kvEPA
United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park NC 27711
£PA-4SO/3-3O-O37b
October 1982
Air
Industrial Surface Final
Coating: Large EIS
Appliances —
Background Information
for Promulgated Standards
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EPA-450/3-80-037b
Industrial Surface Coating:
Large Appliances—
Background Information
for Promulgated Standards
Emission Standards and Engineering Division
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air, Noise, and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
October 1982
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This report has been reviewed by the Emission Standards and
Engineering Division of the Office of Air Quality Planning and
Standards, EPA, and approved for publication. Mention of trade names
or commercial products is not intended to constitute endorsement or
recommendation for use. Copies of this report are available through
the Library Services Office (MD-35), U.S. Environmental Protection
Agency, Research Triangle Park, NC 27711, or from National Technical
Information Services, 5285 Port Royal Road, Springfield, VA 22161.
Publication No. EPA-450/3-80-037b
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for
ENVIRONMENTAL PROTECTION AGENCY
Background Information
and Final
Environmental Impact Statement
Industrial Surface Coating: Large Appliances
^ Prepared by:
Don R. Goodwin
Director, Emission Standards and Engineering Division
U.S. Environmental Protection Agency
Research Triangle Park, NC 27711
(Date)
1. The promulgated standards of performance will limit emissions of
volatile organic compounds from new, modified, and reconstructed large
appliance surface coating operations. Section 111 of the Clean Air
Act (42 USC 7411), as amended, directs the Administrator to establish
standards of performance for any category of new stationary source of
air pollution which ". . . causes or contributes significantly to air
pollution which may reasonably be anticipated to endanger public
health or welfare." The States of Ohio, Illinois, Michigan, Kentucky,
Tennessee, and California would be particularly affected.
2. Copies of this document have been sent to the Office of Management and
Budget; the Federal Departments of Labor, Health and Human Services,
Defense, Transportation, Agriculture, Commerce, Interior, and Energy;
the National Science Foundation; the Council on Environmental Quality;
to members of the State and Territorial Air Pollution Program
Administrators (STAPPA) and the Association of Local Air Pollution
Control Officials (ALAPCO); to EPA Regional Administrators; and to
other interested parties.
3. For additional information contact:
Mr. Gene W. Smith
Standards Development Branch (MD-13)
U.S. Environmental Protection Agency
Research Triangle Park, NC 27711
Telephone: (919) 541-5624
4. Copies of this document may be obtained from:
U.S. EPA Library (MD-35) :
Research Triangle Park, NC 27711
National Technical Information Services
5285 Port Royal Road
Springfield, VA 22161
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IV
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TABLE OF CONTENTS
Chapter page
1.0 SUMMARY 1-1
1.1 Summary of Changes Since Proposal [ 1-1
1.2 Summary of Impacts of the Promulgated Action 1-2
1.2.1 Alternatives to Promulgated Action . 1-2
1.2.2 Environmental Impacts of Promulgated Action 1-3
1.2.3 Energy and Economic Impacts of
Promulgated Action 1-3
1.2.4 Other Considerations 1-3
1.2.4.1 Irreversible and Irretrievable
Commitment of Resources 1-3
1.2.4.2 Environmental and Energy Impacts of
Delayed Standards 1-3
2.0 SUMMARY OF PUBLIC COMMENTS < 2-1
2.1 General 2-5
2.2 Emission Control Technology 2-17
2.3 Modification and Reconstruction 2-21
2.4 Economic Impact 2-22
2.5 Environmental Impact 2-22
2.6 Energy Impact ] 2-25
2.7 Reporting and Recordkeeping 2-26
2.8 References \ 2-28
APPENDIX A—Revised Emissions Estimates ! A-l
LIST OF TABLES
Number
2-1
List of Commenters on the Proposed Standard of
Performance for Industrial Surface Coating: Appliances.
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1. SUMMARY
On December 24, 1980, the U.S. Environmental Protection Agency
(EPA) proposed a standard of performance for appliance surface coating
operations (45 FR 85085) under authority of Section" 111 of the Clean
Air Act. The Federal Register notice requested public comments on the
proposal. There were 19 commenters, most of whom were appliance
manufacturers, and the others were coating manufacturers, trade
associations, and State and Federal Government offices. Three
presentations were made at the public hearing on January 28, 1981.
Comments submitted and their responses are summarized in this docu-
ment. The bases for revisions made to the standard between proposal
and promulgation are also described in this document. !
1.1 SUMMARY OF CHANGES SINCE PROPOSAL
A number of changes have been made since proposal of this
standard. The most significant change to the regulation involved the
definition of "large appliance product." Large appliance products are
now defined as ranges, ovens, microwave ovens, refrigerators,
freezers, washers, dryers, dishwashers, water heaters, and trash
compactors. The following appliance products have been excluded from
the list of products originally proposed and will not be subject to
this regulation: range hoods, refrigerated display cases, dry
cleaning equipment, vacuum cleaners, ice makers, water softeners,
interior lighting fixtures, air purifiers, room heaters, baseboard
heaters, dehumidifiers, humidifiers, fans, furnaces, window air
conditioners, unitary air conditioners, and heat pumps.
The definition of "large appliance surface coating line" has been
changed to include only coating operations within large appliance
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assembly plants. This alteration is specifically intended to exclude
operations that coat only certain parts, such as compressors, which
are sold to a variety of large appliance manufacturers.
Definitions of "organic coating," "powder coating," and "VOC
content" were added to describe more completely the surface coatings
covered in the standard. Powder coatings have been excluded from the
definition of an "organic coating," thereby clarifying that powder
coating users are not affected by any requirement in the regulation.
Another change to the regulation involved adding an in-use
temperature cutoff to the definition of "large appliance part." This
cutoff will ensure that no high-temperature-resistant coatings, some
of which are metal-based, are unintentionally covered by this
standard.
Section 60.453 (Performance test and compliance provisions) has
been restructured in order to be more easily followed and understood.
The results of the calculations required are identical to those in the
proposed standard, but the manner and order in which they are
performed have changed. Numerous editorial changes have also been
made for ease of understanding. In addition, a provision has been
added that will allow an owner or operator to petition the
Administrator for a case-by-case determination of the transfer
efficiency of any application method not listed in the regulation.
As a result of an internal EPA reevaluation, all reporting
requirements have been deleted from this regulation. Monitoring and
recordkeeping sufficient to verify the calculation of monthly
emissions from each affected facility are required. No reports will
be made to EPA, however, except those found in the General Provisions
to 40 CFR Part 60 concerning notification and the results of the
initial performance test.
1.2 SUMMARY OF IMPACTS OF THE PROMULGATED ACTION
1.2.1 Alternatives to Promulgated Action
The regulatory alternatives are discussed in Chapter 6 of the
Background Information Document (BID) for the proposed standard.
These regulatory alternatives reflect the different emission control
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levels from which one will be selected to represent best demonstrated
technology (BDT), considering costs, nonair quality health, and
environmental and economic impacts for large appliance surface
coating. These alternatives remain the same.
1-2.2 Environmental Impacts of Promulgated Action
Environmental impacts that would be incurred under each of the
regulatory alternatives are described in Chapter 7 of the BID for the
proposed standard. These impacts remain unchanged.
1'2-3 Energy and Economic Impacts of Promulgated Action
Energy and economic impacts are discussed in Chapters 7 and 8 of
the BID for the proposed standard. These impacts are unchanged.
1-2.4 Other Considerations
1'2-4-1 Irreversible and Irretrievable Commitment of
Irreversible and irretrievable commitment of resources is described in
Chapter 7 of the BID and has remained unchanged since proposal.
1-2-4-2 Environmental and Energy Impacts of Delayed Standards.
Environmental and energy impacts are described in Chapter 7 of the BID
and have remained unchanged since proposal.
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2. SUMMARY OF PUBLIC COMMENTS
A list of commenters, their affiliations, and the IEPA docket
entry number assigned to each comment are shown in Table 2-1.
Twenty-one letters commenting on the proposed standard and the
Background Information Document (BID) for the proposed standard were
received, and three industry representatives commented at the public
hearing. Significant comments have been combined into the following
seven categories:
1.
2.
3.
4.
5.
6.
7.
General
Emission Control Technology
Modification and Reconstruction
Economic Impact
l
Environmental Impact
Energy Impact
Reporting and Recordkeeping
Comments, issues, and their responses are discussed!in the
following sections of this chapter. Changes to the regulations are
summarized in Subsection 1.2 of Chapter 1. Many written comments and
public hearing presentations fell into more than one of the above
categories, relating to the list of large appliance products to be
covered by the standard and associated economic impacts and record-
keeping requirements. These comments are addressed as part of the
"general" category to avoid duplication of comments and responses in
each of the categories.
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TABLE 2-1. LIST OF COMMENTERS ON THE PROPOSED STANDARD OF
PERFORMANCE FOR INDUSTRIAL SURFACE COATING: APPLIANCES
Docket entry number'
Commenter/affi1i ati on
IV-D-1, D-9, D-15,
F-la
IV-D-2
IV-D-3
IV-D-4
IV-D-5
IV-D-6
IV-D-7, D-17, F-lbc
IV-D-8
IV-D-10
Hayward Thomas, Senior Vice President
Broan Manufacturing Company, Inc.
Hartford, Wisconsin 53027
Walter G. Davies, Sr.
