 3,431 4 12 990 95 95 24

5 95 40 5,498 5 19 800 97 98 5

a tpy = tons per year.

b Although a control efficiency of zero is stated, this model plant is assumed to be using compliant coatings with

#0.20 pound HAP per pound coating solids.
4-5

Table 4-2. Control Options for the POWC Industry

Control

Option

Overall Facility Coating Line Average

HAP Capture

Efficiency,

percent

HAP Collection/

Destruction

Efficiency,

percent Type of Control 

Overall HAP

Control

Efficiency,

percent

1 95-100 95-100

thermal oxidizer,

carbon adsorber/

solvent recovery 95

2 95-99 95-100 inert oven/

condensation 95

3 NA NA

low-HAP coatings

(#0.2 lb HAP per

lb coating solids)

NA

Note: NA = Not applicable.

Improved capture involves containment of previously uncollected

HAP emissions. Capture technologies include canopy hoods, floor

sweeps, partial enclosure of coating stations, room enclosures, and

PTEs (which may include room enclosures). Control options involving

air handling can be specified as varying degrees of air collection,

up to and including construction of (or conversion of existing

coating operation rooms to PTEs), with many gradations existing

between current capture systems and PTEs. The specifications of

ventilation, hooding, and ducting for incremental improvements to

existing systems are site-specific. 

Substitution of coatings with lower HAP content may be an

important pollution prevention control technique at some facilities. 

A reduction in HAP emissions through substitution of nonHAP solvents

for some HAP solvents in the coatings can achieve the same reduction

in HAP emissions as that of the add-on control techniques. 

Facilities that operate efficient HAP add-on control systems,
4-6

however, may have little incentive to reduce the HAP content of their

coatings. 

Reducing the HAP content of coatings also may not be

appropriate for all facilities or product types. From the available

information, it appears that the cost and effects on output quality

resulting from substitution of nonHAP solvents for HAP solvents are

product-specific, with notable success in some areas and notable lack

of success in others.2 Existing control devices (which are usually

designed and operated for volatile organic compounds (VOC) control)

may not be compatible with low-HAP formulations, because of the

potential for low HAP/VOC inlet concentrations. 

While substitution of nonHAP solvents for HAP should be

encouraged as a pollution prevention option, it may affect VOC

emissions if VOC solvents are substituted for HAP solvents. Some

plants have adopted waterborne or radiation-cured coating

technologies to reduce VOC emissions. Some of these formulations are

totally HAP-free, although many low-VOC waterborne coating systems do

contain small percentages of HAP (typically glycols, glycol ethers,

or alcohols), with or without a small amount of nonHAP VOC as well. 

Usually, low-VOC, low-HAP coating formulations are used with no

control devices. 

Control strategies for the POWC industry are influenced by the

composition of coatings and other materials applied on the coating

line and by regulatory requirements. Often, regulations presently in

effect limit emissions of VOC. Existing control devices are, for the

most part, currently specified and operated to meet VOC emission

requirements. However, most of the organic HAP are VOC and,

therefore, the control efficiency for HAP is expected to be the same

as for VOC.3

New control devices can be selected based on the coating system

in use or, if more than one type of device is potentially suitable,
4-7

based on cost or requirements of other regulations, if also

applicable. Usually, if capture efficiency is maximized at 100

percent with PTEs, greater flexibility of control device operation

can be realized to meet the needs of daily operations. 

As noted in Chapter 3, all control devices currently in use in

the POWC industry can achieve efficiencies of at least 95 percent. 

Although higher efficiencies are achievable, consistent high inlet

concentrations of HAP are needed; therefore, reaching high

efficiencies at lower inlet HAP concentrations may be difficult and

not possible all of the time because of the batch nature of the POWC

processes (i.e., different products with different coating

specifications produced on the same line throughout the day). 

Emission stream characteristics (flow rate, concentration,

temperature) are often not constant in batch processes and control

devices are often designed only for maximum flow rates and

concentrations.4 High control device efficiencies reported for this

industry are usually for short term performance tests only and do not

necessarily reflect longer term evaluations. Such tests are more

appropriately used to evaluate whether the control device has been

designed and installed properly. Long term performance depends on a

number of additional considerations, as discussed above. 

The one exception to achieving 100 percent capture is where the

particular product or substrate requires the use of a nitrogenblanketed inert drying oven. These devices allow for coating

operations within a low air flow/high solvent vapor zone without risk

of an explosion with high nitrogen and low oxygen levels within the

oven. For proper operation and safety, there must be an oxygen-free

dead-zone air space after the inert oven.5 This precludes the use of

a PTE, where air is continuously exhausted throughout the coating

area.
4-8

4.4 ENHANCED MONITORING

Facilities in the POWC industry that operate thermal

incinerators or catalytic incinerators usually continuously monitor

control device operating parameters, since variations in combustion

temperature affect, and are directly related to, performance of the

control devices. In this situation, the operators of thermal and

catalytic incinerators install, calibrate, operate, and maintain the

temperature monitoring devices following manufacturers’

specifications. The temperature of the control device is maintained

at a level equal to or higher than the temperature at which

compliance was demonstrated. Continuous emission monitoring systems

(CEMS) may not be reliable for the coating industry, where the HAP in

the emission streams may comprise only a small percentage of the VOC

present. Also, the output of CEMS may not accurately reflect the HAP

concentration of the emission stream due to differences in responses

among the HAP, nonHAP VOC, and products of incomplete combustion, and

the presence of reactive and/or condensable emissions. How to

integrate CEMS software with existing facility software and provide

reports are other challenges in the use of CEMS for any facility in

the coating industry, where starts, stops, and process variations

occur regularly in job shops that coat many and different product

types. Accommodations in reporting requirements are also needed for

the inevitable problems at coating facilities, such as: automatic

shutdowns; back pressure and valve venting; and outages due to

regular on-line maintenance, such as carbon replacement.6

Facilities in the POWC coating industry that operate solvent

recovery systems monitor control system performance using liquidliquid mass balances. These mass balances provide recovery data

averaged over the reporting period. Because the HAP emissions are

recovered rather than destroyed, a mass balance at any point in time

within the reporting period will reflect any intermittent system
4-9

failures or fluctuations in control device efficiency. Since the

efficiency of the solvent recovery system during the reporting period

is not based on the average of discrete measurements of efficiency,

any individually measured control efficiency during the reporting

period may not agree with the overall efficiency calculated at the

end of the reporting period. 

Facilities in the POWC industry that control HAP emissions with

low-HAP coating formulations need to maintain documentation

confirming the HAP content of the materials applied. If

specifications provided by coating suppliers are inadequate to

establish the HAP content, additional compositional analyses need to

be conducted by the facility.
4-10

4.5 REFERENCES

1. Memorandum from Sutton, L., EC/R, Inc., Durham, North Carolina,

to Brown, D., U.S. Environmental Protection Agency, Research

Triangle Park, North Carolina. December 14, 1998. Paper and

other web coating NESHAP: Summary of toxic release inventory

data of 1996 for selected standard industrial classification

codes.

2. Memorandum from Koman, T., U.S. Environmental Protection

Agency, Research Triangle Park, North Carolina to Stakeholders

and Meeting Attendees. July 10, 1998. Minutes from June 4, 1998

stakeholder meeting.

3. Handbook: Control Technologies for Hazardous Air Pollutants

(EPA-625/6-91--014). U.S. Environmental Protection Agency,

Cincinnati, Ohio. June 1991. p. 3-3.

4. Control of Volatile Organic Compound Emissions from Batch

Processes - Alternative Control Techniques Information Document

(EPA/R-94-020). U.S. Environmental Protection Agency, Research

Triangle Park, North Carolina. February 1994.

