# 1 

# CITY OF PH ILADELPHIA

Department of Public Health

Environmental Protection Division

Air Management Services



# InterOffice Memo

To: File

From: Biji Pandisseril

Date: December 18, 2014

Subject: 8-Hour RACT Analysis for Sun Chemical - (PLID # 02052)

Introduction:

The Clean Air Act (CAA) requires that moderate (or worse) ozone nonattainment areas implement reasonably

available control technology (RACT) controls on all major sources of VOC and NOx. Philadelphia County is part

of the Philadelphia-Wilmington-Atlantic City moderate ozone nonattainment area for the 1997 8-hour ozone

NAAQS. This document presents the findings of a RACT evaluation for the 1997 8-hour ozone standard for this

facility.

Company Description:

Sun Chemical manufactures and distributes commercial printi ng ink in Philadelphia, Pennsylvania. Specifically, the

manufacturing process at the Philadelphia facility produ ces solvent-based and water- based printing ink for the

packaging industry, and middle distillate oil-based printing ink for the web publication industry.

Applicability for NOx and VOC RACT:

Sun Chemical is not a major source for Nitrogen Oxides (NOx) emission having potential NOx emissions less than

100 tons per year, the major source threshold in Philadelphi a County that is applicable to NOx RACT for the 1997

8-hour ozone NAAQS. The facility is a major source of Volatile Organic Compounds (VOC) having potential VOC

emissions is greater than 50 tons per year, the major source threshold in Philadelphia County that is applicable to

VOC RACT for the 1997 8-hour ozone NAAQS.

Process Descriptions:

Sun Chemical VOC emission sources include Manufacturing Group 140 – Conventional Blends, Manufacturing

Group 140 – Rotor Stator Production, Manufacturing Grou p 142 – Horizontal Mill Station, Manufacturing Group

141 – Ball Mill Production, and Manufacturing Group 143 – Kady Mill Production. The facility also has fugitive

emissions from underground tanks.

The Manufacturing Group 140 – Conventional Blends include 25 mixers, 3 bench-top mixers, and 2 tanks.

The Manufacturing Group 140 – Rotor Stator Production include 5 mixers.

The Manufacturing Group 142 – Horizo ntal Mill Station include 2 mixers

The Manufacturing Group 141 – Ball Mill Production include 1 ball mill

The Manufacturing Group 143 – Kady Mill Production include 4 kady mills.

# 2 

# RACT Analysis:

I. Manufacturing Group 140 – Conventional Blends

Materials processed in this area are ty pical of solvent-based inks. There ar e three processing stages involved with

this manufacturing group: raw material addition, mixing and packaging into customer ready containers.

Description:

Ink is processed in the conventional blending area using standard post mixer equipped with a radial

dispersion blade. Raw materials for each batch are manually dispensed into the mixing vessel. The vessel

is brought to the mixer for blending.

Drums of raw material are retrieved from the warehouse , covers are removed and the material is poured

into the mixing vessel. Typically, the vessel is equipped with casters and is pushed / pulled into position at

the mixer. Once homogeneous, a sample is taken to the lab for analysis. Adjustments are made to the

batch as necessary; when the mixture is approved for quality, the mixing vessel is removed from the mixer

and brought to the packaging area, where the ink is dispen sed into shipping containers.

The mixing unit is washed using a solvent compatible with the prior batch. The wash cycle is implemented

to prevent color contamination between batches.

The following were considered possible VOC controls: ve ssel covers; water-cooled vessel covers; condensers with

water-cooled vessel covers; and Raw Ma terial Dispensing – Transfer Pump.

Evaluation of Proposed Control Systems

1) Raw Material Dispensing – Transfer Pump

The addition of raw materials is conducted manually. Drums of raw material are retrieved from the

warehouse, covers are removed and the mate rial is poured into the mixing vessel.

One technique considered for raw material additions includes dispensing from a closed head drum by

using a transfer pump instead of the current practice of dispensing from an open drum.

Use of a transfer pump is technically infeasible because colored ink concentr ate and solvent residues will

cling to the inside and outside of the pump, creating potential for contamination of the product. Cleaning

of the pump would be required, which would increase net VOC emissions.