Davies Engineering Company
505 Cherokee Boulevard
Chattanooga, Tennessee 37405
C. E. Baldwin, Vice President—Manufacturing
Miami Carey
203 Carver Road
Monroe, Ohio 45050
Gary L. Ewing, Engineering Manager
Hamilton County (Tenn.) Air Pollution Control Bureau
3511 Rossville Boulevard
Chattanooga, Tennessee 37407
John M. Lipscomb, Chairman
Transfer Efficiency Committee
The Chemical Coaters Association
Post Office Box 241
Wheaton, Illinois 60187
Andrew Nogueira, Finishing Engineer
Scovill-Nutone Division
Madison & Red Bank Roads
Cincinnati, Ohio 45227
Donn W. Sanford, Executive Director, CAE
Home Ventilating Institute
4300-L Lincoln Avenue
Rolling Meadows, Illinois 60008
Steven J. Gunsel, Environmental Specialist
Nordson Corporation
Amherst, Ohio 44001
Harlan J. Lortz, Vice President—Product Safety
Amana Refrigeration, Inc.
Amana, Iowa 52204
See footnotes at end of table.
(continued)
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TABLE 2-1. (continued)
Docket entry number^
Commenter/affi]iation
IV-D-11
IV-D-12
IV-D-13
IV-D-14
IV-D-16, F-lc
IV-D-18
IV-D-19
IV-D-21
IV-H-1
Frank J. Senters, Vice President—Sales
J. Landau & Company, Inc.
Post Office Box 135, 214 Washington Avenue
Carlstadt, New Jersey 07072
Kent W. Larson, Attorney
Graco, Inc.
Post Office Box 1441
Minneapolis, Minnesota 55440
Rodney L. Pennington, Sales Manager
Boxe6nnatJ?n fnv1™™?njal Equipment Company, Inc.
Box 600, 520 Speedwell Avenue
Morris Plains, New Jersey 07950
Jim Sasser, United States Senator
United States Senate
403 Federal Office Building
Memphis, Tennessee 38103
T. H. Goodgame, Director
Corp. Environmental Control
Whirlpool Corporation
Monte Road :
Benton Harbon, Michigan 49022
Howard Baker, United States Senator
United States Senate
Washington, D.C. 20510
James F. McAvoy, Director
State of Ohio Environmental Protection Agency
Box 1049, Broad Street
Columbus, Ohio 43216
Barry L. Maiter, Attorney :
Howrey & Simon
1730 Pennsylvania Avenue, N.W.
Washington, D.C. 20006
Carl W. Penland
Director, Environmental Affairs Division
General Services Administration
Washington, D.C. 20405
See footnotes at end of table.
(continued)
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Docket entry number'
TABLE 2-1. (continued)
= ==
Commenter/affi1i ati on
IV-H-2
Lynne R. Harris
Environmental Affairs Advisor
National Institute for Occupational Safety and Health
Rockville, Maryland 20852
==3==s===========================^^
aThese designators represent docket entry numbers for Docket No. A-80-06.
These documents are available for public inspection at: US. Environmen-
tal Protection Agency, Central Docket Section, West Tower Lobby, Gallery 1,
Waterside Mall, 401 M Street, S.W., Washington, D.C. 20460.
bMr. Sanford's prepared remarks were presented at the public hearing by
Mr. Oakes.
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2.1 GENERAL
2.1.1 Comment: Several commenters said that the numerous small
appliances manufactured by the home ventilating industry should not be
covered by the appliance standard for the following reasons.
(IV-F-la, IV-F-lb) The home ventilating industry is not the same
as the large appliance industry in that different types of coatings
and application equipment are used, line speeds are generally slower
(30 to 40 feet per minute for appliances and 8 to 10 feet per minute
for home ventilating products), product size and production volume are
smaller, and transfer efficiencies are lower.
(IV-F-la, IV-D-1, IV-D-6, IV-D-9, IV-D-17) One company commented
that its range hoods are coated with a single-coat, modified alkyd
baking enamel formulated for a hot, grease-laden environment.
Specifications for this coating differ from specifications for acrylic
coatings used in the large appliance industry. Another commenter
stated that the available high-solids coatings were inadequate for
coating irregularly shaped objects like range hoods and fans.
Although much of the coating equipment used in the home ventilating
industry is similar to that used in the large appliance industry,
distinct shape differences for some parts make spinning disc
electrostatic equipment, which is common in the large appliance
industry, impractical for coating range hoods with high-solids
coatings. Compliance coatings are reasonably available for the five
major appliance colors but are not reasonably available for the other
thirteen colors and color combinations used for range hoods. (A
similar comment concerning the availability of high-solids coatings in
many colors was also received from one manufacturer of refrigerated
display cases [IV-D-21].) While approaches to the development of new,
low-solvent coatings and new, efficient application systems for home '
ventilating products show promise (waterborne and high-so,lids
coatings; exempt solvents, powder coatings, and electrodeposition
EEDP]), they are still in the experimental stage.
(IV-F-lc, IV-D-5, IV-D-9, IV-D-15a, IV-D-17) The manufacturing
environments of the large appliance and small appliance industries
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have some distinct differences, which warrant separate regulation of
their coating operations. Failure to recognize these differences will
allow unfair advantage to a few industries. Line speeds in large
appliance plants are faster, and coating operations of the two
industries are not similar. (A similar comment concerning the
differences in coating systems was also received from one manufacturer
of refrigerated display cases [IV-D-21].) Large appliance plants make
one or two products using a two-coat system, while home ventilating
plants make a wide variety of products using a single-coat system.
The coating technology is not as advanced in the small shops making
the small appliances. Small appliance application equipment, like
large appliance application equipment, will have to undergo
modification before high-solids coatings are used. However, existing
small appliance coating application equipment does not approach the
60-percent assumed average transfer efficiency for large appliances.
Often, in the home ventilating industry, parts of several
appliance products are coated on the same line. As different
standards might then exist for different products, productivity would
suffer while the line was changed to comply with whatever standards
might apply to the units being coated. If the most stringent standard
were used for all products coated on this hypothetical line, those not
covered (but coated in compliance, nevertheless) might no longer be
competitive with products made by manufacturers who did not have to
comply. Different standards might also apply to different lines
within a plant. One of the commenters (IV-D-15a) stated that because
of time constraints and limited resources he was unable to provide
complete cost information on the range hood/fan segment of the
industry, and, therefore, only noted that the model plants used in the
economic analysis are not typical of this segment of the industry.
(IV_p_lb, IV-D-3, IV-D-9, IV-D-17) Several comments dealt with
the economic impact of the proposed standard upon the manufacturers of
range hoods, fans, and other small appliances. One commenter stated
that range hoods and fans could be coated in compliance with the
0.90 kilogram of volatile organic compounds (VOCs) per liter of
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applied coating solids if cost considerations were ignored. Another
commenter stated that because of recent costly changes to comply with
existing standards and the current economic situation, neither the
industry nor its customers could afford the additional financial
burden the standard would impose. !
One commenter indicated that because of differences between the
cost of coating a large flat surface and coating products like range
hoods and household fans, the proposed regulation would add 5 percent
or more to the cost of a typical range hood. At least two companies
predict plant closures as a result of the regulation.
Cost estimates of recordkeeping and reporting requirements for
companies in the home ventilating industry ranged from $20,000 per
year for one multiplant firm to $225,000 per year for another. A
minimum of $5,000 annually per plant was estimated.
(IV-D-14, IV-0-18) The Agency proposal to reclassify fans from
miscellaneous metal parts to large appliances, reducing allowable VOC
content of complying coatings from 3 Ib/gal to 2.8 Ib/gal, is
protested because fans have different finishing requirements than do
large appliances. The fan industry has a large number of small- and
medium-sized plants that would be burdened beyond their financial
capabilities by classification in this more restricted category.
ResP°nse: Tne majority of data upon which the proposed
standard was developed pertained to the surface coating of traditional
household appliances such as ranges, microwave ovens, ovens,
refrigerators, laundry equipment, and freezers. This information is
contained in the proposed standard's BID. The decision to regulate
the manufacture of 17 other appliance products (range hoods,
refrigerated display cases, dry cleaning equipment, water softeners,
interior lighting fixtures, vacuum cleaners, ice makers, air
purifiers, baseboard heaters, room heaters, humidifiers,
dehumidifiers, fans, furnaces, window air conditioners,'unitary air
conditioners, and heat pumps) was made subsequent to development of
the majority of the background information. This decision was made
because the coating application methods appeared to be identical to
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those used in large appliance coating operations and because the
coating materials and coating performance specifications also appeared
to be similar to those used in the large appliance industry.
Therefore, there appeared to be no technical reason to exclude these
other appliance products.
Based upon the comments received, however, EPA agrees that in the
absence of additional analysis and study, it is inappropriate to
conclude that best demonstrated technology (BDT) for the manufacture
of traditional large appliances also applies to the manufacture of
these other appliances. As a result of the revaluation prompted by
these comments, the entire group of 17 other appliance products listed
above has been deleted from the standard. This is not to imply that
none of these industries can achieve the level of control required by
this standard. This or even more stringent requirements may be
appropriate in the application of best available control technology
(BACT) or lowest achievable emission rate (LAER).
2.1.2 Comment: (IV-F-lc, IV-D-16) One commenter stated, both during
the public hearing for this standard and in a subsequent letter, that
one company in its corporation uses an aluminum-based coating on gas
furnace parts that are subject to very high temperatures (1,000° F)
and may use similar coatings on certain parts of gas dryers and water
heaters. While the coating solids are inorganic, the material is
spray applied with an organic carrier that yields organic-solvent
emissions. A question exists as to whether this coating would be
considered an "organic coating." If so, it would not meet the
standard nor would any other temperature-resistant coating known to
the commenter.
