### August 9, 2010

MEMORANDUM

TO: Docket No.: EPA-HQ-OAR-2010-0786

FROM: Kaye Whitfield, Project Lead Risk and Technology Review - National Emission Standards for Hazardous Air Pollutants (NESHAP) for Shipbuilding and Ship Repair (Surface Coating) Operations

SUBJECT: Developments in Practices, Processes, and Control Technologies

The purpose of this memorandum is to present the results of an investigation to identify any developments in practices, processes, and control technologies fo r hazardous air pollutants (HAP) emission sources for the Shipbuilding and Sh ip Repair (Surface Coating) source category. This analysis is part of EPA’s review efforts in accordance with secti on 112(d)(6) of the Clean Air Act (CAA).

Section 1 provides background information on section 112(d)(6), the Shipbuilding and Ship Repair (Surface Coating) source category, and the part 63, subpart DDD requirements of the NESHAP that address emissions from this ca tegory. Section 2 discusses the exploration of developments in practices, processes, and cont rol technologies that have occurred since the original development of this NESHAP, and section 3 provides the conclusions of this investigation.

1.0 BACKGROUND

1.1 Section 112(d)(6)

Section 112 of the CAA required EPA to establish technology-based standards for listed source categories. These technology-based st andards are often referred to as maximum achievable control technology, or MACT, standa rds. Section 112 also contains provisions requiring EPA to revisit these standards. Sp ecifically, paragraph 112( d)(6) section states:

(6) REVIEW AND REVISION. – The Administra tor shall review, and revise as necessary (taking into account developments in practices, processes, and control technologies), emission standards promulgated under this sec tion no less often than every 8 years.

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### 1.2 Description of Shipbuilding and Ship Repair (Surface Coating) Source Category and MACT Standard

The Shipbuilding and Ship Repair (Surface Coating) NESHAP, 40 CFR 63 Subpart II, was promulgated on December 15, 1995 (60 FR 60436) . The rule requires new and existing major sources to control emissions of HAP fr om surface coating operations to the extent achievable by the use of MACT, which is base d on maximum HAP emission limits for various categories of marine coatings. Ma jor source facilities that are subj ect to the rule must not apply any marine coatings with volatile organic HAP (VOHAP) content in excess of the applicable emission limit and must implement the work practices required in the rule.

The primary HAP emitted from surface coating operations at shipbuilding and ship repair facilities include xylenes, ethyl benzene, and toluene. The standards impose emission limits on the VOHAP content of 23 types of marine coatings used at shipyards. Emissions of HAP may also occur from related operations such as paint thinning, handling/tran sfer, and storage. Compliance with the VOHAP limits must be demons trated on a monthly basis. The promulgated standards include three complian ce options to allow flexibility in demonstrating compliance, including compliant coatings with limits on VOHAP content, spill minimization through handling and transfer requirements, and alternat ive means (e.g., add-on controls), if approved by the Administrator.

1.3 Description of Shipbuilding and Ship Repair Coating Operations

The shipbuilding and ship repair source categor y includes facilities (s hipyards) that vary greatly in size and operations. Most of the VOC/VOHAP contained in marine coatings is emitted to the atmosphere as the paint is applie d, dries and cures (e.g., solvent evaporates). The location of surface coating operations in a shipyard depends on many factors, including the size of the shipyard and whether a ship is being bui lt or repaired. In ne w construction operations, assembly is usually modular, and coating is done in several stages at various locations, including outdoors on assembled ships (hereafter referred to as shipside coating operations). During ship repair and maintenance operations, most of the co atings are applied shipsi de. A wide variety of coatings are applied at a typica l facility and the location and du ration of the coating operations vary depending on the facility and the type/size of ship being built or repaired. There are five general areas of ship struct ures that have special coa ting requirements: antennas and superstructures, exterior deck areas, interior habitability ar eas, tanks, and underwater hulls.

Coatings in the shipbuilding industry are generally spray a pplied. The basic components in marine coatings are vehicles (resin binder), solvents (excep t in 100 percent solids coatings), pigment (except for clear coatings ), and additives. Marine coa tings are vital for protecting the ship from corrosive and biotic attacks from the sh ip’s environment. Specific paint selections are based on the intended use of the ship, ac tivity, aesthetics, and fuel costs.

As previously mentioned, many shipyards pe rform both indoor and shipside coating. The massive scale of many ships makes it difficult to capture emissions from shipside coating using any type of enclosure; therefor e, shipside coating normally occu rs outdoors. Some shipyards that paint indoors use spray booths or may use an entire building as a spray area. Buildings and

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### spray booths used in major source shipyards va ry significantly in size, number, and exhaust rates. Some spray booths are partially enclosed ; so, emissions may not be fully captured by the enclosure. In general, faciliti es that use compliant coatings do not have add-on controls on spray booths or building exhausts.

2.0 PRACTICES, PROCESSES, AND CONTROL TECHNOLOGIES

For the purpose of this exercise, EPA considered a “development” to be any:

• Add-on control technology or other equipment that was not identified and considered during MACT development;

• Improvements in add-on control technology or other equipment (that was identified and considered during MACT development) that could result in significant additional emission reduction;

• Work practice or operational procedure that was not identified a nd considered during MACT development;

• Process change or pollution prevention altern ative that could be broadly applied that was not identified and consider ed during MACT development.

Table 1 summarizes the practices, processes, and control technologies considered during the development of the 1995 MACT standards for Sh ipbuilding and Ship Repair (Surface Coating) Operations. This is followed by descriptions of the searches for developments since that time. Section 2.1 provides information collected fr om EPA’s RACT/BACT/ LAER clearinghouse and California’s BACT clearinghouse on sh ipbuilding and ship repair co ntrols (and associated follow up discussions). Section 2.2 provides informa tion obtained from searching the web for technological development information, and S ection 2.3 summarizes correspondence with the shipbuilding and ship repair industr y and air pollution control vendors.

Table 1. Summary of Practices, Processes, and Control Technologies Identified and Considered During 1995 Shipbuilding and Ship Repair (Surface Coating) Operations MACT Development

Source Category/ Emission Source Practices, Processes, and Control Technologies

Coating Application Lower- and No-HAP coating formulati ons, alternative application methods and equipment, capture and control systems Cleaning Operations, including hand wipe, gun cleaning, flush cleaning Work practices (covering containers, etc.) to minimize emissions, capture and control systems

Waste Storage and Handling Leak detection and repair programs, leakless pumps, special solvent dispensers, self-closing funnels



### 2.1 Subsequent Regulatory Development Efforts

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### As noted above, the Shipbuilding and Ship Repair (Surface Coa ting) MACT standards were promulgated on December 15, 1995. Since that time, state regulatory agencies, notably those in California, have develope d stricter and more specific st andards for marine coatings and spray booths. The EPA has developed Control T echniques Guidelines (CTG) for HAP emissions from Automobile and Light-Duty Truck Assemb ly Coatings (2008), and Miscellaneous Metal and Plastic Parts Coatings ( 2008). EPA has also promulgate d NESHAP for Automobile and Light-Duty Truck Assembly Coatings (subpart I III), Miscellaneous Metal and Plastic Parts Coatings (subpart MMMM), and Wood Building Products (subpart QQQQ). The results of the CTG for these coating related NESHAP include more stringent work standards and/or recommendations for add on control equipment (sim ilar to those analyzed in this document) and have been included for analysis.