The following control options are technically feasible:

(a) Vessel Covers

The mixing operation for these manufacturing groups are characterized by short, slow speed mix

cycles and therefore are expected to gene rate a relatively minor amount of VOCs.

(b) Water Cooled Vessel Covers

Water-cooled vessel covers for the mixing stations resu lts in incrementally high er control efficiency.

(c) Condenser and Water-Cooled Vessel Covers

This technology also considered for VOC emission control technology.

Source Control Technology Baseline

Emission

VOC (tpy) VOC

Reduction

(%) VOC

Reduction

(tpy) Total

Annualized

Cost Cost

Effectiveness

($/Ton)

Blends

production Vessel Cover 11.895 35.9 4.27 $164,905 38,619

Water Cooled Cover 11.895 43.59 5.185 $348,543 67,221

Water Cooled Cover and

Condenser 11.895 47.69 5.673 $560,375 98,779

Vessel

clingage Vessel Cover 2.75 100 2.75 $164,905 59,965

Water Cooled Cover 2.75 100 2.75 $348,543 126,743

Water Cooled Cover and 2.75 100 2.75 $560,375 203,773

# 3 

# Condenser

Clean up Vessel Cover 9.15 16.67 1.525 $164,905 108,134

Water Cooled Cover 9.15 16.67 1.525 $348,543 228,553

Water Cooled Cover and

Condenser 9.15 16.67 1.525 $560,375 367,459

All of these technologies ar e determined economically unreasonable. Please see the Appendix for more details on

the calculations.

Conclusions and Recommendations:

It is recommended that the 1-hour ozone RACT in the RACT Plan Approval (PA Permit Number 51-2052) dated on

July 14, 2000 and approved by EPA as 1-hr RACT on 10 /31/01 FR 54710, still be considered to represent NOx

RACT for the 8-hour ozone standard for the Mixing -Vessel covers.

II. Manufacturing Group 142 – Rotor Stator Production

Description

The materials processed in this area will be typical of solvent based ink. There are two processing stages

involved with this manufacturing group: raw material dispensing and high speed pigment dispersion (using

post mixers with rotor stator assemblies ra ther than radial dispersion blades).

Liquid raw materials for each batch are manually dispensed into the mixing vessel. The mixing vessel is

brought to the rotor stator mixer where dry pigment powder is added at a controlled rate. As the mixture is

dispersed, the pigment particles are reduced to smaller particle sizes. The rotor stator assembly increases

the temperature of the mixture because of the “work” being performed by the mixer blades.

Once the particle size reduction cycle is complete, the vessel is removed from the mixer and is either

packaged or further processed through a horizontal mill.

Typically, a wash cycle for the mixer follows batch completion.

The following were considered possible VOC controls: vessel covers; water-cooled vessel covers;condensers with

water-cooled vessel covers; Raw Material Dispensing – Tr ansfer Pump & Vapor Vent-Back Line on Mill Discharge

Drum.

Evaluation of Proposed Control Systems

1) Raw Material Dispensing – Transfer Pump

The addition of raw materials is conducted manually. Drums of raw material are retrieved from the

warehouse, covers are removed and the mate rial is poured into the mixing vessel.

One technique considered for raw material additions includes dispensing from a closed head drum by

using a transfer pump instead of the current practice of dispensing from an open drum.

Use of a transfer pump is technically infeasible because colored ink concentr ate and solvent residues will

cling to the inside and outside of the pump, creating potential for contamination of the product. Cleaning

of the pump would be required, which would increase net VOC emissions.

2) Vapor Vent-Back Line on Mill Discharge Drum

A vapor vent-back line from the discharge drum back to the feed vessel appears technically infeasible; the

productivity will decrease as a result of the increased set-up time for each batch. This technology is

technically infeasible.

# 4 

# The following control options are technically feasible:

(a) Vessel Covers

The mixing operation for these manufacturing groups are characterized by short, slow speed mix

cycles and therefore are expected to gene rate a relatively minor amount of VOCs.

(b) Water Cooled Vessel Covers

Water-cooled vessel covers for the mixing stations resu lts in incrementally high er control efficiency.

(c) Condenser and Water-Cooled Vessel Covers

This technology also considered for VOC emission control technology.

