COATINGS AND INK MANUFACTURING

Last adopted: July 17, 1991

Original Chapter adopted in 1991 (some of the information contained in this chapter may be outdated, however; the standards in this

chapter have been updated as of December 29, 2001).

1. DESCRIPTION

This chapter covers the permitting of paint, varnish, and printing ink manufacturing.

Paint manufacturing involves dispersion of pigment, mixing, blending, and grinding/milling of various ingredients. However in case of varnish, chemical reaction is initiated by heating.

Ink manufacturing involves the three processes of cooking the vehicle and adding dyes; grinding pigment into the vehicle; and replacing water in the wet pigment by ink vehicle.

2. APPLICATION CONTENTS

A. Data Forms

The following forms must be completed by the person submitting an application (these forms are used by the District to characterize the type of process, size, flow rates, abatement device, and exhaust stacks of the system):

Data Form 101B

Data Form P-105, Small Business Certification (if applicable)

Data Form G: for each of the following sources:

a. each separate pigment bulk storage area (Process code: 7014; Material code: 220 or 221; usage unit: ton)

b. each dispersing operation (dry pigment addition)

c. Grinding and Milling (Process code: 7008

d. Mixing or Blending (Process code: 7011)

e. product packaging station

f. Varnish kettle or reactor (Process code: 7073)

Data Form S (Part F): separate form for paint, varnish and ink manufacturing

Data Form C: for fuel fired varnish kettle or reactor

Data Form T: solvent storage , product storage

Data Form A: scrubbers, afterburners, condensers, and adsorbers, water spray and oil filter system.

Data Form P: emission point.

B. Additional Information/Forms

1. Narrative description of operation with process flow diagram.

2. Drawings, equipment specification, and if available manufacturer's literature.

3. Emission source test results from a source with the same or similar type of design.

4. Site plan and plot plan, with dimensions.

5. Copies of Material Safety Data Sheets (MSDS) for each chemicals.

6. Information on whether the plant is located within 1000 feet of the outer boundry of a school.

7. "Risk Assessment Analysis: Request for Information" form if a preliminary toxic risk screen analysis is required.

3. COMPLETENESS

The following items are required to make the determination:

A. All Authority to Construct and/or Permit to Operate fees must be paid

B. All data forms listed in Section 2A must be completed by the applicant. In addition, the other information requested in Section 2B must be submitted when applicable.

C. Any additional information needed to calculate Emissions.

D. Any additional information needed to complete a toxic risk assessment, if applicable.

4. REGULATIONS

Manufacturing of paint, varnish, and ink are subject to the following regulations:

Regulation 1: General Provision

Regulation 2: Permits

Regulation 3: Fees

Regulation 6: PM and Visible Emissions, applies to pigment handling operations.

Regulation 7: Odorous substances, applies to varnish or vehicle preparation if APCO gets more than 10 odor complaints within 90 days period.

Regulation 8:

Rule 5: Storage of organic solvents.

Rule 35: Coating and Ink Manufacturing.

5. ABATEMENT EQUIPMENT

A. VOC emissions from solvent handling operations can be controlled by condensers and adsorbers while emissions from varnish or vehicle reactors can be controlled by scrubbers followed by afterburners.

B. A water spray and oil filter system can also be used to reduce particulate emissions.

6. STANDARDS

A. Standards that must be met before a permit can be issued:

1. Regulation 8-35-301 (Portable Mixing Operating Requirements): Portable mixing vats shall be covered, except to add ingredients or to take samples, with lids which satisfy all of the following conditions:

a. Lids are maintained in good condition, such that when in place, they maintain contact with the rim for at least 90 percent of the circumference of the rim of the vat.

b. Lids may have a slit to allow clearance for insertion of a mixer shaft. The slit shall be covered after insertion of the mixer, except to allow safe clearance for the mixer shaft.

c. There shall be no holes, tears, or openings in the lid that would allow for the emission of organic vapors, except under the provision of Subsections (b) and (d).

d. The difference between the diameter of the mixer shaft and the diameter of the opening in the lid for the mixer shaft, shall be no greater than 5.1 cm (2 inches).

e. Polyethylene or other non-permanent covers may be used provided that the cover material is nonporous, as defined in Section 8-35-217, and the requirements of Subsections (a) through (d) are met.

f. The requirements of Subsection (a) through (d) shall not apply, if the emissions from portable and stationary mixing vats are vented to an approved emission control system that has an overall abatement efficiency of 80% or more on a mass basis. Where such reduction is achieved by incineration, at least 90% of the organic carbon shall be oxidized to carbon dioxide.