2.1.1 California Marine Coating Regulations

Four air districts in California: Ventura County Air Pollution Cont rol District (APCD), Bay Area Air Quality Management District (BAAQMD), South Co ast Air Quality Management District (SCAQMD), and the San Diego Count y APCD have developed and adopted more stringent regulations for marine coati ngs than the 1995 NESHAP for Shipbuilding. Attachment 4 contains a summary table with limits and requir ements of marine vesse l coatings for each of these districts. All districts have imposed VOC limits equal to or less than those established in the 1995 Shipbuilding NESHAP for a ll coating categories, and have made distinctions between baked and air dried coatings, where appli cable. The 1995 Shipbuilding NESHAP does not differentiate between air dried and baked coatings. For certain coating cate gories, some districts have lowered VOC limits by more than 50 percen t. The four Californi a districts also added additional coating categories beyond the 23 li sted marine coating categories in the 1995 Shipbuilding NESHAP and set VOC limits for each.

As shown in Attachment 4, all four distri cts have also added an 85 percent capture efficiency for add-on controls (if a facility c hooses not to comply with coating limits), VOC limits for cleaning solvents, and additional clean ing, monitoring and reco rdkeeping requirements than those listed in th e 1995 Shipbuilding NESHAP.

2.1.2 EPA CTGs for Subsequent Surface Coating Regulations

Flat wood paneling (wood building products) (2 006) controls include low VOC coatings, ultraviolet cure and electron beam cure coa tings, add-on controls, and work practices. Recommended add-on controls incl ude oxidizers and solvent rec overy systems that achieve 90 percent control efficiency. Work practices in clude: (1) frequent visual inspections for all equipment used to transfer or apply coatings, adhesives, or organic so lvents; (2) cleaning and wash off solvent accounting system; (3) coll ecting and containing all VOCs when cleaning coating lines and spray guns; and (4) using low-VOC or low-vapor pressure cleaning materials. Cost effectiveness, in 2005 dollars, is esti mated to be $1,900/ton VOC reduction for interior paneling/tileboard and $2,600/ton VOC reduction for exterior siding.

4

### Auto and light-duty truck assembly coating ( 2008) controls are similar to miscellaneous plastic and metal parts, and in clude electrodeposition co atings, use of reci procators or robot application devices, hybrid control systems usi ng a concentrator followed by an oxidizer, spray booth water wash (overspray partic les), dry filters or dry electros tatic precipitator. Alternate control technologies include condensation, biofiltrati on, and UV oxidation, but these technologies are not currently being used by the industry. Th e September, 2008 CTG for this source category recommends no new control measures for auto and light-duty truck manufacturing facilities, and t hus no additional costs. The wo rk practices recommended are believed to result in net cost savings by reduci ng the amount of coatings and cleaning materials that are used.

Surface coating of miscellaneous metal and plastic parts (2008) recommends product substitution/reformulation, work practice procedures, and equipment substitution. Product substitution includes: powder coatings, waterborne coatings , higher solids coatings, and ultraviolet coatings. Work practice changes include waste reduction, storage of coatings, thinners, and wastes in closed containers, covers on mixing containers, minimizing spills, conveying materials in closed cont ainers or pipes. Equipment s ubstitution include s electrostatic and HVLP spray equipment. Controls include oxidation, adsorption, and absorption. The cost effectiveness of these cont rols is estimated to be $1,758/ton of VOC reduction.

2.1.3 EPA NESHAP for Similar Sources

During the ten years after pr omulgation of the Shipbuilding and Ship Repair (Surface Coating) MACT standards, EPA promulgated NESHAP for other surf ace coating processes under the automobile and light-dut y truck assembly coatings, mi scellaneous metal and plastic parts coatings, and wood building products coatings source categories.

All of these standards identify VOC or volatile HAP limits for surface coating materials and allow for compliance through either: a compli ant material option, an emission rate without add-on controls option, or an emission rate wi th add-on controls options. All of the source categories’ standards require work pract ice activities that reduce emissions.

Differences in work practice requirements be tween the ship building/repair rules and these other surface coating rules are additiona l requirements to convey organic HAP-containing coating materials in closed containers or through pipes and mixi ng organic HAP-containing coating materials only in closed containers. Th e auto and light truck surface coating standards include specific emission-reduc tion activities for coating line purging and flushing, for limiting emissions from spray booth operations, spray bo oth equipment, and areas around spray booths (e.g., use of masking materials in spray-booths to facilitate cleani ng, using parts cleaners to clean spry-booth equipment).

2.1 RACT/BACT/LAER Clearinghouse a nd California’s BACT Clearinghouse

Under EPA's New Source Review (NSR) progr am, if a company is planning to build a new plant or modify an existing plant such that air pollution emissions will increase by a large amount, then the company must obtain an NSR pe rmit. The NSR permit is a construction permit

5

### which requires the company to minimize air pol lution emissions by changing the process to prevent air pollution and/or installing air pollution cont rol equipment.

The terms "RACT," "BACT," and "LAER" are acronyms for different program requirements under the NSR program. RACT, or Reasonably Available Control Technology, is required on sources in areas that are not meeti ng national ambient air quality standards (i.e., nonattainment areas). BACT, or Best Available Control Technology, is required on major new or modified sources in clean areas (i.e., attainment areas). LAER , or Lowest Achievable Emission Rate, is required on major new or modifi ed sources in non-attainment areas.

BACT and LAER (and sometimes RACT) ar e determined on a case-by-case basis, usually by State or local permitting agencies . EPA established the RACT/BACT/LAER Clearinghouse, or RBLC, to provide a central data base of ai r pollution technology information (including past BACT and LAER decisions contained in NSR permits) to promote the sharing of information among permitting agencies and to ai d in future case-by-case determinations. However, data in the RBLC are not limited to sources subject to RACT, BACT, and LAER requirements. Noteworthy prevention and cont rol technology decisions and information are included even if they are not related to past RACT, BACT, or LAER decisions. 1 

### A similar database has been developed for BACT decisions ma de in the state of California. The Statewide Best Available Control Technol ogy (BACT) Clearinghouse is a data base developed by the Air Resources Board staff and staffs from various air pollution control and air quality management districts in California.

The RBLC contains over 5,000 air pollution cont rol permit determinations that can help identify appropriate technologies to mitigate mo st air pollutant emission streams. It was designed to help permit applicants and revi ewers make pollution prevention and control technology decisions for stationary air pollution sources, and includes data submitted by several U.S. territories and all 50 States on over 200 different air pollutan ts and 1,000 industrial
processes.

The RBLC provides several options for search ing the permit database on-line to locate applicable control technologies. We searched RBLC’s determination database for shipbuilding facilities using the RBLC process code for sh ipbuilding and repair surface coating, and shipbuilding and repair SIC and NAICS codes. We identified one shipbu ilding and ship repair facility, NASSCO, in San Diego, CA that listed a surface coating process in the RBLC database. The search results included the following data fiel ds for the five processes (spray booths) listed in this determination:

• Facility Name, County, and State

• Pollutant Name

• Process Description

• Control Technology and Emission Limit

1 Technology Transfer Network: Clean Air Technology Center. RACT/BACT/LAER Clearinghouse Basic Information. Available: http://www.epa.gov/ttn/catc/rblc/htm/welcome_eg.html . Accessed 5/10/10.



### 6

### The information in the RBLC was suppl emented by information obtained from the California BACT database, the San Diego Air Pollution Control Distri ct contact, and the NASSCO contact. The NASSCO San Diego facility contains four large custom built enclosed spray booths, (approximately 100’x 80’x 65’), and one smaller booth (exact dimensions not available). Each spray booth is vented to its own rotary concen trator, which is then followed by a regenerative thermal oxidizer (RTO). Rotary concentrators take in low concentration VOC laden air and through adsorbtion and desorbti on of VOC from a smaller and more VOCconcentrated air stream. The exhaust airflow from each of the five booths is approximately 51,200 cfm, and the VOC concentration is on the orde r of 100 ppmv. This exhaust is routed to the rotary concentrator, wher e it is decreased to approxima tely 5,000 cfm and a higher VOC concentration, and then routed to the RTO. A Method 25A emissions test performed in May, 2009 measured an average spray booth outlet (rotar y concentrator inlet) VOC concentration of approximately 108 ppm, and an average RTO ou tlet VOC concentration of 1.88 ppm. The emission limit from the five RTOs combined is 2 tons per year of VOC. The RBLC report for the NASSCO determination, and the report from th e California BACT database are provided in Attachment 1.

