313198 

where: 

E, - M. = 

K. - A ~ 

P, - 3600 ~ 

HR a 

R • 

T = 

CHAPTER 8- PAl NT AND INK MANUFACTURING 

Emissions of VOC species x from the spill (lblevent): 

Molecular 1veight of VOC species x (lbilb-mole); 

Gas-phase mass transfer coefficient for VOC species x (ftlsee); 

Surface area of spill (~; 

Partial pressure of VOC species x (if a pure chemical is spilled) or the 

partial pressure of chemical x (if a mixture ofVOCs is spilled) at 

temperarure T (psia)'; 

3600 seclhr; 

Duration of spill (hr/cvcnt); 

Universal gas constant at 1 atmosphere of pressure, 

10.73 psia · ft'llb-mole · •R; and 

Temperarure of the liquid spilled. 'R. 

The gas-phase mass tr1l11Sfer coefficient (I<.) may be calculated using Equation 8.4-16: 

where: 

-

= 

-

K, ~ 0.00438 • U 0·

78 • ( D, ) m 

3.1 x lO_. 

Gas-phase mass transfer coefficient for VOC species x (ftlsee); 

Wind speed (milelhr): 

Diffusion coefficient for VOC species x in air (11'/sec) 

(8.4-16) 

Diffusion coefficients {DJ can be found i.n chemical handbooks and are usually expressed in units 

of square centimeters per second (cm'/sec). If a diffusion coefficient is not available for a 

particular chemical, the gas-phase mass transfer coellicient (K.) may be estimated using 

Equation 8.4-17: 

( 

IS ) 

113 

K. = 0.0043~ • U •·

711 • M, (8.4-17) 

• The partial pressure of VOC species x (P.) may be calculated using Equation 8.4-3 or Equation 

8.4-4. 

EIIP VOlume II 8.4- 19 

VESOJ6000 
CHAPTER 8 · PAINT AND INK MANUFACTURING 

where: 

K, 

u 

M, = 

Gas-phuse mass tTansfer coefficient for VOC species x (11/sec); 

Wind speed (mile/hr); and 

Molecular weight ofVOC species x (lb.1b-mole). 

Example 8.4-3 illustrates the use of d1ese equations. 

Example 8.4-3 

Methyl ethyl ketone (MEK) is spilled onto the ground outside of a building. The 

following data are given: 

The spill is not detected for I hour; it takes an additional 2 hour.; to 

recover the remaining MEK; the duration of the spill (HR), therefore, 

is 3 hours. 

The average wind speed (U) is 8 rnilelhr. 

The ambienttempe111ture (1) is 77' F or 537' R ("R = ' F +460). 

The surface area of the spill (A) is 100 ftl. 

The molecular weight of MEK (M.) is 72 lbllb-mole. 

The panial pressure of MEK (P.) at 77'F is approximately 1.93 psia. 

3/3198 

8.4-20 fliP Volume 11 

VES016001 
CHAPTER 8 • PAINT AND INK MANUFACTURING 

Step 1: Using Equation 8.4·17, calcula te the Gas-phase Mass Transfer Coefficient (K,) 

( 

18) 1/) I<_ = 0.00438 • U0

·'" • M, 

; 0.00438 • 8'·'" • ( 7

128) 113 

= o.o 1397 ftfsec 

Step 2: Using Equation 8.4-IS, calculate Emissions (E,) 

M, • K ~ A • P • 3600 • HR 

E = ......::......-':......---='-- --- ' R • T 

72 * 0.01397 • )()() • 1.93 • 3600 • 3 

= .:..=._.:.:..:..:..:..:...:.....,.1 "".:=:: n:-:--5::.:::::: 7-=-.....:.:..;;.::._~ 

~ 3 64 lb MEK/spill 

4.1 .4 EMISSIONS MODEL FOR SURFACE EVAPORATION 

Emissions from surface evaporation during paint and ink mixing operations can be estimated using 

Equation 8.4·1 8, which is based on tbe Oements vaporization model. 

where: 

-

= 

-

= 

EIIP VOlume II 

M, • K, • A* P,-.. 3600 • H 

R * T 

Emissions of VOC species x (lb/yr); 

Molecular weight ofVOC species x (lbllb-molc); 

Gas-phase mass transfer coefficient for VOC species:< (ftfsec); 

Surface area of tank (ft"); 

(8.4-18) 

8.4-21 

VES0l6002 
CHAPTER 8 - PAINT AND INK MANUFACTURING 313198 

3600 = 

H = 

R = 

T • 

B = 

Vapor pressure of VOC x (if a pure chemical is used) or the partial 

pressure of chemical x (if a mixture ofVOCs is used) at temperature T 

(psia)'; 

3600 seclhr; 

Batch time (hrlbatch); 

Universal gos constant at I atmosphere of pressure, 

10.73 psia · f\1/lb mole· ' R; 

Temperature of the liquid, ' R; and 

Number of batches per year (batches/yr). 

Equations 8.4-16 or 8.4-17 can be used to estimate K,.. Total VOC emissions would equal the 

sum of all VOC species emissions. 

Example 8.4-4 illustrates the use of Equation 8.4-1 R. 

Example 8.4-4 

This example estimates emissions from a mixing operatioo due to surface evaporarioo. The 

following data are given: 

The batch time (H) is 4 hours. 

The number of batches per year (B) is 550. 

The average wind speed (U) is 0.1 miles/hr. 

The ambient temperature (T) is 77' F or 537'R (' R = •f +460). 

The surface area of the mixing tank lA) is 80 ff. 

Tite molecular weight of toluene (M.) is 92 lbllb-mole. 

The partial vapor pressure of toluene (P,) at n •r: is approximately 0.58 psia. 

• The partial pressure of VOC species x (P,) may be calculated using Equation 8.4-3 or Equation 

8.4-4. 

8.4-22 EIIP Volume II 

VES016003 
3/31118 CHAPTER 8 - PAINT AND INK MANUFACTURING 

Step I: Using Equation 8.4-17, calculate the Gas-phase Mass Transfer Coemc.ient (K.) 

K. = 0.00438 • u 1

'

111 • ( ~) 113 

G 0.00438 • 0.11·

78 • ( -

18) 113 

92 

= 0. 000422 II/ sec 

Step 2: Using Equation 8.4-IS, calculate Emissions (EJ 

M, • K, E = • A • P • 3600 " H , ~ B 

• R * T 

= 92 • 0.000422 • 80 • 0.58 • 3600 • 4 • 550 

10.73 •. 537 

= 2,4 76 lb toluenelyr 

4-1-5 EMISSION M ODEL FOR LIQUID M ATERIAL STORAGE 

The preferred method for calculating emissions from storage tanks is lhe use of equations 

presented inAP-42. EPA has developed a software package (TANKS) for calculating these types 

of emissions. The reader is referred to Chapter I of this volwne, l11troduction to Stationary Poinl 

&mrcc Emissions lnwm1ory Development, for more information on using lhe TANKS program. 

Additionally, the reader should consult their state agetiCY and/or lhe EPA's Clearinghouse for 

Inventories and Emission Factors (CHIEF) bulletin board system (BBS) or website for the most 

recent version of TANKS. 

4.1.6 EMISSION MODEL FOR WASTEWATER T REATMENT 

VOC emissions from a wastewater treatment system may be estimated using equations prescnled 

in Air Emissions Models for fJiaste lmd Wllstewater (EPA, 1994a), and Chapter 5, Preferretillnd 

A ltemative Methods for E.rtimati11g Air Emi.'<sions from Wastewater Collecrian a11d Treamtenl 

Facilities, oflhis volume. These documents, as well as models such as WATERS and 

CHEMDA 1'8, are available onlhe EPA's CtUEF website. 

EIIP Volume II 8.4-23 

VES016004 
CHAPTER 8 - PAINT AND INK MANUFACTURING 

4.2 EMISSION CALCULATION USING EMISSION fACTORS 

Emission foctors are commonly used to calculate emissions from paint and ink manufacturing 

facilities. EPA maintains a compilation of approved emission factors in AP-42 for criteria 

pollutants and hazardous air pollutants (HAPs). Emission factors for equipment leaks may be 

found in Protocol for Equipmem Leak Emissio11 Est1inates (EPA, 1995g). Chapter 4 of rl1is 

volume diseusses emission estimates from equipment leaks. 

The most comprenensive source for toxic air pollutant emission factors is the Factor Information 

and Retrieval (FIRE) data system, which also contains criteria pollutant emission factors 

(EPA, 1995h). 

Currendy, emission factors are the preferred meiliod for estimating VOC emissions from the 

following types of sources found in a paint and ink rnanufacruring facility: 

Solvent reclamation systems; 

PartS wasbing equipment; and 

Process pi ping. 

Emission factors are also tbe preferred method for estimating PMIPM10 emissions from paint and 

ink manufacturing facilities. 

VOC emission factors are also available in AP-42 for calculating total plant emissions and mixing 

operation emissions from a paint mauufacruring facility and for vehicle cooking and pigment 

mixing emissions JTom an ink manufacturing facility. These emission factors are discussed further 

in Sections 5.1.1 through 5.1.3. 

4 .2 .1 TOT ALAND SPECtATED VOC EMISSIONS FROM S OLVENT RECLAMATION 

VOC emissions from the loading and operation of a distillation device may be calculated using 

emission factors (EPA, 1995d). AP-42 also presents factors for spills and the storage of materials 

associated with the solvent reclamation process; however, the preferred emission estimation 

technique for these sources is the use of models discussed previously in this section. 

To calculate total VOCs from loading or operotion of the distillation device, use Equation 8.4-19: 

(8.4-19) 

8.4-24 EIIP Volume JJ 

VES0l6005 
3/ll98 

where: 

EYUC = 

Efvoc 

Ovoc: = 

CHAPTER 8- PAINT AND INK MANUFACTURING 

VOC emissions from loading or operation of the distillation device (lb/yr); 

VOC emission factor for loading of the distillation device or for the 

distillation column condenser vent (lb VOCs emiuedlton VOCs processed); 

and 

Amount of VOC in spent solvent processed through the distillation device 

(tonfyr). 

Speciated VOC emissions are then calculated using Equation 8.4-20: 

where: 

Evoc = 

C.._ == 

E, = Evoc • CJIOO (8.4-20) 

Emissions ofVOC species x from loading or opemtion of the distiUation 

device (lllfyr); 

VOC emissions from loading or operation of the distillation device. 

calculated using Equation 8.4-20 (lb/yr); oud 

Concentration of VOC species x in the solvent processed through the 

diStillation system (mass %). 

Example 8.4-S il!ustrutes the use of Equations 8.4-19 nod 8.4-20. 

If the species x concentration is provided on a volume basis, the volume percent will need to be 

converted to mass percent. If molecular weight of the total mixture is known, the volume percent 

of species x in the total mixture can be converted to mass percent using Equation 8.4-21: 

where: 

x. 

Y, 

M, 

M 

EIIP Volume II 

= 

= 

= 

X = y • • • 

M, 

M 

• 100 

Mass percent of species x in total mixture; 

Volume percent of species x in total mi.xture; 

Molecular weight of species x; and 

Molecular weight of total mixture. 

(8.4-21) 

8.4-25 

VES016006 
CHAPTER 8 -PAINT AND INK MANUFACTURING 

If molecular weight of the total mixture is not known, th~ volume p.:rcent can!><: convcrttro to 

mass percent using Equation 8.4-22: 

where: 

M 

n 

Y, 

M, 

= 

= 

= 

= 

Examole 8.+5 

M = t (~ "' M,) ,., I 00 

Molecular weight of total mixture; 

Number of species in total mixture; 

Volwne percent of species x in tot>d mixture; and 

Molecular weight of species x. 

(8.4-22) 

First, total VOC emissions from operation of a distillation device may be calculated using 

an emission factor from AP-42, Table 4.7-1 and Equation 8.4-19. 

Efvoc - 3 .30 lb VOCs/ton solvent processed 

Ovoc ~ 5 tons spent solvent processed!yr 

Evoc D EFwl(' • Ovor 

- 3 .30 • 5 

- 16.5 lb VOCs emitteclfyr 

Next, total VOC emissions are speciated using the concentration of VOC species x 

(mass %) and Equation 8.4-20. 

Evoc • 16.5 lb VOCs/yr (calculated above); 

c, - 99% toluene in spent solvent 

E. = Evoc • C/ 100 

• 16.5 • 99/100 

= 16.3 lb toluene emittedlyr 

8.4-26 EIIPVo/urfl$11 

VESOI6007 
CHAPTER 8- PNNT AND INK MANUFACTURING 

4.2.2 VOC EMISSIONS FROM PARTS C LEANING 

VOC emission factors for parts clean.iog in cold cleaners, open-top vapor degreasers. or 

conveyorized degreasers are presented in AP-42. Emission factors for cold cleaners and vapor 

degreasers are in units of tons VOC/yr/unit or lb YOC/hr/ft'. Emission factors for vapor and 

nonboiling conveyoriz.ed degreasers are presented only in units of ton VOC/yr/unit. !fusing 

emission factors based on the snrface area of the exposed solvent use Equation 8.4-23. 

where: 

A = 

OH = 

Evoc • Efvoc • A • OH (8.4-23) 

YOC emissions from a cold cleaner or open-top vapor degreaser, (lb/yr); 

VOC emission factor for cold cleaners or open-top vapor degreasers 

(lblhr/ft'); 

Surface area of solvent exposed to the atmosphere (ft1); and 

Hours per year tl1at the cold cleaner or vapor degreaser is in operation 

(hrlyr). 

!fusing emission factors based on the nwnber of cleaning units, use Equation 8.4-24. 

where: 

EFvoc = 

NU = 

2000 

Evoc = EF voc • NU • 2000 (8.4-24) 

VOC emissions from a cold cleaner, an open--top vapor dcgreaser, or a 

conveyorized dt.'greaser (lblyr); 

VOC emission iactor for cold cleaners, open-top vapor degreasers, or 

conveyorized degreasers (tonlyr/unit); 

Number of cleaning units in use (units); and 

2,000 lb/ton. 

Celtain halogenated solvents that are widely used for solvent cleaning (e.g., 

1,1,1-trichloroethane) have been categorized as "VOC-exempt" by various slate and federal 

regulations. However, the emission factors reported in AP-42 are still applicable for these 

solvents (EPA. 1995e). 

EIIP Volume II 8.4-27 

VES016008 
CHAPTER 8 ·PAINT AND INK MANUFACTURING 313198 

Spcciated VOC emissions from parts cleaning may be calculated using Equation 8.4-25: 

E, • EF voc • CJlOO (8.4-25) 

where: 

E, - Emissions of VOC species x from parts cleaning (lblyr); 

E,'OC = 

c, - VOC emissions calculated using Equation 8.4-22 or 8.4-23 (lblyr); aod 

Concentration of VOC species x in cleaning solvent (mass %). 

Examples 8.4-6 and 8.4-7 show the application of Equations 8.4-23, 8.4-24. and 8.4-25. 

Example 8.4-6 

This example shows how total and speciared VOC emissions from a cold 

cleaner may be calculated using Equations 8.4-23 and 8.4-25 and an emission 

factor (from AP-42, Table 4.6-2) that is based on the surface area of the 

exposed solvent. First, total VOC emissions are calculated using 

Equation 8.4-23. 

EFvoc 0.08 lblhrlft' 

A = 5.25 It' 

OH = 3,000 hrlyr 

Evoc = EFvoc • A • OH 

= 0.08 • 5.25 • 3,000 

= 1,260 lb VOC/yr 

Next, total VOC e.mi£sions are >-peciate<.l using the cooceutrution of VOC 

species x (mass%) o.nd Equation 8.4-25. 

Evoc 

c, = 

= 

= 

= 

1,260 lb VOCs/yr (calculated above) 

990/o trichloroethylene in cleaning solvent 

EFvoc • C,/100 

I ,260 * 99/1 00 

1,247 lb trichloroethylene/yr 

8.4-28 E//PV-11 

VES0!6009 
313198 CHAPTER 8 - PAINT AND INK MANUFACTURING 

Example 8.4-7 

This example shows how total VOC emissions are calculated from several cold 

cleaners using Equation 8.4-24 and an emission fuctor from Table 4-6.2 of AP-42. 

Efvoc "' 

NU 

Evoc 

0.33 ton!yrfunit 

- 5 units 

Efvoc • NU • 2,000 

0.33 • 5 • 2,000 

3,300 lb VOC/yr 

4.2.3 VOC EMISSIONS FROM EQUIPMENT L EAKS 

Emissions from eqtoipment leaks may be calculated using emission factors established by I!PA 

for the synthetic organic chemical manufa.cturing industry (SOCMl). SOCMI average and 

screening value range emission factors are available for various typeS of components 

(e.g., valves, pump seals, comtectors, open-ended Jines). Additionally, EPA has developed 

SOCMI correlation equations rhat can be used if lest data are available. Calculation of 

emissions from equipment leaks is explained in more detail in Chapter 4 of this volume. 