Response: Although an "organic coating" was not defined
explicitly in the proposed standard, EPA considers any coating that
yields VOC emissions to be organic. For clarification, a definition
of an "organic surface coating" has been added in Section 60.451 of
the final regulation. In addition, the specific problem raised by the
commenter is corrected in the final version of the standard by
incorporating a temperature cutoff into the regulation. After several
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industry representatives were consulted,1 2 3 250° F was selected as
the cutoff because coatings required to withstand heat in excess of
this temperature are difficult, if not impossible, to formulate at the
62-percent (vol.) solids level. The coating of appliance parts that
are subject to in-use temperatures above 250° F, therefore, is not
subject to the emission limitations in this standard.
2.1.3 Comment: (IV-F-lb) One commenter stated that confusion exists
within certain segments of the industry concerning implementation and
the economic impact of the proposed standard.
Response: The source of confusion was a misunderstanding of
the proposed standard's applicability. The commenter's main concern
was that existing facilities would no longer be subject to the
reasonably available control technology (RACT) emission limit but
would now be subject to the more stringent New Source Performance
Standard (NSPS) limit. A definition of which facilities will be
affected was outlined in the proposed regulation; however, EPA has
made a special effort to explain the difference between State
RACT-based regulations fo.r existing sources and the Federal NSPS for
new sources and their applicability for modified and reconstructed
sources at the public hearing, at a meeting with member
representatives of an appliance trade association, and in correspond-
ence with industry.4 5 6
As discussed in these documents, EPA issued a series of
guidelines to the States during 1977 and 1978 to .help .them.meet the
ambient air quality standard for ozone by reducing organic-solvent
emissions from existing industrial coating operations. These VOCs are
precursors in the formation of ozone and photochemical smog. EPA
issued guidelines to the States for "miscellaneous metall parts" and
"large appliances." These guidelines for State regulations governing
existing manufacturing plants have not been changed.
This Federal NSPS would cover only new sources—those that
commenced construction, modification, or reconstruction after
December 24, 1980. Modified sources are those that have undergone a
physical or operational change that resulted in increased emissions;
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reconstructed sources are those that have had components replaced at a cost
exceeding 50 percent of the cost of a comparable new facility, and it would
be technologically and economically feasible for them to comply with the
NSPS. Sections 60.14 and 60.15 of the General Provisions to 40 CFR Part 60
provide specific conditions under which a source would become subject to
the standard because of modification or reconstruction.
2.1.4 Comment: (IV-D-9, IV-D-17, IV-F-la) One commenter expressed concern
that the proposed standard was unduly restrictive in that it did not allow
use of the "bubble concept," whereby credit for overcompliance on one line
could be used to offset noncompliance coatings on another line. Other
commenters stated that many firms manufacturing smaller appliances finished
several products on a single line.
Response: The "bubble concept" refers to application of a standard
to an entire plant rather than to separate portions of an individual plant.
The term "affected facility" refers to the particular portion of a plant to
which a standard applies. In this case, the affected facility has been
defined as a surface coating operation, which consists of a coating
application station(s), flashoff area(s), and oven. The choice of the
affected facility for any standard is based on the Agency's interpretation
of the Clean Air Act, as amended, and judicial construction of its meaning.
Under Section 111, the NSPS must apply to "new sources;" a "source" is
defined as "any building, structure, facility, or installation which emits
or may emit any air pollutant" [Section lll(a)(3)]. Most industrial
plants, however, consist of numerous pieces or groups of equipment that
emit air pollutants and that might be viewed as "sources." EPA uses the
term "affected facility" to designate the equipment, within a particular
kind of plant, that is chosen as the "source" covered by a given standard.
In choosing the affected facility, EPA must decide which pieces or
groups of equipment are the appropriate units for separate emission
standards in the particular industrial context. One major consideration in
this decision is that use of a narrower definition results in bringing
replacement equipment under the NSPS sooner. If, for example, an entire
plant were designated the affected facility, no part of the plant would be
covered by the standard unless the plant as a whole were "modified." If,
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on the other hand, each piece of equipment were designated the affected
facility, as each piece were replaced, the replacement piece would be a new
source subject to the standard. Since the purpose of Section 111 is to
minimize emissions by the application of the best demonstrated control
technology (considering cost, other health and environmental effects, and
energy requirements) at all new and modified sources, there is a
presumption that a narrower designation of the affected facility is proper.
This ensures that new emission sources within plants will be brought under
the coverage of the standards as they are installed. This presumption can
be overcome, however, if the Agency concludes that the relevant statutory
factors (technical feasibility, cost, energy, and other environmental
impacts) point to a broader definition. As shown in the BID, it is both
technologically and economically feasible to control each coating
operation. Since selecting this narrowest definition of the affected
facility would achieve the greatest emission reduction, this definition is
most consistent with the purposes of Section 111.
Two other possible definitions of the affected facility for this
standard are all prime coat (or topcoat) operations in a product line and
all prime coat (or topcoat) operations within an assembly plant. The
product line definition would have reduced the number of affected
facilities and would have permitted tradeoffs between different coatings
and application technologies. Likewise, defining all prime coating (or
topcoating) operations within a plant as the affected facility would have
reduced the number of affected facilities and, consequently, the associated
recordkeeping and compliance calculations. However, such definitions would
not necessarily result in either the use of best technology or the
minimizing of emissions from new sources. For these reasons, the Agency
has chosen each surface coating.operation as the affected facility.
The specific concern of small appliance manufacturers who finish
several products on a single line that different standards would apply to
different products on the same coating line is no longer applicable since
the manufacturers of these products are not subject to the promulgated
standard. The Agency is not aware of any large appliance manufacturers
finishing several .products on a single line who might encounter this
situation.
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2.1.5 Comment: (IV-D-10, IV-F-lb) One commenter said that the proposed
regulation has been developed and released for review on such a short time
schedule that the Home Ventilating Institute, a trade association for the
home ventilating industry, had inadequate time to research the technical
aspects and determine the economic impact. Another commenter (IV-D-10)
opposed implementation of the proposed standard at this time for the
following similar reasons:
The proposed standard was hastily put together with little
or no consultation with industry, and there was short notice
for a public hearing; and
The public comment period was less than 60 days, hardly
adequate for this proposed standard.
Response: Development of this regulation started in October 1978,
with the first industrial contacts made in November 1978. A Source
Category Survey Report (SCSR) was completed in February 1979. By
June 1980, the technical and economic information for the standard had been
reviewed within EPA and had been presented to the National Air Pollution
Control Techniques Advisory Committee (NAPCTAC). NAPCTAC is composed of
representatives from industry, State, and local air pollution control
agencies, as well as from environmental and public interest groups. A
month before the NAPCTAC meeting, drafts of the proposed regulation and
supporting documentation v/ere sent to all known interested parties for
review and comment. (Although it is impractical for EPA to verify and
contact all interested industry representatives, the Agency contacted and
visited numerous appliance manufacturers, coating manufacturers, and
equipment manufacturers during the development process. These contacts are
listed in Docket Category II. A notice to the public was also placed in
the Federal Register inviting participation at the NAPCTAC meeting.
Comments from these meetings were considered and incorporated into the
proposed standard, which was published in the Federal Register December 24,
1980. A public hearing was held January 28, 1981. Written comments were
accepted for consideration even after official closing of the comment
period February 23, 1981. EPA has determined that a public comment period
of about 60 days after proposal is appropriate and is sufficient to allow
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interested parties to participate in the rulemaking process. Therefore,
the Agency considers the time thus allowed adequate for public and
industrial participation in development of this standard.
It should also be noted that neither of the two commenters requested
an extension of the public comment period.
2.1.6 Comment: (IV-D-10) One commenter opposed implementation of the
proposed standard at this time because he considered additional regulations
unnecessary and overly burdensome and thought industry deserves to be
advised of the real need for VOC standards more stringent than those now
imposed.
Response: Standards of performance are promulgated under
Section 111 of the Clean Air Act. Section lll(b)(l)(A) requires that the
Administrator establish standards of performance for categories of new,
modified, or reconstructed stationary sources that in her judgment cause or
contribute significantly to air pollution that may reasonably be
anticipated to endanger public health or welfare. Standards of performance
prevent new air pollution problems from developing by requiring application
of the best technological system of continuous emission reduction that the
Administrator determines to be adequately demonstrated. The
1977 Amendments to the Clean Air Act added the words, "in the
Administrator's judgment," and the words, "may reasonably be anticipated,"
to the statutory test. The legislative history for these changes stresses
two points:
The Act is preventive, and regulatory action should be taken
to prevent harm before it occurs; and
The Administrator should consider the contribution of each
single class of sources to the cumulative impact of all VOC
emitters.
The 1977 Amendments to the Clean Air Act also required that the
Administrator promulgate a priority list of source categories for which
standards of performance are to be promulgated. The priority list,
40 CFR 60.16, was promulgated in the Federal Register August 21, 1979
(44 FR 49225). Development of the priority list was initiated by compiling
data on a large number of source categories from literature resources.
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Major stationary source categories were then subjected to a priority
ranking procedure using the three criteria specified in Section lll(f) of
the Act. The procedure ranks source categories on a pollutant-by-pollutant
basis. In this ranking, first priority was given to the quantity of emis-
sions, second priority was given to the potential impact on health or
welfare, and third priority was given to the mobility and competitive
nature of the source category.
In light of the considerations stated above, the Administrator found
that the large appliance coating industry is a "significant contributor."
