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 for hazardous air pollutants 

(HAP) emission sources for the Shipbuilding and Ship Repair (Surface Coating) source category. 

This analysis is part of EPA’s review efforts in accordance with section 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 category. Section 2 discusses the exploration of 

developments in practices, processes, and control 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 standards are often referred to as maximum 

achievable control technology, or MACT, standards. Section 112 also contains provisions 

requiring EPA to revisit these standards. Specifically, paragraph 112(d)(6) section states: 

(6) REVIEW AND REVISION. – The Administrator shall review, and revise as necessary 

(taking into account developments in practices, processes, and control technologies), emission 

standards promulgated under this section no less often than every 8 years. 

1 
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 from surface coating operations to the extent 

achievable by the use of MACT, which is based on maximum HAP emission limits for various 

categories of marine coatings. Major source facilities that are subject 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/transfer, and storage. 

Compliance with the VOHAP limits must be demonstrated on a monthly basis. The promulgated 

standards include three compliance options to allow flexibility in demonstrating compliance, 

including compliant coatings with limits on VOHAP content, spill minimization through 

handling and transfer requirements, and alternative 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 category includes facilities (shipyards) 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 applied, 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 built or repaired. In new 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 coatings are applied shipside. A wide variety of 

coatings are applied at a typical facility and the location and duration 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 structures that have special coating requirements: antennas and 

superstructures, exterior deck areas, interior habitability areas, tanks, and underwater hulls. 

Coatings in the shipbuilding industry are generally spray applied. The basic components 

in marine coatings are vehicles (resin binder), solvents (except in 100 percent solids coatings), 

pigment (except for clear coatings), and additives. Marine coatings are vital for protecting the 

ship from corrosive and biotic attacks from the ship’s environment. Specific paint selections are 

based on the intended use of the ship, activity, aesthetics, and fuel costs. 

As previously mentioned, many shipyards perform 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; therefore, shipside coating normally occurs outdoors. Some shipyards 

that paint indoors use spray booths or may use an entire building as a spray area. Buildings and 

2 
spray booths used in major source shipyards vary 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, facilities 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 and considered during 

MACT development; 

• Process change or pollution prevention alternative that could be broadly applied that 

was not identified and considered during MACT development. 

Table 1 summarizes the practices, processes, and control technologies considered during the 

development of the 1995 MACT standards for Shipbuilding 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 from EPA’s RACT/BACT/LAER clearinghouse and 

California’s BACT clearinghouse on shipbuilding and ship repair controls (and associated follow 

up discussions). Section 2.2 provides information obtained from searching the web for 

technological development information, and Section 2.3 summarizes correspondence with the 

shipbuilding and ship repair industry 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 formulations, 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 

3 
 As noted above, the Shipbuilding and Ship Repair (Surface Coating) MACT standards 

were promulgated on December 15, 1995. Since that time, state regulatory agencies, notably 

those in California, have developed stricter and more specific standards for marine coatings and 

spray booths. The EPA has developed Control Techniques Guidelines (CTG) for HAP emissions 

from Automobile and Light-Duty Truck Assembly Coatings (2008), and Miscellaneous Metal 

and Plastic Parts Coatings (2008). EPA has also promulgated NESHAP for Automobile and 

Light-Duty Truck Assembly Coatings (subpart IIII), 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 (similar 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 Control District (APCD), 

Bay Area Air Quality Management District (BAAQMD), South Coast Air Quality Management 

District (SCAQMD), and the San Diego County APCD have developed and adopted more 

stringent regulations for marine coatings than the 1995 NESHAP for Shipbuilding. Attachment 

4 contains a summary table with limits and requirements of marine vessel 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 all coating categories, and have made distinctions between 

baked and air dried coatings, where applicable. The 1995 Shipbuilding NESHAP does not 

differentiate between air dried and baked coatings. For certain coating categories, some districts 

have lowered VOC limits by more than 50 percent. The four California districts also added 

additional coating categories beyond the 23 listed marine coating categories in the 1995 

Shipbuilding NESHAP and set VOC limits for each. 