4.2.4 PM/PM10 EMISSIONS FROM A PAINT OR INK MANUFACTURING FACIUTY 

AP-41 also presents PM emission factors from paint and ink manufacturing. which are based 

on the amount of pigment used by a facility. The AP-42 factor for paint manufacturing is 

20 lb PM/ton pigment The AP-42 factor for pigment mixing at an ink manufacturing f.1cility 

is 2 Jb PM!ton pigment. To calculate PM emissions using these emission factors, use 

Equation 8.4-26. 

where: 

E"'t = 

EFPM = 

EQ, = 

Total PM emissions (Jb'yr); 

PM emission factor (Ib PM!ton pigment); and 

Total pigment (ton!yr). 

(8.4-26) 

EIIP Volume II 8.4-29 

VES0\6010 
CHAPTER 8- PAINT AND INK MANUFACTURING ~8 

PM10 can conservatively be estimated by assuming that all of the PM t:tuilted is PM10• 

Spcciated PM emissions are calculated using Equation 8.4-27: 

where: 

E, = 

EP,,., = 

Q, = 

c. = 

E = EF,., • Q • C / 100 .. ... s ~ (8.4-27) 

Total emissions of PM species x (lblyr); 

PM emission foetor from AP-42, Table 6.4-1 or Table 6.7-1 (lb PMfton 

pigment); 

Amount of pigment containing species x used by the facility (tonlyr); 

and 

Concentration of PM species x in pigment x (mass %). 

Usc of Equation 8.4-27 is demonstrated in Example 1!.4-8. 

Example 8.4-8 

This example demonstrates bow speciated PM emissions from pigment mi.xing at an 

ink manufacturing facility may be calculated using the consumption-based PM 

emission factor from Table 6.7- 1 of AP-42 and Equation 8.4-27: 

EFJ'I\< • 

Q. = 

c. = 

E, 

= 

-

2 lb PM/ton pigment 

5 tons ZnO/yr 

80% Zn in ZnO 

BF • Q * C/100 PM • 2 • 5 • 80/100 

8 lb Znfyr 

8.4-30 EIIP Volvme II 

VES016011 
5 

ALTERNATIVE METHODS FOR 

ESTIMATING EMISSIONS 

Alternative methods for calculating emissions from paint and ink manufacturing facilities are 

presented in this section. A list of variables used in Equations 8.5-l through 8.5-l 0 is given in 

Table 8.5-1. 

5.1 EMISSION CALCULATIONS U SING EMISSION fACTORS 

Emission factors are commonly used to calculate emissions from paint and ink manufacturing 

facilities. EPA maintains a compilation of approved emission factors in AP-42 for cri er ~ 

pollutants and hazardous air pollutants (HAPs). Available emission factors for paint 

manufacturir1g can be found in Section 6.4 of AP-42 and in a technical memorandum from EPA to 

the National Paint and Coatings Association (1:1'A, 19951). Emission tactors tor ink 

manufacturing can be found in Section 6.7 of AP-42. The National Association of Printing Ink 

Manufacturers, Inc. (NAPJM), has also developed ink manufacturing emission factors (NAPIM, 

1996). The most comprehensive source for toxic air pollutant emission l11ctors is the Factor 

Infonnation and Retrieval (FIRE} data system, which also contains criteria pollutant emission 

factors (EPA, 1995h). 

5.1 .1 TOTAL VOC EMISSIONS FROM PAINT MANUFACTURING FACILITIES 

A VOC emission factor can be used for calculating tota.l VOC emissions from paint manufacturing 

facilities. The emission factor presented in AP-42 is essentially a Joss factor that represents an 

emission rate to be applied to a production rate (NPCA, 1995). The VOC emission factor 

presented in AP-42 for paint manufacturing is 30 lb total VOCs/ton product (EPA, 1995b). To 

calculate total VOCs using tbis emission factor, see Equation 8.5-1; 

where: 

EIIP Volume II 

Total emissions ofVOCs ffom the facility (lblyr); 

VOC emission factor (lb VOCs/ton product); and 

Amount of product produced (ton/yr). 

(8.5·1) 

8.5-1 

VESOI6012 
CHAPTER 8 - PAINT AND INK MANUFACTURING 313!98 

TABLE 8.5· 1 

LIST OF VARIABLES AND SYMBOLS 

Variable Symool Units 

Toml VOC Emissions Evor lblyr 

VOC Emission Factor Er~oc various 

Amount of Product Q, tonlyr 

Produced 

Emissions of VOC or PM E. lblyr 

Species x 

Amount of VOC Species x Q, lb/yr 

Used by the Facility 

Tom! Amount of SolventS Q. lblyr 

Used 

Partial Pressure of VOC J> • psi a 

Species x 

Flow Rate TI>rougb Exhaust FR W/min 

Vent 

Molecular Weight ofVOC or M, lbllb-mole 

PM Species x 

Operating Houn; OH hr/yr 

Universal Gas Constant at I R 10.73 psia · ft'llb- ol~ · •R 

Atmosphere of Pressure 

Temperature of Exhaust Gas T •R 

Quantity ofVOC or PM Q. lb/yr 

Species x that is Received as 

a Raw Material 

8.5-2 E/IP Volume II 

VES016013 
313198 CHAPTER 8 - PAINT AND INK MANUFACTURING 

TABLE 8.5-1 

(CONTINUED) 

Variable Symbol Units 

Quantity ofVOC or PM 

Species x Shipped OU1 in 

Q. lblyr 

Final Product 

Quantity ofVOC or PM Q,.. lb/yr 

Species x Recovered by All 

Methods 

Quantity ofVOC or PM Qw lblyr 

Species x Contained in All 

Waste Generated 

Quantity ofVOC or PM 

Species >.. Remaining in Raw ~ lb/yr 

Material Inventory 

Concentration ofVOC or c,. ppmv or ftl!MMA' 

PM Species x 

EIIP Volume II 8.5-3 

VES0!6014 
CHAPTER 8 • PAINT AND INK MANUFACTURING 

Becuuse the VOC emissions calculated in Equntioo 8.5-1 are plantwide emissions, speciated 

emissions can be estimated based on total solvent used. Speciatcd VOC emissions ore calculated 

using Equation 8.5-2: 

where: 

E,. 

Evor. = 

Q. = 

Q, = 

(8.5-2) 

Emissions of VOC species x from the facility (lblyr); 

VOC emissions from the facility, calculated using Equation 8.5-1 (lblyr); 

Amount of VOC species x used by tbe facility (lb!yr); and 

Total amount of solvents used by the facility {lb/yr). 

Witlt no other information available, one important assumption made in Equation 8.5-2 is that all 

solvents evaporate at the same rate. The amount ofVOC species x used by a facility (Q.) can be 

obtained by reviewing purchase and inventory nxords and appropriate technical data sheets. 

Purchase and inventory records can be used t.o estimate the amount of a paniculnr material 

consumed. 

The sum of speciatc.cl emissions for all VOC components calculated using Equation 8.5-2 crumot 

exceed the toea! VOC emissions calculated in Equation 8.5-1. The use of Equations 8.5-1 and 

8.5-2 is demonstrated in Example 8.5-1. 

Examole 8.5-l 

This example shows how total aod speciated VOC emissions may be calculated for a paint 

manufacturing facility using the production-based VOC emission factor from 

AP-42, Table 6.4-1, and Equations 8.5-1 and 8.5-2. 

Given: 

EFvoc • 

Q, = 

Q,...... = 

Q, = 

30 lb VOC/ton product 

1,250 ton of paint!yr 

250,000 lb used by the facility/yr 

I ,500,000 lb solvents used by the facility/yr 

8.5-4 EIIP Volume II 

VESOI60l5 
l/3198 CHAPTER 8 - PAINT AND INK MANUFACTURING 

Example 8.5· J (Continued) 

Total VOC emissions would be calculated using Equation 1!.5-1: 

= 

Ef'voc * Q. 30. 1,250 

37,500 lb VOCslyr 

The amount ofxylenes used by the facility (Q,,,..,) was estimated by conducting a review of 

purchase and inventory records and technical data sbeets. 

Xylenes emissions would be calculated using Equation 8.5-2: 

= 

37,500 lb VOCs emittedlyr 

250,000 lb xylenes used by the fucility/yr 

I ,500,000 lb solveniS used by the facility/yr 

Evoc • Q/ :EQ 

37,500 • 250,000/1,500,000 

6,250 lb xylcnesfyr 

In addition to the 30 lb VOCsiton product emission factor, EPA has recently restated the emission 

fhctor for total YOC emissions for overnll operations from a paint manufucturing facility based on 

the amount of solvent used (EPA. 1995t). Development of the new proposed factor, 0.034 lb 

VOCs emitted/lb solvent used, is lxlsed on the following information and assumptions: 

The emission estimates used to develop the 30 lb VOCslton coating emission 

factor appear to be based on the formulation of conventional coatings that were 

prevalent in the late 1950s and early 1960s. 

Densities for conventional coatings were typically 10 10 15 lbfgal (an average 

density of 12.5 lb!gal was used) during tbe late 1950s and early 1960s. 

An averuge solvent content of 5.5 lb VOCsfgal coating was assumed for 

conventional coatings (EPA, 19951). 

Use of the proposed factor by facilities that primarily manufacture water-based. low-solvent, or 

high-solids coatings should result in more accurate emissions than use of the 30 lb VOCslton 

coating factor. 

EIIP VolUme II 8.5-5 

VES016016 
CHAPTER 8- PAINT ANO INK MANUFACTURING 313198 

To calculate total VOCs using this proposed emission factor, use Equation 8.5-3: 

where: 

Evoc = EFvoc ~ 

Q, ~ 

Total VOC emissions from a fucility (lblyr); 

VOC emission factor (lb VOCsllb solvent used); nnd 

Total amount of solvents used (Jbfyr). 

Spcciated emissions are then calculated using Equation 8.5-4: 

where: 

E.l( ~ 

EFvoc ~ 

Q. ~ 

Emissions of VOC species x from a facility (Jblyr); 

VOC emission factor (lb VOCs!lb solvent used); and 

Amount of VOC species x used by the facility (lb/yr). 

(8.5-3) 

(8.5-4) 

The sum of speeiated emissions for all VOC components calculated in Equation 8.5-4 cannot 

exceed the total VOC emissions calculated in Equation 8.5-3. The use of Equations 8.5-3 

and 8.5-4 is demonstrated in Example 8.5-2. 

5.1.2 VOC EMISSIONS FROM PAINT M IXING OPERATIONS 

VOC emissions from paint mixing equipment may be calculated using emission factors. AP-42 

suggests that "about I or 2 percent of solvent is lost even under very well controlled conditions" 

(EPA, l995b). This percentage range can be translated into an emission factor range ofO.OI to 

0.02 lb solvent lostllb solvent used. Review of background information indicates that this 

emission factor range applies specifically to paint mixing operations (i.e., operations where 

solvents are added as raw materials) (EPA, 19951). 

AP-42 states that the consumption-based emission factor ofO.OI to 0.02 lb VOCs lost/Jb solvent 

used applies eveo to facilities that have emission sources that are well controlled. If a facility 

conmins mixers or ot ber process vessels that are uncovered or otherwise poorly controlled, an 

emission factor greater than 0.02 lb solvent lostllb solvent used may need to be applied (NPCA, 1995). 

8.5-6 cliP Volu~ II 

VES016017 
313198 CHAPTER 8 - PAINT AND INK MANUFACTURING 

Example 8.5-2 

This example shows how toral and speciated VOC emissions may be calculated for a 

paint manufacturing facility using the proposed solvent-based VOC emission factor, as 

shown in Equation 8.5-3. 

EFvoc = 

Q, ~ 

.Evoc == 

= 

0.034 lb VOC.o;/lb solvent used 

350,000 lb solvents used by the facility/yr 

EFvoc • Q, 

0.034 * 350,000 

11,900 lb VOCs/yT 

Xylene emissions would be calculated using Equ3tion 8.5-4: 

0.034 lb VOCs/lb solvent 

15,000 lb xylenes contained in solventS nsed by the facility/yr 

EF *Q voc ' 0.034 • 15,000 

= 510 lb xylenes/yr 

Total VOC emissions can also be calculated by suuuni.og the speciated VOC emissions. 

Use Eqlllltion 8.5-5 for calculating speciated VOC emissions from mixers using the consumptionbased emission factor. 

where: 

E = EF oc • Q ( v ): (8.5-5) 

Emissions ofVOC species x from mixing equipment (lb/yr); 

VOC emission factor (lb VOCsllb solvent used); and 

AIDount of VOC species x added to mixing equipment as a raw 

material (lbfyr). 

The amount of VOC species x used in mixing equipment (Q.) refers to the total amount of 

VOC species x that is added to mixing equipment as a raw material. Once the solvent is 

mixed with otl•er materials, it is no longer considered a raw materiaL 

EIIP Volume II 8.5-7 

VES016018 
CHAPTER 8 - PAINT AND INK MANUFACTURING 

The u~ of Equation 8.5-5 is also demonstrated in Example 8.5-3. 

Example 8.5-3 

This example shows how speciatcd VOC emissions from mixing equipment may 

be calculated using Equation 8.5-5 and the emission factor from Secnon 6.4.1 of 

AP-42. This example assumes an avernge level ofVOC control on process 

equipment. Consequently, the average of the range (I to 2 percent) reported in 

AP-42 is used. 

EFvoc = 

Q, = 

0.015 lb xylenes cmitted/lb xylenes used 

15,000 lb xylencs added to mixing equipmentlyr 

= EFIIOC * Q O.oJ5 • 1S,ooo = 225 lb xylenes!yr 

5.1.3 VQC EMISSIONS FROM INK MANUFACTURING FACILITIES 

Emission factoiS are also available for VOC SO\trccs from ink manufacturing facilities. Section 

6.7 of AP-42 presents VOC emission factors for vehicle cooking. NAPIM has also developed 

VOC emission factors for mixing, milling, and tub wash processes for both paste and liquid 

inks (NAPIM, 1996). Emission factors are available for sheetfoo three-roll mill and heat~et 

paste inks, and for low-VOC and high· VOC liquid inks. Equation 8.5-6 can be used to 

estimate emissions using emission factors. 

where: 

Evoc 

EFIIOC 

Q. 

= 

= 

= 

VOC emissions (lblyr); 

VOC emission factor (lb VOC/ton product); 

Amount of product produced (ton!yr). 

Speciated emissions can be calculated using Equation 8.5-7: 

8.5-8 

(8.5-6) 

(8.5-7) 

EIIP Vo/lm1e II 

VES016019 
313198 CHAPTER 8 • PAINT AND INK MANUFAC7VRING 

where: 

E. E\1)(' 

Q, 

EQ 

= 

= 

Emissions of VOC species x (lb/yr); 

VOC emissions calculated using Equatioo 8.5-6 Oblyr}; 

Amount of VOC species x used (lb/yr); and 

Total amount of solvent used {lb/yr). 

With no other information available, one important assumption made in Equation 8.5-7 is tbat 

all solvents evaporate at the same rate. The amount of VOC species x used by a facility (QJ 

can be obtained by reviewing purchase and inventory records and appropriate technical data 

sheets. Purchase and inventory records can be used to estimate the amount of a panicular 

material consumed. 

Example 8.5-4 illustrates the use of these equations. 

Examole 8.5-4 

This example shows how VOC and speciated VOC emissions may be calculated for gencrdl 

vehicle cooking at an ink manufactunog faciliry using the productioo-based VOC emission 

factor ITom AP-42, Table 6.7-1, and Equations 8.5-6 and 8.5-7. 

Given: 

Efvoc a 

Q, = 

Q.....,.= 

EQ = 

120 lb VOC/ton product 

500 tons of ink/yr 

I 00,000 lb usedlyr 

I ,000,000 lb solvents usedlyr 

VOC emissions would be c.alculated using Equation 8.5-6: 

Evoc a 

= 

= 

EFvoc • Q. 120.500 

60.000 lb VOCslyr 

The amount of toluene used (Q.,._) was estimated by conducting a review of purchase and 

inventory n:oords, batch records, and technical data sheets. 

Toluene emissions would be calculated using Equation 8.5· 7: 

60,000 lb VOCs emitted/yr 

I 00,000 lb toluene uscd/yr 

1,000,000 lb solvents used/yr 

Evoc • QftQ 

60,000 * I 00,000/1,000,000 

6,000 lb toluene/yr 

EIIP Volume II 8.5-9 

VES016020 
CHAPTER 8 - PAINT AND INK MANUFACTURING 

5.2 EMISSIONS FROM MISCELLANEOUS P ROCESS EQUIPMENT WITH 

EXHAUST SYSTEMS 

The Ideal Gas Law may be used in conjunction with vent discharge rates to calculate 

emissions from proctlss equipment that are equipped with exhaust systems. Use 

Equation 8.5-8 for calculating these emissions: 

where: 

E = 

P, • FR • M, • 60 • OH 

R • T 

Emissions of VOC species x (lb!yr); 

(8.5-8) 

·' P, = Partial pressure of VOC species x (psia), calculated using Equations 

8.4-3 and 8.4-5 or 8.4-4 and 8.4-5; 

Flow rate through the exhaust vent (ft'lmin); 

Molecular weight of VOC species x (1Mb-mole); 

60 min/br; 

FR 

M, 

60 

OH 

R 

T 

= 

= 

-

a 

-

~ 

Hours that the exhaust system is in operation (hr/yr); 

Universal gas constant at I atmosphere of pressure 

(10.73 psia · ft'llb-mole · •R); and 

Temperantre of the exltaust gas ('R). 