5. Memorandum from Sutton, L., EC/R, Inc., Durham, North Carolina,

to Brown, D., U.S. Environmental Protection Agency, Research

Triangle Park, North Carolina. December 2, 1998. Meeting of

October 13, 1998, with the Pressure Sensitive Tape Council.

6. Memorandum from Bhatia, K. And D. Jones, EC/R, Inc., Durham,

North Carolina, to T. Koman, U.S. Environmental Protection

Agency, Research Triangle Park, North Carolina (draft).

September 30, 1998. Summary of continuous emission monitoring

study for the EPA*s Coatings and Consumer Products Group.
5-1

5.0 ENVIRONMENTAL AND ENERGY IMPACTS OF CONTROL OPTIONS

5.1 INTRODUCTION

The impact analyses in this chapter are based on the

application of Control Option 1 to the model plants developed to

represent the paper and other web coating (POWC) major sources. As

discussed in Chapter 4, Control Option 1 corresponds to an overall

control efficiency (OCE) of 95 percent. Thermal oxidation was

selected as the control device used to estimate the worst-case

environmental and energy impacts, since oxidation would generate the

greatest secondary emissions. Also discussed in this chapter are

qualitative assessments of the impacts of using the other two control

options discussed in Chapter 4, which involve the use of inert ovens

with solvent recovery (Control Option 2) and the use of coatings with

low levels of hazardous air pollutants (HAP) as in Control Option 3. 

The use of solvent recovery via carbon adsorption instead of thermal

oxidizers in Control Option 1 is also discussed.

Table 5-1 shows the nine POWC model plants and the estimated

number of facilities nationwide represented by each model plant

category.1 Note that although Model Plant 1c corresponds to an 0CE

of 0 percent, the model plant group corresponds to facilities using

low-HAP coatings with less than or equal to 0.2 pounds (lb)HAP per lb

of solids emitted or applied. Accordingly, no energy and emissions

impacts for Model Plant 1c are expected. Similarly, since Model

Plant 5 has an OCE of 95 percent that is equal to Option 1, no energy 
5-2

Table 5-1. POWC Model Plants and Their Estimated 

Correspondence to the National POWC Industry

Model

Plant

Coating

Line

OCE,

percent

HAP 

Capture

Efficiency,

percent

HAP

Destruction

Efficiency,

percent

Number of

Major

Sources

in POWC

Database

Percent

of

Database

Major

Sources,

percent

Estimated

Number of

U.S.

Facilities

1a 0 0 0 18 20 41

1b 0 0 0 3 3 7

1ca 0 0 0 9 10 21

2a 50 55 90 22 25 50

2b 50 53 95 1 1 2

3a 80 89 90 10 11 23

3b 80 84 95 1 1 2

4 90 95 95 21 24 48

5 95 97 98 4 5 9

Total 89 100 203

 

a Model Plant 1c consists of facilities using low-HAP coatings that meet

the criteria of # 0.2 lb HAP per lb solids (Option 3). 

And emissions impacts were estimated for this model plant group as

well.

5.2 ENERGY IMPACTS

The energy requirements for implementation of Option 1 for the

POWC industry include electricity to collect and process ventilation

air and natural gas for thermal oxidizer fuel. The energy impact

estimates are based on the installation of new capture systems for

all model plants except Model Plants 1c and 5, new thermal oxidizers

for Model Plants 1a and 1b, and improved destruction efficiency of

existing oxidizers for Model Plants 2a and 3a. Table 5-2 shows the

energy impacts for the POWC model plants in terms of incremental 
5-3

Table 5-2. Energy Impacts of Control Option 1 

for the POWC Model Plants

Model

Plant

Energy Impacts of Control

Option 1

Fan Power,

106 kW-hr/yr

Natural Gas,

106 scf/yr

1a 2.2 43.5

1b 7.5 92.5

1c 0 0

2a 1.1 17.8

2b 16.4 0

3a 1.1 16.7

3b 2.2 0

4 1.1 0

5 0 0

Note: This analysis assumes the use of thermal 

oxidizers for Control Option 1.

increases in power consumption (fan electricity) in kilowatt-hours

per year (kW-hr/yr) and natural gas in standard cubic feet per year

(scf/yr).

Average electricity and gas consumption factors were calculated

for the model plants from the energy impacts. For Model Plants 2b,

3b, 4, and 5, that have oxidizers with destruction efficiencies of 95

percent or above, the average amount of electricity consumed for

improved capture systems is 4.8 kW-hr/yr per lb of incrementally

controlled HAP. For Model Plants 1a, 1b, 2a, and 3a, the average

amounts of electricity and natural gas consumed for new capture and

control systems are 5.6 kW-hr/yr and 100 scf/yr per lb of

incrementally controlled HAP, respectively.
5-4

Table 5-3 shows the estimated national energy impacts of the

application of control option 1 to the POWC industry. This estimate

was developed by scaling up the model plant energy impacts to the

estimated 203 POWC major sources in the U.S. Scale-up factors were

developed from the proportion of major sources in the POWC database

represented by each model plant group (see Table 5-1) applied to the

estimated total number of POWC major sources in the U.S. 

Table 5-3. Total Estimated Energy Impacts of 

Control Option 1 for the National POWC Industry

Energy Impacts

Total U.S. 

Impact for

Control Option 1

Fan Power, 

106 kW-hr/yr 313

Natural Gas, 

109 scf/yr 3.7

Note: This analysis assumes the use of thermal oxidizers for

Control Option 1.

The use of Option 1 with carbon adsorption is expected to

entail lower incremental energy consumption. According to an EPA

study, electricity consumption for a regenerable, fixed bed carbon

adsorber was estimated to be between 14 and 30 percent of the

electricity demand for a regenerative thermal incinerator, for

equivalent process stream compositions and flowrates.2 No natural

gas use is expected for carbon adsorption, assuming that steam for

desorption (carbon regeneration) is available on-site. Moreover,

carbon adsorption as part of a solvent recovery system may provide

solvent for reuse in the manufacturing process. At minimum, solvent

recovery is expected to yield fuel that can be burned on-site,

resulting in energy savings.

Option 2 is expected to have incremental electricity

consumption similar to Option 1 with carbon adsorption. Also, Option
5-5

2 would correspond to lower incremental natural gas consumption,

since oxidizers would not be operated. The source reduction benefit

of recovered solvent and energy savings of usable fuel are expected

with this control option as well.

Conversion to low-HAP coatings (Option 3), usually, would

represent a decrease in the total energy requirement associated with

HAP control, since the energy associated with stream capture and

control would not be needed. However, special cases in which the

full energy savings may not be realized include: (1) tandem coating

operations, in which water-based coatings and solvent-based coatings

are applied on the same coating line to the same products;

(2) reformulation involving the substitution of HAP components with

volatile organic compounds (VOC) that are not HAP; and, (3) waterbased coatings for film coating. The first case may involve higher

natural gas consumption by add-on controls on the coating line

because of a lower exhaust inlet temperature due to drying highmoisture coatings. Higher electricity consumption may also be

associated with greater dryer airflow to dry high-moisture coatings.3

In the second case, the facility may not be able to discontinue the

use of add-on controls because of State regulations for VOC control

and emissions. In the third case, corona treaters may be needed to

be operated to treat surfaces of films so that they accept waterbased formulations.

5.3 AIR IMPACTS

The primary air impact of implementing the control options is

reduced emissions of HAP to the atmosphere. Based on POWC survey

responses,4 similar reductions are expected for VOC. Emissions of

other pollutants are generated with Option 1 due to the burning of

fuel and the production of electricity required for fan power. 

Secondary emissions were estimated for the following pollutants:

nitrogen oxides (NOx), sulfur dioxide (SO2), carbon monoxide (CO),
5-6

carbon dioxide (CO2), and particulate matter (PM). Complete

combustion of hydrocarbons generates CO2, water, and PM; incomplete

combustion generates, in addition, CO and SO2. All types of

combustion in air generate NOx, with more generated during incomplete

combustion.