The use of add-on controls on spray booths at shipbuilding and ship repair facilities was considered in the development of the Shipbuild ing and Ship Repair (Surface Coating) MACT standard. At the time the standard was under de velopment, no add-on controls were being used on spray booths at shipbuilding and ship repair facilities to reduce VOC/VOHAP emissions. Due to the high airflows and low HAP concentrations associated with spray booths at shipbuilding and ship repair faci lities, the industry did not cons ider such systems economically viable at the time. Most shipya rd painting is conducted outdoors ( due to the size of ships) and is sporadic in terms of ship constr uction or repair activities, resulting in control strategies that are technically infeasible, too costly, or both.

2.3 Internet Research

An internet search was conducted to determin e if any significant te chnological advances have been made in controlling surface coating emissi ons at shipbuilding and ship repair facilities. An overall search for shipbuild ing air pollution control was conducted on google.com, which lead to investigation of nume rous links. The Air and Waste Management website (awma.org) was searched, as was the website associated w ith Paint & Coatings I ndustry (PCI) magazine. Two websites which detail air pollution control efforts by the military (Joint Service Pollution Prevention and Sustainability Library [p2sus tainabilitylibrary.mil] and National Surface Treatment Center [nstcenter.com]) were also searched. The North Ca rolina Department of Natural Resource’s Pollution Pr evention Pays website (p2pays.or g), and the Pacific Northwest Pollution Prevention Resource Center’s website ( pprc.org), provided links to publications of interest. The Paints and Coati ngs Resource Center website (paintcenter.org) was also examined, as was the website for the US Army Co rps of Engineers (cecer.army.mil).

The internet search did not produce any ne w information regarding the use of add-on controls to control HAP emissions from surface co ating operations like those at shipbuilding and ship repair facilities. Some of the links examined are listed in Attachment 2.

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### 2.4 Correspondence with Industry

The shipyard that was identified as using ro tary concentrators followed by regenerative thermal oxidizers to control spray booth emissi ons (NASSCO in San Diego, CA) was contacted to discuss the installation and us e of the controls. In addition, the vendor that supplied the addon control system to NASSCO, Munters, was contacted to discuss the NASSCO application and to discuss the use of similar systems by other shi pbuilding and ship repair facilities, and the use of such systems by other industries with similar surface coating operations.

2.4.1 NASSCO

The discussions with NASSCO primarily supp lemented information on their installation. An environmental engineering specialist at NA SSCO stated that the five spray booths being controlled by the rotary concentrat or/RTO systems are new booths that were installed as part of a contractual obligation for a particular job. 2 

### The use of add-on controls for the booths was not explicitly required by th e regulatory agency. Instead, the high cost of offsets and other considerations lead to NASSCO’s decision to in stall the rotary concentrator/RTO systems. NASSCO stated that state (CA) regulations requi re NASSCO to use only co mpliant coatings in the spray booths, even with the add-on contro ls operating. NASSCO said that although the permit allows for operation of the spray booths 24 hours per day and 7 days per week, in reality, spraying operations do not occur continuously. The spraying opera tions inside the booths use essentially the same airless spra y equipment that is used in th e outdoor spraying operations at the facility, and the workers in the spray booths use supplied air. Th e whole system is designed with interlocks so that, if for a ny reason the add-on control system stops functioning, the paint application system also shuts down automatically. 2



### The NASSCO San Diego facility is different than many shipyards in that they do both repair work and new construction. The business cycl e at a yard is generally slow to change, but a yard may do mostly new construction for a few y ears (which has been the case for the last few years at NASSCO), then the yard may switc h to doing primarily repair work. NASSCO estimates that last year, during the first year of operation of the new booths with the add-on controls, no more than 25% of the surface coating operations at the NASSCO facility occurred in the spray booths. The other 75% of surface coating is done shipside or in other locations of the facility that are not equipped with booths. Even with new construction, some coatings and pieces, such as tanks, require continuous coati ng application over the whole piece. In such instances, even for new construc tion, the pieces that go into su ch final products cannot be painted individually in spray booths and then assembled. Instead, the whole piece must first be assembled, and then coatings must be a pplied to the whole piece at one time. 2



### NASSCO’s website (http://www.nassco.com) accessed on June 3, 2010) includes the following description of their environmental efforts:

“NASSCO has established Best Ma nagement Practices to protect the environment. Recognizing that shipbuilding and repair activities have a potential impact on air quality, the company has adopted a number of safeguards in its pr oduction processes. Examples include:

2 Conversation with Sara Giobbi of NASSCO on May, 25, 2010.



### 8

### Abrasive blast containment . Granular blasting material is often used to remove paint from ship surfaces. This operation is walled in with containment material to minimize dust being released into the atmosphere. NASSCO also encourages its customers to allow the use of water-jet hydroblasting for exte rior hull paint removal, a procedure that produces less dust than gra nular particle blasting. Paint containment . Shrouds and mesh cloths are us ed to contain paint overspray and reduce emissions. No paint thinning . All painting activities are performed without the use of paint thinners to minimize the release of volatile or ganic compounds into the atmosphere. Filtering discharges . Plasma-burning machines are fitted with filtration systems that collect and filter out potential contaminants from smoke and other discharges. Diesel Crane Repowering Project . NASSCO has voluntarily upgraded the engines of four large overhead cranes with state-of-t he-art pollution control equipment. NASSCO received approximately $1 million of the $3.5 million necessary for this project through a California Air Resources Bo ard Carl Moyer Grant."

2.4.2 Add-On Control Vendor

Munters, the vendor that de signed and supplied the rotary concentrator/regenerative thermal oxidizer (RTO) system at NASSCO, was contacted to discuss the NASSCO installation and other installations with hi gh volume, low concentration airflows similar to those from shipbuilding and ship re pair spray booths.

According to information obtained from Munter s, their rotary concentrator/RTO systems are being used at two shipyard s in the United States. One sy stem is at NASSCO’s San Diego, CA facility, as discussed elsewhere. Another Munters system is being used at the Northrop Grumman facility in Pascagoula, Mi ssissippi. The system at the Nort hrop facility controls a total airflow of 40,000 cfm from surface co ating operations in spray booth( s). Munters indicated that a shipyard in Groton, Connecticut is seriously consideri ng installing their system to control paint booth emissions. 3 

### Munters also knows of a shipbuildi ng operation in Korea that recently awarded a contract to a competitor for installati on of a concentrator/RTO system on paint booths at the facility.