Source Control Technology Baseline

Emission

NOx (tpy) NOx

Reduction

(%) NOx

Reduction

(tpy) Total

Annualized

Cost Cost

Effectiveness

($/Ton)

Blends

production Vessel Cover (1 hr RACT) 20.68 77.8 16.09 $10,591 658

Milling

(vapor

vent back

line) Vessel Cover 0.33 6.8 0.0225 $10,591 470,711

Vessel

Clingage Vessel Cover 0.081 100 0.081 $10,591 130,753

Clean up Vessel Cover 0.27 16.67 0.045 $10,591 235,356

All of these technologies ar e determined economically unreasonable. Please see the Appendix for more details on

the calculations.

Conclusions and Recommendations:

It is recommended that the 1-hour ozone RACT in the RACT Plan Approval (PA Permit Number 51-2052) dated on

July 14, 2000 and approved by EPA as 1-hr RACT on 10 /31/01 FR 54710, still be considered to represent NOx

RACT for the 8-hour ozone standard for the Mixing -Vessel covers.

III. Manufacturing Group 142-Horizontal Mill Station

Description

There are three processing stages involved with this manufacturing group: raw material dispensing, high

speed dispersion, and milling. The raw materials pro cessed in this area will be typical of solvent-based

inks.

Generally, the batch will be processed at the rotor stator mixer or conventional post mixer. Liquid raw

materials are weighed into a mixing vessel and the vessel is locked in position on the mixer. Pigment

powder is added at a controlled rate and the mixtur e is dispersed until the pigment particle sizes are

reduced to a degree acceptable by our quality control standards.

Upon completion of this cycle, the vessel discharge is connected by hose to the horizontal mill inlet. The

ink is processed through the mill to further reduce the pigment particle size. The mill discharges into a

clean drum which, when full, is sealed and brought to the warehouse for storage.

A wash cycle using a solvent compatible with the prior batch is implemented for the mixer following

batch completion. The wash cycle is implemented to prevent color contamination between batches.

The following were considered possible VOC controls: Ra w Material Dispensing – Transfer Pump; vessel covers;

water-cooled vessel covers; Condenser and Water-Cooled Ve ssel Covers; Vapor Vent-Back Line on Mill Discharge

Drum control technologies are identified;.

# 5 

# Evaluation of Proposed Control Systems

1) Raw Material Dispensing – Transfer Pump

Liquid raw materials for each batch are manually dispensed into the mixing vessel. The mixing vessel is

brought to the mixer where dry pigment powder is added at a controlled rate. As the mixture is dispersed,

the pigment particles are reduced to smaller particle sizes. The nature of the dispersion blade is such that

heat generation is expected to occur.

One technique considered for raw material additions includes dispensing from a closed head drum by

using a transfer pump instead of the current practice of dispensing from an open drum.

Use of a transfer pump is technically infeasible because colored ink concentr ate and solvent residues will

cling to the inside and outside of the pump, creating po tential for contamination of the product. Cleaning

of the pump would be required, which would increase net VOC emissions.

2) Vapor Vent-Back Line on Mill Discharge Drum

A vapor vent-back line from the discharge drum back to the feed vessel appears technically infeasible; the

productivity will decrease as a result of the increased set-up time for each batch. This technology is

technically infeasible.

The following control options are technically feasible:

(a) Vessel Covers

The permanently mounted non-cooled vessel covers are expected to reduce the emissions by about one

third from the uncontrolled conditions. Application f easibility will be affected to the extent that these

vessel covers will hinder the addition of pigment to the batch. A chute or similar loading device would

need to be provided to accommodate pigment add itions. The mixing tanks are required to have covers

as required by 1-hour ozone RACT determination. The facility will continue to use cover for the

mixing tanks to meet the 8-ho ur ozone RACT determination.

(b) Water-Cooled Vessel Covers

Water-cooled vessel covers represent a more aggressive control measure against VOC emissions.

(c) Condenser and Water-Cooled Vessel Covers

This technology also considered for VOC emission control technology.