Table 5-4 shows the emissions impacts of Option 1 with thermal

oxidation, in terms of incremental HAP reduced and secondary

pollutant emissions for each of the POWC model plants. Secondary

emissions from natural gas combustion in thermal oxidizers were

calculated using the following emission factors: 100 lb NOx per

million scf of natural gas, 0.6 lb SO2 per million scf, 84 lb CO per

million scf, 120,000 lb CO2 per million scf, and 7.6 lb PM per

million scf.5 Secondary emissions from electric power production

were calculated using the following emission factors: 1.9 lb NOx per

thousand kW-hr, 4.25 lb SO2 per thousand kW-hr, 702 lb CO2 per

thousand kW-hr,6 0.078 lb CO per thousand kW-hr, and 0.081 lb PM per

thousand kW-hr.7 Electricity production was assumed to be entirely

from coal combustion to correspond to a worst-case estimate;

electricity production via “cleaner” methods (i.e., hydroelectric or

nuclear power) would result in lower pollutant emissions. 

Table 5-5 shows the estimated national emissions impacts of the

application of Option 1 with thermal oxidation. This estimate was

developed by scaling up the model plant energy impacts to the 203

estimated major sources in the U.S. Scale-up factors were developed

from the proportion of major sources in the POWC database represented

by each model plant group (see Table 5-1) applied to the estimated

total number of POWC major sources in the U.S.

Selection of other control options could result in equivalent

HAP/VOC reductions. However, other control options would generate

different incremental changes in secondary pollutant emissions. The

use of Option 1 with carbon adsorption is expected to correspond to 
5-7

Table 5-4. Air Impacts of Control Option 1

for the POWC Model Plants

Model

Plant

Air Impacts of Control Option 1, tons per year

HAP/VOC

Reduced

NOx

Emitted

SO2

Emitted

CO

Emitted

CO2

Emitted

PM

Emitted

1a 94 4.3 4.7 1.9 3,382 0.3

1b 1,677 11.8 16.1 4.2 8,194 0.7

1c 0 0 0 0 0 0

2a 124 2.0 2.4 0.8 1,459 0.1

2b 1,135 15.6 34.8 0.6 5,739 0.7

3a 137 1.8 2.2 0.7 1,370 0.1

3b 1,034 2.1 4.6 0.1 755 0.1

4 50 1.0 2.3 0.04 386 0.04

5 0 0 0 0 0 0

Note: This analysis assumes the use of thermal oxidizers for Control

Option 1.

Table 5-5. Total Estimated Air Impacts of Control Option 1 

for the National POWC Industry

Air Impact

Total 

U.S. Impacts

of Control Option 1, 

tons per year

HAP/VOC Reduced 31,673

NOx Emitted 484

SO2 Emitted 666

CO Emitted 168

CO2 Emitted 331,986

PM Emitted 27

Note: This analysis assumes the use of thermal oxidizers for Control

Option 1.
5-8

lower incremental secondary emissions from electricity production,

since carbon adsorption has lower electricity consumption as compared

with thermal oxidation, as previously discussed. Option 2 is

expected to correspond to similar incremental secondary pollutant

emissions from electricity production as with carbon adsorption. 

Secondary emissions from natural gas use are not expected, since

oxidizers would not be operated.

Conversion to low-HAP coatings (Option 3) is a pollution

prevention measure, with capture and control systems generally not

needed. However, in the previously discussed exception where low-HAP

coatings and solvent-based coatings are applied on the same coating

line to the same products, more secondary emissions due to natural

gas combustion may be generated due to a lower exhaust inlet

temperature from the drying of high-moisture coatings.8 Also, when

HAP chemicals are replaced with VOC chemicals in coating

formulations, add-on controls may not be discontinued because of

State regulations for VOC control and emissions. Little change in

the amount of secondary emissions from existing control systems are

then expected.

5.4 WATER IMPACTS

Water impacts resulting from the implementation of the control

options at POWC plants are expected to be small. No significant

amount of liquid waste is generated from the use of thermal

oxidizers.9 Incremental increases in wastewater may result from the

following: (1) plants that use steam for carbon bed desorption in new

or improved solvent recovery systems; and, (2) plants that

reformulate to water-based coatings. In the latter case, there may

be some increase in wastewater generated, since cleaning operations

are more likely to involve water.
5-9

5.5 SOLID WASTE IMPACTS

Solid waste impacts resulting from the implementation of the

control options at POWC plants are not expected to be significant. 

No solid or hazardous wastes are generated from the use of thermal

oxidizers.10 Cases that could involve incremental increases in solid

waste include: (1) plants that use new or improved catalytic

oxidizers and, (2) plants that upgrade carbon adsorbers for existing

or new solvent recovery systems. In the first case, spent catalysts

may require disposal as hazardous waste. However, due to the cost of

the catalyst, it is expected that the incinerator would be operated

in a way that maximizes the catalyst life (expected to be more than

10 years). In the second case, although most of the spent carbon

could be sold for reprocessing, the remainder would become solid

waste.
5-10

5.6 REFERENCES 

1. Memorandum from Jones, D., EC/R, Inc., Durham, North Carolina,

to D. Brown, U.S. Environmental Protection Agency, Research

Triangle Park, North Carolina. March 25, 1999. Paper and other

web coating national estimates.

2. Survey of Control Technologies for Low Concentration Organic

Vapor Gas Streams (EPA-456/R-95-003). U.S. Environmental

Protection Agency, Research Triangle Park, North Carolina. May,

1995. Tables B-5 to B-8, B-13 to B-16.

3. Memorandum from Bhatia, K. And Jones, D., EC/R Inc.,Durham,

North Carolina, to D. Brown, U.S. Environmental Protection

Agency, Research Triangle Park, North Carolina. March 15,1999.

Summary of specialty coating operations derived from AF&PA

trips.

4. Docket No. A-99-09. U.S. Environmental Protection Agency,

Washington, DC. 1999. Response to paper and other web coating

NESHAP survey.

5. Compilation of Air Pollutant Emission Factors (AP-42). Volume

I (5th edition). U.S. Environmental Protection Agency, Research

Triangle Park, North Carolina. March, 1998. pp. 1.4-5 to 1.4-

6.

6. Data from EPA*s Acid Rain program (<www.epa.gov/acidrain/

score97/es1997.html>)

7. Data from EPA*s National Pollutant Emission Trends Update,

1970-1997 on EPA*s TTN CHIEF site (<www.epa.gov/ttn/chief/

trends97>)

8. Reference 3.

9. Stationary Source Control Techniques Document for Fine

Particulate Matter (EPA-452/R-97-00l). U.S. Environmental

Protection Agency, Research Triangle Park, North Carolina.

October, 1998. pp. 5.5-19.

10. Reference 9.
6-1

6.0 MODEL PLANT CONTROL OPTION COSTS

6.1 INTRODUCTION

This chapter presents the estimated costs of applying Control

Option 1 with the use of thermal oxidizers to the paper and other web

coating (POWC) model plants. This control option involves the use of

permanent total enclosures (PTEs) and thermal oxidizers to achieve an

95 percent HAP overall control efficiency (OCE). The model plants

and the criteria used to choose them were described in Chapter 4. 

Control options applicable to the POWC industry were also described

in Chapter 4. Costs are presented for both existing and new

facilities.

Control Option 1 with thermal oxidizers was chosen because this

option was expected to be the worst-case for costs and impacts. All

other control options, therefore, are expected to have lower costs

(and less energy impacts).

Sometimes, catalytic incineration may be more appropriate for

the solvents in use at POWC facilities. Catalytic incineration

systems would have lower operating costs and may have total

annualized costs less than the estimates for thermal oxidation

systems. Concentrator systems may be used to reduce the size and,

therefore, the capital and operating costs of the catalytic oxidizer.