Example 8.5-5 illu>trates the use of Equation 8.5-8. 

Example 8.5-5 

Th.is example shows how toluene emissions are calculated for a process vessel that is 

equipped with ao exhaub1 system. The foUowing data are provided: 

The paint in the process vessel consists of 30% by weight toluene, 20% 

by weight 1\<IEK, and 70% by weight pigments and nonvolatile resins; 

The partial pressure of toluene (P,) is 0.16 psi a at 77"F (see 

Example 8.4-2, Step 2); 

The discharge rate of the ven1 (FR) is 5 ft'lmin; 

8.5-10 EIIP Volume II 

VES016021 
313198 CHAPTER 8- PAINT AND INK MANUFACTURING 

Examole 8.5-5 CContjnuodl 

The molecular weight of toluene (MJ is 92 lbllb-mole; 

• The exhau$t system and process VC$Sel are operated for 1,000 hr/yr 

(QH); and 

The tempcrdture of the paint and the exhaust gas is 77' F or 537°R (D. 

Toluene emissions are calculated with Equation 8.5-8 as follows: 

= E. * FR • M. • 60 • OH 

R*T 

0.16. 5 * 92 • 60 * 1.000 

10.73 • 537 

= 766 lb toluenelyr 

5.3 VOC AND PM EMISSION CALCULATIONS USING MATERIAL 

BALANCE 

The material balnnce method requires the totaling of aU materials received at the plant and then 

subtrocting out all of the known losse$ or transfers of tbe material off-site (including finished 

product and waste material). Tite difference is assumed to have been emitted to the atmosphere. 

The quantity rece.ived and the quanrity lost or used should be for tbe same time period, typically 

January I to December 31 for the year of the inventory (NPCA, 1995). 

Use Equation 8.5-9 for calculating emissions using the material balance approach. 

where: 

EIIP Volume II 

E. = Q, - Q, - Q .... - Q. -o. (1!.5-9) 

= Emissions of VOC or PM species x (lblyr); 

= Quantity of VOC or PM species x that is received as a raw material (lblyr); - Quantity of VOC or PM specie$ x that is shipped out in the final product 

(lb/yr); 

= Quantity of VOC or PM species x that is recovered by all methods (e.g., 

solvent recovery) (lblyr); 

8.5- 11 

VES016022 
CHAPTER 8 - PAINT AND INK MANUFACTURING 

0. ; Quamity of VOC or PM species x that is contained in aU waste generated 

during the evaluation period (e.g .• wastewater, sludge, drum residue) (lblyr); 

and 

Qd ; Quantity of VOC or PM species x that remains in tbe raw material inventory 

(lb/yr). 

The use of Equation 8.5-9 is demonstrated in Example 8.5-6. 

5.4 EMISSION CALCULATIONS USING TEST DATA 

Because vent or stack testing is relatively uncommon for paint and ink manufilcturing fucilitie~ 

emissions test data for these plants are typicaUy in the fonn of exposure monitoring results. Industrial hygiene data may be used in conjunction with exhaust system flow r.ues to calculate 

fugitive c•nissions from a room, floor, or building (NPCA, 1995). Use Equation 8.5-10 for 

calculating these emissions. 

Example 8.5-6 

This example shows how total ethylene glycol emissions for a paint manufacmring 

facility may be calculated using Equation 8.5-9. Data are as follows: 

In a given year, a paint facility receives I 00,000 lb of ethylene glycol 

(Q,). 

Based on the total amount of product shipped off-site and records of 

product composition, the facility estimates that the amount of ethylene 

glycol shipped out in final product (Q,.) is 69,000 lb; 

The amount of ethylene glycol that was recovered by the facility's 

distillation system (Q,.J is I 0,000 lb; 

Based on waste composition analyses, the amowlt of waste sent 

off-site, and wastewater discharge rates, the facility estimaies that the 

amount of ethylene glycol that was found in all wastes generated during 

the ycnr (Qw) is 5,000 lb; and 

The amount of ethylene glycol that was found to be in the facility's 

inventory at the end of the evaluation period (Q.,) is 15,000 lb. 

8.5-12 EIIP Volume II 

VES016023 
313198 CHAPTER 8 - PAINT AND INK MANUFACTURING 

Example 8.5-6 (Continued) 

Emission of ethylene glycol are calculated as follows: 

E, Q, - Q.- Q"' - Q., 

100,000 -69,000 - 10,000-5,000- 15,000 

= 1,000 lb ethylene glycol/yr 

E = ' 

FR • 60 • OH ~ C,. ~ 0.0026 

1 • to• 

• M • (8.5-1 0) 

wbere: 

B, e 

FR = 

60 = 

OH = 

c .. , - 0.0026 = 

M. = I • 100 "' 

Emissions of VOC or PM species x (lblyr); 

Flow rate through exhaust ventilation system (W/min); 

60 minlhr; 

Hours per year that tl1e exhaust system is operational (hr/yr); 

Concentration ofVOC or PM species x (ppmv or W!MMft>); 

Molar volume of gas at 68•F (molelft'1); 

Molecular weight ofVOC or PM species x (lbllb-mole); and 

1 • 1 0" fTJMMft'. 

EXllmple 8.5-7 illustrates tbe use of Bquation 8.5-10. 

VOC losses from certain operations (e.g., filling of containers) may also be measured by 

perfom1ing a study using u gravimetric analysis such as American Society For Testing ood 

Materials (ASTM) Standard 02369, Testl•felltodfor Volatile Co11tent o(Coati11gs. The 

operation under evaluation could be simulated on a small scale, and VOC analysis would be 

conducted on samples taken before and after the simulated activity (EPA, 1992b). 

EIIP VOlume II 8.5-13 

VES016024 
CHAPTER 8 ·PAINT AND INK MANUFACTURING 

Exarno!e 8.5-7 

1l1is example shows how Equation 8.5· I 0 is osed to calculate fugitive emissions of 

xylenes from a building where several mixing vessels are located The following data 

are given: 

The building exhaust flow rate (FR) is 20,000 Jll/min; 

The eKhaust system operates for 7,920 hr/yr (OH); 

Industrial hygiene data indicate that the concentration of mixed xy!enes 

in the building (C.) is 0.1 ppmv; and 

The molecular weight of mixed xylenes (M.) is I 06 lbflb-mole. 

Xylenes emissions arc calculated as follows: 

= FR * 60 • OH • C, • 0.0026 * M. 1 • to• 

= 20.00Q • 60 • 7.92() • 0.1 • 0.0026 • 106 

1 • to• 

262 lb xylcnes/yr 

3/31'98 

8.5- 14 EIIP Volut7>6 II 

VES016025 
6 

QUALITY ASSURANCE/QUALITY 

CONTROL 

The consistent use of standardized methods and prooedures is essential in the compilation of 

reliable emission inventories. QA and QC of an inventory is accomplished through a set of 

procedures that ensure the quality and reliability of data coUection and analysis. These procedures 

include the use of appropriate emission estimation teChniques, applicable and reasonable 

assumptions, accuracy/logic checks of computer models, checks of calculations, and data 

reliability checks. Figure 8.6-1 provides an example completeness checklist that could aid the 

inventory preparcr at a paint and inlc manufacturing plant. Volume VI. Q.A Proced~tres, of tbe 

EITP series of documents describes additional QNQC methods and tools for pcrfonning tllese 

procedures. 

Volume ll, Chapter l, introduction to Srationary Point Sourc.e Emission lnvemory Development, 

also presents recommended standard procedures to follow to ensure that the reported inventory 

data are complete and accurate. This section discusses the use of QC checklists, QA/QC 

procedures for specific emission estimation methods (e.g., emission factors), and the application 

of the Data Attribute Rating System (DARS). 

6.1 GENERAL QA/QC CONSIDERATIONS INVOLVED IN EMISSION 

ESTIMATION TECHNIQUES 

6 .1.1 EMISSION FACTORS 

The use of emission factors is straigbtfofWllrd when lhe relationship between process data and 

emissions is direct and relatively uncomplicated. When using emission factors, the user should be 

aware of the quality indi.catot· associated with the value. Emission factors published within EPA 

documents and electronic tools have a quality rating applied to them. The lower the quality 

indicator, the more likely !hot a given emission factor mny not be representative of the source 

type. When an emission factor for a specific soUTCe or category may not prmide a reasonably 

adequate emission estimate, it is always better to rely on actual stack test dam, where available. 

The reliability and uncertainty of using e111ission factors as an emission estimation technique are 

discussed in detail in the QNQC section of Chapter I of this volwne and Chapter 4 of 

Volume VI. 

EIIP Volume II 8.6-1 

VES016026 
CHAPTER 8- PAINT AND INK MANUFACTURING J/3198 

Corrtdin Att.lon 

(Complete if "N"; 6Cri~, 

YIN Si:n, and .Date) 

Rnvc emissions from all source$ been inc100ed? Pol'entiul sources 

include process vessels, solvent reclamation systems~ clc-dning 

activities. wasttm·ater trcalnl\.~ system, sto.rnge tanks. process 

piping, :md spills. 

HliS on cmisston estimating tcchmque ~ idenlilied for each 

source·! 

If toxic emissions are to be ea1culatcd using testing datn. are tbe 

test methods approved? 

If toxic c1nissions are to be cafculott>:d. LLcoing cmlsi'iOn facum:;, are 

the emission factors from AP·42 or FIRE? 

If Eoxic emissions are io be t11lcuhucd using a materisl balance 

opproacb, have all fonm of wsstelxm included (e.g., used filler 

bogs or cmridges, spent solvem or 5till botiOIDS, dust collec1or 

mau:rial. pigmcnl bag and/or drum residue. aod wast<Wlltcr)? 

Have s.tnck parameters been provided for each stack or ven1 that 

emit8 Cl'iteria or toxic air J)OIIutflnts? 

If emission models are being used to calculale emissions from 

process vessels. has a manageable oumber of reprcsema1ive 

product groups been defined? 

If required by the stale. bas a site diagrom been included with the 

em•nions inventory? This should ~a de!lllled plant drowtng 

showing the location of soun:eslstack$ with ID numbers for ull 

process.,, control equipment, ond exhaust points. 

Have examp!es of all calcul>lion< been included? 

Have all assumptions been documented? 

Have references for all calculation metbods been included? 

Have Ill conversions aod units been revic•wed and dtecked for 

accuracy? . 

FIGURE 8.6· 1 

ExAMPLE EMISSION INVENTORY CHECKLIST FOR 

PAINT AND INK MANUFACTURING FACILITIES 

8.6-2 EIIP Volume II 

VES016027 
CHAPTER 8 ·PAINT AND INK MANUFACTURING 

6.1 .2 EMISSION MODELS 

The level of effort for using models otbe.r than emission factors is related to the complexity of the 

equation, the types of data that must be collected, and the diversity of products manufactured at a 

facility. Typically. the use of emission models involves making one or more conservative 

assumptions. As a resull, their use may result in an overestimation of emissions. However, the 

accuracy and reliability of models can be improved by ensuring that data collected for emission 

cnlculations (e.g., material speciation data) are of the highest possible quality. 

6.1.3 MATERIAL BALANCE 

Calculating emissions from a paint and ink manufacturing facility via a material (ma~s) balance 

approach appears tO represent a straightforward approach to emissions estimations. However, 

few facilities track material usage and waste generation with the overall accuracy needed to make 

the method wori<, and inaccuracies inherent to each material handling step often accumu.lal.e into 

large deviations. As emissions of specific materials are typically below 1.5 percent of gross 

consumption, an error of only :~oS.O percent in any one step of the operution can significantly skew 

emissions. Potential sources of error in the material balance calculation method include the 

following: 

The delivery ofmw materials at a puint and ink manufucturing facility is often 

tracked by volume, not by weight. Since density will vruy with temperature, the 

actual mass per unit volume of material delivered in tl1e summer may be less than 

that delivered in d1e winter; 

Raw materials received by paint and ink facilities may potentially be used in 

hundreds or thousands of finished products. In order to complete the material 

balance, it is crucial that the exact quantity and speciation of each material shipped 

off-site in product be known. For many facilities, it is extremely diffiCult, or 

currently impossible, to accurately track the distribution of specific raw materials 

across their entire product line; 

The amount of ruw material contained in waste must also be considered. This 

may involve precise analysis of the concentration of the material in question in 

each waste stream; and 

Batch production of paint and ink ofien requires the manual addition of raw 

materials. Somctiroes tl1ese additions are not accurately measured or recorded 

(NPCA. 199 5). 

6.1.4 TESTING 

Stack or industrial hygiene tests must meet quality objectives. Test data mUSt be reviewed to 

ensure that the test was conducted w1der normal operating conditions, or under maximum 

operating conditions in some states, and that it was generated according to an acceptable 

method for each pollutant of imercst. Calculation and intetpretation of accuracy for stack 

fliP Volume II 8.6-3 

VE$016028 
CHAPTER 8 - PAINT AND INK MANUFACTURING lr.l/98 

testing methods are described in detail in Qualiry Assurance Handbook for Air Pollution 

Measrmmrmts Systems: Volume Ill. Suuionary Source Specific Methods (Interim Edition) 

(EPA, l994b). 

The acceptable criteria, limits, and values for each control parameter associated with manual 

sampling methods, such as dry gas meter calibration and leak rates, are summarized in tabular 

forrual in the QAJQC section of Chapter I of this volume. QC procedures for aU instruments 

used to continuously collect emissions data are similar. The primary control check for 

precision of the continuous monitors is daily analysis of control standards. 

6.2 DATA ATIRIBUTE RATING SYSTEM (OARS) SCORES 

One measure of emission inventory data quality is the OARS score. Four examples are given 

here to illustrate OARS scoring using the preferred and alternative methods. DARS provides 

a numerical ranking on a scale of 0 to 1.0 for individual attributes of the emission factor and 

the activity data. Each score is based on what is known about the factor and activity data, 

such as the specificity to the source categoty and the measurement technique employed. The 

composite nttribute score for the emissions estimate can be viewed as a statement of tbe 

confidence that can be placed in the data. For a complete discussion of DARS and other 

rating syStems, see the QA Procedure.t (Volume VI, Chapter 4), and the QAJQC section of 

Volume II, Chapter I, Introduction to Stational)' Point Source Emissr'on l11ventory 

Development. 

llacb of the examples below is hypothetical. A range is given where appropriate to covet· 

di·ffercnt situations. Table 8.6-1 gives a set of scores for an estimate made ''~th an AP-42 

emission factor. The activity data are assumed to be measured directly. Table 8.6-2 shows 

scores developed for tbe use of emission models. Tables 8.6-3 and 8.6-4 demonstrate scores 

detennined for material balance and testing data, respectively. The reader should note that 

although the composite score for the material balance method is good, this technique will not 

practically be applied or used by many paint and ink manufactwi11g facilities. Because few 

facilities tr~ck material usage and waste gen~ration with the overall accuracy needed to make 

the material balance approach work, use of emission factors and other emission models may 

provide tbe best choice when selecting an appropriate method for estimating emissions. 

These examples are given as an illustration of the relative quality of each method. If the same 

analysis were done for an actual site, the scores could be different but the relative ranking of 

methods should stay the same. Note, however, that if the source is not truly a member of the 

population used to develop the EPA con·e lation eqnations or the emission factors, these 

approaches ar·e less appropriate and the DARS scores will drop. 

If sufficient data are available, the uncertainty in the estimate should be evaluated. Qualitative 

and quantitative methods for conducting uncertainty analyses are described in tl1e QA 

Procedw·es (Volume VI, Chapter 4). 

8.6-4 EIIP Volume II 

VES016029 
lll 

"0 

~ ~ 

"' 

oe 

'? 

"'' 

Attrlb•U 

Measurement/ Method 

Sou~ Specificity 

SJX11i.al Cungruily 

Temporal ConJVUity 

Composile s-... 

Fanor Score 

OJ -06 

0.8 

0.1 -0.9 

0.1. 0.9 

0.3.1 - 0.80 

TABLE 8.6·1 

OARS SCORES: AP-42 EMISSION FACTORS 

Adh'ity Rmlssiu•t 

-· Store F~ r Au u_m:ptioas 

1.0 0.3 . 0.6 L.owtr ~ore rellccts a fnclor of 

r.:or qll&li~~ :,. score rellecls • 1CfiOt of hi ttv. 

1.0 0.8 Factor developed from a 11upcrse1 

of intended source c.a.t<-"g.of) with 

<Jq>«l<d low vanob1htj, 

10 0.1· 0.9 loY.-er s.core ~nccts a factor of 

low quali~ dcwlopcd for oo tmkno-...·n !l{.latilll scale; uflpec score ~llec s a high qua ity factor 

~·eJopcd from a sotuce of simifllr ..... 0.7. 0.9 0.7 . 0.81 Lower ~e rellcc1s a low quality 

factor. temporal basis unlr:nO\v-.; 

upper JCOre refl«ts • high quolil)' 

f.'let(lt' detived r~n an 1averog_e oi numerou5 teSLi. 

093 - 0.98 0.48 - 0.18 

Acthi~ AsmnpllKs 

Da1o arc ba:Wd on dirt<:t and continuous mcasurt.~nctu of 

ll<livil)-. 

Aclivily data rcprcsen1lhc emitHiod proceiS exaedy. 

Activity cblta are. developed for lnd sp«ifte to the 

1oven10£)' an:a. 