As shown in Attachment 4, all four districts have also added an 85 percent capture 

efficiency for add-on controls (if a facility chooses not to comply with coating limits), VOC 

limits for cleaning solvents, and additional cleaning, monitoring and recordkeeping requirements 

than those listed in the 1995 Shipbuilding NESHAP. 

2.1.2 EPA CTGs for Subsequent Surface Coating Regulations

Flat wood paneling (wood building products) (2006) controls include low VOC coatings, 

ultraviolet cure and electron beam cure coatings, add-on controls, and work practices. 

Recommended add-on controls include oxidizers and solvent recovery systems that achieve 90 

percent control efficiency. Work practices include: (1) frequent visual inspections for all 

equipment used to transfer or apply coatings, adhesives, or organic solvents; (2) cleaning and 

wash off solvent accounting system; (3) collecting 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 estimated 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 include electrodeposition coatings, use of reciprocators or robot 

application devices, hybrid control systems using a concentrator followed by an oxidizer, spray 

booth water wash (overspray particles), dry filters or dry electrostatic precipitator. Alternate 

control technologies include condensation, biofiltration, and UV oxidation, but these 

technologies are not currently being used by the industry. The September, 2008 CTG for this 

source category recommends no new control measures for auto and light-duty truck 

manufacturing facilities, and thus no additional costs. The work practices recommended are 

believed to result in net cost savings by reducing 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 containers or pipes. Equipment substitution includes electrostatic 

and HVLP spray equipment. Controls include oxidation, adsorption, and absorption. The cost 

effectiveness of these controls is estimated to be $1,758/ton of VOC reduction. 

2.1.3 EPA NESHAP for Similar Sources

 

During the ten years after promulgation of the Shipbuilding and Ship Repair (Surface 

Coating) MACT standards, EPA promulgated NESHAP for other surface coating processes 

under the automobile and light-duty truck assembly coatings, miscellaneous 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 compliant material option, an emission rate without 

add-on controls option, or an emission rate with add-on controls options. All of the source 

categories’ standards require work practice activities that reduce emissions. 

Differences in work practice requirements between the ship building/repair rules and 

these other surface coating rules are additional requirements to convey organic HAP-containing 

coating materials in closed containers or through pipes and mixing organic HAP-containing 

coating materials only in closed containers. The auto and light truck surface coating standards 

include specific emission-reduction activities for coating line purging and flushing, for limiting 

emissions from spray booth operations, spray booth equipment, and areas around spray booths 

(e.g., use of masking materials in spray-booths to facilitate cleaning, using parts cleaners to clean 

spry-booth equipment). 

2.1 RACT/BACT/LAER Clearinghouse and California’s BACT Clearinghouse

 Under EPA's New Source Review (NSR) program, 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 permit. The NSR permit is a construction permit 

5 
which requires the company to minimize air pollution emissions by changing the process to 

prevent air pollution and/or installing air pollution control 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 meeting 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 modified sources in non-attainment areas. 

 BACT and LAER (and sometimes RACT) are 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 air pollution technology information 

(including past BACT and LAER decisions contained in NSR permits) to promote the sharing of 

information among permitting agencies and to aid 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 control 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 made in the state of California. The Statewide 

Best Available Control Technology (BACT) Clearinghouse is a database 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 control permit determinations that can help 

identify appropriate technologies to mitigate most air pollutant emission streams. It was 

designed to help permit applicants and reviewers 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 pollutants and 1,000 industrial 

processes. 