Similarly, solvent recovery may be more appropriate as a

control method. As discussed in Chapter 5, the electricity

consumption is expected to be lower for a solvent recovery system

than for a thermal oxidizer.1 In addition, the associated natural
6-2

gas use is expected to be no more than that required for the thermal

oxidizer, and the recovered solvent would have some additional fuel

value. Thus, overall costs for a solvent recovery system are

expected to be lower.

Alternatively, some facilities may choose to switch to low HAP

coatings. Switching to low HAP coatings could, sometimes, represent

a net savings over baseline levels of control. The applicability of

this option depends largely on the type of coating and the

performance requirements of the product. Where feasible, conversion

to low HAP coatings could result in substantial reductions in

operating costs, compared with the use of add-on controls. Note that

low HAP coatings may still require operation of a control device to

meet volatile organic compound (VOC) emissions standards established

by other regulations if VOC has been substituted for the HAP

eliminated.

New source costs were based on upgrading to the new source MACT

level of control (98 percent OCE) a facility with an emission control

configuration that would be expected in the absence of any new

regulation. This emission control configuration was assumed to be a

PTE and a thermal oxidizer operating at 95 percent destruction

efficiency. The upgraded facility was based on the same control

configuration, but the thermal oxidizer destruction efficiency was

increased to 98 percent. Model plant 4 was chosen as the best

representation of this facility for costing purposes.

6.2 CAPTURE AND CONTROL APPROACH

The POWC model plants are presented in Table 6-1. The capture

and control approaches to implementing Control Option 1 for the model

plants are summarized in Table 6-2. 
6-3

Table 6-1. Specifications for Model Plants Representing 

the POWC Industrya

Model Plant 

No.

Coating Line

Overall HAP

Control

Efficiency,

percent

Controlled

Coating Line 

HAP

Emissions, 

tpy

Coating

Use,

tpy

Average

Number of

Coating

Lines

Average

Number of

Coating

Stations

Uncontrolled

Coating Line 

HAP

Emissions, 

tpy

HAP Capture

Efficiency,

percent

HAP

Destruction

Efficiency,

percent

1a 0 99 2,108 2 5 99 0 0

1b 0 1,765 7,521 12 9 1,765 0 0

1cb 0 48 6,597 3 17 48 0 0

2a 50 138 8,607 5 11 276 55 90

2b 50 1,261 369,929 31 154 2,522 53 95

3a 80 183 7,518 3 8 915 89 90

3b 80 1,378 14,516 8 15 6,890 84 95

4 90 99 3,431 4 12 990 95 95

5 95 40 5,498 5 19 800 97 98

a tpy = tons per year.

b

Although a control efficiency of zero is stated, this model plant is assumed to be using compliant

coatings with less than or equal to 0.20 lb HAP per lb coating solids that are considered equivalent

to 95 percent overall control. Therefore, no additional control is needed to comply with Control

Option 1.
6-4

Table 6-2. Capture and Control Approach for the POWC Model Plants 

with Control Option 1

Model

Plant

Model Plant

Coating Line

Overall HAP

Control

Efficiency,

percent

Model Plant

HAP Capture

Efficiency,

percent

Model Plant

HAP

Destruction

Efficiency,

percent

Approach for Capture and Control 

to Comply with Control Option

1

a,b

1a 0 0 0 PTE and new T.O., plus MR&R

1b 0 0 0 PTE and new T.O., plus MR&R

1c 0 0 0 MR&R

2a 50 55 90

PTE and increase T.O.

destruction efficiency, plus

MR&R

2b 50 53 95 PTE, plus MR&R

3a 80 89 90

PTE and increase T.O.

destruction efficiency, plus

MR&R

3b 80 84 95 PTE, plus MR&R

4 90 95 95 PTE, plus MR&R

5 95 97 98 MR&R

a PTE = permanent total enclosure; T.O. = thermal oxidizer; MR&R = monitoring, recording, and

recordkeeping.

b Control Option 1 is the use of a PTE and a thermal oxidizer operating at 95 percent destruction

efficiency to achieve an OCE of 95 percent.
6-5

As shown in Table 6-1, Model Plants 1a and 1b do not have any

capture or control devices. To implement Control Option 1, it was

assumed that a PTE would be installed to increase the capture

efficiency to 100 percent, and a new thermal oxidizer (T.O.) with a

destruction efficiency of 95 percent would be added, to produce an

overall control efficiency of 95 percent. Model plant 1c uses

compliant coatings equal to an OCE of 95 percent and, thus, no

additional control was needed to meet the requirements of Control

Option 1.

Model Plants 2a and 3a have less than 100 percent capture and

destruction efficiencies of 90 percent. The approach to implement

Control Option 1 for these model plants included installing a

permanent total enclosure, and increasing the destruction efficiency

of the existing thermal oxidizers from 90 to 95 percent.

Three of the remaining model plants (2b, 3b, and 4) have 

destruction efficiencies equal to 95 percent and capture 

efficiencies less than 100 percent. Therefore, it was assumed that a

PTE would be installed at these facilities to implement Control

Option 1, increasing the capture efficiency to 100 percent and the

corresponding OCE to 95 percent. Since Model Plant 5 has an OCE of

95 percent, no increase in capture or destruction efficiency was

needed to implement Control Option 1. Because monitoring,

reporting, and recordkeeping (MR&R) costs apply to all facilities,

these costs were applied to each model plant, including Model

Plants 1c and 5. 

6.3 MODEL PLANT CAPITAL AND ANNUAL COSTS - EXISTING SOURCES

The capital and annual costs of the four primary cost items to

meet Control Option 1 are presented in this section. The four cost

items are: (1) installation of a permanent total enclosure, (2) a new

thermal oxidizer, (3) increasing destruction efficiency of existing

thermal oxidizers from 90 to 95 percent, and (4) monitoring,
6-6

reporting, and recordkeeping. Each of the model plants will incur at

least one of these cost items and some combination, but not all, of

the others.

6.3.1 Permanent Total Enclosures--Cost Related Background

A PTE is an enclosure that surrounds a source of emissions such

that all emissions are captured and contained, usually for discharge

to a control device. If the EPA's five point criteria for a fully

enclosed room from Method 204 are met, 100 percent capture of the

contaminants in the room can be assumed. These criteria are not

discussed here, but detailed discussions can be found in the

literature.2,3,4

The process of designing a PTE for any given capture

application can be broken down into four basic areas of concern: 

regulatory, operational, safety and health, and economic. Each area

must be considered alone and with the others. For example, designing

an enclosure based solely on regulatory requirements would not ensure

operator safety. Similarly, a PTE designed solely with safety in

mind could result in several operational and economic deficiencies.5,6

The regulatory issues consist primarily of meeting the five

criteria established for PTEs in Method 204 as mentioned above. 

Operational considerations include material selection and

process/operator needs. Common PTE materials of construction are

plastic over frame, frame and drywall, sheet metal, prefabricated

panels, plywood, and cinder block. Important process/operator needs

include optimum product flow, operator access, maintenance

accessibility, and expansion capability.7,8 

Safety and health considerations have a significant impact on

all the other areas of PTE design consideration. Room ventilation

and air changes must be considered for their effect on health and

safety. There is no specific ventilation or air change requirements
6-7

established by the EPA for PTE design. The Occupational Safety and

Health Administration (OSHA) does recommend four air changes per hour

in dusty environments, but does not address gaseous environments. 

Some industry experts recommend between four and twelve air changes

for gaseous environments, depending on the application.9 One

recognized PTE expert who has been involved with more than 100 PTE

installations, believes PTEs with less than four room air changes per

hour are uncomfortable for workers and may result in product quality

problems for facilities; further, all PTEs should be designed for at

least ten room air changes per hour, whenever possible.9 The airflow

characteristics of the PTE are important to insure that a steady flow

of fresh air is supplied around or past operator work stations. 