Lower score renet·ts llC1ivity 

dala represtntative of • shM 

period of time with low to moderate tel\lporal 

vari abHi~:y. uppecscore 

n-fl«:tS activtC)• cbta 

measured numerous time!): 

0 \'C:f the yel\r. 

' 

I 

~ 

~ "tl 

~ ... 

~ 

~ 

~ 

~ 

~ 

~ )> 

0 

~ 

~ 

VESOl6030 
oc 

~ 

~ 

~ il 

"' 

Attribute 

McasurernciHIMethod 

Soun;Q Specifteicy 

Spatial Coogroily 

Temparal Congruity 

Composfle. Scoros _____ 

TABLE 8.6·2 

OARS ScORES: EMISSION MODELS 

Actl•-ity EOlbsi.ons 

f'uctor Score &."Ore ScMe Factor Ass,u~~tl ns 

0.3 1.0 0.3 F octotS (inp•tt io model) at< 

besed on m;.,s baJ•nces. 

known princ•ples, etc. 

0.9 · 1.0 1.0 0.9· 1.0 Lower scon: ~Deets modct 

inpms dc:veloped for subset or supetsec of 1he inttnded 

cat~~ S(:(W'C. rdleat 

inpuu oped &ptcificaJI)' 

for the Intended source. 

1.0 1.0 I 0 Model ;,p.,. are cb'Cio_ped 

far ar.d m ~fic to the 

given sp1Hill e. 

L.O 1.0 l.O Mod-el inpucs are ~·eloped 

for and applicable to Lhe same 

temporal scale. 

0.80 . 0.83 1.0 0,80 . 0.83 

Acth+tty JJJWm~tiPll 

0011.,.. based on dirc<t 

and continuous 

meaM.aremcnt Of$Un'OgothJ activhy. 

Attiv1ty dalol n:prcstr~t cbe 

emissioo pmcciS exactly. 

AaiVIty d1n:a ~ developed 

for and are spcc;lfie to the 

area included in the 

in\'tnHxy. 

Acdvicyda.t1 arc: specific 

for the tcmporlll peciod 

reprcscntni In lbe inveft-t<M).. 

~ ~ 

"' ' )2 

~ 

~ ~ "' 

~ ~ C) 

~ 

~ 

~ 

VESOJ 6031 
E!! 'ii 

~ i 

"' 

00 

"' .:.., 

Attribllte 

Me:lSl!rcmem/Method 

Sautee SP<Cificily 

Spatial Cougroity 

Tempotll Coopoly 

Composloe Sc:ores 

factor Score 

o.s 

1.0 

1.0 

1.0 

0.88 

TABLE8.6-3 

OARS SCORES: MATERIAL BALANCE 

At'll y Embsiol\j 

Sf.uro Store Fudor Auu.•ptloas 

1.0 0.5 fac:tor is based oo nus.s balance; 

all/or most cndf'C)ints tUC" 

accounted for. 

1.0 1.0 Facwr is devtklpcd specUicaUy for lhe i.nteoded toui'U. 

1.0 1.0 Fac.lor IS developed 10. ftod s:pec.ir~e to \he tpvm spadal 

scale. 

1.0 1.0 FaciO<;. developed for ard 

applic-.1ble to the same tempOral 

seale. 

1.0 0.88 

At1h'IIV ~s,UMptiO -' 

Oirttt continuous 

measurement of •c:tivity 

surrogate. 

Ac:.ti"ity dau ~ th~ 

cmissio~w aacd_.__1__ 

Ac~ data arc developod 

for .. "Ciflc to the 

$00grllplu< reclou of !be mvc:ntory. 

AccM-cy ds:ta are spccif.e for 

lhc 1emporal period ~resented in the in\'cntory. 

i 

0 

~ 1l 

ii1 

~ 

Q) 

~ 

:i: 

_, 

~ :i: 

"' 

c: 

~ 

~ 0 

C! 

~ 

VES016032 
oc 

9-

oc 

!!! 

'ij 

f 

"' 

Attribtlte 

Meaurcme&it.IMcthod 

Soun:e S~focity 

Spatial Corwui1y 

Temp<>r.>IQmsruity 

Composite Scores 

FactDr Seore 

06· 1.0 

1.0 

1.0 

0.7. 1.0 

0.83 ·1.0 

TABLE 8.6-4 

OARS SCORES: TESTING DATA 

Atllvlry 

Score biuiou Store Fartor Assumpliou 

0.6 . 1.0 0.36. 1.0 Lower score reflects • factor 

cbdoped llom • small sample of data representative ot"typical loods; upper score l>eHectS A f3clor baiitd 00 

coorinuous or near COtU:iouous 

mea..wrcment of i:ntendtd 

pollutant from all n:Levnnt 

:lites. with data c.apcurt 

s;realer dmn 90'!-'.. 

1.0 1.0 Factor is dcveJopc:d 

specifically ror the intended source CIUilRorv. 

1.0 I U Faaor u de><:loped for-ond 

specific 1.0 the given sptliaJ 

scale. 

0.7. 1.0 0.49. 1.0 Lower sco~ reDeccs • facwr 

derived fOI' longer/thoner 

lime (!Cf·iOt:l.. or from a different J)(lnod; UPf)er 500ft 

reflects a (ador de\-etopro forand applicable to fhe same: teruporol scaJe. 

0.83. 1.0 o.n. 1.0 

Activity A.ss•mptio nll 

Lower score:: reflec:ts 

lctivity ra~e derived f.rom • diffttent measured 

surrogate l\Ssociated with 

ori.ginaJ activ~um>~l'te; upper sc.ore re · dtnxt 

co®nuous measurt"tnCtt1 

ofacrivity ilwrogarr. 

~vtty data represent the 

cmisston process exac:IJy. 

A<:li>ity dota ~ 

devdoped fO< and sp«:ific 

to the rt&ioo of tbe 

lO\'ClltorY. 

Lower ttorc renecu activity rqnesemanve of a longer/shorter period. or a different pc._-riod; upper $0Cif"('. reflecu ac:riviry data 

specific ror rhe ·~ p~riod reptesented tn \he 

iuvenlo,Y. 

0 

, 

~ 

ill 

:0 

"' 

~ 

~ 

~ 

~ 

~ ~ 

Iii )> 

0 

~ 

~ 

i 

VES016033 
7 

DATA CODING PROCEDURES 

This section describes the methods and codes available for characterizing emission sources at 

paint and ink manufacturing fitcilities. Consistent categorizmion and coding wiU resuh in 

greater unifonnity among inventories. ln addition, tl1e procedures described here will assist 

the render who is preparing data for input to the Aerometric Information Retrieval Sy~1em 

(AIRS) or n similnr database management system. For example, the usc of the Source 

Qassification Codes (SCCs) provided in Table 8.7-1 are recommended for describing paint and 

ink nuf.~ctwing operations. Refer to the CHTEF bulletin board for a complete listing of 

sees for paint and ink facilities. 

7.1 S OURCE C LASSIFICA TION C ODES 

SeCs for paint and ink manufucturing operations are presented in Table 8.7- 1. A brief 

description of each source description listed in the table is given below. 

7.1.1 PAINT AND INK MANUFACTURING EMISSIONS 

Traditional paint and ink manufacturing consists of preassembly and premix, pigment 

grinding/dispersing, product finishing/blending. and product filling/packaging. The sees that 

correspond to these activities appear in Table 8.7-1 under the "Paint Mrumf.1crure" and "Ink 

Manufacture" source descriptions. This source category also includes Sees for cleaning of 

equipment. 

7.1.2 COLD SOLVENT CLEANING AND DEGREASING 

Small items used in the paint and ink manufacnrring process may be cleaned by washing with 

solvents in a cold cleaner or vapor dcg.reaser. SCCs that correspond to these types of 

cleaning operations appear under the "Cold Solvent Cleaning" and "Deg:reasing" source 

descriptions in Table 8.7-1. 

7.1.3 SOLVENT RECLAMATION 

Emissions from the solvent reclamation process occur from loading solvent into distillation 

equipment. operation of tile distillation equipment, and spillage. The codes in Table 8.7-1 

under the "Wa;1e Solvent Recovery Operations" proce:os description are recotrunended to 

describe these emissions. 

7.1.4 MATERIAl. STORAGE 

In paint and ink manufacturing facilities, solvents are typically stored in fLxed roof storage 

tanks. The SCCs that correspond to e-missions of various types of organjc solvents are 

presented in Table 8.7- 1 under the "Fixed Roof Tank" process description. 

cliP Volume II 8.7-1 

VES016034 
CHAPTER 8 • PAINT AND INK MANUFACTURING :V.WB 

7.2 AIRS CONTROL DEVICE CODES 

Control device codes applicable to the paint and ink manufacturing industry are presented in 

Table 8.7-2. These should be used to enter the type of applicable emission control device into 

the AIRS Facitity Subsystem (AFS). The "099" control code may be used tor miscellaneous 

control devices that do not have a unique identification code. 

8.7-2 EIIPVo/IJme/1 

VES016035 
3/3/98 CHAPTER 8 • PAl NT AND INK MANUFACTURING 

TABLE 8.7·1 

SOURCE CLASSIFICATION CODES FOR PAINT AND INK MANUFACTURING 

OPERATIONS (SIC CODE 2851) 

Source 

Description Process Description sec Uolts 

Paint Geaeral Mixing and Handling 3010 1401 Tons paint produced 

Manufacture 

Pigment Handling 30101402 Tons pigment 

processed 

Solvent Loss: General 30101403 Tons of solvent lost 

Raw Material Storage 30101404 I ,000 gallons stored 

Premi.v'Preassembly 30101415 Tons paint produced 

Premix/Preassembly: Mix Tanks and 30101416 Tons paint produced 

Agitators 

Premix/Preassembly: Drums 30101417 Tons paint produced 

Premix!Preassembly: Material Loading 30101418 Tons paint produced 

Pigm<:nt Grinding/Milling 30101430 Tons pigment 

processed 

Pigment Grinding/Milling: Roller Mills 30101431 Tons pigment 

processed 

Pigment Grinding/Milling: Ball and 30 101432 Tons pigment 

Pebble Mills processed 

Pigment Grinding/Milling: Attritors 30101433 Tons pigment 

processed 

Pigment Grinding/Milling: Sand Mills 30101434 Tons pigment 

processed 

Pigment Grinding/Milling: Bead Mills 30101435 Tons pigment 

processed 

Pigment Grinding/Milling: Shot Mills 30101436 Tons pigment 

processed 

EIIP Volume II 8.7-3 

VESOI6036 
CHAPTER 8 - PAINT AND INK MANUFACTURING 

TABLE 8.7·1 (CONTINUED) 

Source 

Description Process Description sec Units 

Paint Pigment Grinding/Milling: Stone Mills 30101437 Tons pigment 

Manufacture processed 

(Cont.) Pigment Grinding/Milling: Colloid 30101438 Tons pigment 

Mills processed 

Pigment Grinding/Milling: Kady Mills 30 101439 Tons pigment 

processed 

Pigment Gtinding/Milling: 30 101440 Tons pigment 

Impingement Mills processed 

Pigment Grinding/Milling: Horizontal 30101441 Tons pigment 

Media Mills processed 

Product Finishing 30101450 Tons paint produced 

Product Finishing, Tinting: Mix Tank 30101451 Tons paint produced 

ond Disperser 

Product Finishing, Tinting: Fixed 30 101452 Tons paint produced 

Blend Tank 

Product Finishing, Thinning: Mbt 30 101453 Tons paint produced 

Tank and Disperser 

Product Finishing, Thinning: Fixed 30101454 Tons paint produced 

Blend Tank 

Product Filling 30101460 Tons paint produced 

Product Filling: Scale Systent 301 01461 Tons paint produced 

Product Filling: Produc1 Filtering 30101462 Tons paint produced 

Product Filling: Filling Qperalions 30101463 Tons paint produced 

Equipment Cleaning 30101470 Tons paint produced 

8.7-4 EIIP Vo/IJme II 

VE$016037 
3/3198 CHAPTER 8- PAINT AND INK MANUFACTURING 

TABLE 8 .7-1 (CONTINUED) 

Source 

Descripllon Process Description sec Units 

Paint Equipment Cleaning: Hand Wipe 30101471 Tons paint produced 

Manufacture Equipment Cleaning: Tanks, Vessels, 30101472 Tons paint produced 

(Cont.) etc. 

Other Not Classified 30101498 Tons processed 

Other Not Classified 30101499 Tons product 

Lnk Vehicle Cooking: General' 30102001 Tons produced 

Manufacture Vehicle Cooking: Oils" 30102002 Tons produced 

Vehicle Cooking: Oleoresin' 30102003 Tons produced 

Vehic lc Cooking: All-yds' 30102004 Tons produced 

Pigment Mixing 30102005 Tons Pigment 

Other Not Classified 30102099 Tons produced 

Cold Solvent Methanol 40100301 Tons solvent 

Cleaning/Stri consumed 

pping 

Metl1ylene Chloride 40100302 Tons solvem 

consumed 

Stoddard (Petroleum) Solvent 40100303 Tons solvent 

consumed 

Perchloroethylenc 40100304 Tons solvent 

consumed 

I , I, I-Trichloroethane (Methyl 40100305 Tons solvent 

Chloroform) consumed 

Trichloroethylene 40100306 Tons solvent 

consumed 

Isopropyl Alcohol 40100307 Tons solvent 

consumed 

' These processes typically occur in a chemical plant rather than an ink manufacturing plant (EPA, 

l992a). 

EIIP Volume// 8.7-5 

VESOI6038 
CHAPTER 8 - PAINT AND INK MANUFACTURING 3/31118 

TABLE 8.7-1 (CONTINUED) 

Source 

Description Process Description sec Units 

Cold Solvent Med1yl Ethyl Ketone 401 00308 Tons solvent 

CleaningfStri conswned 

pping Freon® 40100309 Tons solvent 

(Cont.) consumed 

Acetone 40100310 Tons solvent 

consumed 

Glycol Ethers 4010031 I Tons solvent 

com;umed 

Entire Unit 40100335 Cold cleaners in 

opemtion 

Degreaser: Entire Unit 40100336 1,000 sq. ft. product 

surface area 

Other Not Classified 40100398 Gallons solvent 

consumed 

Other Not Classified 40100399 Tons solvent 

consumed 

Degreasing Stoddard (Petroleum) Solvent: Open- 40100201 Tons make-up solvent 

top Vapor Degrcasing used 

I, I ,1-Trichlorocthnne (Methyl 401 00202 Tons make-up solvent 

Chloroform): Open-top Vapor used 

Degreasing 

Perchloroethyleue: Open-top Vapor 40 100203 Tons make-up solvent 

Degreasing used 

Methylene Chloride: Open top Vapor 40100204 Tons make-up solvent 

De greasing used 

Trichloroethylene: Open-top Vapor 40100205 Tons make-up solvent 

Degreasing used 

Toluene: Open-lop Vapor Degreasing 40 100206 Tons make-up solvent 

used 

8.7-6 EIIP Volume II 

VES016039 
CHAPTER 8 - PAl N T AND INK MANUFACTURING 

TABLE 8.7-1 (C ONTINUED) 

Source 

Description Process Description sec Units 

De greasing Trichlorotrifluoroelhane (Freon®): 40100207 Tons make-up solvent 

(Cont.) Open-top Vapor Degrcasing used 

Chlorosolve: Open-top Vapor 40100208 Tons make-up solvent 

Degreasing used 

Butyl Acetate 40100209 Tons make-up solvent 

used 

Entire Unit: Open-top Vapor 40100215 DegreasiJ'lg units in 

Oegreasing operation 

Degreaser: Entire Unit 40100216 1,000 sq. ft. product 

surface area 

Entire Unit 40100217 Sq. ft. surface area x. 

hours operated 

Stoddard (Petroleum) Solvent: 40100221 Tons make-up solvent 

Conveyomed Vapor Oegreasing used 

1,1,1 -Trichloroethane (Methyl 40100222 Tons muke-up solvent 

Chloroform): Conveyorized Vapor used 

Degreasing 

Perchloroelhylene: Conveyorized 40100223 Tons make-up solvent 

Vapor Degreasing used 

Methylene Chloride: Conveyorized 40100224 Tons make-up solvent 

Vapor Degreasing used 

Trichloroethylene: Couveyorized 40100225 Tons make-up solvent 

Vapor Oegreasing used 

EIIP Vo/umo/1 8.7-7 

VESOI6040 
CHAPTER 8 - PAINT AND INK MANUFACTURING 

TABLE 8.7-1 (CONTINUED} 

Source 

De5crlption Process Description sec Units 

Degreasing Entire Unit: witb Vaporized Solvent: 40100235 Degreasing units in 

(Cont.) Conveyorized VaJlOr Degreasing . operation 

Entire Unit: with Non-boiling Solvent: 40100236 Degreasing units in 

Conveyorized Vapor Degreasing operation 

Stoddard (PetrOleum) Solvent: 40100251 Gallons soh•eot 

General Oegreasing Units consumed 

1,1,1 -Tricbloroetbane (Methyl 40100252 Gallons solvent 

Chlorofonn): General Oegreasiug consumed 

Units 

l'erchloroethylcoe: General 40100253 Gallons solvent 

Degreasiog Units consumed 

Methylene Chloride: General 40100254 Gallons solvent 

' Del(reasingUnits consumed 

Trichloroethylene: General Dcgreasing 40100255 Gallons solvent 

Units consumed 

Toluene: General Degreasing Units 40100256 Gallons solvent 

consumed 

Trichlororrifluoroethane (Freon®): 40100257 Gallons solvent 

General Degreasing Units consumed 

Trichlorofluorometbane: General 40100258 Gallons solvent 

Degreasing Units consumed 

1,1,1-Trichloroethane (Methyl 40100259 Gallons solvent 

Chloroform): Genernl Degreasing consumed 

Units 

Other Not Classified: General 40100295 Gallons solvent 

Oegreasing Units consumed 

8.7-8 EIIP Volum<t II 

VES016041 
3/3198 CHAPTER 8 ·PAINT AND INK MANUFACTURING 

TABLE 8 7-1 (CONnNUED) 