(Applying the criteria for prioritizing such contributors, the
Administrator ranked the surface coating of large appliances 28th;of 59
source categories on the priority list.) This listing decision requires
the Agency to promulgate standards of performance for new sources in this
category.
Another study was conducted to investigate the large appliance surface
coating industry in more detail. This study resulted in development of the
BID, which specifically addressed the industry in terms of structure,
processes, and emission control techniques. The BID also described
modification and reconstruction; alternative regulatory options; and the
environmental, economic, and energy impacts that would be associated with
implementing each of the various regulatory options. During this study it
was estimated that a minor reduction in emissions would result from the
proposed regulations, primarily because of the dramatic improvements
already achieved by State regulations. However, the regulation has other
benefits in addition to reducing emissions beyond those required in State
regulations. The transfer efficiency concept incorporated in this
regulation was not included in the Control Technique Guidelines (CTG)
document. Its inclusion here is a major benefit because specifying an
emissions limit based upon a specific VOC content and transfer efficiency
automatically incorporates an equivalency provision into the regulation and
allows tradeoffs between VOC content and transfer efficiency. That is, an
operator using application equipment with a high transfer efficiency could
use a coating with a higher VOC content. Such a provision also enables the
diverse coatings and application techniques within the industry to be
accommodated by a single standard.
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Also, standards of performance establish a degree of national
uniformity, which precludes situations in which some States may attract
industries by relaxing air pollution standards relative to other States.
They improve the efficiency of case-by-case determinations of BACT for
facilities located in attainment areas and LAER for facilities located in
nonattainment areas, by providing a starting point for the basis of these
determinations. This starting point results from the process of developing
a standard of performance, which involves comprehensive analysis of
alternative emission control technologies and evaluation and verification
of emission test methods.
For these reasons, as well as for the estimated emission reduction of
several hundred tons per year, VOC emissions from large appliance surface
coating operations have been selected for regulation under an NSPS.
2.1.7 Comment: (IV-D-8) Key operating parameters of application equipment
should be checked regularly to ensure that equipment is being operated in
accordance with manufacturers' specifications. These checks could be
performed at the same time monthly determinations of VOC emissions
compliance are made. It is recommended that the Agency encourage operator
training by offering an incentive in the form of additional transfer
efficiency credits for firms that have operator training programs.
Response: Proper operation and maintenance of facilities is
required in Section 60.11(d) of the General Provisions of 40 CFR Part 60.
Although EPA certainly encourages industry to provide adequate training for
their spray equipment operators, a program that would "credit" operator
training is not within the scope of EPA's regulatory development program.
The training program's adequacy would have to be monitored, and the
implementation and enforcement requirements are considered to be excessive.
Decreases in coating use, part rejection, and maintenance are major
economic incentives for a company to implement an operator training
program. The Agency believes these reasons are sufficient to encourage
proper operation and maintenance of application equipment.
2.1.8 Comment: (IV-D-4, IV-D-11, IV-D-2) Three commenters noted that
technical requirements for surface coating of coal and wood stoves,
furnaces, and room heaters are not similar to surface coating of large
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appllcances in that high temperature requirements preclude use of
water-based coatings. High-solids coatings are also not available to meet
these performance specifications. Consequently, wood stoves, furnaces, and
room heaters should be classified as miscellaneous metal parts and products
with extreme performance characteristics and should not be covered in this
regulation.
Response: Wood stoves and direct-fired room heaters were never
intended to be included in this regulation. Although one commenter
indicated successful testing of a coating that could achieve the proposed
emission limit (IV-D-11), EPA does not have sufficient data to conclude
that such coatings have been adequately demonstrated. Because the coating
of large appliance parts exposed to extreme temperatures was not intended
to be subject to the proposed standard, the definition of large appliance
parts to be covered by this regulation has been clarified. In addition,
furnaces and room heaters have been excluded from the list of products to
be covered by this regulation.
2.1.9 Comment: (IV-F-lc) One commenter noted a typographical error in
Section 60.453 of the proposed regulation, stating that N should be equal
to or less than 0.90 kg'/£.
Response: This error is corrected in the final version of the
standard but was also corrected in 46 FR 9130, January 28, 1981.
2.1.10 Comment: (IV-H-2) One commenter stated that in Subsection 4.4 of
the BID, the first sentence should read, "Process designs in other coating
industries allow emissions to be controlled easily by the control devices,
which are usually carbon adsorption units or incinerators," not captured.
In Subsection 4.4.2, the first sentence should read "Incineration is the
most universally applicable technique for oxidizing the emission of
volatile organics from industrial processes," not reducing, because some
readers may object to the term "reducing" to describe an oxidizing process.
Response: For the first question, captured is the word and concept
EPA intends. Any control device must first capture a pollutant, at a
certain efficiency, before the pollutant can either be destroyed or
retained for reuse. For the second question, while the verb reducing is
correctly used to describe a decrease in total emissions, it can be seen
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how a reader, especially a chemist, could misinterpret the intended
meaning. The word abating might have been a better choice. The use of the
verb reducing has no implication, in this sentence, to the
physical-chemical process of oxidation-reduction. Despite this possible
misinterpretation, no problem is expected by leaving the statement as
written.
2.2 EMISSION CONTROL TECHNOLOGY
2.2.1 Comment: (IV-D-3) One commenter stated that bath and kitchen fans,
range hoods, bath cabinets, and mailboxes should not be reclassified from
metal furniture to large appliances. In most cases, these products have
different coating specifications than do large appliances.
Response: For NSPS development, bath cabinets are still classified
as metal furniture, while bath and kitchen fans and range hoods never were.
These appliances were included in the proposed standard. However, as
discussed in Subsection 2.1, several small appliances were excluded from
this standard, fans and range hoods among them. Mailboxes were not
included in either the metal furniture or appliance NSPS. However, they
are classified as miscellaneous metal parts and products in the CTG
document for existing sources.
2.2.2 Comment: (IV-D-5, IV-D-8, IV-D-12) Several commenters stated that
the proposed standard is inequitable because the concept of assumed
transfer efficiency does not account for the following parameters:
Part configuration,
Different types of coatings, •;
Different solids levels,
Different resin types,
Different charging voltages,
Flow rate,
Operator efficiency, ;
Local environmental conditions, and
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Interaction of all of the above variables with each type of
application equipment.
Two of these commenters (IV-D-12, IV-D-8) suggested that spray equipment
manufacturers have not had adequate opportunity to suggest an appropriate
means of incorporating transfer efficiency into the standard. It was
suggested that the National Spray Equipment Manufacturers Association
(NSEMA) coordinate industry responses on transfer efficiency. Exception
was taken to NSEMA not being contacted during development of this standard.
Response: EPA believes that to reflect the BDT for the large
appliance coating industry, emission limits for new sources must
incorporate the use of both high-solids coatings and relatively efficient
application equipment, but must not at the same time deny industry
flexibility to use different types of application equipment and different
coatings. For this reason, the Agency has included the key transfer effi-
ciency concept in this standard.
The commenter's claim that all the listed parameters affect transfer
efficiency is correct. However, a universally acceptable test method for
determining precise transfer efficiency under each conceivable set of
variables has not yet been developed. This means that the Agency must
either delete this crucial component of BDT or instead include in the
standard assigned transfer efficiency values that correlate at least
generally to the efficiencies of the application equipment used in the
industry. EPA has chosen the latter course. The Agency has included
values that are correlated to each piece of equipment and are sufficiently
high to ensure that, regardless of coating properties and other relevant
variables, each facility will be credited with at least the efficiency its
equipment attains with the particular coatings it applies. These transfer
efficiencies listed are based on data provided by spray equipment manu-
facturers and results of tests conducted during standard development. EPA
contacted and visited several equipment and coatings manufacturers during
the standard development process. Summaries of these contacts are
contained in Docket Category II.
Moreover, the standard provides that if the operator can demonstrate
to the satisfaction of the Administrator that other transfer efficiencies
are appropriate (e.g., due to variables such as those cited in the
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comment), the Administrator will approve their use on a case-by-case basis.
This provision ensures that a facility using equipment that achieves an
efficiency greater than that assigned by the standard Is fully credited for
the efficiency achieved.
2.2.3 Comment: (IV-D-5) The equation relating transfer efficiency to
maximum allowable VOC content is in error in that it incorrectly assumes:
A linear relationship between the pigment and the binder for
all coatings types;
An equal density for all types of pigments; and
An equal volume solids for all types of resins.
Response: The comment implies that the solids in a coating are a
mixture of components; e.g., pigments, resins, and binders, whose relative
ratio may vary from coating to coating, even if the organic-solvent content
remains constant. This variance, coupled with differing physical
properties, could result in different coatings with the same
organic-solvent content being transferred at different efficiencies. As in
the response to the previous comment, it is acknowledged that the method
used to incorporate transfer efficiency into this regulation is not
perfect. Nonetheless, the resulting improvements in equity and the
additional flexibility afforded manufacturers are seen as ample
justification to include the concept in the standard at this time.
Improved precision will be incorporated as standard test methods are
developed.
2.2.4 Comment: (IV-D-8) The case-by-case request for determining
alternate transfer efficiencies additionally burdens suppliers of
high-performance equipment who will have to prove continually that their
equipment performs better than the ratings. This will cause unnecessary
delays and additional expense. :
Response: Listed transfer efficiencies for high-performance
equipment are based on test data and data provided by equipment manufac-
turers. As discussed in the response to comment 2.2.2,: above, the values
assigned are sufficiently high that EPA is reasonably confident that each
facility will be credited with at least the efficiency its equipment
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attains. The burden of proof that equipment performs better than these
estimations must fall on the user. However, such a demonstration wi.ll only
be required once for any particular make and model of equipment and not
continually as the commenter believes.
