United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park NC 27711
EPA-453/D-95-002
August 1995
Air
Guideline Series
Control of Volatile
Organic Compound
Emissions from
Wood Furniture
Manufacturing Operations
DRAFT DOCUMENT
-------
EPA-453/D-95-002
; Guideline Series
i Control of Volatile Organic Compound
Emissions from Wood Furniture ~
Manufacturing Operations-Draft
Emission Standards Division
U. S. Environmental Protection Agency
Office of Air and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, NC 27711
August 1995
U.S. Environments! Protection Agency
Region 5, Lir-ra.y (PL-l/Jj
77 West Jackson Boulevard, 12th Floor
Chicago, IL 60604-3590
-------
GUIDELINE SERIES
The guideline series of reports is issued by the Office of
Air Quality Planning and Standards (OAQPS) to provide information
to State and local air pollution control agencies. Mention of
trade names or commercial products is not intended to constitute
endorsement or recommendation for use. Reports published in this
series will be available - as supplies permit - from the Library
Services Office (MD-35, U. S. Environmental Protection Agency,
Research Triangle Park, North Carolina 27711, or for a nominal
fee, from the National Technical Information Service, 5285 Port
Royal Road, Springfield, Virginia 22161.
-------
TABLE OF CONTENTS
Page
1.0 INTRODUCTION 1-1
1.1 THE REGULATORY NEGOTIATION PROCESS 1-2
1.2 DEVELOPMENT OF THE CTG THROUGH REGULATORY
NEGOTIATION 1-3
2~. 0 INDUSTRY DESCRIPTION .' 2-1
2.1 INDUSTRY STRUCTURE 2-1
2.2 FINISHING PROCESS 2-8
2.2.1 Finish Application Methods 2-10
2.2.2 Finishing Materials 2-13
2.2.3 Finishing Sequences 2-18
2.3 EMISSION SOURCES 2-20
2.3.1 Industry Source Definition 2-20
2.3.2 Emission Sources 2-20
2.3.3 VOC Emission Summary . . . . „ 2-26
2.4 EXISTING REGULATIONS 2-28
2.4.1 Introduction 2-28
2.4.2 Summary of Existing Regulations .... 2-29
2.5 REFERENCES FOR CHAPTER 2 2-37
3.0 EMISSION CONTROL TECHNIQUES 3-1
3.1 ADD-ON CONTROL DEVICES 3-1
3.1.1 Combustion Control Devices 3-2
3.1.2 Recovery Devices 3-12
3.1.3 Methods of Minimizing Control Costs--
Volume Reduction 3-24
3.1.4 Total Enclosure of the Finishing Line . 3-30
3.2 LOWER VOC FINISHES 3-32
3.2.1 Use of Lower VOC Finishing Materials . . 3-33
3.2.2 Applicability of Lower-VOC Finishes to
Wood Furniture Finishing Operations . . 3-45
3.2.3 Advantages and Disadvantages of Lower
VOC Finishes 3-50
3.3 EMERGING/SPECIALIZED TECHNOLOGIES 3-52
3.3.1 Mobile Zone Spray Booth 3-53
3.3.2 Three-Dimensional Ultraviolet Curing . . 3-54
3.3.3 Biofiltration 3-55
3.4 MINIMIZATION OF FINISH/SOLVENT USAGE AND
EVAPORATION 3-57
3.4.1 Required Work Practices 3-57
3.4.2 Reduction in Cleaning Material Usage . . 3-60
3.4.3 Washoff Operations 3-64
3.5 REFERENCES FOR CHAPTER 3 3-66
ill
-------
TABLE OF CONTENTS (continued)
Page
4.O MODEL PLANTS AND EMISSIONS ESTIMATES 4-1
4.1 MODEL PLANTS 4-1
4.1.1 Finish Application Method 4-5
4.1.2 Finishing Sequence 4-5
4.1.3 Model Plant Sizes 4-6
4.1.4 Finish Parameters . . .' 4-10
4.2 EMISSIONS ESTIMATES 4-12
4.2.1 Emissions by Finishing Step 4-13
4.2.2 Emissions by Emission Point 4-13
4.3 REFERENCES FOR CHAPTER 4 4-19
5.0 SELECTION OF RACT 5-1
5.1 BACKGROUND 5-1
5.2 SELECTION OF REFERENCE CONTROL TECHNOLOGIES . . 5-2
5.3 SELECTION OF WORK PRACTICE STANDARDS 5-6
5.3.1 Coating Operations 5-7
5.3.2 Cleaning and Washoff Operations .... 5-10
5.3.3 General Work Practice Requirements ... 5-14
5.4 SELECTION OF COMPLIANCE PROVISIONS 5-15
5.5 SMALL BUSINESS CONSIDERATIONS 5-16
5.6 REFERENCES FOR CHAPTER 5 5-18
6.0 COST, ENVIRONMENTAL, AND ENERGY IMPACTS 6-1
6.1 COST OF THE RECOMMENDED RACT OPTIONS 6-2