Source 

Description Process Description sec Units 

De greasing Other Not Classified: General 40100296 Gallons solvent 

(Com.) Degreasing Uni1S consumed 

Other Not Classified: Open-top Vapor 40100297 Gallons solvem 

Degreasing COnSW11Cd 

Other Not Classified: Conveyorized 40100298 Tons make-up solvent 

Vapor Degreusing used 

Other Not Classified: Open-top Vapor 40100299 Tons make-up solvent 

Degrcasing used 

Waste Stomge Tank Vent 49000201 Tons reclaimed 

Solvent solvent 

Recovery Condenser Vent 49000202 Tons reclaimed 

Operations solvem 

Incinerator Stack 49000203 Tons reclaimed 

solvent 

Solvent Spillage 49000204 Tons reclaimed 

solvent 

Solvent Loading 49000205 Tons reclaimed 

solvent 

Fugitive Leaks 49000206 Process unit -year 

Disti Uation Vent 49000207 Tons reclaimed 

solvent 

Decanting 49000208 Tons reclaimed 

selvent 

Salting 49000209 Tons reclaimed 

solvent 

Other Not Classified 49000299 Tons reclaimed 

solvent 

Fixed Roof n-Buty l Alcohol: Breathing Loss 4070080 1 1,000 gallons storage 

Tanks - capacity 

Alcohols 

n-Butyl Alcohol: Working Loss 40700802 1,000 gullons 

tbroughp~t 

sec-Butyl Alcohol: Brcathiog Loss 40700803 1,000 gallons storage 

capacity 

EIIP Volume II 8.7-9 

VES0\6042 
CHAPTER 8 -PAINT AND INK MANUFACTURING 313198 

TABLE 8.7-1 (CONTINUED) 

Source 

Description Process Description sec Units 

Fixed Roof sec-Butyl Alcohol: Working Loss 40700804 I ,000 gallons 

Tanks- throughput 

Alcohols 

(Cont.) 

ten-Butyl Alcohol: Breathing Loss 40700805 1,000 gallons storage 

capacitv 

ten-Butyl Alcohol: Working Loss 40700806 1.000 gallons 

throughput 

Cyclohexanol: Breathing Loss 40700807 1,000 gallons stordge 

capacity 

Cyclohexanol: Working Loss 40700808 I ,000 gallons 

throughput 

Ethyl Alcohol: Breathing Loss 40700809 1,000 gallons storage 

capacity 

Elhyl Alcohol: Working Loss 40700810 1,000 gallons 

throughput 

Isobutyl Alcohol: Breathing Loss 4070081 I 1,000 gallons storage 

capacity 

Isobutyl Alcohol: Working Loss 407008 12 1,000 gallons 

throughput 

Isopropyl Alcohol: Breathing Loss 40700813 1,000 gallons storage 

capacity 

Isopropyl Alcohol: Working Loss 40700814 1,000 gallons 

throughput 

Methyl Alcohol: Breathing Loss 40700815 1,000 gallons storage 

capacity 

Methyl Alcohol: Working Loss 40700816 1.000 gallons 

tluougbput 

n-Propyl Alcohol: 40700817 1,000 gallons storage 

Brealhing Loss capacity 

8.7-10 EJIP Volume II 

VES016043 
313198 CHAPTER 8- PAINT AND INK MANUFACTURING 

TABLE 8.7-1 (CONTINUED) 

Source 

~criplion Process lptio n sec UnitS 

Fixed Roof n-Propyl Alcohol: Working Loss 40700818 1.000 gallons 

Tanks - throughput 

Alcohols Xylol: Breathing Loss 40700819 I ,000 gallons storage 

(Cont.) capacity 

Xylol: Working Loss 40700820 1,000 gallons 

throughput 

SpecifY Alcohol: Breathing Loss 40700897 I ,000 gallons storage 

capacity 

S[X-'Cify Alcohol: Working Loss 40700898 I ,000 gallons 

throughput 

Fixed Roof n-Decane: Breathing Loss 40701601 1.000 gallons storage 

Tanks. capacity 

Alkanes n-Decane: Working Loss 4070 1602 I ,000 gallons 

(Paraffins) throughput 

n-Dodecane: Breathing Loss 40701603 I ,000 gallons storage 

capacity 

n-Dodecane: Working Loss 40701604 I ,000 gallons 

throughput 

n-Heptane: Breathing Loss 40701605 I ,000 gallons storage 

ca:pacitv 

n-Heptane: Working Loss 40701606 I ,000 gallons 

throughput 

lsopentaoe: Breathing Loss 4070 1607 1,000 gallons storage 

capacity 

lsopentane: Working Loss 40701608 1,000 gallons 

throughput 

Pcntadecane: Breathing Loss 40701 609 1.000 gallons storage 

capacity 

EIIP Volume// 8.7-11 

VES016044 
CHAPTER 8- PAINT AND INK MANUFACTURING 313198 

TABLE 8.7-1 (CONTINUED) 

Source 

Description Process Description sec Units 

Fixed Roof Pentadecane: Working Loss 40701 610 1,000 gallons 

Tanks- throughput 

Alkanes Naphtha: Breathing Loss 40701611 1,000 gallons storage 

(Paraffins) capacity 

(Cont.) Naphtha: Working Loss 40701612 1,000 gallons 

throughput 

Petroleum Distillate: Breathing Loss 40701613 1,000 gallons storage 

capacity 

Petroleum Distillate: Working Loss 40701614 1,000 gallons 

throughput 

Hexane: Breathing Loss 40701615 1 ,000 gallons storage 

capacity 

Hexane: Working Loss 40701616 I ,000 gallons 

throughput 

Specify Alkane: Breathing Loss 40701697 I ,000 gallons storage 

capacity 

Specify Alkane: Working Loss 40701698 I ,000 gallons 

throughput 

Fixed Roof Dodecene: Breathing LO$S 40702001 1,000 gallons storage 

Tanks- capacity 

Alkenes Dodecene: Working Loss 40702002 1,000 gallons 

(Oicfins) throughput 

Heptenes - General: Breathing Loss 40702003 1,000 gallons storage 

capacity 

Heptenes - General: Working Loss 40702004 1,000 gallons 

throughput 

Specify Olefin: Breathing Loss 40702097 I ,000 gallons storage 

capacity 

8.7-1 2 EIIP Volume// 

VES01604S 
CHAPTER 8 • PAINT AND INK MANUFACTURING 

TABLE 8.7-1 (CONTINUED) 

Source 

Description Process Dcscrlprlon sec Units 

Fixed Roof Specify Olefin: Working Loss 40702098 I ,000 gallons 

Tanks· throughput 

Alkeoes 

(Olefins) 

(Cont.) 

Fixed Roof Benzene: Breathing Loss 40703601 I ,000 gallons storage 

Tanks - capacity 

Aromatics Benzene: Working Loss 40703602 I ,000 gallons 

tlrrougbput 

Cresol: Breathing Loss 40703603 I ,000 gallons storage 

capacity 

Cresol: Working Loss 40703604 1,000 gallons 

throughjlllt 

Cumene: Breathing Loss 40703605 I ,000 gallons storage 

capacity 

Cumene: Working Loss 40703606 1,000 gallons 

throughput 

Diisopropyl Benzene: Breathing Loss 40703607 I ,000 gallons storage 

capacity 

Oiisopropyl Benzene: Working Loss 40703608 I ,000 gallons 

throughput 

Ethylbcnzene: Breathing Loss 40703609 I ,000 gallons storage 

capacity 

Etbylbcuzene: Working Loss 40703610 1,000 gallons 

throughput 

Methyl Styrene: Breathing Loss 4070361 1 I ,000 gallons storage 

c-apacity 

Methyl Styrene: Working Loss 40703612 I ,000 gallons 

throughput 

EIIP Volume II 8.7-13 

VESO I6046 
CHAPTER 8- PAINT AND INK MANUFACTURING .l/3.198 

TABLE 8.7-1 (C ONTINUED} 

Source 

Description Process Descri.ption sec Units 

Fixed Roof Styrene: Breathing Loss 40703613 I ,000 gallons storage 

Tanks- capacity 

Aromatics Styrene: Working Loss 40703614 I ,000 gallons 

(Cont.) throughput 

Toluene: Breathing Loss 40703615 1,000 gallons storage 

capacity 

Toluene: Working Loss 40703616 1,000 gallons 

throughput 

m-Xylene: Breathing Loss 40703617 1,000 gallons storage 

capacity 

m-Xylene: Working Loss 40703618 1,000 gallons storage 

capacity 

o-Xylene: Breathing Loss 40703619 1,000 gallons storage 

capacity 

o-Xylene: Working L<>ss 40703620 I ,000 gallons 

throughput 

p-Xylene: Breathing Loss 40703621 1,000 gallons storage 

1 capacity 

p-Xylene: Working Loss 40703622 1,000 gallons 

throughput 

Xylenes, Mixed: Breathing Loss 40703623 1,000 gallons storage 

capacity 

Xylenes, Mixed: Working Loss 40703624 I ,000 gallons 

throughput 

Creosote: Breathing Loss 40703625 1,000 gallons storo~ge 

capacity 

Creosote: Working Loss 40703626 I ,000 gallons 

throughput 

8.7-14 EIIP Volume II 

VESOI6047 
313198 CHAPTER 8- PAINT AND INK MANUFACTURING 

TABLE 8.7-1 (CONTINUED) 

Source 

Description P roccs5 Description sec Uniu 

Fixed Roof Specify Aromatic: Breathing Loss 40703697 1,000 gallons storage 

Tanks - capacity 

Aromatics Specify Aromatic: Working Loss 4070369R 1,000 gallons 

(Cont.) throughput 

Fixed Roof Butyl Carbitol: Breathing Loss 40705201 1,000 gallons storage 

Tanks- capacity 

Glycol Ethers Butyl Carbitol: Working Loss 40705202 1,000 gallons 

throughput 

Butyl Cellosolve: Breathing 40705203 1,000 gallons storage 

capacity 

Butyl Cellosolve: Working Loss 40705204 1,000 gallons 

throughput 

Carbitol: Breathing Loss 40705205 1,000 gallons storage 

capacity 

Carbitol: Working Loss 40705206 I .000 gallons 

throughput 

Cellosolve: Breathing Loss 40705207 1,000 gallons storage 

capacity 

Cellosolve: Working Loss 4070520R 1,000 gallons 

throughput 

Diethylene Glycol: Breathing Loss 40705209 I ,000 gallons storage 

capacity 

Diethylene Glycol: Working Loss 40705210 I ,000 gallons 

throughput 

Methyl Carbitol: Breathing Loss 4070521 I 1,000 gallons storuge 

I capacity 

Methyl Carbitol: Working Loss 40705212 1,000 gallons 

throughput 

CliP Volume II 8.7-15 

VESOL6048 
CHAPTER 8- PAINT AND INK MANUFACTURING 

TABLE 8.7-1 (CONTINUED) 

Source 

DescriptJon Process DescriptJon sec Units 

Fixed Roof Methyl Cellosolve: Breathing Loss 40705213 1 ,000 gallons storage 

Tanks- cnp:~city 

Glycol Etl1ers Methyl Cellosolve: Working Loss 407052 14 1 ,000 gallons 

(Cont) throughput 

Polyethylene Glycol: Breathing Loss 40705215 I ,000 gallons storage 

capacity 

Polyethylene Glycol: Working Loss 40705216 I ,000 gallons 

throughput 

Triethylene Glycol: Breathing Loss 407052 17 I ,000 gallons storage 

capacity 

Triethylene Glycol: Working Loss 40705218 1.000 gallons 

throughput 

Specify Glycol Ether: Breatlling Loss 40705297 1.000 gallons storage 

capacity 

Specify Glycol Ether: Working Loss 40705298 1 ,000 gallons 

throughput 

Fixed Roof 1,4-Butanediol: Breathing Loss 40705601 1 ,000 gallons storage 

Tanks· capacirv 

Glycols 1 ,4-Butanediol: Working Loss 40705602 1,000 gallons 

dll'Oughput 

Ethylene Glycol: Breathing Loss 40705603 I ,000 gallons storage 

capacity 

Ethylene Glycol: Working Loss 40705604 1 ,000 gallons 

throughput 

Dipropyleoe Glycol: Brentl1ing Loss 40705605 1 ,000 gallons storage 

capacity 

Dipropylene Glycol: Working Loss 40705606 1 ,000 gallons 

throughput 

8.7-16 EJIP Volume II 

VESOI6049 
CHAPTER 8- PAINT AND INK MANUFACTURING 

TABLE 8 .7-1 (CONTINUED) 

Source 

Description Process Description sec Units 

Fixed Roof Glycerol: Breatbing Loss 40705607 I ,000 gallons storage 

Tanks- capacity 

Glycols Glycerol: Working Loss 4070560& I ,000 gallons 

(Cont.} throughput 

Propylene Glycol: Breathing Loss 40705609 I ,000 gallons storage 

capacity 

Propylene Glycol: Working Loss 40705610 I ,000 gaUons 

throughput 

Speecy Glycol: Brealhing Loss 40705697 1,000 gallons storage 

capacity 

Spee.cy Glycol: Working Loss 40705698 1,000 gallons 

throughput 

Fixed Roof Benzyl Chloride: Breathing Loss 40706001 I ,000 gaUons storage 

Tanks - capacity 

Halogenated Benzyl Chloride: Working Loss 40706002 I ,000 gallons 

Organics throughput 

Caprolactam (Solo): Breathing Loss 40706003 1,000 gallons storage 

capacity 

Caprolactam (Soln): Working Loss 40706004 I ,000 gallons 

tbrou&bput 

Carbon Tetrachloride: Oreathing Loss 40706005 I ,000 gallons storage 

capacity 

Carbon Tetrachloride: Working Loss 40706006 I ,000 gallons 

throughput 

Chlorobenzene: Brealhing Loss 40706007 I ,000 gallons storage 

capacity 

Chlorobenzene: Working Loss 40706008 1,000 gallons 

throughput 

EIIP Volume II 8.7-17 

VESOI6050 
CHAPTER 8- PAINT AND INK MANUFACTURING 313198 

TABLE 8.7-1 (CONTINUED) 

Source 

Description Process Description sec Units 

Fixed Roof o-Dichlorobenzene: Breathing Loss 40706009 I ,000 gallons storage 

Tanks - capacity 

Halogenated o-Dichlorobenzene: Working Loss 40706010 I ,000 gallons 

Organics throughput 

(Cont.) p-Dichlorobcnzene: Breathing Loss 4070601 1 I ,000 gallons storage 

capacity 

p-Dichlorobcozene: Worlciug Loss 40706012 1 ,000 gallons 

throughput 

Epichlorohydrin: Breathing Loss 40706013 I ,000 gallons storage 

capacity 

Epichlorohydrin: Working Loss 40706014 I ,000 gallons 

throughput 

Ethylene Dibromide: Breathing Loss 40706015 I ,000 gallons storage 

capacity 

Ethylene Dibromide: Working Loss 40706016 I ,000 gullons 

throug/l_QUI 

Ethylene Dichloride: Breathing Loss 407060!7 1,000 gallons storage 

capacity 

Ethylene Dichloride: Working Loss 40706018 1,000 gallons 

throuj.\bput 

Methylene Chloride: Breathing Loss 40706019 1,000 gallons storage 

capacity 

Methylene Chloride: Working Loss 40706020 1,000 gallons 

throughput 

Perchloroethylene: Breathing Loss 40706021 I ,000 gullons storJge 

capacity 

Perchloroethylene: Worlcing Loss 40706022 I ,000 gallons 

tbroug_hput 

8.7- 18 EIIP Volume II 

VESOI6051 
J131!18 CHAPTER 8- PNNT AND INK MANUFACTURING 

TABLE 8.7-1 (CONTINUED) 