According to Munters, their rotary concentrator/R TO systems are being used extensively in other industries that have high airflow volumes and low VO C concentrations (on the order of 100 ppm). For example, Munters’ control device s are being used in the automobile painting industry. Airflows in the automobile painti ng operations can range from 30,000 to 300,000 cfm. For applications much greater than 50,000 cfm, M unters “gangs”, or connects, systems together. 3 

### The Munters rotary concentrat or/RTO systems are also used by the semi-conductor industry. Although the installations at semi conductor facilities control emi ssions from fabrication rooms, rather than surface coating operations, the airf low to be treated is similar to that from shipbuilding paint booths in th at is it high volume (gener ally 10,000 - 40,000 cfm, though some are smaller), and the VOC concentration is relativ ely low. The Munters ro tary concentrator/RTO systems are also used in the composite industr y. The operations controlled in the composite

3 Conversation with Chris Jensen of Munters May 25, 2010, provided in Attachment 3.



### 9

### 10 industry involve a build up of resin, layer by laye r. Although the process creating the emissions is not a surface coating operation, again, the ex haust airflows are relatively large (20,000-50,000 cfm), and the heating value of the exhaust is low. 3



### Munters also provided an installation list for their rotary concentrat or/RTO systems. The list provides the customer name, location, flow rate , and type of applicatio n controlled. Seventy one of the installations, which re present 67 facilities, are describe d as paint/coating applications. It appears a wide variety of i ndustries are represented by the pain t/coating applications, including but not limited to automobile and truck painti ng, shipbuilding and ship repair, and aerospace manufacturing. Twenty nine of the paint/coating operations on the Munters list have controlled airflows of 50,000 cfm or greater. Copies of te lecons and emails summarizing the discussions with San Diego APCD, NASSCO, and Munters, as well as the Munters installation list, are provided in Attachment 3.

3.0 CONCLUSION

This investigation did not reveal any developm ents in practices or processes used in the shipbuilding and ship repair industry. However, there have been advances in add-on control technology since the shipbuilding and ship repair NESHAP was origin ally developed in 1995. The exhaust from spray booths in the shipbuildin g and ship repair indus try is generally a high volume, low VOC concentration airflow. Hist orically, treatment of such airflows was considered economically prohibitive, due to the ex treme size of the controls and the quantity of fuel needed. However, add-on control syst ems have been developed that incorporate concentrators which reduce the airflow sent to the oxidizer by 90 percent. These concentrator systems can be designed to be combined with re generative thermal oxidizers. The airflow from the concentrator is a much lower volume (10 per cent of the original), and the VOC concentration is increased, which translates into increased heat value of the airstream (which in turn reduces the amount of fuel needed for combustion in th e regenerative thermal oxidizer). The reduced airflow, higher concentration airstream can be treated more economically by regenerative thermal oxidation.

Control systems that incorporate rotary c oncentrators followed by regenerative thermal oxidation are offered by more than one manufactur er. Data from one of the manufacturers, Munters, indicates that these systems are currently being used in certain types of spray booths in the shipbuilding and ship repair industry. Furthe r, these systems are being used in a variety of other industries to treat high volum e, low VOC concentration airflo ws similar to airflows from spray booths in the shipbuildi ng and ship repair industry.

### ATTACHMENT 1

INFORMATION FROM THE RACT/B ACT/LAER CLEARINGHOUSE AND CALIFORNIA BACT DATABASE

RBLC REPORT

COMPREHENSIVE REPORT Report Date:05/17/2010


## Facility Information

RBLC ID: 

### CA-1168 (final) Date Determination Last Updated: 12/10/2009

Corporate/Company Name: NASSCO Permit Number: 986868-72

Facility Name: NASSCO Permit Date: 08/14/2008 (actual)

Facility Contact: FRS Number: 0607300158

Facility Description: SIC Code: 3731

Permit Type: A: New/Greenfield Facility NAICS Code: 336611

Permit URL:

EPA Region: 9 COUNTRY: USA

Facility County: SAN DIEGO

Facility State: CA

Facility ZIP Code: 92113

Permit Issued By: SAN DIEGO COUNTY APCD, CA (Agency Name) MR. STAN ROMELCZYK(Agency Contact) (858)650-4599

Other Agency Contact Info: MR. ARTURO GONZALEZ 858-586-2721 ART.GONZALEZ@SDCOUNTY.CA.GOV

Permit Notes:



### Process/Polluta nt Information

PROCESS NAME: SPRAY BOOTH

Process Type: 41.024 (Ship Building & Repair Surface Coating)

11Primary Fuel: NATURAL GAS

Throughput:

Process Notes: FIVE(5) CONCENTRATOR(S)/RTO(S) HAVE BEEN ISSUED ACS. AS OF OCTOBER 14, 2008, NO CONSTRUCTION HAS TAKEN PLACE.

POLLUTANT NAME: Volatile Organic Compounds (VOC)

CAS Number: VOC

Test Method: Unspecified

Pollutant Group(s): ( Volatile Organic Compounds (VOC) )

Emission Limit 1: 2.0000 T/YR

Emission Limit 2:

Standard Emission:

Did factors, other then air pollution technology considerations influe nce the BACT decisions: U

Case-by-Case Basis: BACT-PSD

Other Applicable Requirements:

Control Method: (A) VOC CONCENTRATOR AND RTO

Est. % Efficiency:

Compliance Verified: Unknown

Pollutant/Compli ance Notes:

Previous Pag e

12

### CALIFORNIA STATEWIDE BEST AVAI LABLE CONTROL TECHNOLOGY CLEARINGHOUSE 

# BACT Determination Detail

bar1q.gif 

## Category

Source Category: Spray Booth

SIC Code 3731 N

AICS Code 336611



## Emission Unit Information

M

anufactu

rer: Munters
Type: M

odel: IZS-4200 RTO E quipment D escriptio

n: Concentrator/RTO

Capacity / D imention

s 5,000 scfm

F

uel Type N atural Gas M

ultiple F

uel Types Operating Schedule (hours/day ) /(days/we ek)/(weeks / year)e Continuous (24/7/51)

F

unction of E quipmen t



## Bact Information

VOC Limit 2 VOC Limit Units tons/yr

VOC A verage Time VOC Control Add-on

13M ethod VOC Control M

ethod D esc VOC concentrator and RTO



## Project / Permit Information

A

pplicatio n/Permit N

o.: 986868-72

N

ew Constructi on/Modific ation: N ew Construction

A TC Date: 08-14-2008 P TO Date: Startup D ate: Technolog

y Status: BACT Determination

Source Test A vailable: N o

Source Test R esults: The equipment has not been installed to date.



## Facility / District Information

F

acility N

ame: N ASSCO

F

acility Zip Code: 92113

F

acility County: San Diego

D istrict N

ame: San Diego County APCD

D istrict Contact: Arturo Gonzalez

Contact P hone N

o.: 858.586.2721

Contact EM

ail: Art.Gonzalez@SDCounty.ca.gov



## Notes

N

otes: Five(5) concentrator(s)/RTO(s) have been issued ACs. As of October 14, 2008, no constrution has taken place.

14

### ATTACHMENT 2

INTERNET SEARCH – PARTIAL LIST OF LINKS EXAMINED

Typed in shipbuilding pollution control at google.com. Some of links that came back and were checked include:

http://www.yourshipbuild ingnews.com/news_item.php?newsID=46498 Shipbuilding news site, with articles for shipbuilding industry overall, including environmental news

http://www.ship-technology.com/search.do?q=air+pollution&baseId=1 Searched for pollution and not much came back; what did show up had to do with reducing emissions from engines

http://www.evergreen-line.com /tbi1/jsp/TBI1_Index.jsp#0 This is website for Evergreen Corp, and discusses how they make their container ships green, including use of tin-free paints

http://www.ssa.org.uk/link/list UK shipbuilding and shiprepairing industry association. Nothing useful on this site, or on links provided on this site

http://www.nstcenter.com/RegulationsLaws.aspx National Surface Treatment Center and The McConnell Technology & Training Center for the U.S. Navy. Had links to some of sites below. Resources section of this website has info on surface prep (blas ting, etc.) for Navy overall, with cont act info. Also contains a lot of information related to corrosion prevention

http://www.p2sustainabilitylibrar y.mil/query.aspx?topic=142 Pollution Prevention Site of Navy called Joint Service Pollution Prevention and Sustainability Library maintain ed by Naval Facilities Engineering Service Center

Other sites examined include but are not limited to:

http://www.usace.army.mil/Search/ results.aspx?k=air%20pollution US Army Corp of Engin eers. Searched this site and two additional links for air pollution articles....included abstracts of some in other file. Searched CERL – Construction Engineering Research Lab; USACE – US Army Corp of Engineers

http://www.nassco.com/ NASSCO/General Dynamics site

15

### ATTACHMENT 3

CORRESPONDENCE WITH AG ENCIES AND INDUSTRY

Date: 5/11/10 Person Calling: Art Gonzalez Source Name: San Diego County APCD City, State, County: San Diego, CA NEI Number: N/A
State #: N/A Dept/Phone Number: 858-586-2721; art.gonzalez@sdcounty.ca.gov

Mr. Gonzalez was listed as the agency contact for a project that involved the installation of concentrator/regenerative thermal oxidizers on spray booths at th e NAASCO facility in San Diego county. I contacted Mr. Gonzalez to find out if the permitted add on control units were ever installed, and if so, to lear n more about the installation.