Odors and explosion potential are additional health and safety

concerns that must be considered in the design of a PTE.10 

There are also economic considerations involved in designing a

PTE. The costs associated with PTE installations vary with the scope

of the project. The construction cost of a PTE is dependent upon how

much cutting is needed to place walls or ceilings, the type of doors

used, the amount of duct work that has to be modified to meet the

Method 204 criteria, how much air conditioning is needed (if any),

and the degree to which modifications to the make up air system are

required.11 One consulting firm with experience in more than 100 PTE

installations reports that total PTE installation costs can range

from $8,000 to $200,000, depending on the size and scope of the work

involved.12,13 Costs for a PTE can be higher where substantial airconditioning changes are required, or cuts are needed for conduits,

ducts, pipes, electrical switchgear, etc.14,15

A common misconception concerning the installation of PTEs is

the assumption that increased air volumes will need to be handled,

and, therefore, the control device will need to be bigger to handle

the increased airflow. While this is true for some PTE
6-8

configurations, a well-designed enclosure can be adequately

ventilated using the existing process exhaust air flow.16,17,18,19,20 By

incorporating airflow reduction techniques, such as cascading the

exhaust air from a lower concentration source to a higher

concentration source, lowering the ceiling/raising the floor, and the

use of closed-loop systems, air flows can be sometimes decreased over

those associated with the process before the installation of the

PTE.21,22,23 One company that has retrofitted PTEs at more than 50

plant sites in ten different industries has found that air flows from

the workplace can be reduced by 25 to 50 percent while simultaneously

enhancing the air quality in the working environment.24

Another popular misconception concerning PTE use is that the

operator’s environment is necessarily compromised due to the

concentration of contaminants in the reduced work area. In a welldesigned PTE with appropriate room air changes, well-designed

ventilation pattern, and sometimes, addition of a closed-loop airconditioning system, the air quality within the enclosure is often

far better than pre-PTE conditions.25,26,27,28

There are five basic designs for the PTEs built over the last

ten years. These include: (1) large room/building PTE using existing

walls; (2) PTE for one or more sources using newly constructed walls;

(3) PTE around the wet end of equipment (manned); (4) PTE attached to

or made part of the equipment (unmanned); and (5) PTE within a PTE

(for use of compliant and noncompliant materials).29 One firm with

extensive PTE installation experience has found that most facility

owners/operators initially desire that the entire room be the

enclosure with little modification and little disruption to their

existing operations. Worker comfort and lower explosive limit

evaluations lead to other decisions on PTE designs.30 This costing

analysis assumes that the PTE would consist of either the entire

coating room or completely cover each of the coating lines. 
6-9

6.3.2 PTEs for the Model Plants

The costs of the PTEs for the model plants were based on case

study information from the literature,31 adjusted to reflect the

estimated relative size of the coating rooms and anticipated

difficulty of installation (number of cuts needed, etc.).32 Since

the PTEs must be custom-designed for each facility, it was not clear

if these engineering/design costs were fully accounted for in the

case study costs. Therefore, an additional engineering cost, equal

to 10 percent of the cost of the PTE, was assumed for the model

plants. Further, it was assumed that spot air conditioning (AC)

would be installed along with the PTE, with the cost of the AC

estimated based on the exhaust flowrates for each model plant.33 The

total model plant capital costs of the PTE-related components varied

from $110,000 to $1.7 million. The capital costs associated with the

design and installation of a PTE for the POWC model plants are

presented in Table 6-3.34

The annual PTE costs are presented for each of the model plants

in Table 6-4. These costs include the capital recovery 

costs associated with the capital investment, plus the electricity

required to operate the spot air conditioning. The annual model

plant costs of the PTEs range from approximately $37,000 to

$873,000.35

6.3.3 New Thermal Oxidizers

For Model Plants 1a and 1b, which have no capture or control

systems, costs for new thermal oxidizers were estimated, along with

the costs associated with the installation and operation of PTEs. 

Because of the relatively high air flows associated with these two

model plants, it was assumed to be reasonable that regenerative

thermal oxidizers would be chosen. The costs associated with the new

regenerative thermal oxidizers were estimated using costing

spreadsheets developed by the EPA.36 
6-10

Table 6-3. Capital Costs of Permanent Total Enclosures

for the POWC Model Plants

Model Plant

Exhaust,

scfm

PTE Cost, 

$

Engineering

Cost,

 $

Airconditioning

Capital

Cost, $

Total PTErelated

Capital

Cost, $

1a 61,829 20,000 2,000 106,000 128,000

1b 212,620 130,000 13,000 170,000 313,000

1c 71,089 N/A N/A N/A N/A

2a 115,751 50,000 5,000 94,000 149,000

2b 1,690,700 260,000 26,000 1,400,000 1,690,000

3a 108,703 20,000 2,000 88,000 110,000

3b 222,390 100,000 10,000 180,000 290,000

4 113,698 50,000 5,000 92,000 147,000

5 92,320 N/A N/A N/A N/A

Assumptions:

1) All costs 1998 dollars.

2) Base permanent total enclosure (PTE) cost based on case studies37,38 and engineering judgement.39

3) PTE costs of individual model plants based on estimated relative size of coating room, and engineering

judgement.40

4) Engineering cost estimated as 10 percent of PTE cost.41

5) Air conditioning (AC) calculations assume spot air conditioning is installed.

6) Air-conditioning cost based on cost factors of 25 tons per 20,000 scfm, and $30,000 per 25 tons

capacities.42

7) Electricity required for AC capacity calculated using an equation from the literature.43
6-11

Table 6-4. Annual Costs Associated with Installation 

and Operation of Permanent Total Enclosures (PTE) 

for the POWC Model Plants 

Model Plant 1a 1b 1c 2a 2b 3a 3b 4 5

Total

Capital

Investment,

$

128,000 313,000 N/A 149,000 1,686,000 110,000 290,000 147,000 N/A

ANNUAL COSTS, 1998 DOLLARS

Electricity,

$/yr

26,967 92,737 N/A 50,486 737,418 47,412 96,998 49,591 N/A

Capital

Recovery, 

$/yr

10,315 25,224 N/A 12,007 135,869 8,865 23,370 11,846 N/A

Total Annual

Costs 

$37,282 $117,960 N/A $62,493 $873,287 $56,277 $120,368 $61,437 N/A

Assumptions:

1) Total capital investment includes cost of PTE, engineering, and spot air conditioning capacity, as

described in Table 6-3.44

2) PTE capital costs based on estimated size of coating room, case study cost data, and engineering

judgement.45,46

3) Electricity required for calculated AC capacity calculated using equation presented in the

literature.47

4) Capital recovery based on a 10-year equipment life, 7 percent interest rate.48,49,50

5) Electricity costs based on 6,600 hours of operation per year and a unit rate of $0.0451/kWh, based on

information from Energy Information Administration for 1998.51
6-12

The capital costs associated with installation of new thermal

oxidizers and associated PTEs at model plants 1a and 1b are presented

in Table 6-5. The capital costs are those associated with (1) the

new regenerative thermal oxidizer, and (2) the PTE. The capital

costs for Model Plants 1a and 1b were estimated at approximately $2.5

million and $6.8 million, respectively.

The annual costs associated with installation of new thermal

oxidizers and associated PTEs at model plants 1a and 1b are also

presented in Table 6-5. Besides capital recovery costs, these

annual costs also include annual costs for labor and maintenance

materials; natural gas for the thermal oxidizer; electricity for the

thermal oxidizer and the PTE air conditioning; annual monitoring,

reporting, and recordkeeping costs; and overhead and other

miscellaneous costs. The annualized costs of new thermal 

oxidizers and associated PTEs for Model Plants 1a and 1b were

approximately $725,000 and $1.9 million, respectively.