2.2.5 Comment: (IV-D-13) One commenter noted that the potential for cost
effectiveness and overall performance of regenerative thermal oxidation
systems was not included in background documentation for the proposed
standard. A system designed by this company is said to be capable of
providing primary heat exchange efficiencies of up to 95 percent in the
thermal oxidation process. The high thermal energy recovery of this system
allows operation in a self-sustaining mode on hydrocarbon contents of from
3 to 5 percent of the lower explosive limit (LEL). Little or no additional
fuel is required. This system virtually eliminates the following problem
areas generally associated with incineration systems:
Fouling of heat transfer surfaces,
Corrosion,
Catalyst poisoning,
Secondary emissions, and
High operating costs with low-LEL gas streams.
The commenter requested clarification of the potential of regenerative
thermal oxidation systems in the documentation for the promulgated
standard.
Response: Regulatory Alternative B-III, outlined in Chapter 6 of
the BID, presents EPA's analysis of incineration of the topcoat exhaust.
The analysis reveals that this option has a signficantly greater capital
investment and an increase in energy consumption over other options.
Although the annual operating costs and energy use of a regenerative
thermal oxidation system may be lower, initial capital investment is large
compared to that for low-solvent coatings technology. Reduction in total
organic-solvent emissions realized by controlling the topcoat oven exhaust
is small because only 20 percent of these emissions are concentrated in the
oven. The remaining 80 percent of the emissions are fugitives from the
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application and flashoff areas. The small percentage of emissions
available for reduction by incineration makes any incinerator difficult to
cost justify when compared to low-solvent coatings. For this reason and
others set forth in the preamble to the proposal, EPA has decided to base
the standard on low-solvent processes, rather than on incineration.
Therefore, EPA does not consider necessary further clarification of the
potential of regenerative thermal oxidation systems in the documentation
for the promulgated standard. i
2.2.6 Comment: (IV-F-la) One commenter stated that one large company is
using powder coatings on range hoods, but in a small plant physical space
limitations make it impossible to put in a separate powder system for each
of five appliance colors. In addition, the cost of such systems would be
prohibitive.
Response: EPA has found no instances when technical considerations
demanded use of powder coatings to achieve compliance with the proposed
standard. High-solids coatings are available and can be applied at reason-
able cost. However, one commenter (IV-D-6) has stated that the
electrostatic coating techniques, commonly used in the large appliance
industry, are not technically practical for applying coatings to parts with
numerous corners, such as range hoods. For this reason and as discussed in
the response to comment 2.1.1, range hoods, fans, and similar products are
not being included in the promulgated standard.
2.3 MODIFICATION AND RECONSTRUCTION
2.3.1 Comment: (IV-F-la) One commenter expressed concern that in
modifying facilities to meet State requirements, he would also be covered
under this more restrictive Federal regulation.
Response: It is possible that when an existing facility is modified
to meet a State requirement, capital costs incurred could be large enough
to trigger reconstruction provisions of the Federal regulations, thereby
forcing compliance with the Federal requirement. The commenter was the
manufacturer of range hoods scheduled to attain compliance by January 1983
with a standard less strict than the NSPS. This State standard is based
upon the CTG-recommended emission limit for miscellaneous metal parts and
products. This was a valid concern at the time the standard was proposed.
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However, since proposal, the List of products to be covered in the standard
has been revised and manufacturers of range hoods will not be subject to
the final standard. The similarity between the CTG-recommended State
limits and the NSPS for the appliance products that will be subject to the
promulgated standard obviates this as an issue.
2.4 ECONOMIC IMPACT
2.4.1 Comment: (IV-D-4) Imposition of the proposed standard on the wood
stove industry would create economic hardships that could force discontinu-
ance of the manufacture of these devices. Therefore, wood stoves and room
heaters should not be included as products to be covered in this
regulation.
Response: Furnaces and room heaters were included in the proposed
regulation. However, it was never intended that wood stoves or
direct-fired room heaters would be included in this regulation. For
reasons discussed in Subsection 2.1, furnaces and room heaters have been
deleted from the list of appliance products covered by this regulation.
2.4.2 Comment: (IV-D-12) One commenter questioned the validity of the
cost data upon which the standard was based. (A followup telephone conver-
sation7 with the commenter revealed that the costs of concern were those
pertaining to powder application. These costs were considered too low.)
It was also requested that cost data be solicited from the industry through
NSEMA for additional analysis.
Response: Data for the cost analysis were obtained from a number of
different industrial sources, including appliance manufacturers, coating
manufacturers, and application equipment manufacturers. These data are
available in Docket Subcategory II-D. EPA predicts NSEMA data would be
from the same basic sources. No additional analyses have been performed as
a result of this comment'because the use of powder coating was not selected
as the basis for the standard. Therefore, an understatement of powder
costs would not generate erroneous conclusions regarding the standard's
economic impact.
2.5 ENVIRONMENTAL IMPACT
2.5.1 Comment: (IV-D-5) One commenter stated that increased use of
high-solids coatings will lead to entrapment of increased quantities of
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solids in the spray booth wash water regardless of transfer efficiency,
while another commenter (IV-D-8) stated that increased transfer efficiency
will directly reduce solid waste generation regardless of solids content.
Response: The quantity of solids in overspray depends solely upon
the transfer efficiency of the application equipment. As used in this
regulation, transfer efficiency is defined as the ratio of the amount of
coating solids deposited onto the surface of an appliance part or product
to the total amount of coating solids used. Use of increased transfer
efficiency as a means of compliance will therefore decrease the solid waste
generated.
If compliance is to be attained by increasing the solids content of
the coating, the relationship is not as direct. Information obtained
subsequent to proposal8 indicates that the transfer efficiency for a given
piece of application equipment may vary somewhat with differing solids
contents. This is more apparent at levels of solids in excess of
70 percent by volume. It is the Administrator's judgment, however, that
within a realistic range of solids contents (30 to 76 percent [vol.]), the
quantity of solids not applied to a coated object (i.e., overspray) that
may become entrapped in spray booth wash water depends to a greater extent
upon the relative efficiencies of families of application equipment (i.e.,
transfer efficiency) than upon the solids content of the coatings.
2.5.2 Comment: (IV-D-8) One commenter stated that the generic
classifications of equipment in Table 2-1 (Section 60.453) are poorly
defined and inappropriate. The Agency's listing of transfer efficiencies
for generic equipment will encourage the use of lower priced, inferior
equipment that does not perform as well as the Agency has indicated. The
listing will also discourage use of equipment that presently exceeds listed
values, since added credit may be difficult to obtain. For this reason,
the Agency's estimates of emission reductions are overstated and the
objectives will not be met. The commenter suggested that a standardized
test method be adopted to determine transfer efficiency. Equipment could
then be "certified" by the manufacturer and a list of equipment ratings and
operating conditions could be supplied to EPA for publication. The
equipment operator should be required to use these published transfer
efficiencies to determine compliance.
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Response: The promulgated standard will significantly benefit the
users of equipment that has a high transfer efficiency because of the
flexibility of coating selection that it will afford. Incorporation of the
transfer efficiency concept in this proposed standard is one of the main
improvements over the earlier RACT guidelines and existing State reg-
ulations because the existing regulations do not give credit for transfer
efficiency. This regulation includes a provision by which an owner or
operator may request approval by the Administrator to use a transfer
efficiency higher than those listed in the regulation. Additionally, the
regulation provides that transfer efficiencies for application methods not
included in the regulation will be determined by the Administrator on a
case-by-case basis.
EPA recognizes that the actual transfer efficiency achieved in
production line situations depends on a large number of variables. It was
this difficulty in determining transfer efficiency values that caused EPA
to use the table of assigned numbers. Any improvement in the efficiency at
which coatings are applied will benefit both the EPA's goal of reducing VOC
emissions and the industry's goal of achieving more economical operation.
A more detailed listing of transfer efficiency values would require a
uniform test method for all situations. Such a method has not yet been
developed but is under investigation by EPA's Industrial Environmental
Research Laboratory (IERL). The Agency does not believe the listed
transfer efficiencies will promote the use of inferior equipment because
operating cost advantages, such as decreased coating usage, will dictate
the use of efficient equipment and encourage its proper operation.
2.5.3 Comment: (IV-H-2) The stated particle size classes of powder
coatings (page 3-14 of the BID [Industrial Surface Coating:
Appliances—Background Information for Proposed Standards,
EPA-450/3-80-037a]) do not appear to represent a respirable dust hazard.
However, fine autogenously produced dusts may pose a health hazard if they
contain toxic pigments such as lead or chromate. Also, as noted in the
BID, for powder coatings there are potential VOC emissions from the curing
process. It is unfortunate that EPA did not obtain sampling data from this
process or other processes. EPA and the National Institute of Occupational
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Safety and Health (NIOSH) are both interested in paint and coating
operations, with few apparent mutual benefits from field studies by either
party alone.
Response: As noted on page 3-15 of the BID, the potential VOC
emissions from powder coatings are post-application emissions that can
occur during the heat merging of powder particles in the oven. Data
concerning these emissions are limited, but no evidence indicates that the
quantity of these emissions is significant. Powder coatings, therefore,
have been exluded from all requirements in the promulgated regulation.