Mr. Gonzalez said that the five concentrator/regen erative thermal oxidizers were installed on five spray booths last summer. He said he thought they had been installed last August, and would confirm the installation date in a subsequent emai l to me. He said so far the units have been operating as designed, as far as he knows. He’s not aware of any problems. The facility originally considered modifying existing permits to allow inst allation of the spray booths, but due to concerns about emission caps, decided to get new permits for the spray booths. Because offsets are complex and expensive, the facility decided to install add-on controls to control HAP emissions from coating operations.

Mr. Gonzalez is going to email me the data sheets for the installation. He indicated the units are manufactured by Triton. The coating booths, or cells, are quite large. Four of the paint spray booths, or cells are approximately 100’x80’x65’; and one is slightly smaller. The airflow from each of the spray booths is approximately 52,000 cfm. Mr. Gonzalez said he thought his file contained information regarding the VOC/HA P concentration into the concen trator, and would include that information in his email to me. He said primers an d topcoats are sprayed in the booths, and that he would include more specifics regarding the type s of paints as available, in his email.

I asked Mr. Gonzalez if he knew of any installation s at shipyards that use ad d-on controls to control HAP emissions from shipside painting operations (i .e., painting of assemb led ship, outside of any spray booth or cell). He said he was not aware of any such installations. I asked him if he knew of any add-on controls being used to control abrasi ve blasting or welding emissions from shipside blasting or welding. He said that was not his ar ea, and promised to provid e the contact information for the San Diego APCD person to ask.

16From: Gonzalez, Art

To: MJCaldwell@NC.RR.com

Sent: Wednesday, May 12, 2010 Subject: Re: NASSCO / Controls

Regarding the cost you’ll have to talk with NASSCO (Sara Gobbi; SGobbi@NASSCO.com ) I don’t have any precise number regarding the cost. Regards,

Art Gonzalez

Celebrating 50 years of air quality progress! San Diego Air Pollution Control District

Phone 858.586.2721 Fax 858.586.2801

From: Mary-Jo Caldwell [mailto: mjcaldwell@nc.rr.com] Sent: Wednesday, May 12, 2010 6:27 AM To: Gonzalez, Art Subject: Re: NASSCO / Controls Art, Thank you for in the information you provided. It's very helpful. I would like to know more about the HAP emissions controlled at the facility, and the annual costs and cost effectiveness of the add-on co ntrols, etc. Would it be possible for you to send me an electronic version of the NAASCO application? I think it probably contains what I'm after. If you don't have an electronic version or cannot share it, I will ask you sp ecific questions and ask that you search through the information for me. Thanks. Mary-Jo Caldwell

----- Original Message -----

From: Gonzalez, Art

To: MJCaldwell@NC.RR.com

Sent: Tuesday, May 11, 2010 1:59 PM Subject: NASSCO / Controls

Mary,
Per our conversation the following information is provided.
**Five rotatary concentrators have been installed.** 

### Four (4) marine coating operation(s) consisting of: One (1) Custom built enclosed paint sp ray booth, 100’x 80’x 65’; approximately 51,200 cfm; Flanders PrecisonAire Series 332 PA f ilters or equivalent; One(1) Adwest Retox 5.0 Regenerative Thermal Oxidizer; 5,000 cfm; One(1) Zeolite Concentrator; chart recorder/data logger; cont rols as required for safe continuous operation. One (1) marine coating operation consisting of: One(1) Custom built enclosed paint spray booth, < 100’x 80’x 65’; approximately 51,200 cfm; Flanders PrecisonAire Series 332 PA f ilters or equivalent; One(1) Adwest Retox 5.0

17

### Regenerative Thermal Oxidizer; 5,000 cfm; One(1) Zeolite Concentrator; chart recorder/data logger; cont rols as required for safe continuous operation.

**The listing of the coatings reviewed is given below.** Paint Family Air Dried or Baked? Rule 67.18 Marine Coating Category Rule 67.18 VOC Limit (gm/liter) Product VOC Content (gm/liter) Intertuf 262 Air Dried Primer 340 320 Intertuf 262 Air Dried Primer 340 320 Intertuf 262 Air Dried Primer 340 320 Intertuf 262 Air Dried Primer 340 320 Interspeed 640 Air Dried Antifoulant 400 385 Interspeed 640 Air Dried Antifoulant 400 385 Interline 604 Air Dried Primer/Topcoat 340 194 Interline 604 Air Dried Primer/Topcoat 340 194 Intergard 264 Air Dried Primer 340 194 Intergard 264 Air Dried Primer 340 194 Intergard 403 Air Dried Primer/Topcoat 340 304 Intergard 403 Air Dried Primer/Topcoat 340 304 Intergard 403 Air Dried Primer/Topcoat 340 304 Intersleek 731 Air Dried Topcoat 340 325 Intersleek 970 Air Dried Topcoat 340 248 Intersleek 970 Air Dried Topcoat 340 248 Intershield 300 Air Dried Topcoat 340 326 Intershield 300V Air Dried Topcoat 340 326 International GT 4637 Air Dried Equipment Cleaning & Surface Prep. 200 868

**The inlet concentration per the source test (May 19, 2009) is given below.** 
Average inlet 108 ppmv
Average outlet 2.0 ppmv **The equipment was installed in April 2009.**
Sarah Goobi (i.e. NASSCO) can provide equipment regarding the vendor: SGobbi@Nassco.com.
Regards,

Art Gonzalez
Celebrating 50 years of air quality progress!
San Diego Air Pollution Control District

Phone 858.586.2721

Fax 858.586.2801

18Date: 5/11/10 Person Calling: Jeanne Pandes Villacorte Source Name: South Coast Air Quality Mgmt. District City, State, County: Diamond Bar, CA NEI Number: N/A
State #: N/A Dept/Phone Number: (909) 396- 2621; jpvillacorte@aqmd.gov

I contacted Ms. Pandes Villacorte to discuss the use of add-on contro ls by the shipbuilding and ship repair industry. She said that the high flowra tes and low concentrations associated with spray booths used by industries such as shipbuilding do not lend themselves to the use of add-on controls. She said she did not think any kind of add-on HAP controls would be feasible for any shipside painting or blasting operations due to the difficulty in capt uring the emissions.

Ms. Pandes Villacorte suggested I check the EP A BACT/LAER clearinghouse, and the BACT/LAER database for California, to see if any add-on controls are being used at other shipyards.

Ms. Pandes Villacorte also suggested I call her su pervisor, Ms Stacey Ebiner (909) 396-2504, to ask her if she’s aware of any add-on controls being used at shipyards.

19Date: 5/11/10 Person Calling: Stacey Ebiner Source Name: South Coast Air Quality Mgmt. District City, State, County: Diamond Bar, CA NEI Number: N/A
State #: N/A Dept/Phone Number: (909) 396-2504; sebiner@aqmd.gov

I contacted Ms. Ebiner to ask her if she was aware of any shipbuilding or ship repair facility using add-on controls to control HAP from either spray boot hs or shipside painting or blasting operations. She said she was not aware of any such application, and she indicated that her previous supervisor (Brian Yeh) also indicated he is no t aware of any such installations.