6.3.4 Increasing Destruction Efficiency of Existing Thermal

Oxidizers

To meet the requirements of Control Option 1 with Model Plants

2a and 3a, the destruction efficiencies of the existing thermal

oxidizers were increased from 90 to 95 percent and a PTE was used to

increase the capture efficiency to 100 percent. The capital costs of

this capture and control approach are presented for Model Plants 2a

and 3a in Table 6-6. The capital costs associated with any capital

improvements to the existing thermal oxidizers that may be needed

were estimated as 10 percent of the cost of a new regenerative

thermal oxidizer. The capital costs of PTE and monitoring,

reporting, and recordkeeping requirements were calculated as

described for the other model plants, above.
6-13

Table 6-5. Regenerative Thermal Oxidizer Capital and Annual

Operating Costs for POWC Model Plantsa,b,c

Model Plant 1a 1b

Flowrate to Thermal Oxidizer, scfm 61,829 212,620

CAPITAL INVESTMENT

T.O. and auxiliaries (A) $2,351,820 $6,467,733

PTE (B) $128,000 $313,000

MR&R (C) $0 $0

Total Capital Investment (A+B+C) $2,479,820 $6,780,733

ANNUAL COSTS

Operating labor $15,515 $15,515

Supervisory labor $2,327 $2,327

Maintenance labor $2,151 $2,151

Maintenance materials $2,151 $2,151

Natural gas $134,940 $286,649

Electricity associated with T.O.

operation $71,903 $247,096

Electricity associated with PTE

operation $26,967 $92,737

Overhead $13,287 $13,287

Taxes, insurance, administration $99,193 $271,229

Capital recovery for T.O. and PTE $345,161 $960,648

Capital recovery for MR&R $0 $0

MR&R $11,827 $11,827

Total Annual Costs $725,422 $1,935,616

a Calculated using the EPA cost spreadsheet program for regenerative

thermal oxidizers.52

b In 1998 dollars.

c

T.O. = thermal oxidizer, PTE = permanent total enclosure,

MR&R = monitoring, recording, and recordkeeping
6-14

Assumptions:

1) Permanent total enclosure (PTE) costs estimated based on case studies

and engineering judgement.53,54,55

2) PTE costs assume engineering = 10 percent PTE cost; spot air

conditioning, 10-year life, 7 percent interest rate.56,57,58,59

3) Because regenerative thermal oxidizers are field built, it was assumed

that ductwork costs are included in the Total Capital Investment

estimate.60,61

4) Assumes 95 percent heat recovery, 20 inch pressure drop, 6,600 operating

hours per year.62

5) Operator labor rate = $37.61/hr, maintenance labor rate = 1.1*operator

rate =$41.37/hr. Both based on escalated Bureau of Labor Statistics

data for 1998.63

6) Electricity cost $0.0451/kWh, natural gas cost $3.099/mscf, both based

on information from Energy Information Administration for 1998.64,65

Table 6-6. Capital and Annual Costs of Increasing Destruction

Efficiency of Existing T.O.s in the POWC Industry a,b

MODEL PLANT 2a 3a

CAPITAL COSTS

Improvements to existing T.O. (A) $382,480 $363,044

PTE (B) $149,000 $110,000

MR&R (C) $0 $0

Total Capital Costs (A+B+C) $531,480 $473,044

ANNUAL COSTS

Capital recovery of A,B,C above $68,585 $62,121

Increased fuel and electricity (T.O.) $55,090 $51,718

Increased electricity for PTE $50,486 $47,412

MR&R $11,827 $11,827

Total Annual Costs $185,988 $173,078

a

All costs in 1998 dollars.

b

T.O. = thermal oxidizer. PTE = permanent total enclosure

MR&R = monitoring, reporting, and recordkeeping

Assumptions:

1) Overall control efficiencies of existing oxidizers were increased to 95

percent by a) adding a PTE, b) increasing combustion temperature, and c)

making any necessary capital improvements to the existing oxidizers to

allow increased destruction efficiency to be achieved.
6-15

2) Cost of capital recovery calculated based on a 10-year equipment life

and 7 percent interest rate (according to OMB guidance).66,67,68

3) Increased fuel and electricity costs for thermal oxidizer were

calculated (using the EPA regenerative thermal oxidizer spreadsheet) as

the difference in fuel and electricity costs for an oxidizer of the

appropriate size operating at combustion temperatures of 1300oF and

1600oF.69 

4) Operator labor rate = $37.61/hr, maintenance labor rate = 1.1*operator

rate =$41.37/hr. Both based on escalated Bureau of Labor Statistics

data for 1998.70

5) Electricity cost $0.0451/kWh, natural gas cost $3.099/mscf, both based

on information from Energy Information Administration for 1998.71,72

The annual costs of increasing the destruction efficiency of

the existing thermal oxidizers at Model Plants 2a and 3a, including

those associated with the PTE and monitoring, reporting, and

recordkeeping, are also presented in Table 6-6. 

The increased natural gas and electricity usage associated with

increasing the destruction efficiency from 90 to 95 percent was

calculated (using the EPA costing spreadsheets) as the difference in

fuel and electricity use for an appropriately-sized regenerative

thermal oxidizer operating at 1300oF and 1600oF.73 The costs of

capital recovery were added to these increased fuel and electricity

costs to estimate the annualized costs for Model Plants 2a and 3a as

approximately $186,800 and $173,000, respectively. The capital costs

of increasing the destruction efficiency from 90 to 95 percent,

including the associated PTE and monitoring, reporting, and

recordkeeping, were approximately $531,000 and $473,000 for Model

Plants 2a and 3a, respectively.

6.3.5 Monitoring, Reporting, and Recordkeeping

There will be monitoring, reporting, and recordkeeping

requirements for all affected POWC facilities, and therefore, for all

of the model plants. In addition, the model plants with capture and

control devices will require parameter monitoring devices for the

capture and control systems, such as pressure and/or temperature

monitors. Because such monitoring devices are typically included in
6-16

the cost of the control device, no additional capital costs were

included here.

The annual monitoring, reporting, and recordkeeping costs for

each of the model plants are presented in Table 6-7. The model plant

total annual monitoring, reporting, and recordkeeping costs were

$14,322 for all model plants except for 1c. This model plant was the

only one using all compliant coatings, resulting in an increased MR&R

burden. The total annual MR&R costs for Model Plant 1c were $17,231. 

These costs reflect the requirements specified in the proposed

regulation and for which detailed labor hour and cost estimates were

developed in the Standard Form 83-I Supporting Statement.74

Table 6-7. Capital and Annual Operating Costs Associated with

Monitoring, Recording, and Recordkeeping (MR&R) Requirements 

for the POWC Model Plants

Model Plant

MR&R Annual Operating

Cost

1a $14,322

1b $14,322

1c $17,231

2a $14,322

2b $14,322

3a $14,322

3b $14,322

4 $14,322

5 $14,322

Assumptions:

1) All costs 1998 dollars.

2) Annual operating costs are detailed in the Standard Form 83-I Supporting

Statement.75
6-17

6.4 TOTAL COSTS AND COST EFFECTIVENESS - EXISTING SOURCES

The total capital investment (capital cost) for each capture

and control approach for the nine model plants with Control Option 1

is summarized in Table 6-8. Depending on the capture and control

approach taken, these capital costs include the costs of new thermal

oxidizers or improvements to existing thermal oxidizers, and PTEs. 

Because Model Plant 1c uses all compliant coatings and Model Plant 5

is already achieving 95 percent OCE

through the use of controls, there were no capital costs for these

model plants. The total capital costs for the remaining model plants

ranged from approximately $147,000 to $6.8 million. 