2. Regulation 8-35-303 (Portable and Stationary Cleaning): portable or stationary mixing vats, high dispersion mills, grinding mills, tote tanks and roller mills are cleaned, except as provided in Section 7, by one or more of the following methods:

a. Use a cleaning material that either contains less than 200 grams VOC (wt) per liter or is a low volatility compound, as defined in Section 8-35-216. The low volatility cleaning material shall be collected and stored in closed containers.

b. Operate a closed cleaning system that has been approved by the APCO in writing and that meets the following conditions:

- The system, including equipment being cleaned, is maintained leak free,

- Organic solvent must be drained from the cleaned equipment before the system is opened to the         atmosphere, and

- Solvent, including waste solvent, shall not be stored or disposed of in such a manner that will cause or     allow evaporation into the atmosphere.

c. Collect and vent the emissions from equipment cleaning to an approved emission control system that has an overall abatement efficiency of 80% or more on a mass basis. Where such reduction is achieved by incineration, at  least 90% of the organic carbon shall be oxidized to carbon dioxide.

d. Use organic solvents other than those allowed in Section (a) provided the following conditions are met:

- No more than 228 liters (60 gallons) of fresh solvent shall be used per month. Organic solvent that is reused or recycled (either onsite or offsite), for further use in equipment cleaning or the manufacture of coating, ink, or adhesive shall not be included in this limit.

- Organic solvent, including cleanup solvent is collected and stored in closed containers.

- Cleanup solvent records are maintained as required per Section 8-35-501.

3. Regulation 8-35-304 (Grinding Mills): Grinding mills shall have fully enclosed screens.

4. Regulation 8-35-305 (Stationary Vats): A stationary vat which emits more than 6.8 kg (15 lbs.) per day of organic compounds unless all emissions from the vat have been vented to an approved emission control system that has an overall abatement efficiency of 80% or more on a mass basis. Where such reduction is achieved by incineration, at least 90% of the organic carbon shall be oxidized to carbon dioxide.

5. Regulation 8-35-320 (Wipe Cleaning and Cleanup Solvent): The requirements of this Section shall apply to any person using solvent for wipe cleaning:

a. A person shall not use open containers for the storage or disposal of cloth or paper impregnated with organic compounds that is used for cleanup, or coating, ink, or adhesive removal.

b. A person shall not store spent or fresh organic compounds to be used for cleanup or coating, ink, or adhesive removal in open containers.

6. Regulation 6-301 (Ringelmann No. 1 Limit on): Visible emissions shall not be as dark as or darker than No. 1 on the Ringelmann Chart for more than three minutes in any hour.

7. Regulation 6-311 (General Operations): Particulate matter shall not be emitted into the atmosphere at a rate in excess of that specified in Table 1 of this regulation.

8. Regulation 7-301 (Limit on Odorous Substances at or Beyond Property Line): A person shall not discharge any odorous substance which causes the ambient air at or beyond the property line of such person to be odorous and to remain odorous after dilution with four parts of odor-free air.

B. Toxics: Source must comply with the District's Risk Management Procedure.

7. EMISSIONS

A. Emission Factors

Emission factors can be obtained from EPA Document AP-42, Compilation of Air Pollutant Emission Factors, September 1988, or later edition. AP-42 Table 5.10-1 gives emission factors for coatings manufacturing. Similarly, AP-42 Table 5.14-1 gives emission factors for ink manufacturing.

Emission factors from other EPA publications equivalent to AP-42 or from applicant/vendor source test data, using District approved methods, may also be acceptable.

B. Sample Emission Calculations

a. Paint manufacturing operation

Sample:

1. A baghouse of 99% control efficiency is used to abate emissions of particulate.

2. An afterburner of 99% control efficiency is used to abate emissions of POC.

3. The maximum annual throughputs of paint and pigment are 1,000 tons and 100 tons respectively:

POC emissions:

= 1,000 (ton/yr) x 30* (lb/ton) x (1-0 .99) /365 (day/yr)

= 0.8 lb/day

Particulate emissions:

= 0 lb/day (All emissions are attributed to the disperser)

___________

* Emission factor from AP-42 Table 5.10-1.

b. Varnish manufacturing operation

Sample:

1. A baghouse of 99% control efficiency is used to abate emissions of particulate.

2. An afterburner of 99% control efficiency is used to abate emissions of POC.

3. The maximum annual throughputs are as follows:

Type of product:

Varnish

Maximum Annual

Throughput (ton/yr)

Bodying oil

200

Oleo resinous

300

Alkyd

400

Acrylic

500

POC emissions:

= 200 (ton/yr) x 40* (lb/ton) + 300 (ton/yr)

x 150* (lb/ton) + 400 (ton/yr) x 160* (lb/ton)

+ 500 (ton/yr) x 20* (lb/ton) x (1-0.99)/365 (day/yr)

= 3.5 lb/day

Particulate emissions:

= 0 lb/day

___________

* Emission factor from AP-42 Table 5.10-1.

c. Ink manufacturing operation

Sample:

1. A baghouse of 99% control efficiency is used to abate emissions of particulate.

2. An afterburner of 99% control efficiency is used to abate emissions of POC.

3. The maximum annual throughputs are as follows:

Type of product

Maximum Annual Throughput (ton/yr)

General vehicle

200

Oils

300

Oleo resinous

400

Alkyds

500

Pigment

100

POC emissions:

= 200 (ton/yr) x 120* (lb/ton) + 300 (ton/yr)

x 40* (lb/ton) + 400 (ton/yr) x 150* (lb/ton)

+ 500 (ton/yr) x 160* (lb/ton) x (1-0.99) /365 (day/yr)

= 4.8 lb/day

Particulate emissions:

= 0 lb/day (All emissions are attributed to the disperser)

____________

* Emission factor from AP-42 Table 5.14-1.

d. Disperser

A disperser is a mixing operation in which dry pigment is added. If no dry pigment is added, the process is considered to be mixing.

1. For paint manufacturing operation

POC emissions:

= 0 lb/day (All emissions are attributed to the paint manufacturing operation)

Particulate emissions:

= 100 (ton/yr) x 20* (lb/ton) x (1-0.99)/365 (day/yr)

= 0.1 lb/day

___________

* Emission factor from AP-42 table 5.10-1.

2. For varnish manufacturing operation

POC emissions:

= 0 lb/day (All emissions are attributed to the varnish manufacturing operation)

Particulate emissions:

= 0 lb/day

3. For ink manufacturing operation

POC emissions:

= 0 lb/day (All emissions are attributed to the ink manufacturing operation)

Particulate emissions:

= 100 (ton/yr) x 2* (lb/ton) x (1-0.99) /365 (day/yr)

= 0.01 lb/day

___________

* Emission factor from AP-42 table 5.14-1.

e. Solvent storage

Please refer to the Storage Tanks chapter.

f. Product storage tank

Please refer to the Storage Tanks chapter.

g. Pigment storage area

POC emissions:

= Negligible

Particulate emissions:

= Negligible

h. Grinder/mill

Grinder/mill is used to grind and disperse coating solids.

POC emissions:

= 0 lb/day (All emissions are attributed to any one of the paint, varnish or ink manufacturing operations)

Particulate emissions:

= 0 lb/day (All emissions are attributed to the disperser)

i. Fixed mixing tank/mixing station (portable vats)

POC emissions:

= 0 lb/day (All emissions are attributed to any one of the paint, varnish or ink manufacturing operations)

Particulate emissions:

= 0 lb/day (All emissions are attributed to the disperser)

j. Product packaging station

POC emissions:

= 0 lb/day (All emissions are attributed to any one of the paint, varnish or ink manufacturing operations)

Particulate emissions:

= 0 lb/day (All emissions are attributed to the disperser)

k. Reactor/cooker

POC emissions:

= 0 lb/day (All emissions are attributed to any one of the paint, varnish or ink manufacturing operations)

Particulate emissions:

= 0 lb/day (All emissions are attributed to the disperser)

8. CONDITIONS

Operating conditions control material usage and/or emissions in order to ensure compliance with District regulations and to maintain air emissions at permitted levels.

a. Paint manufacturing operation

1. The throughput of paints shall not exceed xxx tons or gallons during any consecutive twelve month period.

2. The usage of pigment shall not exceed xxx tons during any consecutive twelve month period.

3. In order to demonstrate compliance with the above conditions, the monthly throughputs of paints and pigments shall be maintained in a District approved log. These records shall be kept on site, and made available for District inspection for a period of 24 months from the date on which a record is made.

b. Varnish manufacturing operation

1. During any consecutive twelve month period, the following throughputs shall not exceed:

i Bodying oil xxx tons

ii Oleo resinous xxx tons

iii Alkyd xxx tons

iv Acrylic xxx tons

2. In order to demonstrate compliance with the above condition, the monthly throughputs of bodying oil, Oleo resinous, alkyd and acrylic shall be recorded in a District approved log. These records shall be kept on site, and made available for District inspection for a period of 24 months from the date on which a record is made.