This telecom was confirmed by Ms. Ebiner on May 13, 2010.

20Date: 5/25/10 Person Calling: Chris Jensen Source Name: Munters, Inc. Dept/Phone Number: (978) 241- 1132 cjensen@munters.com

I told Mr. Jensen that Sara Giobbi of NASSCO San Diego told me to call him to discuss applications similar to the five rotary concentrator/RTO system s installed on the five new spray booths at the NASSCO San Diego facility.

Mr. Jensen said that to his knowledge, the on ly shipbuilding facility using their rotary concentrator/regenerative thermal oxidizer system for surface coating operations is the NASSCO San Diego. However, he said that a sister compan y to NASSCO is strongly considering one of their systems for their Groton, CT facility. Mr. Jensen also said that he knew that at least one shipbuilding surface coating operation is using a concentrator/RTO system similar to theirs in Korea, because they bid on the job but it was awarded to someone else (he didn’t know who).

Mr. Jensen said that their concentrator/RTO system s are being used in other industries that have high airflow volumes and low VOC concentrations (on the order of 100 ppm), similar to the shipbuilding surface coating booths. Their system is being used in:

• the semi-conductor industry. Although it’s no t surface coating, but rather exhaust air from fabrication rooms, the exhaust is high volu me, low concentration (generally 10,000 – 40,000 cfm, though could be as small as 5,000 cfm)

• the auto painting industry. Surface coating oper ations like those in shipbuilding industry. Exhaust airflows range from 30,000 to 200, 000 or 300,000 cfm. For applications much bigger than 50,000 cfm, they “gang”, or conne ct, systems together to treat the larger volumes of air.

• the composite industry. Not a su rface coating operation, but similar in that it involves a build up of resin, layer by layer. Exhaust ai rflows in composite industry are on the order of 20,000 – 50,000 cfm.

Mr. Jensen said that to get a listing of actual a pplications in the semi-conductor, auto painting, and composite industries, I should contac t Cheryl Thibault at (978) 241-1163

21

# Emails Regarding Use of Add-on Controls

From: Mary-Jo Caldwell To: cthibault@munters.com Sent: Wednesday, May 26, 2010 8:25 AM Subject: Installations with high vol low conc exhausts

Hi Cheryl, I just left you a voicemail. Yesterday I spoke with Chris Jensen, and he suggested I contact you. I am working with EPA in conducting a residual risk analysis for the shipbuilding and sh ip repair industry. As part of the residual risk analysis, we are trying to determine what developments have occurred regarding HAP control since the shipbuilding NESHAP was originally developed.

Chris told me that Munters has rotary concentrat or/regenerative thermal oxidizer units in several industries that have high volume, low VOC concentration airstreams, similar to shipbuilding. He specifically mentioned the semi-cond uctor, auto paint, and composite industries. I would very much like to know more about your installations on high volume , low concentration airstreams. Specifically, for each installation I would like the following information, as it's available:

• Name of facility, location, industry, date of installation

• reason for installation (regulatory comp liance, VOC or specific HAPs, etc.)

• airflow sent to rotary concentrator, and airflow from concentrator to RTO (cfm)

• types of VOC/HAP controlled

• VOC (and HAP, as available) concentration (ppm) in airflow sent to concentrator, airflow sent to RTO, and airflow from RTO to atmosphere

• VOC and HAP reduction (%, and tpy)

• Approximate size of booths controlled

• Whether application in booth is manual or automatic, and if manual, do workers use supplied air (and if so, did they before installation of concentrator/RTO)

• Estimated capital and operating costs

I will be out of the office today and tomorrow, but can be reached at the number below. I look forward to hearing from you.

Thank you.

Mary-Jo Caldwell Caldwell Environmental, Inc. 6205 Winthrop Drive Raleigh, NC 27612 mjcaldwell@nc.rr.com (919) 812-5309

22From: < Cheryl.Thibault@munters.com > To: "Mary-Jo Caldwell" < mjcaldwell@nc.rr.com > Sent: Wednesday, May 26, 2010 1:40 PM Subject: Re: Installations with high vol low conc exhausts

3⁄4 Hi Mary-Jo,

> > As I mentioned in my voicemail, we have an installation list with customer > name, location, flow rate and application but other details are not readily > available. Take a look at the att ached list. Perhaps we can supply more > information on a targeted subset of the list. Give me a call to discuss > further when you get a chance. Also here is the link to our website if you > haven't already taken a look there...

>
> http://www.munters.us/en/us/Division-start-pages/Munters-DH-Div ision/Indirect-Heating--Cooling/

> > Regards, > Cheryl Thibault > Senior Applications Engineer > Munters Corporation > 79 Monroe St. Amesbury, MA 01913 > work 978-241-1163 > cell 978-660-3243

>

From: Mary-Jo Caldwell To: Cheryl.Thibault@munters.com Cc: Dave Reeves Sent: Tuesday, June 01, 2010 3:28 PM Subject: Re: Installations with high vol low conc exhausts

Hi Cheryl, Thanks very much for the list of installations. As I mentioned in my previous email, I'm currently working on the shipbuilding and ship repair industry, so I'm most interested in your applications in that industry. Just based on company names, I've identified two shipbuilding facilities with controlled paint/coating operations on your list - NASSCO San Diego and Northrup Grumman Pascagoula, MS. But perhaps there are more? I am most anxious for informatio n on the shipbuilding surface coating applications.

NAASCO, San Diego CA I already have some information on the NASSCO San Di ego application. I know control system operation started in 2009, there are 5 new booths, 5 control systems, ~100 ppm from each booth to concentrator, and I have approximate dimensions of booths and know they have manual spraying with supplied air for workers. I do not have any cost information for that installation. For the NASSCO installation, can you tell me: 1. Estimated capital cost of installation (and tell me if booths and supplied air systems are included, or separate) 2. Estimated annual operating costs, with breakdown as available (electricity, natural gas, labor, etc) 3. Estimated amount of VOC and/or HAP controlled (tons per year)

Northrop Grumman, Pascagoula, MS I don't have any information on this installation, except the flowrate from the list you sent me. Can you tell

me: 1. Is the 40,000 cfm from one booth? 2. When was system installed, and why (regulat ory compliance, contractual obligation, etc) 3. Concentration of VOC from booth to conc entrator, and from concentrator to RTO (ppm) 4. Spray booth information (approximate dimensions; manual or automatic spraying, if manual do workers have supplied air; if booth was existing, modifications made to booth re recirculation, etc.) 5. Amount of VOC and/or HAP controlled (tpy and % control)

236. Estimated capital costs (and w hether booths and supplied air systems, as applicable, are included or separate) 7. Estimated annual operating costs, with breakdown as available (electricity, natural gas, labor, etc.)

Costs in General (shipbuilding industry or overall, as applicable)

1. Do you have any rules of thumb or other es timates regarding capital and/or operating costs for concentrator/RTO systems (perhaps $/ cfm, $/ton VOC controlled, or some other parameter) I am looking for a rough guideline, not something to be used for budgeting purposes. 2. Is there a minimum VOC concentration that must be present in spray booth exhaust to make installation cost effective? 3. In an existing booth, is it generally necessary to modify spray booth exhaust to increase ppm to concentrator (i.e., perhaps decrease flowrate or inco rporate spray booth recircul ation, and install supplied air for workers)? 4. Do you have any installations that control VOC from surface coating operations that do not occur in a fixed spray booth? If so, please describe the installations and when they were installed.