Source 

Description Process Description sec Units 

Fixed Roof Trichloroethylene: Breathing Loss 40706023 1,000 gallons storage 

Tanks- capacity 

Halogenated Trichloroethylene: Working Loss 40706024 I ,000 gallons 

Organics tlu·oughput 

(Cont.) 1,1,1-Trichloroethane: Breathing Loss 40706027 1,000 gallons storage 

capacity 

1,1,1-Trichloroet:hane: Working Loss 40706028 1,000 gallons 

throughput 

Chlorosolve: Breathing Loss 40706029 I ,000 gallons storage 

capacity 

Chlorosolve: Working Loss 40706030 1,000 gallons 

throughput 

Methyl Chloride: Breathing Loss 40706031 1,000 gallons storage 

capacity 

Methyl Chloride: Working Loss 40706032 1,000 gallons 

throu!iliput 

Chloroform: Breathing Loss 40706033 1,000 gallons storage 

capacity 

Chlorofonn: Working Loss 40706034 1,000 gallons 

throughput 

Hexachlorobenzcue: Breathing Loss 40706035 I ,000 gallons storage 

capacity 

Hexachlorobenzene: Working Loss 40706036 I ,000 gallons 

throughput 

Specify Halogenated Organic: 40706097 1,000 gallons stomge 

Breathing Loss capacity 

Specify Halogenated Organic: 40706098 1,000 gallons 

Working Loss throughput 

EIIP Volume II 8.7-19 

VESOI6052 
CHAPTER 8 ·PAINT AND INK MANUFACTURING .lf.li!IB 

TABLE 8.7-1 (CONTINUED) 

Source 

Description Process Description sec Units 

Fixed Roof Cyclohexanone: Breathing Loss 40706801 1,000 gallons storage 

Tanks- capacity 

Kerones Cyclohexanone: Wori<ing Loss 40706802 I ,000 gallons 

throughput 

Acetone: Breathing Loss 40706803 I ,000 ga llons storage 

capacity 

Acetone: Working Loss 40706804 1,000 gallons storage 

capacity 

Methyl Ethyl Ketone: Breathing Loss 40706805 1,000 gallons storage 

capacity 

Methyl Ethyl Ketone: Working Loss 40706806 1,000 gallons 

throughput 

Methyl Isobutyl Ketone: Breathing 40706807 1.000 gallons storage 

Loss capacity 

Methyl Isobutyl Ketone: Working 40706808 I ,000 gallons 

Loss throughput 

Methylamyl Ketone: Breathing Loss 40706813 1,000 gallons storage 

capacity 

Methylamyl Ketone: Worldng Loss 407068 14 1,000 gallons 

throughput 

Specify Ketone: Breathing Loss 40706897 I ,000 gallons storage 

capacity 

Specify Ketone: Working Loss 40706898 1,000 gallons 

throughput 

Fixed Roof Specify in Comments: Breathing Loss 40714697 1,000 gdllons stordge 

Tanks- capacity 

Miscellaneou Specify in Comments: Working Loss 40714698 J ,000 gallons 

throughput 

8.7-20 EIIP Volume II 

VES016053 
CHAPTER 8 -PAINT AND INK MANUFACTURING 

TABLE8.7·2 

AIRS CONTROL TECHNIQUE CODES 

Contn1l Device Code 

Fabric Filter - High Temperature 016 

Fabric Filter · Medium Temperature 017 

Fabric Filter - Low Temperature 018 

Venturi Scrubber 053 

Miscellaneous Control Device 099 

EIIP Volume II 8.7-21 

VES016054 
CHAPTER 8- PAINT AND INK MANUFACTURING 313198 

This page is intentionally left blank. 

8.7-22 EIIP Volume II 

VES01 6055 
8 

REFERENCES 

EriP. 1996. Preferred and Alter11atil'l! Methods far Estimati11g Air Emissions from Hot-Mix 

Asphalt Plams, Final Report. l'repared for the Point Sources Committee, Emission Inventory 

Improvement Program under EPA Contract No. 68-0 2-0160, Work Assignment No. 82. U.S. 

Enviromnental Protection Agency, Office of Air Quality Planning and Standards. Research 

Triangle Park, North Carolina. 

EPA. 1987. Estimaring Releases and Waste Th?atment Efficiencies for the Toxic Chemical 

Release lnvent01y Fonn . U.S. Environmental Protection Agency, Office of Pesticides and Toxic 

Substances, EPA-5()0/4-88.002. Washington, D.C. 

EPA. 1991 . Comrol Technologies for Hazardous Air Pollutants Handbook. 

U.S. Envirorunental Protection Agency, Air and Energy Engineering Resew-ch Lllbotatory, 

EP A-625/6-91/0 14. Research Triangle Park. North Carolina. 

EPA. 1992a. Control ofVOC Emissions from Ink and Paim Manufacturing Processes. U.S. 

Environmental Protection Agency, Office of Air Quality Planning and Standards, 

EPA-450/3-92.()13. Research Triangle Park, North Carolina. 

EPA. 1992b. Protocol for Determining Emissions from Paint and Coating Mixing Processes. 

U.S. Environmental Protection Agency, Office of Air Quality PlaMing and Standards, Reseanch 

Triangle Park, North Carolina. 

EPA. 1994a. Air Emissions Models for Waste and Wastewater. U.S. Environmental Protection 

Agency, Office of Air Quality Planning and Standards, EPA-453/R-94-0SOu. Research Triangle 

Pari<, North Carolina. 

EPA. 1994b. Quality Assurance Handbook for Air Pollution Measurements Systems: Volume 

m. Stationary Source Specific Methods (Interim Edition). U.S. Environmental Protection 

Agency, Office of Research and Development, EPA-600/R-94-038c. Washington,-D.C. 

EPA. !994c. Co111rol of Volatile Organic Compou11d Emissions from Batch ProcessesAlternate C£Jfltrol Techniques. U.S. Environmental Protection Agency, Omce of Air Quality 

Planning and Standards, EPA-453/R-93-017. Research Triangle Park, North Carolina. 

EPA. 1995a. Compilation of Air Pollutalll Emission Factors. Volume 1: Stationary Point and 

Area Sources, Fifth Edition, AP-42. Section 7.1. Organic Liquid Storage Tanks. U.S. 

Environmental Prote<.1ion A~ency, Office of Air Quality Planning and Stamdards. Research 

Triangle Park, Nonh Carolina. 

EttP Volume It 8.8-1 

VES016056 
CHAPTER 8- PAINT AND INK MANUFACTURING 

EPA. 1995b. Compilation of Air Polluta111 Emission Factors. Volwne I: Stationary Point am/ 

Area Source.v, Fifth Edition, AP-42. Seciion 6.4, Paint and VanrLvh. U.S. Environmental 

Proccction Agency, Office of Air Quality Planning and Standards. Research Triangle Park, North 

Carolina. 

EPA. 1995c. CompilaTion of Air Pollutant Emissio11 Factors. Volume I: Stationary Point and 

Area Sources. Fifth Edition. AP-41. Section 5.1, Tratrsportarion and Marketing of Petroleum 

Uquidv. U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards. 

Research Triangle Park, North Carolina. 

EPA. 1995d. Compilation of Air Pollutant Emission Factors. Volume 1: StationaJy Point and 

Area Sources. Fifth Editum. AP-42. Section 4. 7, Waste Solvent ~XIamarion. U.S. 

Enviromnental Protection Agency, Office of Air Quality Planning and Standards. Research 

Triangle Park, North Carolina. 

EPA. 1995e. Compilation of Air Pollutallt Emission Factors. Volume I: Stationmy Point and 

Area Sources. Fifth Edition, AP-42. Section 4.6, Solvent DegretLving. U.S. Environmental 

Protection Agency, Office of Air Quality Planning and Standards. Research Triangle Park, North 

Carolina. 

EPA. 1995f. Memorandum on AP-42 Emission Factors for the Paint and Vamish Jndustry from 

Dennis Beauregard, U.S. Environmental Protection Agency. Office of Air Quality Planning and 

Standards, Research Triangle Park. North Carolina, to Robert J. Nelson, National Paint and 

Coatings Association. Wasbing10o, D.C. 

EPA. 1995g. Protocelfor Equipment Leak Emission Estimates. U.S. Environmental Protection 

Agency, Office of Air Quality Planning and Standards, EPA-453/R-95-017. Research Triangle 

Park, North Carolina. 

EPA. 1995b. Factor lnfon11afion aJld Retrieval {FIRE) Data System. Version 5.I. Updated 

annually. U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards, 

Research Triangle Park, Nonh Carolina. 

Fisher, Perty W., Steven A. Frey, and Kaushik Deb. 1993. Emission E.ftimation Methodologies -

Paint Mamlfacturing Industry, Paper 93-TP-57.07, Air and Waslc Management Association, 

presented at the 86th Annual Meeting and Exb.ibition, Denver, Colorado, June 13-18, 1993. 

NAPIM. 1996. National Associalion of Printitlg Ink Manufacturers Guide to Estimating VOC 

Emissions from Prinritlg Ink Manrlfacturing. National Association of Printing Ink 

Manufacturers, Inc. Hasbrouk Heights, New Jersey. 

NPCA. 1995. Emission Estimation Guidance Manual for the Paint and Coatings industry 

(Second Edition). National Paint and Coatings Association, Inc., Washington, D.C. 

8.8-2 EIIP Volume II 

YES016057 
CHAPTER 8 • PAINT AND INK MANUFACTURING 

Noyes, Roben, Editor. 1993. Pollution Prevention TL't:hnology Ham/book. Noyes Publications, 

Park Ridge, New Jersey. 

EIIP Volume II 8.8-3 

VES016058 
CHAPTER 8 - PAINT AND INK MANUFACTURING 3/3198 

This page is intentionally left blank. 

8.8-4 EJIP Volume If 

VES016059 
CHAPTER 8 - PAINT AND INK MANUFACTURJNG 

APPENDIX A 

EXAMPLE DATA COLLECTION FORMS 

AND INSTRUCTIONS -

PAINT AND INK MANUFACTURING 

EIIP Volume II 

VESOI6060 
CHAPTER 8 · PAINT AND INK MANUFACTURING 313198 

This page is intentionally left blank. 

EJFP Volume II 

VES016061 
:V.WB CHAPTER 8 ·PAINT AND INK MANUFACTURING 

EXAMPLE DATA COLLECTION FORMS INSTRUCTIONS · 

PAINT AND INK MANUFACTURING FACILITIES 

I. These forms may be used as a work sheet to aid tbe plant engineer in collecting the 

infonnation necessary to calculate emissions from paint and ink manufacruring facilities. 

Tite information requested on the forms relate to the methods (described in Sections 3, 4, 

and 5) for quanrizying enlis. ions. These forms may also be used by lhe regulatory agency to 

assist in area-wide inventory preparation. 

2. The completed foons should be maintained in a reference file by the plant engineer wilb. 

other supporting documentation. 

3. If the information requested is unknown, wrile "unknown" in tbe blank. If the information 

requested does not apply to a particular unit or process, write "NA" in the blank. 

4. If you want to modify the form to better serve your needs, an electronic copy of the form 

may be obtained lb.rough the EUP on lhe Clearinghouse for Inventories and Enlission 

Factors (CHIEF) website (www.epa.gov/ttn/cbief7). 

5. Collect all Manufucturer's Teclutical Data Sheets (TOSs) for all materials containing 

potential air contaminants that are used at the facility. 

6. The plant engineer should maintain all material usage information and TOSs in a reference 

file. 

EIIP VolimrB II S.A-1 

VES016062 
CHAPTER 8- PAINT AND INK MANUFACTURING 

ExAMPLE DATA COLLECTION f ORM 

fORM A: GENERAL INFORMATION 

Facility/Plant Name: 

SIC Code: 

SCC: 

sec Description: 

Location: 

County: 

Ci : 

State: 

Plant Geographical Coordinates: 

Latitude: 

Longitude: 

UTMZone: 

liTM Easting: 

UTM Northing: 

Contact Name: 

Title: 

Telephone Numbetc 

8.A-2 EIIP Vol"'"" II 

VES016063 
3/lf98 CHAPTER 8 • PAINT AND INK MANUFACTURING 

EXAMPLE DATA COLLECTION FORM 

FORM B: S OURCE INFORMATION 

Unit lD: 

Pennit No.: 

Location: 

Unit Description: 

Manu facrurer: 

Date Jnsllllled: 

Date Modified: 

Opemting Schedule: 

Houn;/Da : 

Da s/Week: 

Weeks/Year: 

Raw Material Used: 

Material Name Constituents Mass % 

EIIP VoiiMno II S.A-3 

VES016064 
CHAPTER 8 - PAINT AND INK MANUFACTURING 313198 

El<AMPL.E DATA COLLECTION f ORM 

FORM C : CONTROL DEVICE INFORMATION 

Unit!D: 

PennitNo.: 

Location: 

Pollutant Controlled: 

Control Efficiency (Indicate source of information): 

Type of Conn·ol Device: 

o Baghouse 

0 Thermal Incinerator 

0 Other (indicate type) 

Manu lacturer. 

Date Installed: 

Date Modified: 

Operating Schedule: 

Hours/Day: 

Da s/Week: 

WeeksfYear. 

Source(s) Linked to this Control Device: 

8.A-4 EJ/P Volume II 

VES016065 
313198 CHAPTER 8 - PAINT AND INK MANUFACTURING 

EXAMPLE DATA C OLLECTION FORM 

FORM 0 : STACK INFORMATION 

Stack ID: 

Unit!D: 

Stack (Release) Height (ft): 

Stack Diameter (inch): 

Stack Gas Temperalllre (•F): 

Stack Gas Velocity (ftlsec): 

Stack Gas Flow Rate (ascGmin): 

Source{s) Linked to this Stack: 

EJIP Volume II S.A-5 

VES016066 
CHAPTER 8 - PAJIVT AND INK MANUFACTURING 

EXAMPLE DATA COLLECTlON FORM 

FORME: PRODUCTlON INFORMATION 

Product Name Year Amount Produced (lb/yr) 

8.A·6 EIIP Volume II 

VES016067 
CHAPTER 8 - PAINT AND INK MANUFACTURING 

ExAMPLE DATA COLLECTION FORM 

FORM F- SOLVENT USAGE -

Amount Used 

Solvent Name Conslltucnts Mass% (lb/yr) 

EIIP Volume II 8.A-7 

VES016068 
CHAPTER 8 - PAINT AND INK MANUFACTURING 313198 

ExAMPLE DATA COLLECTION FORM 

FORM G· PIGMENT USAGE 

Amount Ust'il 

Pigment Name Constituents Mass% (lb/yr) 

S.A-8 EIIP Volume II 

VES016069 
CHAPTER 8 • PAINT AND INK MANUFACTURJNG 

EXAMPLE DATA COU.ECTION FORM 

F ORM H · DATA FOR M IXER EMISSIONS 

Amount of 

Solvent 

Added to 

1\tbcr 

Equipment ID Solvent Constituent Mass •;. (lblyr) 

EIIP Volume II 8.A·9 

VES016070 
CHAPTER 8- PAIIVT AND INK MANUFACTURING 3'31!18 

EXAMPLE DATA COLLECTION FORM 

FORM 1: DATA FOR SOLVENT RECLAMATION EMISSIONS 

Amount Processed 

Solvent Constituent Mass '~'• 

Through Dtst1Uation evlc~ (lb/br) 

S.A-10 EIIP Volume II 

VES016071 
31l'98 CHAPTER 8 • PAIHT AND INK MANUFACTURING 

EXAMPLE DATA COLLECTION FORM 

FORM J: DATA FOR PARTS CLEANING EMISSIONS 

Hours of 

Operation SurfaccA Soh·ent Solvent Mass 

Unit 1D (br/yr) rca(ft1

) Used Consdtuent 'Yo 

EJIP Volume II 8.A·l l 

VES016072 
CHAPTER 8 · PAINT AND INK MANUFACTURING 313198 

ExAMPLE D ATA COLLECTION f ORM 

FORM K· . D ATA FOR EMISSIONS FROM C LEANING OF PROCESS VESSELS 

Volume 

Used Temp. 

Unit ID Solvent Constituent Mass •;. (gal/hr) (•F) 

S.A-12 EIIP Volume II 

VES016073 
3/3198 CHAPTEER 8 • PAl NT AND INK MANUFACTURING 

EXAMPLE DATA COLLECTION fORM 

FORM l : DATA NEEDED FOR EMISSIONS FROM SPILLS 

Duration 

of 

Date of Area Spill Temp 

Spill Material Constituent Mass o/o (ft'} {hr) (•F) 

EIIP Volume II 8.A·I 3 

VES016074 
oc: 

~ .,. -

~ 

~ 

~ ~ 

ExAMPLE DATA COLLECTION FORM 

FORM M: EMISSION ESTIMATION RESULTS 

Emission 

Ertlmalion Emissions Emission 

Pollutant' Method• Emissions Units Factor' 

• Polltllants include VOCs, I'Mii'M,.. and HAPs (liS! individually). 

Equipment ID .. ·_ ------

Emission 

Factor 

Units Comments 

b Use the rollowin,g codes to ill<licate '"hich emission estimatioo method is used for each pollutant: 

IZntission Foetor • BfMnterinl Balance • MB 

Other Method (indicotc) • 0 

Stack Test • ST 

Emission Model • EM 

"' Where opplicable. enter the emission fuctor ond provide filii citation of the reference or source ofmfonnation from where the emission 

factor c-.amc. Include cdhion, version. table and pag:e numbers if AP-42 is used.. 

Please oopy tbc blank fonn ond attuch additional sheets, os necessary. 