The total annual costs of the capture and control approach to

Control Option 1 for the nine model plants are presented in 

Table 6-9. These total annual costs include capital recovery costs

and operating costs such as labor, fuel, and electricity, as well as

MR&R costs. The total annual costs for the model plants ranged from

approximately $12,000 to $1.9 million.

The cost effectiveness of the capture and control approaches

for the nine model plants are presented in Table 6-10. The amount of

HAP controlled represents the additional HAP controlled from

implementing the capture and control approach to implement Control

Option 1 in the model plants. For instance, for Model Plants 1a and

1b, which have no control, the HAP controlled represents 95 percent

of the uncontrolled emissions. Model Plants 2b, 3b, and 4, however,

all have existing capture and control systems. The HAP controlled

for these model plants represents the additional HAP that is

controlled by increasing the capture efficiency to 100 percent by 
6-18

Table 6-8. Total Model Plant Capital Costs for Complying with Control Option 1

Model Plant

Approach for Capture

and Controla

Average

Number of

Coating

Lines

Average

Number of

Coating

Stations

Coating Use,

tpy

Uncontrolled

Coating Line 

HAP

Emissions, 

tpy

Total 

Model Plant 

Capital

Costsb

1a PTE and new control device 2 5 2,108 99 $2,479,820

1b PTE and new control device 12 9 7,521 1,765 $6,780,733

1c no change 3 17 6,597 48 $0

2a PTE and increase T.O. efficiency 5 11 8,607 276 $531,481

2b PTE 31 154 369,929 2,522 $1,686,000

3a PTE and increase T.O. efficiency 3 8 7,518 915 $473,044

3b PTE 8 15 14,516 6,890 $290,000

4 PTE 4 12 3,431 990 $147,000

5 no change 5 19 5,498 800 $0

a PTE = permanent total enclosure

T.O. = thermal oxidizer

b Includes MR&R for all model plants.
6-19

Table 6-9. Total Model Plant Annual Costs for Complying with Control Option 1

Model

Plant

Approach for Capture

and Controla

Average

Number of

Coating

Lines

Average

Number of

Coating

Stations

Coating Use,

tpy

Uncontrolled

Coating Line 

HAP

Emissions, 

tpy

Total Annual 

Model Plant

Costsb

1a PTE and new control device 2 5 2,108 99 $725,422

1b PTE and new control device 12 9 7,521 1,765 $1,935,616

1c no change 3 17 6,597 48 $17,231

2a PTE and increase T.O. efficiency 5 11 8,607 276 $185,988

2b PTE 31 154 369,929 2,522 $885,113

3a PTE and increase T.O. efficiency 3 8 7,518 915 $173,077

3b PTE 8 15 14,516 6,890 $132,194

4 PTE 4 12 3,431 990 $73,263

5 no change 5 19 5,498 800 $11,827

a PTE = permanent total enclosure; T.O. = thermal oxidizer

b Includes MR&R for all model plants.
6-20

Table 6-10. Cost Effectiveness of Capture and Control Approaches 

to Control Option 1 for the POWC Model Plants

Model

Plant

Approach for Capture and

Controla

HAP

Reduction,

tpy

Annual

Cost,

1998$

Cost

Effectiveness

, $/ton

1a PTE and new control device 94 $725,422 7,717

1b PTE and new control device 1,677 $1,935,616 1,154

1c Compliant coatings/no change 0 $17,231 N/A

2a PTE and increase T.O. efficiency 124 $185,988 1,500

2b PTE 1,135 $885,113 780

3a PTE and increase T.O. efficiency 137 $173,077 1,263

3b PTE 1,034 $132,194 128

4 PTE 50 $73,263 1,465

5 no change 0 $11,827 N/A

a PTE = permanent total enclosure

T.O. = thermal oxidizer
6-21

adding a PTE. The cost effectiveness for the nine POWC model plants

ranged from approximately $130 to $7,700 per ton of incrementally

controlled HAP.

6.5 MODEL PLANT CAPITAL AND ANNUAL COSTS - NEW SOURCES

Based on projected growth rates for the four major POWC

industry SIC codes, it was estimated that 32 new major source POWC

facilities will be built in the five years following promulgation of

the regulation.76 For costing purposes, Model Plant 4 was chosen as

being the most representative of the level of control these new

facilities will use absent any new regulation. Thus, the baseline

level of control for the new facilities was assumed to be a PTE

operating at 100 percent efficiency and a thermal oxidizer operating

at 95 percent destruction efficiency.

In order to estimate the cost for new facilities to upgrade

from the baseline level of control to the new source MACT floor level

of control of 98 percent OCE, it was assumed that the facility would

make capital improvements to the existing thermal oxidizer to

increase its destruction efficiency to 98 percent. The costing

methodology presented in Section 6.3 was used for the annual costs of

operating the PTE. The improvements in the operation of the thermal

oxidizer were assumed to require 10 percent of the capital cost of a

new thermal oxidizer. The estimated annual cost for the operation of

the thermal oxidizer was based on the increased cost of operation at

1800EF versus 1600EF. Total annual costs also include MR&R costs.77

The new source annual and capital costs were estimated to be

approximately $5.2 million and $12 million, respectively. These

costs are summarized in Table 6-11.
6-22

Table 6-11. Annual and Capital Costs of Achieving New Source MACT

Floor Level of Control

POWC Costs Facility

Costs

Number of

New

Facilities

Total Annual

Cost

Annual Costs Associated with... 

Operation of Permanent Total

Enclosure (PTE)

$61,437 32 $1,965,984

Monitoring, Reporting, and

Recordkeeping (MR&R) Requirements

$11,827 32 $378,464

Capital Improvements and Operation

of New Thermal Oxidizers (TO)a

$89,725 32 $2,871,200

Total Annual Cost of Complying with

98 Percent OCE

$162,989 32 $5,215,648

Capital Costs Associated with...

Purchase of Permanent Total

Enclosure (PTE)

$0 32 $0

Capital Improvements to New Thermal

Oxidizers (TO) Operating at 1800

degrees F

$376,753 32 $12,056,096

Equipment for Monitoring, Reporting,

and Recordkeeping (MR&R)

Requirements of POWC Rule

$0 32 $0

Total Capital Investment for

Complying with 98 Percent OCE 

$376,753 32 $12,056,096

a Annual Costs of Capital Improvements and Operation of New Thermal Oxidizers

include: 10 percent of the capital costs of purchasing a new TO operating at

1800 degrees F plus the increase in electricity and natural gas costs from

1600 to 1800 degrees F.
6-23

6.6 REFERENCES

1. U.S. Environmental Protection Agency. Survey of Control

Technologies for Low Concentration Organic Vapor Gas Streams

(EPA-456/R-95-003). May 199S. Tables B-5 to B-8, B-13 to B-16.

2. Lukey, M. “Permanent Total Enclosures needed in Response to

Subpart KK and Changes in Test Procedures.” Paper No. 97 -

TA4B.05. Presented at Air and Waste Management Association 1997

Annual Meeting, Toronto, Ontario, Canada. June 8-13, 1997.

p. 4.

3. Bemi, D. “Demonstrating VOC Capture Efficiency using Permanent

Total Enclosure Technology: Common Practices, Challenges and

Rewards.”Paper No. 97-TA4B.04. Presented at Air and Waste

Management Association 1997 Annual Meeting, Toronto, Ontario,

Canada. June 8-13, 1997. p. 2.

4. Oiestad, A. “Fugitive VOC Capture Systems Using the ‘Total

Permanent Enclosure Concept*.” Paper No. 93-TA-33.0. Presented

at Air and Waste Management Association 1993Annual Meeting,

Denver, Colorado. June 13-18, 1993. p. 4.

5. Reference 3, p. 3.

6. Bemi, D. “Permanent Total Enclosures Used to Capture VOCs in

Process Air Streams.” EM (Environmental Managers), Air and

Waste Management Association, Pittsburgh, Pennsylvania. April

1999. 

p. 39.