Eventually I may ask for more information on some of t he other installations, but for right now, if you could supply the information above I'd be very appreciati ve. Please don't hesitate to call me if you need clarification.

Thank you for your time.

Mary-Jo Caldwell Caldwell Environmental, Inc. 919-812-5309

24From: Mary-Jo Caldwell To: cjensen@munters.com Sent: Wednesday, June 02, 2010 9:44 AM Subject: Groton CT possibility

Hi Chris,

When we spoke on the phone, you said that a shipyard in Groton CT is seriously considering installation of one of your systems. Can you tell me anything more about the potential installation, including any of the following:

- Company Name - Number of spray booths to be controlled, and exhaust flowrate from each - Number of control systems - Approximate VOC concentration in exhaust from spray booths

Thanks.

Mary-Jo Caldwell Caldwell Environmental, Inc. 6205 Winthrop Drive Raleigh, NC 27612 mjcaldwell@nc.rr.com (919) 812-5309

25

### Munters Zeol Installation List

CUSTOMER LOCATION SCFM Nm3/h r APPLICATION

Firestone Building Products Bristol, CT 10,000 17000 Building Materials Corus Lightstrip Ijmuiden, Nether lands 18,000 30582 Coil Coating Corus/EIS No Lincolnshire UK 13,700 21600 Coil Coating Preussac Stah/L&E Salzgitter, Germany 17,000 28900 Coil Coating Amerimax Building Products Plano, TX 36,000 56775 Composites Masonite Laurel, MS 20,000 31500 Composites National RV Perris, CA 28,000 47600 Composites Azimut Yachts Avigliana, Italy 28,500 45000 Composites M+M Mars Illinois 6,000 9500 Food & Drug R.P. Scherer St. Petersburg, FL 600 1100 Food & Drug McClellan Air Force Base McClellan, CA 11,000 18700 Groundwater GEO Levelland, TX 7,000 11000 Groundwater Hitchiner Manufacturing Milford, NH 13,400 21100 Investment Casting Precicast Switzerland 9,000 15300 Investment Casting Medtronics Tempe, AZ 15,0 00 25485 Medical Instruments Soab Molndal, Sweden 13,000 22100 Metal Fabrication Termoregulator Motala, Sweden 18,000 30600 Metal Fabrication Brentwood Industries Reading, PA 15,000 25500 Packaging/Printing Danapak Slagelse, Denmark 152,000 258250 Packaging/Printing Munksjo Inpack Norway 12,600 20000 Packaging/Printing Stenqvist Norway 21,500 34000 Packaging/Printing Tetra Pak Arganda, Madrid, Spain 27,000 45900 Packaging/Printing Tetra Pak Berlin, Germany 26,000 44200 Packaging/Printing Tetra Pak Forshaga, Sweden 27,000 45900 Packaging/Printing Tetra Pak Latina, Italy 35,000 59500 Packaging/Printing Tetra Pak Lund, Sweden 5,000 8500 Packaging/Printing Tetra Pak Lund, Sweden 27,000 45900 Packaging/Printing Tetra Pak Wrexham, UK 4,500 7700 Packaging/Printing Trioplast Sweden 15,800 25,000 Packaging/Printing ABB Flakt Sweden 59,000 100300 Paint/Coating ADAC Saranac, MI 35,000 59465 Paint/Coating Adept Plastic Finishing Wixom, Michigan 20,000 33800 Paint/Coating Alcoa Wheel Products Hungary 10,600 16800 Paint/Coating Alltub Czech Republic 8,200 13,000 Paint/Coating Barstow Marine Corps Base Barsto w, CA 14,000 22000 Paint/Coating Barstow Marine Corps Base Barsto w, CA 40,000 68000 Paint/Coating Becker Acroma Marsta, Sweden 11,000 18700 Paint/Coating Beckers Sweden 24,000 40800 Paint/Coating Boeing Wichita, KS 86000 146200 Paint/Coating Bombardier Aerospace, Dorval Montreal, Canada 250,000 424753 Paint/Coating Bombardier Aerospace, Miralbel Montreal, Canada 200000 339802 Paint/Coating Calhac, Inc. Anaheim, CA 25,000 42500 Paint/Coating Callaway Golf Carlsbad, CA 20,000 33800 Paint/Coating Chromium Corporation Lufkin, TX 32,500 55300 Paint/Coating Chrysler Toluca, Mexico 36,000 56900 Paint/Coating Chrysler Detroit, MI 240,000 407763 Paint/Coating Daihan Ink Seoul, Korea 17000 27000 Paint/Coating Dampa Tommerup, Denmark 22,500 38300 Paint/Coating Donnelly Hohe Dorfprozelten, Germany 32250 54900 Paint/Coating Dragon Products LaPorte, TX 90,000 142000 Paint/Coating

26

### Munters Zeol Installation List

CUSTOMER LOCATION SCFM Nm3/h r APPLICATION

Dragon Products Silsbee, Texas 164,000 259000 Paint/Coating Elizabeth Tayler Shutters Colton, CA 29,000 49370 Paint/Coating Ferrari Moranello, Italy 45,625 77600 Paint/Coating Fort Bragg ALMD Fort Bragg, NC 40,000 68000 Paint/Coating General Dynamics NASSCO San Diego, CA 250,000 395000 Paint/Coating General Motors Shreveport, LA 305,000 518198 Paint/Coating Haartz Corporation Acton, MA 20,000 34000 Paint/Coating Harbor Truck Brea, CA 38,400 60600 Paint/Coating Honda of America Marysville, OH 86,000 136000 Paint/Coating Indalex Montreal, Canada 72,000 114,000 Paint/Coating International Truck Chatham, Ont. 16,500 26000 Paint/Coating Intesa Meccanica At essa, Italy 40,000 630 00 Paint/Coating J.B Nielsen Bramming, Denmark 88,000 149600 Paint/Coating JLG Industries Inc. McConnellsburg, PA 54,000 91800 Paint/Coating Koito United Kingdom 44,000 74757 Paint/Coating Leer West Woodland, CA 42,000 339,802 Paint/Coating Letterkenny Army Depot Chambersburg, PA 135,000 229500 Paint/Coating Masonite Laurel, MS 42,000 71400 Paint/Coating Medias Industries Medias, Romania 51,300 81000 Paint/Coating Mercedes Benz Bremen, Germany 140,000 238000 Paint/Coating Mercedes Benz Bremen, Germany 60,000 102000 Paint/Coating Mercedes Benz Sindelfingen, Germany 24,000 40800 Paint/Coating Metso Minerals Trelleborg, Sweden 15,800 25,000 Paint/Coating Monaco Coach Corp Coburg, OR 2 x 50,000 2 x 85,000 Paint/Coating National RV Perris, CA 6 x 40,000 6 x 67,600 Paint/Coating Northrup Grumman Ship Systems Pascagoula, MS 40,000 68000 Paint/Coating NUMMI Fremont, CA 58,700 92700 Paint/Coating Peugeout Sevelnord, France 128,750 218900 Paint/Coating Plastic Omnium Measham, UK 50,500 85900 Paint/Coating Plastic Omnium Measham, UK 50,500 85900 Paint/Coating
PLM Vienna, Austria 12,000 20400 Paint/Coating Rehau/Mercedes Cullman, AL 62,300 105800 Paint/Coating Renault Douani, France 30000 51000 Paint/Coating
R-TEK Washington Tyne & Wear, UK 20725 36000 Paint/Coating Saab – Scania Lulea, Sweden 18000 30600 Paint/Coating Saleen Irvine, CA 55,000 87000 Paint/Coating Schmalbach/ Lubeca Wellimdorf, Germany 53000 90100 Paint/Coating Schmalbach/ Lubeca Wellimdorf, Germany 2 x 19,000 2 x 33,000 Paint/Coating Sevelnord Sevelnord, France 30000 51000 Paint/Coating Silgan Container Rochelle, IL 18,000 32000 Paint/Coating SST Truck Garland, TX 25,000 42500 Paint/Coating Toyo Seican Yokohama, Japan 9,000 15300 Paint/Coating Toyota France 23,000 39077 Paint/Coating Uralvagonzavod Russia 760,000 1,200,000 Paint/Coating Vestfrost Denmark 40,000 67960 Paint/Coating Volkswagon Mosel, Germany 170,000 288832 Paint/Coating Volvo Dublin, VA 191,000 324700 Paint/Coating Volvo Gothenburg, Sweden 5,000 8500 Paint/Coating Volvo Torslanda, Sweden 34,000 57800 Paint/Coating Volvo Umea, Sweden 75,000 127500 Paint/Coating