 

 The RBLC provides several options for searching 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 shipbuilding and repair surface coating, and 

shipbuilding and repair SIC and NAICS codes. We identified one shipbuilding 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 fields 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 supplemented by information obtained from the 

California BACT database, the San Diego Air Pollution Control District 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 concentrator, which is then followed by 

a regenerative thermal oxidizer (RTO). Rotary concentrators take in low concentration VOC 

laden air and through adsorbtion and desorbtion 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 order of 100 ppmv. This exhaust is routed to 

the rotary concentrator, where it is decreased to approximately 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 (rotary concentrator inlet) VOC concentration of 

approximately 108 ppm, and an average RTO outlet 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 the 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 Shipbuilding and Ship Repair (Surface Coating) MACT 

standard. At the time the standard was under development, 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 facilities, the industry did not consider such systems economically 

viable at the time. Most shipyard painting is conducted outdoors (due to the size of ships) and is 

sporadic in terms of ship construction 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 determine if any significant technological advances 

have been made in controlling surface coating emissions at shipbuilding and ship repair facilities. 

An overall search for shipbuilding air pollution control was conducted on google.com, which 

lead to investigation of numerous links. The Air and Waste Management website (awma.org) 

was searched, as was the website associated with Paint & Coatings Industry (PCI) magazine. 

Two websites which detail air pollution control efforts by the military (Joint Service Pollution 

Prevention and Sustainability Library [p2sustainabilitylibrary.mil] and National Surface 

Treatment Center [nstcenter.com]) were also searched. The North Carolina Department of 

Natural Resource’s Pollution Prevention Pays website (p2pays.org), and the Pacific Northwest 

Pollution Prevention Resource Center’s website (pprc.org), provided links to publications of 

interest. The Paints and Coatings Resource Center website (paintcenter.org) was also examined, 

as was the website for the US Army Corps of Engineers (cecer.army.mil). 

 The internet search did not produce any new information regarding the use of add-on 

controls to control HAP emissions from surface coating operations like those at shipbuilding and 

ship repair facilities. Some of the links examined are listed in Attachment 2. 

7 
2.4 Correspondence with Industry 

The shipyard that was identified as using rotary concentrators followed by regenerative 

thermal oxidizers to control spray booth emissions (NASSCO in San Diego, CA) was contacted 

to discuss the installation and use 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 shipbuilding 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 supplemented information on their installation. 

An environmental engineering specialist at NASSCO stated that the five spray booths being 

controlled by the rotary concentrator/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 the regulatory agency. Instead, the high cost of offsets and other 

considerations lead to NASSCO’s decision to install the rotary concentrator/RTO systems. 

NASSCO stated that state (CA) regulations require NASSCO to use only compliant coatings in 

the spray booths, even with the add-on controls 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 operations inside the booths use 

essentially the same airless spray equipment that is used in the outdoor spraying operations at the 

facility, and the workers in the spray booths use supplied air. The whole system is designed with 

interlocks so that, if for any 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 cycle at a yard is generally slow to change, but 

a yard may do mostly new construction for a few years (which has been the case for the last few 

years at NASSCO), then the yard may switch 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 coating application over the whole piece. In such 

instances, even for new construction, the pieces that go into such 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 applied 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 Management 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 production 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 exterior hull paint removal, a procedure that 

produces less dust than granular particle blasting. 

Paint containment. Shrouds and mesh cloths are used 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 organic 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-the-art pollution control equipment. NASSCO 

received approximately $1 million of the $3.5 million necessary for this project through a 

California Air Resources Board Carl Moyer Grant." 

2.4.2 Add-On Control Vendor

Munters, the vendor that designed and supplied the rotary concentrator/regenerative 

thermal oxidizer (RTO) system at NASSCO, was contacted to discuss the NASSCO installation 

and other installations with high volume, low concentration airflows similar to those from 

shipbuilding and ship repair spray booths. 

 According to information obtained from Munters, their rotary concentrator/RTO systems 

are being used at two shipyards in the United States. One system is at NASSCO’s San Diego, 

CA facility, as discussed elsewhere. Another Munters system is being used at the Northrop 

Grumman facility in Pascagoula, Mississippi. The system at the Northrop facility controls a total 

airflow of 40,000 cfm from surface coating operations in spray booth(s). Munters indicated that 

a shipyard in Groton, Connecticut is seriously considering installing their system to control paint 

booth emissions.3 Munters also knows of a shipbuilding operation in Korea that recently 

awarded a contract to a competitor for installation of a concentrator/RTO system on paint booths 

at the facility. 