Contact with a major manufacturer of appliance powder coatings subsequent
to proposal9 indicates that all of these coatings either are or very soon
will be lead and chromate free. Data for all organic-solvent emissions
were calculated by mass balance, an accurate, accepted method for compounds
that completely evaporate during a process. Use of this method precluded
the need for emissions tests, and, therefore, sampling data were not
obtained.
2.6 ENERGY IMPACT
2.6.1 Comment: (IV-D-5) One commenter took exception to EPA's conclusion
that the reduced air flow rates used in ovens where waterborne coatings are
cured would save energy. The commenter stated that increased energy usage
would result from using waterborne coatings, compared to conventional
organic-solvent-borne coatings.
Response: Energy required to evaporate solvent (whether water or
organic) amounts to less than 10 percent of the total energy used within
the large appliance surface coating industry. Some debate continues within
the industry over the energy savings attributable to waterborne coatings.
EPA's conclusion that an energy reduction would result is based upon the
fact that less airflow would be required to maintain oven concentrations of
organic-solvents below 25 percent of the LEL for waterborne coatings.
Control of relative humidity to ensure proper curing of the coating was not
considered in the analysis but likely could require increased, rather than
decreased, airflow and require proportionally more energy than
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solvent-borne coatings. Any error introduced by this oversight, however,
is minor and would not invalidate the general conclusions reached
concerning energy usage.
2.7 REPORTING AND RECORDKEEPING
2.7.1 Comment: (IV-D-8) Powder coating systems should be declared in full
compliance, with no requirements for reports and recordkeeping.
Response: Powder coating systems for large appliances are excluded
from the promulgated standard.
2.7.2 Comment: (IV-D-10, IV-F-lb) One commenter expressed concern over
the time a facility would need for recordkeeping and reporting to determine
monthly compliance as proposed in the regulation and stated that an added
overhead burden would be placed on the industries that would ultimately be
passed on to the consumer. Another commenter estimated that it would
probably require 1 person per year at each affected plant, considerably
more than estimated in the preamble.
Response: The requirement to report violations of monthly
compliance tests has been removed since proposal. In the preamble to the
regulation it was estimated that in the fifth year of applicability the
promulgated regulation would apply to 160 affected facilities and over
these 5 years require about 40 industry person-years for recordkeeping and
reporting. This amounts to about 1 person-month per affected facility per
year.10 (Because all reporting requirements except for the initial
performance test results have been eliminated from the standard, and
because of the requirement to estimate the Agency resources needed for
observing performance tests and for litigation, the Reports Impact Analysis
has been revised since proposal. It is now estimated that the industry
burden for recordkeeping and reporting will be 28 person-years over the
first 5 years of applicability.) Information a manufacturer needs to keep
on a day-to-day basis to determine compliance with this standard includes
volume of coating used and volume of dilution solvent used. These data are
normally kept by companies to provide adequate stock room balances of
needed supplies. The other item of information needed to determine
compliance, the fraction of solids in the coating, can be obtained from the
coating manufacturer. The recording of these data is important to both the
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owner/operator and to EPA to determine that the source is in compliance.
EPA considers the lower time estimates in the Reports Impact Analysis to be
reasonably accurate. Therefore, the Agency does not consider the record-
keeping, which is necessary to determine compliance, an unreasonable
burden.
2.7.3 Comment: (IV-D-9) If range hoods and fans are included in the
regulation, recordkeeping and reporting requirements will cost one company
in excess of $20,000 per year and will require the hiring of a fulltime
employee for the job.
Response: Based on information provided by manufacturers, which has
been discussed in previous sections, range hoods and fans are being
excluded from the promulgated standard. Therefore, the comment does not
warrant further consideration. However, EPA has determined the costs and
person-hours to be significantly lower than those stated by the commenter.
2.7.4 Comment: A comment received during development of another surface
coating standard that is considered applicable to large appliance surface
coating indicated that the 10-calendar-day period within which violations
of the standard must be reported was insufficient to permit the
coordination and clearances required to notify EPA that a violation has
occurred.
Response: As a result of this comment and others, EPA has been
investigating alternative ways of reducing monitoring, recordkeeping, and
reporting burdens on owners and operators. The goal is to reduce all
recordkeeping and reporting not essential to determining compliance or to
ensuring proper operation and maintenance. After reviewing requirements in
the proposal, EPA determined that monthly compliance tests, monitoring, and
compilation of monitoring data are essential for both the owner or operator
and EPA to determine compliance and to ensure proper operation and
maintenance. A responsible owner or operator would need monitoring
information compiled in a usable form to determine when adjustments in the
control system are needed to ensure that it is performing at its intended
effectiveness level.
EPA is therefore requiring only the additional step of filing the
information in an accessible location. Because EPA judges that monthly
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compliance tests, monitoring, and recordkeeping are essential for
determining compliance and proper operation and maintenance, these
requirements have not been changed since proposal. It was judged, however,
that reporting is not essential to EPA. In addition, when States are
delegated the authority to enforce this standard, they may prefer either
not to have reporting or to have reporting on a different schedule than EPA
proposed. Therefore, the requirement to report violations of the standard
and quarterly incineration reports has been removed since proposal. A
State, however, at any time is free to impose its own reporting
requirements in conjunction with this regulation.
2.8 REFERENCES
1. Letter from Daum, K. A., Research Triangle Institute, to Bill Anthony,
Glidden Coatings and Resins Company. May 5, 1981. Enclosing telecon
regarding a proposed method to exclude high-temperature-resistant
coatings from the large appliance surface coating standard. (Docket
Entry IV-E-3.)
2. Letter from Daum, K. A., Research Triangle Institute, to Norm Emily,
General Electric Company. May 5, 1981. Enclosing May 1 telecon for
confirmation or correction of contents. (Docket Entry IV-E-4.)
3. Letter from Daum, K. A., Research Triangle Institute, to
T. H. Goodgame, Whirlpool Corporation. May 7, 1981. Enclosing May 7
telecon for confirmation or correction of contents. (Docket Entry
IV-E-5.)
4. Letter from Tabler, S. K., Standards Development Branch, U.S.
Environmental Protection Agency, to H. Thomas, Broan Manufacturing
Company, Inc. February 3, 1981. Followup of post-public hearing
discussion. (Docket Entry IV-C-6.)
5. Letter from McCrodden, B. J., Research Triangle Institute, to
D. W. Sanford, Home Ventilating Institute. February 3, 1981.
Enclosing questions concerning impact of proposed standards on the
industry. (Docket Entry IV-C-7.)
6. Transcript of Public Hearing, Standards of Performance for New
Stationary Sources: Appliance Surface Coating. U.S. Environmental
Protection Agency. Research Triangle Park, North Carolina.
January 28, 1981. (Docket Entry IV-F-1.)
7. Letter from McCrodden, B. J., Research Triangle Institute, to
M. Miller, Graco, Inc. April 23, 1981. Enclosing March 27 telecon
for confirmation or correction. (Docket Entry IV-E-2.)
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8. Letter from McCrodden, B. J., Research Triangle Institute, to
R. M. Acker, Ransburg Electrostatic Equipment Corporation. August 11,
1981. June 16, 1981, telecon regarding relationship of coating solids
content and transfer efficiency. (Docket Entry IV-E-11.)
9. Letter from McCrodden, B. J., Research Triangle Institute, to R. F.
Parrel!, Glidden Powder Coatings. July 15, 1981. Enclosing June 19,
1981, telecon regarding heavy metals in powder coatings. (Docket
Entry IV-E-10.)
10. Reports Impact Analysis: Appliance Surface Coating Operations. U.S.
Environmental Protection Agency. September 1980. (Docket Entry
II-1-20.)
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APPENDIX A
REVISED EMISSIONS ESTIMATES
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APPENDIX A—REVISED EMISSIONS ESTIMATES
A.I INTRODUCTION
At the time emissions estimates for the proposed standard were
prepared, State Implementation Plan (SIP) regulations were being
revised for localities considered to be nonattainment areas for
achieving the National Ambient Air Quality Standard (NAAQS) for ozone.
Most existing large appliance manufacturing plants are located in such
areas, and it was expected that new facilities would locate in similar
areas. In revising their SIPs, most States were relying upon the
Control Techniques Guidelines (CTG) Document, Control of Volatile
Organic Emissions from Existing Stationary Sources—Volume V: Surface
Coating of Large Appliances (EPA-450/2-77-034[CTG]). It appeared that
most States were adopting the CTG recommendations statewide, in
attainment as well as in nonattainment areas. For this reason, no
distinction was made between the "no additional regulation"
alternative and the alternative eventually selected as best
demonstrated technology (BDT). Both were based upon 62 percent (vol.)
solids coatings, and the transfer efficiency incorporated into the BDT
alternative was an estimate of the average transfer efficiency
actually achieved in the industry. Therefore, in the documents
supporting the proposed standard, the emissions reduction attributable
to the New Source Performance Standard (NSPS) was reported as
"minimal." Full documentation of the original estimates is contained
in the Background Information Document (BID) for the proposed
standard, Industrial Surface Coating: Appliances—Background
Information for Proposed Standards (EPA-450/3-80-037a).
Now that the majority of SIP revisions have been approved, it is
possible to refine the emissions estimates. This study was prompted
by the realization that fewer States than originally expected have
A-2
-------
adopted the CTG- recommended emission limit in attainment areas as well
as in nonattainment areas. To the extent possible, the format used
here parallels that used in the BID for the proposed standard so
comparisons can be made easily.
It was first necessary to determine regulations in existence or
scheduled to be implemented prior to 1986 in order to determine the
fraction of large appliance manufacturing plants that would be subject
to more stringent emission limits as a result of NSPS. Assuming new
plants will be geographically distributed in the same manner as are
existing plants, it is then possible to estimate the impact of NSPS.