7. Reference 3, p. 3.

8. Reference 6, p. 39.

9. Reference 3, p. 5.

10. Reference 2, p. 2.

11. Reference 3, p. 5.

12. Reference 2, p. 4.

13. Reference 2, p. 6-7.

14. Lukey, M. “Designing Effective and Safe Permanent Total

Enclosures.” Paper No. 93-TA-33.05. Presented at Air and Waste
6-24

Management Association 1993 Annual Meeting, Denver, Colorado.

June 13-18, 1993. pp. 12-13.

15. Reference 3, p. 6.

16. Reference 2, p. 3.

17. Reference 3, p. 7.

18. Reference 2, p. 3.

19. Lukey, M. “Five Design Options for Permanent Total Enclosures.”

Paper No. VIP-69. Presented at Air and Waste Management

Association Specialty Conference “Emerging Solutions to VOC and

Air Toxics Control,” San Diego, California. February 26-28,

1997. p. 281.

20. Turner, T. “Local capture or Total Enclosure? The Answer is

Yes!” Paper No. 94-RAlll.01. Presented at Air and Waste

Management Association 1994 Annual Meeting, Cincinnati, Ohio.

June 19-24, 1994. p. 7.

21. Reference 4, p. 2.

22. Reference 20, p. 6.

23. Reference 2, p. 3.

24. Reference 4, p. 2.

25. Reference 4, p. 2.

26. Reference 3, p. 7.

27. Reference 6, p. 41.

28. Reference 4, p. 2.

29. Reference 20, p. 4.

30. Reference 2, p. 2.

31. Reference 2, p. 3.

32. Reference 2, p. 6-7.

33. Reference 14, pp. 12-13.
6-25

34. Reference 2, p. 5.

35. Memorandum from Caldwell, M., Caldwell Environmental, Inc.,

Raleigh, North Carolina, to D. L. Jones, EC/R, Inc., Durham,

North Carolina. June 1, 1999. Explanation of POWC costing

methodology.

36. Reference 35.

37. U. S. Environmental Protection Agency. CO$T-AIR Control Cost

Spreadsheets. February 1996. Internet address: http: //www.epa.

gov/ttn/catc/products.html#cccinfo.

38. Reference 2, pp. 5-7.

39. Reference 14, pp. 12-13.

40. Reference 35.

41. Reference 35.

42. Reference 35.

43. Reference 2. 

44. Lindeburg, M. Mechanical Engineering Reference Manual. 8th 

Edition. 1990. pg. 7-28.

45. Reference 35. 

46. Reference 2, pp. 5-7.

47. Reference 35.

48. Reference 44, p. 7-28.

49. U.S. Environmental Protection Agency. National Emission

Standards for Hazardous Air Pollutants: Printing and Publishing

Industry--Background Information for Proposed Standards (EPA453/R-95-002a). February 1995.

50. U.S. Environmental Protection Agency. OAQPS Control Cost

Manual, Fifth Edition (EPA-453/B-96001). Chapter 3. December

1995. pp. 3-20 to 3-64.
6-26

51. U.S. Office of Management and Budget. 0MB Circular A-94,

“Discount rates to be used in evaluating time-distributed costs

and benefits.” Revised October 29, 1992. Website address: 

http: //www.whitehouse.gov/WH/EOP/OMB/html/circular.html.

52. U.S. Energy Information Administration, Department of Energy,

Washington, D.C. World wide web homepage. Table 9.9,Retail

Prices of Electricity sold by Electric Utilities. March 4,

1999. Website address:

http://www.eia.doe.gov.emeu/mer/contents.htm.

53. Reference 50, pp. 3-20 to 3-64.

54. Reference 2, pp. 5-7.

55. Reference 14, pp. 12-13.

56. Reference 35.

57. Reference 49.

58. Reference 50, pp. 3-20 to 3-64.

59. U.S. Office of Management and Budget. 0MB Circular A-94,

“Discount rates to be used in evaluating time-distributed costs

and benefits.” Revised October 29, 1992. Website address:

http://www.whitehouse.gov/WH/EOP/OMB/htmlicircular. html.

60. Reference 35. 

61. Reference 50, pp. 3-20 to 3-64.

62. Reference 37. .

63. Reference 37.

64. U.S. Government, Bureau of Labor Statistics. Table 11, Private

Industry: goods-producing and service-producing industries.

March 30, 1999. Website address:

http://stat.bls.gov/news.release/ecec.ttl.htm.

65. U.S. Energy Information Administration, Department of Energy,

Washington, D.C. World wide web homepage. Table 9.11, Natural

Gas Prices. March 4, 1999. Website address:

http://www.eia.doe.gov.emeu/mer/contents.htm.
6-27

66. Reference 52.

67. Reference 49.

68. Reference 50, pp. 3-20 to 3-64.

69. Reference 51.

70. Reference 37.

71. U.S. Government, Bureau of Labor Statistics. Table 11, Private

Industry: goods-producing and service-producing industries.

March 30, 1999. Website address:

http://5tat.bls.gov/news.release/ecec.ttl.htm.

72. Reference 65.

73. Reference 52.

74. Reference 37.

75. Information Collection Request for the Paper and Other Web

Coating Operations Source Category. Standard Form 83-I

Supporting Statement for 0MB Review of ICR No. 1951. U.S.

Environmental Protection Agency. March 22, 2000.

76. Reference 75.

77. Memorandum from Hendricks, D., and Lee-Greco, J., EC/R

Incorporated, Durham, North Carolina, to D. Brown, U.S.

Environmental Protection Agency, Research Triangle Park, North

Carolina. March 22, 2000. New Source MACT and Above the Floor

Costs for the Paper and Other Web Coating Source Category.
TECHNICAL REPORT DATA

(Please read Instructions on reverse before completing)

1. REPORT NO.

 EPA-453/R-00-002

2. 3. RECIPIENT'S ACCESSION NO.

4. TITLE AND SUBTITLE

 National Emission Standards for Hazardous Air Pollutants for Source

Categories: Paper and Other Web Coating Operations - Background

Information for Proposed Standards

5. REPORT DATE

 April 2000

6. PERFORMING ORGANIZATION CODE

7. AUTHOR(S) 8. PERFORMING ORGANIZATION REPORT NO.

9. PERFORMING ORGANIZATION NAME AND ADDRESS

 U.S. Environmental Protection Agency

 Office of Air Quality Planning and Standards

 Emission Standards Division (Mail Drop 13)

 Research Triangle Park, North Carolina 27711

10. PROGRAM ELEMENT NO.

11. CONTRACT/GRANT NO.

 68-D6-0010

12. SPONSORING AGENCY NAME AND ADDRESS

 U.S. Environmental Protection Agency

 Office of Air and Radiation

 Office of Air Quality Planning and Standards

 Research Triangle Park, North Carolina 27711

13. TYPE OF REPORT AND PERIOD COVERED

 

14. SPONSORING AGENCY CODE

 EPA/200/04

15. SUPPLEMENTARY NOTES

16. ABSTRACT

This document contains a summary of the EPA's current level of knowledge on hazardous air pollutants and their

emission points at paper and other web coatings production facilities. This document presents descriptions of

representative processes and operations, hazardous air pollutant emission sources and estimated emissions, and

applicable air emission control technologies. The capital and annual costs of air emission controls are also presented

in this document.

17. KEY WORDS AND DOCUMENT ANALYSIS

a. DESCRIPTORS b. IDENTIFIERS/OPEN ENDED TERMS c. COSATI

Field/Group

Hazardous air pollutants

Paper and Other Web Coatings Operations

Air pollution control

18. DISTRIBUTION STATEMENT

 Release unlimited

19. SECURITY CLASS (Report)

 Unclassified

21. NO. OF PAGES

20. SECURITY CLASS (Page)

 Unclassified

22. PRICE