 According to Munters, their rotary concentrator/RTO systems are being used extensively 

in other industries that have high airflow volumes and low VOC concentrations (on the order of 

100 ppm). For example, Munters’ control devices are being used in the automobile painting 

industry. Airflows in the automobile painting operations can range from 30,000 to 300,000 cfm. 

For applications much greater than 50,000 cfm, Munters “gangs”, or connects, systems together.3

The Munters rotary concentrator/RTO systems are also used by the semi-conductor industry. 

Although the installations at semiconductor facilities control emissions from fabrication rooms, 

rather than surface coating operations, the airflow to be treated is similar to that from 

shipbuilding paint booths in that is it high volume (generally 10,000 - 40,000 cfm, though some 

are smaller), and the VOC concentration is relatively low. The Munters rotary concentrator/RTO 

systems are also used in the composite industry. 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 layer. Although the process creating the emissions 

is not a surface coating operation, again, the exhaust 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 concentrator/RTO systems. The 

list provides the customer name, location, flow rate, and type of application controlled. Seventy 

one of the installations, which represent 67 facilities, are described as paint/coating applications. 

It appears a wide variety of industries are represented by the paint/coating applications, including 

but not limited to automobile and truck painting, 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 telecons 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 developments 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 originally developed in 1995. 

The exhaust from spray booths in the shipbuilding and ship repair industry is generally a high 

volume, low VOC concentration airflow. Historically, treatment of such airflows was 

considered economically prohibitive, due to the extreme size of the controls and the quantity of 

fuel needed. However, add-on control systems 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 regenerative thermal oxidizers. The airflow from 

the concentrator is a much lower volume (10 percent 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 the regenerative thermal oxidizer). The reduced 

airflow, higher concentration airstream can be treated more economically by regenerative 

thermal oxidation. 

 Control systems that incorporate rotary concentrators followed by regenerative thermal 

oxidation are offered by more than one manufacturer. 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. Further, these systems are being used in a variety of 

other industries to treat high volume, low VOC concentration airflows similar to airflows from 

spray booths in the shipbuilding and ship repair industry. 
ATTACHMENT 1

INFORMATION FROM THE RACT/BACT/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)

 11
Primary 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 influence 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 Page

 12
CALIFORNIA STATEWIDE BEST AVAILABLE CONTROL TECHNOLOGY 

CLEARINGHOUSE 

BACT Determination Detail bar1q.gif

Category

Source 

Category: Spray Booth 

SIC Code 3731 

NAICS 

Code 336611 

Emission Unit Information

Manufactu

rer:

Munters 

Type:

Model: IZS-4200 RTO 

Equipment 

Descriptio

n:

Concentrator/RTO 

Capacity / 

Dimention

s

5,000 scfm 

Fuel Type Natural Gas 

Multiple 

Fuel Types

Operating 

Schedule 

(hours/day

)/(days/we

ek)/(weeks

/year)e

Continuous (24/7/51) 

Function 

of 

Equipment

Bact Information

VOC Limit 2 

VOC Limit

Units tons/yr 

VOC 

Average 

Time

VOC 

Control Add-on 

 13
Method

VOC 

Control 

Method 

Desc

VOC concentrator and RTO 

Project / Permit Information

Applicatio

n/Permit 

No.:

986868-72 

New 

Constructi

on/Modific

ation:

New Construction 

ATC Date:08-14-2008 

PTO Date:

Startup 

Date:

Technolog

y Status: BACT Determination 

Source 

Test 

Available:

No 

Source 

Test 

Results:

The equipment has not been installed to 

date. 