A list of 104 major household appliance manufacturing plants was
developed based on the 1981 "Who's Who in The Industry" ^from Appliance
magazine,1 supplemented with knowledge of individual plants acquired
during standard development. The list, together with the applicable
State regulation, is included as Annex 1 to this appendix. State
emission limits were obtained primarily from an EPA summary of
volatile organic compound (VOC) reasonably available control
technology (RACT) regulations* and examination of individual State
regulations, where needed.
Of the 104 listed major household appliance manufacturing plants,
68 are located in nonattainment areas. Of the 36 remaining, 25 are
(or would be if they were new) subject to regulation at least as
strict as the CTG- recommended limit of 2.8 pounds of VOC per gallon of
coating (minus water).* Thus, 89 percent of known existing plants are
(or would be if they were new) subject to the CTG- recommended limit.
Assuming, as we do, that the industry average transfer efficiency is
60 percent, the CTG- recommended limit approximates the NSPS limit of
0.90 kilogram of VOC per liter of applied coating solids.t In
flall°n
is
fThe difference between the two levels results because the transfer
efficiency dictated by the NSPS is the minimum that can be used with a
coating of that given solids content; e.g., a 62-percent (vol ? solid?
coating would require at least a 60-perce^ transfer e??iciency T e
average transfer efficiency will, therefore, be somewhat higher than the
mqireL The differ*nce between ^e CTG- recommended limH an the
is, however, considered minimal.
A-3
-------
addition to assuming the new plants will be geographically distributed
in the same manner as existing plants are, the revised estimates are
based on assumptions that:
Plants brought under the NSPS because of^modification or
reconstruction provisions also will be similarly
distributed, and
All plants are of equal size.
The effect of these assumptions is that the baseline from which the
NSPS emissions impact is measured is the average State regulation
weighted in proportion to the number of existing plants subject to
each regulation. For example, the 1981 estimate assumes that
89 percent of all production is subject to the CTG/NSPS limit and that
the remaining 11 percent is completely uncontrolled.
Revised annual VOC emissions estimates are shown in Table A^l.
Only the appliance products that will be subject to the final standard
are included. Annual production estimates also have been updated from
those in the BID for the proposed standard. For comparison, these new
estimates have been superimposed on a graph of the comparable, earlier
estimates (see Figure A-l).
A.2 COMMENTS/ANALYSIS
When the accuracy of these estimates is assessed, the following
facts should be considered. The impact of the NSPS may be more than
that calculated because commercial appliances will be subject to the
standard but were not included in the production figures. The
following three factors, however, would have the opposite effect. The
impact may be overstated because plants were assumed to meet the
emission limit exactly, whereas some plants actually use technologies,
such as powder, that yield substantially fewer emissions. Also,
emissions for uncontrolled plants were based on 30 percent (vol.)
solids coatings and a 50-percent transfer efficiency. The assumption
is that a new plant would select the same coating system if there were
no air pollution regulations. This may not be true, however.
Partially as a result of the pressure of air pollution regulations but
also because of petroleum-based economic pressures, improvements have
A-4
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Original
estimate
Revised
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With NSPS
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1976
1981
1986
Figure A-1. Combined annual emissions (prime coat and topcoat)
for large appliance surface coating operations.
A-6
-------
been made in coatings and application methods that might supplant the
30-percent solids, 50-percent transfer efficiency base case. The
third factor is the validity of the presumption that all growth
between 1981 and 1986 will occur in plants subject to the NSPS. There
is considerable unused capacity in the appliance industry and, to the
extent that growth will be accommodated through increased use of
existing capacity, the emissions reduction attributable to the NSPS
may be overstated.
A.3
1.
3.
4.
REFERENCES
A Portrait of the U.S. Appliance Industry—1981.
September 1981.
Appliance.
Capone, Stephen V., Richard M. Rehm, Andrea M. Kiddie, and
David C. Misenheimer. Status Summary of State's Group I VOC RACT
Regulations as of June 1, 1981; Second Interim Report. GCA
Corporation. Bedford, Massachusetts. (Prepared for U.S. Office
of Air Quality Planning and Standards, U.S. Environmental
Protection Agency. Research Triangle Park, North Carolina.)
July 1981. 183 p.
Statistical Review. Appliance. April 1980. }
Stevens, James, and David E. Simpson. Twenty-Ninth Annual
Forecasts. Appliance. January 1981.
A-7
-------
ANNEX 1—MAJOR HOUSEHOLD APPLIANCE MANUFACTURING PLANTS
Absocold Corporation
Richmond, Indiana (Wayne County - 2.8 Ib/gal for new sources over 25
TPY)
Admiral Division of Magic Chef, Inc.
Galesburg, Illinois (Knox County) - 2.8 Ib/gal)
Amana Refrigeration, Inc.
Amana, Iowa (Iowa County - no standard)
Amana Refrigeration, Inc.
Fayetteville, Tennessee (Lincoln County - 2.8 Ib/gal)
American Appliance Manufacturing Corporation
Santa Monica, California (Los Angeles County [nonattainment] -
2.8 Ib/gal)
Anaheim Manufacturing Company
Anaheim, California (Orange County [nonattainment] - 2.8 Ib/gal)
Anetsberger Brothers, Inc.
Northbrook, Illinois (Cook County [nonattainment] - 2.8 Ib/gal
Athens Stove Works
Athens, Tennessee (McMinn County - 2.8 Ib/gal)
Bock Corporation
Madison, Wisconsin (Dave County [nonattainment] - 2.8 Ib/gal)
Bradford-White Corporation
Middleville, Michigan (Barry County [nonattainment] - 2.8 Ib/gal)
Broan Manufacturing Company, Inc.
Hartford, Wisconsin (Washington County - 2.8 Ib/gal)
Broan Manufacturing Company, Inc.
Old Forge, Pennsylvania (Lackawanna County [nonattainment] - 2.8 Ib/gal)
Brown Stove Works, Inc.
Cleveland, Tennessee (Bradley County [nonattainment] - 2.8 Ib/gal)
A-8
-------
Caloric Corporation
Topton, Pennsylvania (Berks County [nonattainment] - 2.8 Ib/gal)
Chambers Corporation
Oxford, Massachusetts (LaFayette County - no standard)
Charmglow Products
Bristol, Wisconsin (Kenosha County [nonattainment] - 2.8 Ib/gal)
Columbus Products Company
(While Consolidated Industries) Columbus, Ohio (Franklin County
[nonattainment] - 2.8 Ib/gal)
Design and Manufacturing Corporation
Connersville, Indiana (Fayette County - 2.8 Ib/gal for new sources over
25 TPY)
Design and Manufacturing Corporation
Richmond, Indiana (Wayne County - 2.8 Ib/gal for new sources over 25
TPY)
Dwyer Products Corporation
Michigan City, Indiana (La Porte County - 2.8 Ib/gal for new sources
over 25 TPY)
Emerson Quiet Kool Corporation
Woodbridge, New Jersey (Middlesex County [nonattainment] - 2.8 Ib/gal)
Franklin Manufacturing Company
(White Consolidated Industries) St. Cloud, Minnesota (Benton County -
no standard)
GR Manufacturing Company
(White Consolidated Industries) Grand Rapids, Michigan (Kent County
[nonattainment] - 2.8 Ib/gal)
General Electric Company
Laundry and Dishwasher Products Division, Appliance Park, Kentucky
(Jefferson County [nonattainment] - 2.8 Ib/gal)
General Electric Company
Range Products Division, Appliance Park, Kentucky (Jefferson County
[nonattainment] - 2.8 Ib/gal)
General Electric Company
Refrigeration Products Division, Appliance Park, Kentucky (Jefferson
County [nonattainment] - 2.8 Ib/gal)
General Electric Company
Bloomington, Indiana (Monroe County - 2.8 Ib/gal for new sources over 25
TPY)
A-9
-------
General Electric Company
Cicero, Illinois (Cook County [nonattainment] - 2.8 Ib/gal)
General Electric Company
Columbia, Maryland (Howard County [nonattainment] - 2.8 Ib/gal)
General Electric Company
Decatur, Alabama (Morgan County [nonattainment] - 2.8 Ib/gal)
General Electric Company
Milwaukee, Wisconsin (Milwaukee County [nonattainment] - 2.8 Ib/gal)
The Glass-Lined Water Heater Company
Cleveland, Ohio (Cuyahoga County [nonattainment] - 2.8 Ib/gal)
Glenwood Range Company
(Caloric Corporation) Delaware, Ohio (Delaware County [nonattainment]
2.8 Ib/gal)
Gray & Dudley Company
Nashville, Tennessee (Davidson County [nonattainment] - 2.8 Ib/gal)
Greenville Products Company
(White Consolidated Industries) Greenville, Michigan (Montcalm County
[nonattainment] - 2.8 Ib/gal)
Hardwick Stove Company
(Maytag) Cleveland, Tennessee (Bradley County [nonattainment] -
2.8 Ib/gal)
Hobart Corporation
Louisville, Kentucky (Jefferson County [nonattainment] - 2.8 Ib/gal)
Hobart Corporation
Mt. Sterling, Kentucky (Montgomery County - 15% [wt.] net VOC input—
assumed to be 2.8 Ib/gal)
The Hoover Company
North Canton, Ohio (Stark County [nonattainment] - 2.8 Ib/gal)
Hoyt Heater Company of Northern California
Oakland, California (Alameda County [nonattainment] - 2.8 Ib/gal)
Hussman Refrigerator Company
Fremont, California (Alameda County [nonattainment] - 2.8 Ib/gal)
Indesit, Inc.