Source Control Technology Baseline

Emission

NOx (tpy) NOx

Reduction

(%) NOx

Reduction

(tpy) Total

Annualized

Cost Cost

Effectiveness

($/Ton)

Blends

production Vessel Cover 2.21 35.29 0.78 $13,951 17,886

Water Cooled Cover 2.21 50.88 1.125 $27,754 24,670

Water Cooled Cover

and Condenser 2.21 50.88 1.125 $44,673 39,709

Vessel clingage Vessel Cover 0.117 100 0.117 $13,951 119,239

Water Cooled Cover 0.117 100 0.117 $27,754 237,217

Water Cooled Cover

and Condenser 0.117 100 0.117 $44,673 381,821

Milling (vapor

vent back line) Vessel Cover 1.43 93.18 1.333 $13,951 10,489

Water Cooled Cover 1.43 93.18 1.333 $27,754 20,868

Water Cooled Cover

and Condenser 1.43 93.18 1.333 $44,673 33,589

Clean up Vessel Cover 0.39 83.33 0.325 $13,951 42,926

Water Cooled Cover 0.39 83.33 0.325 $27,754 85,397

Water Cooled Cover

and Condenser 0.39 83.33 0.325 $44,673 137,455

# 6 

# All of these technologies ar e determined economically unreasonable. Please see the Appendix for more details on

the calculations.

Conclusions and Recommendations:

It is recommended that the 1-hour ozone RACT in the RACT Plan Approval (PA Permit Number 51-2052) dated on

July 14, 2000 and approved by EPA as 1-hr RACT on 10 /31/01 FR 54710, still be considered to represent NOx

RACT for the 8-hour ozone standard for the Mixing -Vessel covers.

IV. Manufacturing Group 141 – Ball Mill Production

Description

There are three stages involved w ith this manufacturing group: raw material additions, milling, and

finished product dispensing into drums ready for warehousing.

The ball mill is a sealed cylindrical container which is rotated in its horizontal axis. The function of the

ball mill is similar to the horizontal mill previously di scussed - to disperse pigment particles. The liquid

raw material and dry pigment powder are added via a chute mechanism. Once raw material additions are

complete, the ball mill is sealed and the milling cycle is initiated. Upon completion of the milling cycle,

the ink product is discharged into drum containers via a discharge pipe.

The following were considered possible VOC controls for Raw Material Dispensing – Transfer Pump; for

Dispensing of Finished Ink.

Evaluation of Proposed Control Systems

1) Raw Material Dispensing – Transfer Pump

One technique considered for raw material additions includes dispensing from a closed head drum by

using a transfer pump instead of the current practice of dispensing from an open drum

Use of a transfer pump is technically infeasible because colored ink concentr ate and solvent residues will

cling to the inside and outside of the pump, creating potential for contamination of the product. Cleaning

of the pump would be required, which would increase net VOC emissions.

2) Dispensing of Finished Ink

At completion of the mill cycle, the finished product is dispensed via a constricted opening into a clean

drum. The drum is immediately sealed and brought to the warehouse for storage or shipping.

Control equipment was not evaluated for this operation because the facility believes that this operation is

currently conducted in its simplest form and no alternative technique nor control equipment could be

applied. Therefore control options are technically infeasible.

Conclusions and Recommendations:

It is recommended that there is no identified control technology for this source.

V. Manufacturing Group 143 – Kady Mill Production

Description

The Kady Mill operation consists of three stages: raw material addition, high-speed dispersion, and

finished product dispensing into drums ready for warehousing.

The Kady Mill is a covered mixing tank with a bo ttom mounted rotor stator dispersion assembly. The

mixing tank is water-jacketed for cooling during the high speed dispersion cycle. The liquid raw material

is added via a chute mechanism. Once raw material additions are complete, the milling cycle is initiated.

# 7 

# Upon completion of the milling cycle, the ink product is discharged into drum containers via a discharge

pipe.

The following were considered possible VOC controls: Raw Material Dispensing – Transfer Pump; vessel

covers; water-cooled vessel covers;Condenser; and Dispensing of Finished Ink control technologies are

identified

Evaluation of Control Systems

The material handling techniques are similar to the Evaluation of Proposal Control Systems for Ball Mill

equipment.