27

### Munters Zeol Installation List

CUSTOMER LOCATION SCFM Nm3/h r APPLICATION

Acer Taiwan, ROC 37,000 62900 Semiconductor Acer Taiwan, ROC 38,000 64600 Semiconductor
AMD Wellimdorf, Germany 2 x 30,000 51,000 x 2 Semiconductor Analog Devices Wilmington, MA 28,000 47600 Semiconductor Applied Materials Sunnyvale, CA 15,000 25485 Semiconductor AU Taichung Taiwan 30,000 47000 Semiconductor Conexant Newport Beach, CA 15,000 25500 Semiconductor Conexant Newport Beach, CA 25,000 42500 Semiconductor Fairchild Semiconductor Portland, ME 28,000 47600 Semiconductor Fujitsu Gresham, OR 29,000 49300 Semiconductor Harris Corporation Mountain Top, PA 6,000 10200 Semiconductor Headway Technologies Milpitas, CA 16,000 27200 Semiconductor Hewlett Packard San Jose, CA 10,000 17000 Semiconductor Hitachi Irving, TX 24,000 40800 Semiconductor
IBM Manassas, VA 35,000 59500 Semiconductor IBM Corporation Corbeil-Essonnes, France 30,000 51000 Semiconductor IM Flash Technologies Lehi, UT 2 x 18,200 2 x 28800 Semiconductor Infineon Sandston, VA 40,000 67960 Semiconductor Infineon Sandston, VA 44,000 74757 Semiconductor Integrated Device Tech. Hillsboro, OR 17,500 29800 Semiconductor Integrated Device Tech. Salinas, CA 8,000 13600 Semiconductor Integrated Device Tech. San Jose, CA 10,000 17000 Semiconductor Linfinity Microelectronics Garden Grove, CA 2 x 3000 2 x 4700 Semiconductor LSI Logic Gresham, OR 15,000 25485 Semiconductor LSI Logic Gresham, OR 25,000 42500 Semiconductor MagIC Technologies Milpitas, CA 10,000 15800 Semiconductor Matsushita Puyallup, WA 22,000 37400 Semiconductor Matsushita Puyallup, WA 16,100 27200 Semiconductor Merix Forest Grove, OR 17,000 28883 Semiconductor Micrel Semiconductor San Jose, CA 8,000 13600 Semiconductor Microchip Gresham, OR 29,000 49300 Semiconductor Micron Nampa Boise, ID 15,000 23700 Semiconductor Micron Nano Boise, ID 5,000 7900 Semiconductor Micron Technology Boise, ID 6,000 10200 Semiconductor Micron Technology Boise, ID 6,000 10200 Semiconductor Micron Technology Boise, ID 10,000 17000 Semiconductor Micron Technology Boise, ID 15,000 25500 Semiconductor Micron Technology Boise, ID 15,000 25500 Semiconductor Micron Technology Boise, ID 30,000 51000 Semiconductor Micron Technology (Twinstar) Richardson, TX 25,000 42500 Semiconductor Motorola Phoenix, AZ 3 x 33,000 3 x 56,100 Semiconductor Motorola Toulouse, France 38,000 64600 Semiconductor Motorola Phoenix, AZ 25,000 42500 Semiconductor Motorola Tempe, AZ 15,000 25500 Semiconductor Nanofab Albany Albany, NY 9,600 15000 Semiconductor National Semiconductor Portland, ME 25,000 39,500 Semiconductor NEC Roseville, CA 10,000 17000 Semiconductor OHKA America, Inc. Hillsboro, OR 14,000 23800 Semiconductor Powerchip Taiwan, ROC 30,000 51000 Semiconductor Qimonda Sandston, VA 20,800 32,900 Semiconductor

28

### Munters Zeol Installation List

CUSTOMER LOCATION SCFM Nm3/h r APPLICATION

Quantum Shrewsbury, MA 20,000 34000 Semiconductor Read Rite Corporation Fremont, CA 30,000 51000 Semiconductor Sanmina Santa Clara, CA 22,000 37378 Semiconductor Semicon - confidential Hillsboro, OR 25,000 39500 Semiconductor Semicon - confidential Hillsboro, OR 25,000 39500 Semiconductor Semicon - confidential Santa Clara, CA 25,000 39500 Semiconductor Semicon - confidential Chandler, AZ 25,000 39500 Semiconductor Semicon - confidential Hillsboro, OR 25,000 39500 Semiconductor Semicon - confidential Hillsboro, OR 25,000 39500 Semiconductor Semicon - confidential Chandler, AZ 25,000 39500 Semiconductor Semicon - confidential Colorado Springs, CO 25,000 39500 Semiconductor Semicon - confidential Dallas, Texas 6,000 10200 Semiconductor Semicon - confidential Dallas, Texas 10,000 17000 Semiconductor Semicon - confidential Dallas, Texas 15,000 25500 Semiconductor Semicon - confidential Dallas, Texas 40,000 68000 Semiconductor Semicon - confidential Dallas, Texas 2 x 30,000 2 x 50,970 Semiconductor Semicon - confidential Dallas, Texas 3 x 30,000 3 x 50,970 Semiconductor Semicon - confidential Leixlip, Ireland 25,000 39500 Semiconductor Semicon - confidential Leixlip, Ireland 25,000 39500 Semiconductor Semicon - confidential Richardson, TX 20,000 34000 Semiconductor Siliconix, Inc (Vishay) Santa Clara, CA 2 x 10,000 2 x 17,000 Semiconductor Silterra Kulim, Malaysia 3 x 36,000 3 x 61,164 Semiconductor Skyworks Woburn, MA 30,000 47300 Semiconductor SMIC Shanghai, China 40,000 63200 Semiconductor ST Microelectronics Phoenix, AZ 45,000 71000 Semiconductor Supertex San Jose, CA 4,000 6400 Semiconductor SVA FujiFilm Shanghai, China 13,600 23,900 Semiconductor Symbios Logic Colorado Springs, CO 20,000 34000 Semiconductor Symbios Logic Fort Collins, CO 20,000 34000 Semiconductor Tianma Micro-electronics Shanghai, China 38,000 60000 Semiconductor Triquint Richardson, TX 25,000 42500 Semiconductor TSMC Taiwan, ROC 4 x 10,000 4 x 17,000 Semiconductor Wafertech Camas, WA 10,000 17000 Semiconductor Wafertech Camas, WA 10,000 17000 Semiconductor Wafertech Camas, WA 4 x 10,000 4 x 17,000 Semiconductor Western Digital Fremont, CA 39200 62000 Semiconductor White Oak Richmond, VA 40,000 68000 Semiconductor Winbond Taiwan 32,000 54368 Semiconductor Winbond Taiwan, ROC 40,000 68000 Semiconductor WJ Communications San Jose, CA 20,000 31600 Semiconductor Zycon Corporation Santa Clara, CA 22,000 37400 Semiconductor

2930 

### ATTACHMENT 43132333435363738