0 

..., 

~ 

~ Q> 

• 

~ 

~ 

~ 

~ 

~ ~ 

!ii :.; 

0 

~ 

~ 

i 

VESOJ6075 
VES016076.pdf 
-------- ·- --- ----

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION 5 

77 WEST JACKSON BOULEVARD 

CHICAGO, IL 60604·3590 

SEP 2 j 2006 

CERTI FIED MAIL 

RETURN RECEIPT REQUESTED 

Doug Harris 

General Manager 

Veolia Environmental Services 

*7 Mobile Avenue 

Sauget, Ill inois 62201 

Dear Mr . Harris: 

REPt.V TO 1ME ATTENTION OF: 

AE-17J 

This is to advise you that the United States Environmental 

Protection Agency (U.S. EPA} has determined that Veolia 

Environmental Services' facility at n7 Mobile Avenue, Sauget, 

Illinois is in v i olation of the Cl ean Air Act (CAAl and Resource 

Conservation and Recovery Act (RCRAl and associated state or 

local pollution control requirements . A l i st of the 

re~irem~nts violated is provided below. A Finding of Violation 

and Notice of Vi olation (FOV/NOV} for these violati ons is being 

issued and is enclosed. 

The CAA requires the development of Primary and Secondary 

Nati onal Ambient Air Quality Standards to protect publ ic health 

and welfare. To attain and maintai n these standards, each State 

is required to develop an implementat ion plan . The I l linois 

State Implementation Plan (Illinois SIP) includes the fol lowing 

requi rement: 

l l A source that has maximum theoretical emissions of 100 tons 

or more per cal endar year of VOM and is not limited t o less than 

100 tons of volatil e organic material (VOM} emi ssi ons per 

calendar year in the absence of air poll ution control equipment, 

through production or capacit y l imitations contained in a 

federally enforceabl e permit or a SI P revision, must control 

their emissions by 81% overall: The purpose of VOM standards is 

to reduce the amount of ground level ozone formed, which may 

cause shortness of breath, coughing, wheezing, and eye and nose 

irritation. 

VES016076 
2 

The CAA also requires the development of regulations to protect 

and enhance the quality of the• nation's air so as to promote 

public health and we lfare and the productive capacity of its 

population. To attain and maintain these standards the u.s. EPA 

has developed -emission standards as the National Emission 

Standards of Hazardous Air Pollutants (NESHAP) and emission 

standards to reflect the Maximum Achievable Control Technology 

(MACT) . Hazardous a i r pollutants (HAPS) may cause serious 

health e ffects including birth defects and cancer. They may 

also cause harmful environmental and ecological effects. The 

RCRA and Illinois Administrative Code (IAC) have similar 

requirements. The NESHAPs and MACTs and, in part , the RCRA and 

·rAe include the following requirements: 

1) Each open-ended valve or line at the facility shall be 

equipped with a cap, blind flange, plug or a second valve and 

each open-ended valve or line equipped with a second valve shall 

be operated in a manner such that the valve on the process fluid 

end is closed before the second valve is closed. 

2) A list of identification numbers for a ll equipment subject 

to the requirements of the subpart shall be recorded in a log 

that is kept in a readily accessible location. 

3) An owner or operator must test equipment for compliance with 

no detectable emissions following Me~od 21 and an owner or 

operator of each stationary source must maintain and operate the 

source, including associated equipment for.air pollution 

control, in a manner consistent with good air pollution control 

practice for minimizing emissions. 

4) A source must commence the initial comprehensive performance 

testing on an incinerator not later than six months after t he 

co.mpliance date. 

5) A source must limit its combined emissions of arsenic, 

beryllium. and chromium to 97 dry standard cubic meters. 

EPA finds that Veolia has violated the above listed Illinois 

SIP, IAC, RCRA, ~HAP and MACT requirements. 

Section 113 of the CAA and Section 3008 of the RCRA give us 

several enforcement options to resolve these violations, 

including: issuing an administrative compliance order, issuing 

,· 

VESOI6077 
3 

an administrative penal ty order, bringing a judicial civil 

action, and bringing a j udicial criminal action. The opti on we 

select, in part, depends on the efforts taken by Veolia to 

correct the alleged violations and t he time f r ame in which you 

can demonstra t e and maintai n continuous compliance with the 

requirements cited i n the FOV/NOV. 

Before we decide which enforcement option is a ppropriate, 

Sect ion 113 of the CAA provides you with the opportunity to 

request a conference with us about the viol ations all eged in the 

FOV/NOV. This conference will provide you a chance to present 

information on the identified violations. any efforts you have 

taken to comply, and the steps you will take to prevent future 

violations. Please plan for your f acility's techni cal and 

management personnel to take part in these discussions. You may 

have an attorney represent and accompany you at this conference . 

The EPA contacts in t his matter are Sarah Marshall, Air and 

Radiation Division, and Spires Bourgikos, Waste Pesticides and 

Toxics Di vision . You may call Ms. Marshal l at (312) 886- 6797 or 

Mr. Bourgikos at (312) 886- 6862 if you wi sh to request a 

conference . EPA hope s that this FOV/NOV will encourage Veolia' s 

compliance with the requi rements of the Clean Air Act and the 

Resource Conservation and Recovery Act. 

Since.r ely yours, 

t on, Acting Director 

Radiat ion Di vision 

Lorna M. Jereza, 

Compl iance Section 

Enforcement and Compliance Assurance Branch 

Waste, Pesticides and Toxics Division 

&\closure 

VE$016078 
4 

cc : Julie Armitage, Acting Chief 

Compliance and Systems Management Section 

Illinois Environmen~al Protection Agency 

Todd Marvel 

Illinois Environmental Protection Agency 

VES016079 
United States Environmental Protection Agency 

IN THE MATTER OF : ) . ) ' 

Veolia Environmental Services ) NOTICE OF VIOLATI ON and 

) FINDING OF VIOLATI ON 

Proceedings Pursuant to ) 

the Clean Air Act, ) ~PA-5-06 28 IL 

42 u.s.c . §§ 7401 et seq. and ) 

the Resource Conservation and ) 

Recovery Act, 42 u.s .c . §§ ) 

p901 e t seq . 

NOTICE AND FINDING OF VIOLATION 

Veolia Environmental Services (you or Veolia) (formerly known as 

Onyx Environmental Services) owns and operates three hazardous 

waste inc inerators, two t ank f arms and two material processing 

units a t 17 Mobil e Avenue, Sauget, I llinois (Facility) . The · 

incinerators are identified as Incinerators 2,3 and 4, the tank 

farms as 1 and 3 and the material processing areas as MP- 1 and 

MP- 2 . 

u.s. EPA is sending this Noti ce of Vi olation and Finding of 

Violation (NOV/FOV or Notice/Findi ng) to you for: Ill 

uncontrolled emissions of volat ile or ganic material (VOM) from 

MP-1 and MP- 2; (2 ) open- ended lines conveying VOM and hazardous 

air pollutants (HAPs) in the tank farms; (3) not including 

connect ors for l ines conveying VOM and HAPs in the tank farms on 

l ist of monitored equipment; 14) exceeding breakt hrough limits 

on the carbon canisters, which control s benzene, HAP, and VOM 

emissions from the tank farms; (S)late performance of the 

initial testing on Incinerator 3 as required by t he National 

Emission Standards for Hazardous Air Pollutants regulations; and 

(6) exceeding t he NESHAP limit f or a rsenic, beryllium, and 

chromium at Incinerator 3 . The underlying st atutory and 

regulatory requirements include provisions of the Clean Air Act 

(CAA) and t he Resour ce Recove ry and Conservation Ac t (RCRA) and 

their respective implementing regulati ons and the Illinois State 

·----·-· ... ·-·--- -------- -- -···· 

VES0!6080 
2 

Implementation Plan (Illinois SIP) and Administrative Code 

(IAC). 

Section 113 of the CAA provides you with the opportunity to 

request a conference with us to discuss the violations alleged 

in the FOV/NOV . This conference will provide you a chance t o 

present information on the identified violations, any efforts 

you have taken to compl y, and the steps you wil l take to prevent 

future violations. Please p lan for the Facility's technical and 

management personnel to take part in these discussions. You may 

have an attorney represent and accompany you at this conference. 

Explanation of violations 

The following provides a descri ption of the regulations Veolia 

violated and how Veolia violated them: 

1. The Illinois SIP at Part 219 regulates organic material 

emissions, which includes volatile organic compounds, for the 

Metro East Area. Subpart TT of the Part 219 includes the rules 

for emission. units not regulated under the ot her subparts of 

Part 219. 

a . Subpart TT of the Illinois SIP, Section 219 . 980, states 

that a source is subject to the rules of Subpart TT if the 

source contains process emission units1 that as a group both 

have maximum theoretical emissions of 100 tons or more per 

calendar year of VOM and are not l imited t o less t han 100 

tons of volatile organi c material (VOM or VOC) emissions 

per calendar year in the absence of air pollution control 

equipment through production or capacity l imitations 

contained i n a federally enforceabl e permit or a SIP 

rev~s~on . Subpart TT requires a source to install and 

operate controls to reduce VOM emissions by at least 81%. 

b. Based on an evaluation of the maximum throughput 

information and maximum possible VOC material processed in 

the material. processing units, MP-1 and MP- 2, U. S. EPA has 

determined that the maximum theoreti cal emissions from MP-1 

and MP- 2 exceed 100 tons per year of VOC . Therefore, MP-1 

and MP-2 are required to be controlled by 81% overall 

control. 

1Sources regulated underSubparts B, E, F, H, Q, R, s, T, v, x, Y, z, AA, BB, 

PP, QQ, or RR of Part 219 are not subject to Subpart TT requirements. 

VES016081 
--------··--------------- ----

3 

2 . 40 C.F.R. Part 61 Subpart V regulates hazardous air 

poll utant emissions, •1hich include benzene and vinyl 

chloride, from equipment leaks. 

a. 40 C.F.R. §§ 61.242- 6 !a ) and {b), 35 Illinois 

Administrative Code {lAC) § 725.956{a) (1) [40 C.F.R. 

§ 265.1056(a) (1) ] require that each open- ended valve or 

line shall be equipped with a cap, blind flange, plug or a 

second valve and each open- ended valve or line equipped 

with a second valve shall be operated in a manner such that 

the valve on t he process fluid end is closed before the 

second valve is closed. 

b. 40 C.P.R.§ 61.246(e){l), 35 IAC § 725.964{b)(l )(A) [40 

C.F .R. § 265. 1 064 (b) (1 ) {i)) require a source to record on a 

l og that is kept in a readily accessible location the 

identification numbers for a l l equipment subject to the 

requirements of Subpart V (CAA) and Subpart BB (RCRA) . 

c . During an inspection the v1eek of May 15, 2006, at the 

Veol ia facility, comparati ve Leak Detection and Repair 

(LDAR) monitoring was conducted by u .s. EPA. As a result 

of the comparative monitoring, U. S. EPA found 11 openedended valves. Veolia also kept an incomplete list of 

components to be monitored. The connectors were not 

included on the list. 

3 . 40 C.F.R Part 61 Subpart FF provides emission standards f or 

benzene waste operations . a. 40 C.F .R. § 61.354 {h), requires that an owner or 

operator must test equipment for compliance with no 

detectable emissions fol lowing Method 21 . 40 C.P.R. 

§ 61.12{c) requires that an owner or operator of each 

stationary source must maintain and operate the source, 

i ncluding associated equipment for air pollution control, 

in a manner consistent wi th good air pollution control 

practice for minimizing emissions. 

b. During the May inspection at the Veolia facility, U.S. 

EPA conducted comparative LDAR monitoring . As a result of 

the comparative monitoring, U.S . EPA foUnd that 2 of the 18 

carbon caniste rs (11.1%) that were moni tored exceeded the 

breakthrough limit of 1275 ppm VOM. veolia monitors its 19 

carbon canisters biweekly. Upon review of Veolia's 

VES016082 
4 

monitoring records, from January 2001 until the time of 

U.S . EPA's i nspection, 20 carbon canisters have exceeded 

the a f orementioned br eakthrough limit . Thus, Veol ia's 

historical breakthrough rate is 0 . 19% , which is 

significantly lower than the 11.1% of breakthr oughs that 

U.S . EPA found during the inspection. This leads U.S . EPA 

to find that Veolia is not conducting the LDAR monitoring 

in accordance with the appropriate methodology. 

4. 40 C.F.R. Part 63, Subpart EEE provides the emission 

standards for HAPs from hazardous wast e combustors. 

a. 40 C.F.R. § 63.1207(c), requires that a source must 

commence the initial comprehensive performance testing on 

an incinerator to determine if its operations are in 

compliance with the applicable HAPS standard not later than 

six months after the compli ance date. 

b. Veol ia tested Incinerator 3 on May 10 and 11 , 2006, 

which i s later than six months after Veolia's compliance 

date of December 30, 2004. 

c . 40 C.F .R. § 63.1203(a) (4) prohibits the emission of 

arsenic, berylli um, and chromium, combined, over 97 

micrograms per dry standard cubic meter (ug/dscm) . 

d. Veolia tested Incinerator 3 emissions on May 10 .and 1, 

2006 . The test resul ts showed total low volatile 

emissions including arsenic , beryllium and chromium at 

249 ug/dscm in excess of the regulatory standard of 

97 ug/dscm. 

Env ironmen t a l Xmpact of Violationa 

5. Vi olation of VO~I standards increases the amount of ground 

level ozone. Ozone may cause shortness of breath, coughing, 

wheezing, and eye and nose irritation. Ozone is especially 

dangerous to older adults, children, asthmatics and persons 

with other chronic respiratory ailments. 

6. Violation of HAP standards may cause serious heal th effects 

incl uding birth def ects and cancer. HAPs may also cause 

harmful envir onment al and ecological e f f ects. 

VES016083 
5 

7 . Vi olation of Benzene st andards may cause serious health 

effects including cancer of the lymph system, lung cancer 

and bladder cancer. 

Date I I 

Date . 

t on, Acting Di rector 

~~d Radiation Division 

~~,~~ Enforcement and Coropliance 

Assu.rance Branch 

Wa ste, Pesticides. and Toxics 

Division 

VES016084 
6 

CERTIFICATE OF MAILDfG 

I, Betty Williams, certify that I sent a Notice and Finding 

of Violation, No. EPA-5-06- 28-IL, by Certified Mail, Retu.rn 

Receipt Requested, t o: 

Doug Harris 

General Manager 

veolia Environmental Services 

#7 Mobi l e Avenue 

Sauget, Illinois 62201 

I also certify that I sent copies of the Finding of 

Violation and Notice of Violation by first class mail to: 

J ul ie Armitage, Acting Chief 

Compliance and Systems Management Section 

Illinoi s Environmental Protection Agency 

1021 North Grand Avenue 

Spri ngf ield, I llinois 62702 

on the J.Jr£day of ~ ' 2006 . 

~;,___ ~liams, Secretary 

AECAS(IL/INJ 

VES016085 
VES016086.pdf 
Ogulei, David 

From: 

Sent: 

To: 

Cc: 

Subject: 

Hello David, 

Nancy L Paddock <nancy.paddock@veoliaes.com> 

Thursday, August 15, 201312:45 PM 

Ogulel, David 

Dennis J Warchol 

Veolia Submittal 

Two copies of Veolla's Addendum to Application for Renewal of a Major Source Operating Permit have been Fed-Ex'd to 

you. I requested overnight delivery so you should receive them tomorrow. 

Have a nice day. 

Nancy Paddock 

Environmental Engineering Spedallst 

Veolla ES Technical Solutions, L.L.C. 

7 Mobile Avenue 

Sauget, IL 62201 

618.271.2804 (X-115} 

618.271.2128 (fax} 

Nancy,Paddod<@YeoliaES.com 

www.~eol aES.com 

This e-mail message from Veolia ES Technical Solutions, L.L.C. is for the sole use of the intended recipient(s) and may 

contain confidential and privileged information. Any unauthorized review, use, disclosure or distribution is prohibited. If 

you are not the intended recipient, please communicate with the sender by reply e-mail and destroy all capies of the 

original message and delete it from all computers. 

1 

VES016086 
VES016087.pdf 
Ogulei, David 

From: 

Sent: 

To: 

Subject: 

From: Bivins, Dan 

Gamel!. Kim 

Wednesday, October 08, 2014 1:32PM 

Ogulei, David 

FW: Xact questions 

Sent: Tuesday, May 21, 2013 2:15 PM 

To: John Cooper 

Cc: Ga mett, Kim 

Subject: Xact questions 

John, 

We are answering some comments from a facility on a permit submittal. Could you comment on the following? 

Thanks ! 

Dan 

p.s. - there may be more questions If that's ok? 

Comment EPA's statement that "Multi-metals CEMS are commercially available and have been-demonstrated 

to be reliable for measuring mercury and other metal emissions from hazardous waste combustors" (Statement 

of Basis at22) is incorrect or misleading. When the Statement of Basis was wrinen, the Xact was offered by 

Pall Col]loration. This is no longer correct Pall no longer manufactures and sells the Xact unit. The marketing 

rights to the Xact have reverted to Cooper Eoviroruneutal Services. It should also be noted tbat this instrument 

is not au instrument that is carried in inventory. If a facility wanted to purchase an Xact u.nit, Cooper 

Eovirorunental Services has indicated that it would take them at least six months to build it. This is the time to 

build the instrument itself and does not include time to develop the site-specific sampling train or the time to 

develop the software interface between the instrument and the facility's control systems. The software 

development process (custom software for that site) would take several months after the instrument was 

installed. Only one Xact unit has been installed and operated for an extended period of time at only one 

hazardous waste combustor, the combustor at Evoniks Tippecanoe Laboratories. Due to frequent maintenance 

issues and equipment failure, that Xact unit is no longer operating. (CR WI 6-7) 

Thm Bivins 

U.S. Enviromucnt'al Pro l~l' n Agt'n<·y 

Oflice or Ait· Quatity Plannin~ and Standards 

A·feastJremenl Tedmology Croup 

!H9-54-l-5244 

VE$016087 
VES016088.pdf 
Ogulei, David 

From: 

Sent: 

To: 

Cc: 

Subject: 

Your welcome! 