c. Ink manufacturing operation

1. During any consecutive twelve month period, the following throughputs shall not exceed:

i General vehicle xxx tons

ii Oils xxx tons

iii Oleo resinous xxx tons

iv Alkyd xxx tons

2. The usage of pigment shall not exceed xxx tons during any consecutive twelve month period.

3. In order to demonstrate compliance with the above condition, the monthly throughputs of general vehicle, oil, Oleo resinous and alkyd shall be recorded in a District approved log. These records shall be kept on site, and made available for District inspection for a period of 24 months from the date on which a record is made.

d. Disperser

1. Visible emissions from this source shall not exceed Ringelmann 1.

2. This source shall be covered except to add ingredients or take samples.

e. Solvent storage tank

Please refer to the Storage Tanks chapter.

f. Product storage tank

Please refer to the Storage Tanks chapter.

g. Pigment storage area

1. The operator shall keep this area clean and tidy.

h. Grinder/mill

1. This source shall have fully enclosed screens.

2. This source shall be covered except to add ingredients or take samples.

i. Fixed mixing tank, reactor or cooker

1. Visible emissions from this source shall not exceed Ringelmann 1.

2. This source shall be covered except to add ingredients or take samples.

3. This source shall not emit more than 15 lbs/day of POC and at a concentration greater than 300 ppm total carbon unless it is abated by a control device with a control greater than 90 percent efficiency

4. In order to demonstrate compliance with Condition No. 3, the operator shall perform a source test within 30 days to determine the POC emission rate and concentration or the control efficiency. The source test shall be approved by the District's Source Test Manager.

5. The operator shall receive approval from the District's Source Test Manager for installation of testing ports, platform and source testing procedures. The operator shall notify the Permit Services Division and Source Test Manager at least two weeks prior to any source test. Complete reports of source test results shall be submitted to the District's Source Test Section and Permit Services Division within 30 days of the source test.

j. Mixing station (portable vats)

1. Portable mixing vats shall be covered to satisfy the conditions as required by Regulation 8-35-301.

2. Visible emissions from this source shall not exceed Ringelmann 1.

k. Product packaging station

1. This source shall be operated in a way which minimizes the emissions of POC into the atmosphere.

9. ENFORCEMENT

Permit conditions are enforced by the inspection staff of the Enforcement Division during the start-up inspection, on-going inspection, and through record keeping by the applicant. The inspector compares the actual operation of the source to the conditions required in the permit, and to applicable regulations.

10. FEES

Per Regulation 3, the following fees are required. Please note that fees are subject to change. These fees are to serve as examples only.

A. Filing Fee: $ 167 for each source

B. Schedule F: Miscellaneous sources for

a. paint manufacturing operation

b. varnish manufacturing operation

c. ink manufacturing operation

d. disperser

e. Grinder/mill

f. Fixed mixing tank

g. Mixing station (portable vats)

h. Product package station

i. Reactor/cooker

1. Initial Fee: $117 per source

2. Permit to Operate Fee: $84 per source

3. Toxic Surcharge: The Initial Fee shall be doubled and the Permit to Operate Fee shall be raised by 10 percent if the source emits a Toxic Air Contaminant (TAC) as identified by the Air Resources Board

4. Late Fee

5. Retroactive Permit Fee

Schedule C: Stationary containers for stationary

a. solvent storage tank

b. product storage tank

1. Initial Fee: $117 per source (<100,862 gallons)

2. Permit to Operate Fee: $84 per source (<143,836 gallons)

3. Toxic Surcharge: The Initial Fee shall be doubled and the Permit to Operate Fee shall be raised by 10 percent if the source emits a Toxic Air Contaminant (TAC) as identified by the Air Resources Board

4. Late Fee

5. Retroactive Permit Fee

C. Sample calculation

Assume the paint manufacturing operation consists of the following source:

a. One paint manufacturing operation

b. One solvent storage tank

c. One product storage tank

d. One disperser

e. One Grinder/mill

f. One Fixed mixing tank

g. One Mixing station (portable vats)

h. One Product package station

Filing Fee (8 sources)

$1336

Initial Fee (8 sources)

936

Permit to Operate Fee (8 sources)

672

Toxic Surcharge (assume no TAC)

0

Late Fee

0

Retroactive Permit Fee

0

TOTAL FEES

$2944

11. TOXICS

This policy is applicable to any source that emits any identified toxic chemical listed in the Air Toxic Screening Policy. Any source that emits below its trigger level or with a risk of 1x10-6 or less is considered a nonsignificant risk. Risk screens are conducted by the Toxics Section after the District Air Quality Engineer provides the needed information to the Toxics Section evaluator. The information required for the screen is listed on the "Risk Assessment Analysis: Request for Information" form (attached).