1) Raw Material Dispensing – Transfer Pump

One technique considered for raw material additions includes dispensing from a closed head drum by

using a transfer pump instead of the current practice of dispensing from an open drum.

Use of a transfer pump is technically infeasible because colored ink concentr ate and solvent residues will

cling to the inside and outside of the pump, creating potential for contamination of the product. Cleaning

of the pump would be required, which would increase net VOC emissions.

2) Dispensing of Finished Ink

At completion of the mill cycle, the finished product will be dispensed via a constricted opening into a

clean drum. The drum is immediately sealed and brought to the warehouse for storage or shipping.

Control equipment was not evaluated for this operation because the facility believes that this operation is

currently conducted in its simplest form and no alternative technique nor control equipment could be

applied without generating additional emissions from wash-up solvents required to clean discharge units.

The following options are considered technically feasible:

(a) Vessel Covers

A vessel cover is standard for this equipment. Therefore, an evaluation of this option has not been

included in this report. The mixing tanks are required to have covers as required by 1-hour ozone

RACT determination. The facility will continue to use cover for the mixing tanks to meet the 8-

hour ozone RACT determination.

(b) Water Cooled Covers

Water-cooled covers appear technically feasible. In creased condensation rates are anticipated with the

use of water cooled vessel covers. .

(c) Condenser and Water-Cooled Vessel Covers

Replacing existing covers with water-cooled covers and a condenser is expected to increase VOC

removal efficiency.

Source Control Technology Baseline

Emission

NOx (tpy) NOx

Reduction

(%) NOx

Reduction

(tpy) Total

Annualized

Cost Cost

Effectiveness

($/Ton)

Candy

Mills

Production Vessel Cover 2.09 100 2.09 $56,992 27,269

Water Cooled Cover 2.09 98.9 2.07 $56,992 27,532

Water Cooled Cover and

Condenser 2.09 98.2 2.05 $56,992 27,801

Vessel

clingage Vessel Cover 1.4 100 1.4 $111,316 79,511

Water Cooled Cover 1.4 100 1.4 $111,316 79,511

Water Cooled Cover and

Condenser 1.4 100 1.4 $111,316 79,511

# 8 

# All of these technologies ar e determined economically unreasonable. Please see the Appendix for more details on

the calculations.

Conclusions and Recommendations:

It is recommended that the 1-hour ozone RACT in the RACT Plan Approval (PA Permit Number 51-2052) dated on

July 14, 2000 and approved by EPA as 1-hr RACT on 10 /31/01 FR 54710, still be considered to represent NOx

RACT for the 8-hour ozone standard for the Mixing -Vessel covers.