Harriman, New York (Orange County [nonattainment] - 2.8 Ib/gal)
Independent Refrigeration Manufacturers
Millstadt, Illinois (St. Clair County [nonattainment] - 2.8 Ib/gal)
A-10
-------
In-Sink-Erator Division
(Emerson Electric Company) Racine, Wisconsin (Racine County
[nonattainment] - 2.8 Ib/gal)
W. L. Jackson Manufacturing Company, Inc.
(Bradford-White Corporation) Chattanooga, Tennessee (Hamilton County
[nonattainment] -2.8 Ib/gal)
Jenn-Air Corporation
Indianapolis, Indiana (Marion County [nonattainment] - 2.8 Ib/gal)
Litton Microwave Cooking Products
Minneapolis, Minnesota (Hennepin County - no standard)
Litton Microwave Cooking Products
Sioux Falls, South Dakota (Minnehaha County - no standard)
Lochinvar Water Heater Corporation
Nashville, Tennessee (Davidson County [nonattainment] - 2.8 Ib/gal)
Magic Chef Microwave Division
Anniston, Alabama (Calhoun County - 2.8 Ib/gal)
Magic Chef, Inc.
Cleveland, Tennessee (Bradley County [nonattainment] - 2.8 Ib/gal)
Magic Chef West
Los Angeles, California (Los Angeles County [nonattainment] - 2.8 Ib/gal)
Mansfield Products Company ;
(White Consolidated Industries) Mansfield, Ohio (Richland County
[nonattainment] - 2.8 Ib/gal)
The Maytag Company
Newton, Iowa (Jasper County - no standard)
Modern Maid Company
Chattanooga, Tennessee (Hamilton County [nonattainment] - 2.8 Ib/gal)
Monarch Range and Heater Division i
(Malleable Iron Range Company) Beaver Dam, Wisconsin (Dodge County -
2.8 Ib/gal)
Mor-Flo Industries, Inc.
Johnson City, Tennessee (Washington County - 2.8 Ib/gal)
Norcold, Inc.
(Stolle Corporation) Sidney, Ohio (Shelby County [nonattainment] -
2.8 Ib/gal)
Norge Division of Magic Chef
Herrin, Illinois (Williamson County [nonattainment] - 2.8 Ib/gal)
A-11
-------
Northland Refrigeration Company
Greenville, Michigan (Montcalm County [nonattainment] - 2.8 Ib/gal)
Northern Metal Specialty Division
(Western Industries) Osceola, Wisconsin (Polk County - 2.8 Ib/gal over
100 TPY potential)
Panasonic Company
(Matsushita Electric Corporation of America) Secaucas, New Jersey
(Hudson County [nonattainment] - 2.8 Ib/gal)
Philco International Corporation
Blue Bell, Pennsylvania (Montgomery County [nonattainment] - 2.8 Ib/gal)
Premier Stove Company
Belleville, Illinois (St. Clair County [nonattainment] - 2.8 Ib/gal)
Rangaire Corporation
Cleburne, Texas (Johnson County - no standard)
Revco, Inc.
(Magic Chef) Willisten, South Carolina (Richland County - 2.8 Ib/gal)
Reynolds Products, Inc.
Schaumburg, Illinois (Du Page County [nonattainment] - 2.8 Ib/gal)
Rheem Manufacturing Company
Chicago, Illinois (Cook County [nonattainment] - 2.8 Ib/gal)
Rheem Manufacturing Company
Montgomery, Alabama (Montgomery County - 2.8 Ib/gal)
Riccar America Company
Costa Mesa, California (Orange County [nonattainment] - 2.8 Ib/gal)
Roper Corporation
Kankakee, Illinois (Kankakee County [nonattainment] - 2.8 Ib/gal)
Roper Corporation
LaFayette, Georgia (Walker County - 2.8 Ib/gal)
Roper Corporation
Chattanooga, Tennessee (Hamilton County [nonattainment] - 2.8 Ib/gal)
Sanyo E & E Corporation
San Diego, California (San Diego County [nonattainment] - 2.8 Ib/gal)
Sanyo Electric, Inc.
Little Ferry, New Jersey (Bergen County [nonattainment] - 2.8 Ib/gal)
Sharp Manufacturing Company of America
Memphis, Tennessee (Shelby County - 2.8 Ib/gal)
A-12
-------
A. 0. Smith Corporation
Kankakee, Illinois (Kankakee County [nonattainment;] - 2.8 Ib/gal)
A. 0. Smith Corporation
Seattle, Washington (King County [nonattainment] - 2.8 Ib/gal)
A. 0. Smith Corporation i
Newark, California (Alameda County [nonattainment] - 2.8 Ib/gal)
A. 0. Smith Corporation
McBee, South Carolina (Chesterfield County - 2.8 Ib/gal)
Speed Queen Company
Ripon, Wisconsin (Fond du Lac County - 2.8 Ib/gal)
Speed Queen Company
Searcy, Arkansas (White County - no standard)
State Industries, Inc.
Ashland City, Tennessee (Cheatham County - 2.8 Ib/gal)
State Industries, Inc.
Henderson, Nevada (Clark County [nonattainment] - 2.8 Ib/gal)
Sub-Zero Freezer Company, Inc.
Madison, Wisconsin (Dave County [nonattainment] - 2.8 Ib/gal)
Tappan Appliance Division
(Electrolux) Mansfield, Ohio (Rich!and County [nonattainment] -
2.8 Ib/gal)
Tappan Appliance Division
(Electrolux) Springfield, Tennessee (Robertson County - 2.8 Ib/gal)
Tappan Appliance Division
(Electrolux) Dal ton, Georgia (Whitfield County - 2.8 Ib/gal)
Thermador/Waste King
Brockton, Maine (Plymouth County [nonattainment] - 2.8 Ib/gal)
Toshiba America, Inc. !
Torrance, California (Los Angeles County [nonattainment] - 2.8 Ib/gal)
Vaughn Corporation
Salisbury, Massachusetts (Essex County [nonattainment] - 2.8 Ib/gal)
Warwick Manufacturing Company
Chesapeake, Virginia (Chesapeake County [nonattainment] -2.8 Ib/gal)
Watertown Metal Products Division '
(Western Industries) Watertown, Wisconsin (Dodge/Jefferson Counties -
2.8 Ib/gal)
A-13
-------
Webster City Products Company
(White Consolidated Industries) Webster City, Iowa (Hamilton County -
no standard)
Welbilt Corporation
Maspeth, New York (Kings County [nonattainment] -2.8 Ib/gal)
Whirlpool/St. Joseph
St. Joseph, Michigan (Berrien County [nonattainment] - 2.8 Ib/gal)
Whirlpool/St. Paul
St. Paul, Minnesota (Ramsey County - no standard)
Whirlpool Corporation/Evansville Division
Evansville, Indiana (Vanderburgh County [nonattainment] - 2.8 Ib/gal)
Whirlpool Corporation/Clyde Division
Clyde, Ohio (Sandusky County [nonattainment] - 2.8 Ib/gal)
Whirlpool Corporation/Danville Division
Danville, Kentucky (Boyle County - 2.8 Ib/gal)
Whirlpool Corporation/Ft. Smith Division
Ft. Smith, Arkansas (Sebastian County - no standard)
Whirlpool Corporation/Marion Division
Marion, Ohio (Marion County [nonattainment] - 2.8 Ib/gal)
Whirlpool Corporation/Find!ay Division
Findlay, Ohio (Hancock County [nonattainment] - 2.8 Ib/gal)
White-Westinghouse Appliance Company
(White Consolidated Industries) Pittsburgh, Pennsylvania (Allegheny
County [nonattainment] - 2.8 Ib/gal)
A-14
-------
TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
PORT NO. ' 2.
EPA-450/3-80-037b
FLE AND SUBTITLE
Industrial Surface Coating: Large Appliances -
Background Information for Promulgated Standards
THOR(S)
RFORMING ORGANIZATION NAME AND ADDRESS
Office of Air Quality Planning and Standards
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
PONSORING AGENCY NAME AND ADDRESS
DAA for Air Quality Planning and Standards
Office of Air, Noise, and Radiation
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
3. RECIPIENT'S ACCESSION NO.
5. REPORT DATE /
October 1982
6. PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT NO.
1O. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-02-3056
13. TYPE OF REPORT AND PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
EPA/200/04
UPPLEMENTARY NOTES
This document is the second volume of EPA 450/3-80-037 series. The first volume
discussed the proposed standards and the resulting environmental and economic impacts.
BSTRACT
Standards of performance are being promulgated under Section 111 of the Clean
Air Act to control volatile organic compound emissions from new, modified, and
reconstructed large appliance surface coating operations. This document contains
a detailed summary of the public comments on the proposed standards (.45 FR 85085),
responses to these comments and a summary of the changes to the proposed standards.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
Air pollution
'Dilution control
Standards of performance
Appliance
Volatile organic compound
Surface Coating
STRIBUTiON STATEMENT
Unlimited
b.lDENTIFIERS/OPEN ENDED TERMS
Air Pollution Control ;
i
19. SECURITY CLASS (This Report/
Unclassified
20. SECURITY CLASS (This page/
Unclassified
c. COSATI Field/Group
13B
21. NO. OF PAGES
51
22. PRICE
:orm 2220-1 (Rev. 4-77)
PREVIOUS EDITION IS OBSOLETE
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