Kathy Strubberg 

Principal Engineer 

Kathy Strubberg <kathys@syaeng.com> 

Thursday, April 03, 2014 9:42AM 

Ogulei, David 

'Padclod<, Nency'; 'Dennis W archer 

RE: Veolia Response 

Schreiber, Yonley & Associates 

16252 Westwoods Business Park Drive 

Ellisville, MO 63021 

Cell: (314) 607-9753 

Work: (636) 256-5641 

kathys@syaeng.com 

From: Ogulei, David [mallto:Ogulei.David@epa.gov] 

Sent: Thursday, April 03, 2014 9:40 AM 

To: Kathy Sb'ubberg 

Cc: 'Paddock, Nancy'; 'Dennis Wardlol' 

Subject: RE: Veolfa Response 

No problem. This explanation should do iL Thank you. 

From: Kathy Sb'ubberg [mailto;kathys@syaeog.com] 

Sent: Thursday, April 03, 2014 9:28AM 

To: Ogulei, David 

Cc: 'Paddock, Nancy'; 'Dennis Warchol' 

Subject Veolia Response 

Importance: High 

David, 

I apologize for not getting this to you sooner. There was a mixup as I thought Veolia was sending this 

response directly to you and they thought I was sending it. Anyway, here is Veolia's response to your 

question. 

As we discussed in our phone conversation, Veolia requests the ability to change the methodology 

used to calculate volatile emissions from the following emission units: 

Emission Unit Description 

MP-1 Material Processing Area 

MP-2 Material Processing Area 

Lab Pack Repack Batch Material Processing Area 

Bulk Feed Building Bulk Solid Waste Storage 

VESOI6088 
The current Part 71 permit requires the use of the most recent version of the TANKS program to 

calculate VOM/HAP emissions from the MP-1, MP-2 and Lab Pack Repack emission units [Permit 

Condition 2.2(E)(3). Although the permit doesn't contain a similar condition for the Bulk Feed 

Building, the proposed new methodology differs from that used in the permit application. 

Veolia believes that a more appropriate calculation methodology is the Surface Evaporation Model as 

found In the EPA's EIIP Volume II: Chapter 8 Section 4.1.4, "Preferred and Alternative Methods of 

Estimating Air Emissions from Paint and Ink Manufacturing Facilities·. February 2005. This model 

calculation is more appropriate than the TANKS model for the following reasons. 

1. MP-1, MP-2 and the Lab Pack Repack units are waste storage and processing buildings utilized 

for containers. Containers are received into the buildings and held there prior to processing either 

within the building or directly to the incinerator feeds. The stored containers are closed with a lid or 

cover which allows no volatiles to escape the container during storage. Containers are only opened 

to sample and process the contents. The processing consists of placing the waste from a container 

either into open troughs through which the waste moves through sizing activities and is repacked into 

feed containers; or directly into feed containers. The waste in the trough is open to the atmosphere of 

the building. As such constituents in the waste volatilize Into the building atmosphere and are emitted 

through the building exhaust. 

2. The surface evaporation model estimates the amount of constituents volatized based on the 

volatility of the different waste constituents and the air flow across the exposed surface of the 

waste. It is a conservative estimate as the calculations assumes that the air flow will be saturated 

with organic compounds where in reality, this is not the case. 

This summarizes the reasons why the Surface Evaporation Model produces more representative 

emission estimations than the TANKS program for the MP-1, MP-2, Lab Pack Repack and Bulk Feed 

Building emission units at the plant. 

Please call me if you need anything further regarding this matter. 

Regards. 

Kathy 

Kathy Strubberg 

Principal Engineer 

Schreiber, Yonley & Associates 

16252 Westwoods Business Park Drive 

Ellisville, MO 63021 

Cell: (314) 607-9753 

Work: (636) 256-5641 

kathys@syaeng.com 

2 

VES016089 
VES016090.pdf 
Ogulei, David 

From: 

Sent 

To: 

Cc: 

Subject: 

Paddock, Nancy <nancy.paddock@veolia.com> 

Thursday, April 03, 2014 9:24AM 

Ogulei, David 

Dennis Warchol 

Re: Title V Request regarding material processing areas and emissions calculalions 

You should be bearing from Kathy shortly. Sorry for the delay. 

Nancy 

Nancy Paddock 

Environmental Engineering Specialist 

Veolla ES Technical Solutions, L.L.C. 

7 Mobile Avenue 

Sauget, IL 62201 

618.271.2804 (x-115) 

618.271.2128 (fax) 

Please note that my e-mail address has changed: 

Nancy.Paddock@Veolia.com 

This e-mail message from Veolia ES Technical Solutions, L.L.C. is for the sole use of the intended 

recipient(s) and may contain confidential and privileged information. As1y unauthorized review, use, 

disclosure or distribution is prohibited. If you are not ltle intended recipient, please communicate 

wiltl the sender by reply e-mail and destroy all copies of the original message and delete it from all 

computers. 

On Thu, Apr 3, 2014 at 8:59AM, Ogulei, David <Ogulei.David(il)epa.gov> wrote: 

N 9.11C)', 

Yes, 1 received the CT J\C package. 111anks! 

Kathy Stn1bberg called me on Tuesday to discuss rhe re:osons wby the surface model might be n better model than 

TANKS for estimating emissions from the bulk feed building. 1 asked Kathy ro send me ru1 email on Tuesday 

documenting some of the things she mentioned regarding the unique characteristics of the BF J3ldg's 

operations. She said she would send me an email Iacer that aftcmoon after running it by Vcolia bur 1 haven't seen 

the email. 

VES016090 
As I explained to Kathy on Tuesday, although the estimated VOM/HAP emissions from the BF Bldg ate very low, 

we still need a clear and complete explanation of why we axe deviating from an established periodic monitoring 

methodology so as to avoid establishing impr<.,per precedence. T he key here is to expand o n )'OUr explanation 

below. 

David 

From: Paddock, Nancy [mailto:nancy.oaddock@yeolia.coml 

Sent: Thursday, April 03, 2014 8:43AM 

To: Ogulel, David 

Cc: Dennis Wardlol 

Subject: Fwd: Title v Request regarding material processing areas and emissions calculations 

Good morning David, 

Just checking in to see if Kathy Strubberg was able to fully resolve this issue for you. Let me know if there are 

any loose ends to be tied up here. Hopefully you've also received the CTAC package and we can cross that off 

the list 

Thanks and have a good day! 

Nancy 

Nancy Paddock 

Environmental Engineering Specialist 

Veolia ES Technical Solutions, L.L.C. 

7 Mobile Avenue 

Sauget, IL 62201 

618.271.2804 (x-115) 

618.271.2128 (fax) 

2 

VESOI6091 
Please note that my e-mail address has changed: 

Nancy.Paddock@Veolia.com 

This e-mail message from Veolia ES Technical Solutions, L.L.C. is for the sole use of the intended 

redplent(s) and may contain confidential and privileged information. Any unauthorized review, use, 

disclosure or distribution is prohibited. If you are not the intended redpient, please communicate 

with the sender by reply e-mail and destroy all copies of the original message and delete it from all 

computers. 

---Forwarded message -------

From: Paddock, Nancy <nancy.paddocklcvveolia.com> 

Date: Mon, Mar 31 , 2014 at 3:12PM 

Subject: Re: Title V Request regarding material processing areas and emissions calculations 

To: "Ogulei, David" <Ogulei.David@ena.go>> 

Cc: Dennis Warchol <dennis.warchol(tl.veolia.com>, Kathy Strubberg <kmhvsrwsvaenQ.com> 

Hi David, 

Kathy Strubberg will be contacting you tomorrow morning to discuss the differences in detail. lo the 

meantime, fll give you my very simplistic understanding of the matter. TANKS is, of course, a model for 

emissions from tanks, whereas.the evaporative method is a model for spills. Tanks are closed systems which 

produce emissions from vapors displaced during loading operations and temperature changes. Spills have 

surface area directly exposed to the environment Our processing areas are not closed systems, they have 

surface area directly exposed to the environment. We believe our processing areas are more analogous to spills 

than tanks. Does this help? 

Also, Dennis told me you were looking for the CTAC for revisions. 1 copied aU the revisions and Doug signed 

the CTAC once for aU of them. They went out Fed Ex today. 

Thank you for your patience, David. Have a great day! 

Nancy 

3 

VES016092 
Nancy Paddock 

Environmental Engineering Specialist 

Veolia ES Technical Solutions, l.l.C. 

7 Mobile Avenue 

Sauget, IL 62201 

618.271.2804 (x-115) 

618.271.2128 (fax) 

Please note that my e-mail address has changed: 

Nancy.Paddock@Veolia.com 

This e-mail message from Veolia ES Technical Solutions, l.l.C. is for the sole use of the intended 

redpient(s) and may contain confidential and privileged information. Any unauthorized review, use, 

disclosure or distribution is prohibited. If you are not the intended recipient, please communicate 

with the sender by reply e-mail and destroy all copies of the original message and delete it from all 

computers. 

On Moo, Mar 31, 2014 at 8:14AM, Ogulei, David <O!wlei.David<a:·epa.gov> wrote: 

Hi Nancy, 

Good morning! I'm just trying to Ltndersi1Uld why exactly the surrnce model is superior to TANKS. T:\NK.S also 

relies on the compound's vapor prcssw:c to estimate the bead space conccnrrarion . .Is it possible cl1at TANKS 

could estimate higher emissions than the surface. modeJ in some years? What is the fundamental difference 

betl<•een the two methods that guarantees that the surface model will always yield higher emissions? 

From: Paddock, Nancy [mailto:nancy.paddock@yeolia,coml 

Sent: Monday, March 31, 2014 7:33AM 

To: Ogulei, David 

Cc: Dennis Warchol 

Subject: Re: Title V Request regarding material processing areas and emissions calculations 

Good morning, David I 

4 

VES016093 
We used five years worth ofTRl data to determine composite YOM and HAP concentration values for use in 

the evaporative equation.. I did not compare five years worth of data. I am working on the 20 I 3 annual 

emissions inventory. Since thruput data for 2013 was handy, I used it to compare TANKS and evaporative 

methods in the small table I sent on March 3, 2014. 

I hope this clears things up! 

Have a great day! 

Nancy Paddock 

Environmental Engineering Specialist 

Veolia ES Technical SOlutions, L.L.C. 

7 Mobile Avenue 

Sauget, IL 62201 

618.271.2804 (x-115) 

618.271.2128 (fax) 

Please note that my e-mail address has changed : 

Nancy.Paddock@Veolia.com 

This e-mail message from Veolia ES Technical Solutions, L.L.C. is for tfle sole use of the intended 

recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, 

disclosure or distribution is prohibited. If you are not the intended recipient, please communicate 

witfl the sender by reply e-mail and destroy all copies of the original message and delete It from all 

computers. 

-------- Forwarded message -·--·· 

From: Ogulei, David <OuuleJ.Dav•dlli coa.uov> 

Date: Fri, Mar 28, 2014 at 4:43PM 

Subject: RE: Title V Request regarding material processing areas and emissions calculations 

To: "Paddock, Nancy" <nancv.paddock:((• veolia.com> 

Cc: Dennis Warchol <dcnnis.warcholra vcolia.com> 

5 

VES016094 
Hi Nancy, 

As srated in your email below, rhe emissions comparison shown in d1e cable below is for one calendar year. Whkh 

year is this? Do you have etnissions dam for more than one calendar year that show what the. difference in 

ernissions b<:twe<:n the two methods is? The email says you looked at 5 years of TRI darn. 

Thanks, 

David 

From: Paddock, Nancy [mailto:oaocy.padd«k(o)veolia.coml 

Sent: Monday, March 03, 2014 1:43 PM 

To: Ogulel, Davfd 

Cc: Dennis Warchol 

Subject: ntte V Request regarding material processing areas and emissions calculations 

Hello David, 

Section 2.2(EX3) ofTWI's 2008 Title V permit states that the TANKS program must be used to calculate 

emissions from MPI, MP2 and LPR. 

Last year, a consultant reviewed our emissions inventory process. The Surface Evaporation Model from EPA 

Guidance EIIP Volume II :Chapter 8 Section 4.1.4. Preferred and Altemative Melhods for Estimating Air Emissions from Paint 

and Ink Manufacturing Facilities, MSJCh 1998. Equation 8.4·18 was used to calculate emissions from MP I, MP2 and 

LPR. The consultant compiled an a''erage of 5 years of the roost recent TRI concentration data to determine 

the concentration ofVOC and HAP in the waste, which was then used in the EPA Surface Evaporatioo Model 

referenced above. 

TANKS is based on routine displacement of liquids. The surface evaporation model is based on the volatility 

and ability of a compound to evaporate from the surface of solids and then be picked up by the air in the 

building and carried to the atmosphere. The evaporation method seems to be more appropriate for MP I, MP2 

and LPR; TWI would like to change section 2.2(E)(3) of the upcoming permit (or the equivalent section 

thereof) to indicate the Surface Evaporation Model will be used to calculate emissions 11-om these sources. 

VES01609S 
This table compares emissions calculated by both methods for the same calendar year: 

TANKS Model 

area TPY lb 

MP-1 0.06 117 

MP-2 0.02 44 

LABPACKIREPACK 0.03 68 

Evaporative 

model 

TPY lb 

0.21 424 

0.11 212 

0.04 85 

I hope this makes sense. Please let me know if you have questions. 

Thank you, 

Nancy 

Nancy Paddock 

Environmental Engineering Specialist 

Veolia ES Technical Solutions, LL.C. 

7 Mobile Avenue 

Sauget, IL 62201 

618.271.2804 (x- 115) 

618.271.2128 (fax) 

Please note that my e-mail address has changed: 

Nancy.Paddock@Veolia.com 

This e-mail message from Veolia ES Technical Solutions, L.L.C. is for the sole use of the intended 

redpient(s) and may contain confidential and privileged information. Any unauthorized review, use, 

disclosure or distribution is prohibited. If you are not the Intended recipient, please communicate 

7 

VES016096 
with the sender by reply e-mail and destroy all copies of the original message and delete it from all 

computers. 

8 

VES016097 
VES016098.pdf 
Ogulei, David 

From: 

Sent: 

To: 

Cc: 

Subject: 

Hello David, 

Paddock, Nancy <nancy.paddock@veolia.com> 

Monday, March 03, 2014 1:43PM 

Ogulei, David 

Dennis Warchol 

Tide V Request regarding material processing areas and emiSsions calculations 

Section 2.2(E)(3) ofTWI's 2008 Title V permit states that the TANKS program must be used to calculate 

emissions from MPI , MP2 and LPR. 

Last year, a consultant reviewed our emissions inventory process. The Surface Evaporation Model from EPA 

Guidance EIIP Volume II:Chapter 8 Section 4.1.4. Preferred and Alternative Methods lor Estimating Air Emissions from Paint 

and Ink Manufacturing Facilities, March 1998. Equation 8.4-t 8 was used to calculate emissions I rom MP 1, MP2 and 

LPR. The consultant compiled an average of 5 years of the most recent TR1 concentration data to determine the 

concentration ofVOC and HAP in the waste, which was then used in the EPA Surface Evaporation Model 

referenced above. 

TANKS is based on routine displacement of liquids. The surface evaporation model is based on the volatility 

and ability of a compound to evaporate from the surface of solids and then be picked up by the air in the 

building and carried to the atmosphere. The evaporation method seems to be more appropriate for MPI, MP2 

and LPR; TWI would like to change section 2.2(E)(3) of tbe upcoming permit (or the equivalent section 

thereof) to indicate the Surface Evaporation Model will be used to calculate emissions from these sources. 

This table compares emissions calculated by both methods for the same calendar year: 

TANKS Model 

area TPY lb 

MP-1 0.06 

MP-2 0.02 

LABPACKIREPACK O.QJ 

117 

44 

68 

Evaporative 

model 

TPY lb 

0.21 

0.11 

0.04 

424 

212 

85 

I hope this makes sense. Please let me know if you have questions. 

Titank you, 

Nancy 

Nancy Paddock 

Environmental Engineering Spedalist 

Veolla ES Technical Solutions, LL.C. 

7 Mobile Avenue 

Sauget, IL 62201 

618.271.2804 (x-115) 

618.271.2128 (fax) 

VE$016098 
Please note that my e-mail address has changed: 

Nancy.Paddock@Veolia.com 

This e-mail message from Veolia ES Technical Solutions, L.L.C. is for the sole use of the intended 

redpient(s) and may contain confidential and privileged information. Any unauthorized review, use, 

disclosure or distribution is prohibited. If you are not the intended redpient, please communicate 

with the sender by reply e-mail and destroy all copies of the original message and delete it from all 

computers. 

2 

VES016099