1 / 9 / 1 5

Edward Wiener, Chief of Source Registration Date9Emission CalculationsaEmission Factors and production rates were developed for the original 1999 VOC RACT Study. The total production rate was reduced due to removedmanufacturing groups. Emissions factors were developed from EPA emission factors using the Emission Master Program, taken froma study conducted by theNorth American Printing Ink Manufacturer’s Association (NAPIM) and an internal materialbalance investigation approved by AMS.UncontrolledProcessMaximumProduction(lbs/yr)EstimatedBatchesVOCUncontrolled(lbs)EmissionFactoraVOCControlled(lbs)EmissionFactoraVOCControlled(lbs)EmissionFactoraVOCControlled(lbs)BlendsProduction6,100,000‐0.0039lbVOC/lbinkprocessed23,7900.002515,0060.002213,4200.002012,444VesselClingage‐15,2500.3600lbVOC/batch5,4900.36005,4900.36005,4900.36005,490CleanUp‐15,2501.2lbVOC/batch18,3001.015,2501.015,2501.015,250VesselsInTransit6,100,000‐0.0001lbVOC/lbinkprocessed610‐‐‐‐‐‐BlendsProduction450,000‐0.0919lbVOC/lbinkprocessed41,3550.02049,171‐‐‐‐Milling(VaporVentBackLine)150,000‐0.0044lbVOC/lbinkprocessed6600.0041615‐‐‐‐VesselClingage‐4500.3600lbVOC/batch1620.3600162‐‐‐‐CleanUp‐4501.2lbVOC/batch5401.0450‐‐‐‐VesselsInTransit450,000‐0.0003lbVOC/lbinkprocessed135‐‐‐‐‐‐BlendsProduction650,000‐0.0068lbVOC/lbinkprocessed4,4200.00442,8600.00332,1710.00261,671Milling(VaporVentBackLine)650,000‐0.0044lbVOC/lbinkprocessed2,8600.00412,6650.00412,6650.00412,665VesselClingage‐6500.3600lbVOC/batch2340.36002340.36002340.3600234CleanUp‐6501.2lbVOC/batch7801.06501.06501.0650VesselsInTransit650,000‐0.0002lbVOC/lbinkprocessed 130‐‐‐‐‐‐141 BallMill BallMillsProduction650,000‐0.0003lbVOC/lbinkprocessed 2210.00032210.00032210.0003221KadyMillsProduction8,000,000‐0.0005lbVOC/lbinkprocessed4,1760.00054,1760.00054,1360.00054,104VesselClingage‐2,6671.1lbVOC/batch2,8001.12,8001.12,8001.12,800Total(lbs/yr) 16,650,000106,66359,75047,03745,529Total(tons/yr) 8,32553302423ProductionRatesProcessDescriptionEmissionFactorUnitsUncontrolledEmissionFactoraKadyMills143ManufacturingGroup140140142Covers WaterCooledCoversWaterCooledCoversandCondensersConventionalBlendingRotorStatorHorizontalMillsProcessMaximumProduction(lbs/yr)EstimatedBatchesUncontrolledEmissionFactoraEmissionFactorUnitsVOCUncontrolled(lbs)ControlledEmissionFactoraVOCControlled(lbs)UndergroundStorageTanks 7,013,618‐0.00024 lbVOC/lbinkprocessed 1,6830.000024 168Total(tons/yr) 3,5070.80.1FugitivesVaporVentBackLineNon‐processRelatedFugitiveEmissions102014 Cost SummaryaCost estimates were developed for the original 1999 VOC RACT Study and adjusted to2014 dollar values.The annualized capitalcost includes the cost of the control device andinstallation, mulitplied by the number of units ineach manufacturing group, annualized over five years.bFor the original RACT study, a time study was completed for each manufacturing groupto determine additional time spent to complete each batch and to clean due to theaddition of pollution controls. The study also determined additional costs from cleaning materials and cost of additional wateruse due to the addition of controls. The additionaltime required was converted into labor costs. The total added costs were multiplied by batches per year to determine annual added costs due to pollution controls.cConsumer Price Index (CPI) was obtained from Bureau of LaborStatistics 2000 and 2014 Detailed Reports, from Table 1. ConsumerPrice Index for All Urban Consumers (CPIU), unadjusted annual average for expenditurecategory is "All items" and 1982-84=100.ControlAnnualizedCapitalCostaAddedOvertimebAddedOperatingCostbAddedCleanUpCostbTotalAddedCostcMixerCovers 16,456123,879‐24,571164,905WaterCooledCovers 27,716139,364156,89224,571348,543WaterCooledCoversandCondensers 42,599154,848313,78649,142560,375VesselsInTransit 39330,969‐‐31,362MixerCovers 4,5494,778‐1,26410,591WaterCooledCovers 5,4765,3096,3581,26418,406WaterCooledCoversandCondensers 7,1615,83912,2252,52727,754VesselsInTransit 1681,061‐‐1,230VaporVentBackLineonMillDischargeDrum 2,9494,6011,060‐8,610MixerCovers 4,5495,751‐3,65113,951WaterCooledCovers 5,4766,90211,6553,65127,682WaterCooledCoversandCondensers 7,1616,90223,3107,30144,673VaporVentBack 2,9494,6011,060‐8,610VesselsInTransit 841,150‐‐1,234141 BallMillNone‐‐‐‐‐WaterCooledCovers(andVentingFlameArrestor) 3,22914,15735,8613,74556,992WaterCooledCoversandCondensers(andVentingFlameArrestor) 3,79128,31671,7227,488111,316VaporVentBackLine 7,020‐‐‐7,020ManufacturingGroup140ConventionalBlendingRotorStator140142 HorizontalMill143 KadyMillNon‐processRelatedFugitiveEmissions‐Tanks