Facility / District Information

Facility 

Name:

NASSCO 

Facility 

Zip Code: 92113 

Facility 

County: San Diego 

District 

Name: San Diego County APCD 

District 

Contact: Arturo Gonzalez 

Contact 

Phone 

No.:

858.586.2721 

Contact EMail: Art.Gonzalez@SDCounty.ca.gov

Notes

Notes:

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.yourshipbuildingnews.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 (blasting, etc.) for Navy overall, with contact info. Also contains a lot of 

information related to corrosion prevention 

http://www.p2sustainabilitylibrary.mil/query.aspx?topic=142 Pollution Prevention Site of Navy called Joint Service 

Pollution Prevention and Sustainability Library maintained 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 Engineers. 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 AGENCIES 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 the 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 learn more about the installation. 

Mr. Gonzalez said that the five concentrator/regenerative 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 email 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 installation 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/HAP concentration into the concentrator, and would include that 

information in his email to me. He said primers and topcoats are sprayed in the booths, and that he 

would include more specifics regarding the types of paints as available, in his email. 

I asked Mr. Gonzalez if he knew of any installations at shipyards that use add-on controls to control 

HAP emissions from shipside painting operations (i.e., painting of assembled 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 abrasive blasting or welding emissions from shipside 

blasting or welding. He said that was not his area, and promised to provide the contact information 

for the San Diego APCD person to ask. 

 16
From: 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 controls, 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 specific 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 spray booth, 100’x 80’x 65’; approximately 51,200 

cfm; Flanders PrecisonAire Series 332 PA filters or equivalent; One(1) Adwest Retox 5.0 

Regenerative Thermal Oxidizer; 5,000 cfm; One(1) Zeolite Concentrator; chart 

recorder/data logger; controls 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 filters or equivalent; One(1) Adwest Retox 5.0 

 17
Regenerative Thermal Oxidizer; 5,000 cfm; One(1) Zeolite Concentrator; chart 

recorder/data logger; controls 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 

 18
Date: 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 controls by the shipbuilding and ship 

repair industry. She said that the high flowrates 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 capturing the emissions. 

Ms. Pandes Villacorte suggested I check the EPA 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 supervisor, Ms Stacey Ebiner (909) 396-2504, to 

ask her if she’s aware of any add-on controls being used at shipyards. 

 19
Date: 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 booths 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 not aware of any such installations. 

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

 20
Date: 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 systems installed on the five new spray booths at the 

NASSCO San Diego facility. 

Mr. Jensen said that to his knowledge, the only 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 company 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 systems 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 not surface coating, but rather exhaust air from 

fabrication rooms, the exhaust is high volume, low concentration (generally 10,000 – 40,000 

cfm, though could be as small as 5,000 cfm) 

• the auto painting industry. Surface coating operations 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 connect, systems together to treat the larger 

volumes of air. 

• the composite industry. Not a surface coating operation, but similar in that it involves a 

build up of resin, layer by layer. Exhaust airflows in composite industry are on the order of 

20,000 – 50,000 cfm. 

Mr. Jensen said that to get a listing of actual applications in the semi-conductor, auto painting, and 

composite industries, I should contact 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 ship 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 concentrator/regenerative thermal oxidizer units in several 

industries that have high volume, low VOC concentration airstreams, similar to shipbuilding. He 

specifically mentioned the semi-conductor, 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 compliance, 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

 22
From: <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 attached 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-Division/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 information on the shipbuilding surface coating applications.

 

NAASCO, San Diego CA

I already have some information on the NASSCO San Diego 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 (regulatory compliance, contractual obligation, etc)

3. Concentration of VOC from booth to concentrator, 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)

 23
6. Estimated capital costs (and whether 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 estimates 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 incorporate spray booth recirculation, 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 the other installations, but for right now, if you could 

supply the information above I'd be very appreciative. 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

 24
From: 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/hr APPLICATION

Firestone Building Products Bristol, CT 10,000 17000 Building Materials 

Corus Lightstrip Ijmuiden, Netherlands 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 15,000 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 Barstow, CA 14,000 22000 Paint/Coating 

Barstow Marine Corps Base Barstow, 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/hr 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 Atessa, Italy 40,000 63000 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/hr 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/hr 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 

 29
 30

ATTACHMENT 4
31
32
33
34
35
36
37
38