6.1.1 Limitation on VOC Content of Coatings . 6-2
6.1.2 Application Equipment Requirements ... 6-8
6.1.3 Work Practice Standards 6-10
6.2 MODEL PLANT COSTS 6-11
6.3 NATIONWIDE IMPACTS OF PRESUMPTIVE RACTS .... 6-14
6.3,1 Nationwide Emission Reductions 6-21
6.3.2 Nationwide Costs 6-23
6.4 ENVIRONMENTAL AND ENERGY IMPACTS 6-23
6.4.1 Environmental Impacts 6-23
6.4.2 Energy Impacts 6-26
6.4.3 Other Environmental Impacts 6-26
6.5 IMPACTS OF OTHER CONTROL OPTIONS 6-27
6.5.1 Hybrid Waterborne . 6-31
6.5.2 Full Waterborne 6-33
6.5.3 Add-On Controls 6-33
6.6 REFERENCES FOR CHAPTER 6 6-37
IV
-------
TABLE OF CONTENTS (continued)
Page
7.0 RACT IMPLEMENTATION 7-1
7.1 INTRODUCTION 7-1
7.2 DEFINITIONS 7-2
7.3 APPLICABILITY 7-2
7.4 FORMAT OF STANDARDS 7-4
7.5 COMPLIANCE AND MONITORING PROVISIONS 7-7
7.5.1 Compliance Provisions 7-7
- 7.5.2 Monitoring Requirements 7-9
7.6 REPORTING AND RECORDKEEPING 7-13
-------
LIST OF FIGURES
Page
Figure 3-1. Thermal incinerator--general case 3-3
Figure 3-2. Regenerable-type thermal incinerator .... 3-6
Figure 3-3. Catalytic incinerator 3-10
Figure 3-4. Typical two-bed, continuously operated
fixed-bed carbon adsorber system 3-16
LIST OF TABLES
Page
TABLE 1-1. WOOD FURNITURE NESHAP REGULATORY NEGOTIATION
COMMITTEE MEMBERSHIP 1-6
TABLE 2-1. WOOD FURNITURE INDUSTRY STRUCTURE 2-2
TABLE 2-2. WOOD FURNITURE SIC CATEGORIES 2-3
TABLE 2-3. WOOD FURNITURE FACILITIES BY EPA REGION . . 2-4
TABLE 2-4. 1990 FDM 300 TOP 10 FURNITURE MANUFACTURERS 2-7
TABLE 2-5. FINISHING MATERIALS USED IN THE WOOD
FURNITURE INDUSTRY 2-14
TABLE 2-6. TYPICAL FINISHING SEQUENCES 2-18
TABLE 2-7. WOOD FURNITURE INDUSTRY STRUCTURE BY
FINISHING SEQUENCE ... 2-19
TABLE 2-8. SPRAY BOOTH CHARACTERISTICS 2-22
TABLE 2-9. SOLVENT CONSUMPTION IN PAINTS AND
COATINGS ORIGINAL EQUIPMENT MANUFACTURERS
(OEM), 1989 2-27
TABLE 2-10. WOOD FURNITURE INDUSTRY SOLVENT
USAGE--1989 . . . . 2-28
TABLE 2-11. REGULATORY SUMMARY--WOOD FURNITURE COATING . 2-30
TABLE 2-12. VOC CONTENT LIMITATIONS--WOOD FURNITURE
FINISHING ..... 2-36
VI
-------
LIST OF TABLES (continued)
TABLE 3-1.
TABLE 3-2.
*«,
TABLE 3-3.
TABLE 3-4.
TABLE 4-1.
TABLE 4-2.
TABLE 4-3.
TABLE 4-4.
TABLE 4-5.
TABLE 4-6.
TABLE 4-7.
TABLE 4-8.
TABLE 5-1.
TABLE 5-2.
TABLE 6-1.
TABLE 6-2.
TABLE 6-3.
TABLE 6-4.
TABLE 6-5.
TABLE 6-6.
LOWER-VOC FINISH ALTERNATIVES--FINISH
SUPPLIERS' COMPARISON OF FINISH PROPERTIES .
WORK PRACTICE REQUIREMENTS -- PRESUMPTIVE
RACT
•
COMMERCIALLY AVAILABLE SPRAY GUN WASHING
UNITS .
LOW-VOLATILITY ALTERNATIVE SOLVENTS ....
CHARACTERISTICS OF MODEL PLANT CATEGORIES .
MODEL PLANT DESCRIPTIONS
RANGES OF VOC USAGE AND EMPLOYMENT DATA FOR
MODEL PLANTS
FINISHING MATERIAL CHARACTERISTICS . . . .
RELATIVE PERCENTAGE OF VOC EMISSIONS . . . .
MODEL PLANT SUMMARY--UNCONTROLLED VOC
EMISSION RATES, tons/yr
EMISSIONS DISTRIBUTION, tons/yr
EMISSIONS DISTRIBUTION, tons/yr
REFERENCE CONTROL TECHNOLOGIES TO MEET RACT
WORK PRACTICE STANDARDS TO MEET RACT ....
COST BY MODEL PLANT FOR PLANTS CONVERTING
TO HIGHER SOLIDS SEALER AND TOPCOAT ....
COST BY MODEL PLANT FOR PLANTS CONVERTING TO
WATERBORNE TOPCOATS
MODEL PLANT CONTROL COSTS FOR PRESUMPTIVE
RACT
DISTRIBUTION OF WOOD FURNITURE PLANTS
IN NONATTAINMENT AREAS BY MODEL PLANT . . .
BASELINE AND CONTROLLED VOC EMISSIONS . . .
NATIONWIDE CONTROL COSTS FOR PRESUMPTIVE
RACT
Page
3-51
3-58
3-62
3-63
4-3
4-4
4-7
4-9
4-12
4-13
4-15
4-19
5-3
5-8
6-15
6-16
6-17
6-18
6-22
6-24
VI1
-------
TABLE 6-7.
TABLE 6-8.
TABLE 6-9.
TABLE 6-10.
TABLE 6-11.
TABLE 6-12.
LIST OF TABLES (continued)
ENERGY USE ASSOCIATED WITH WATERBORNE
TOPCOATS
INDUSTRY REPORT MODEL PLANTS .
EARLIER DRAFT CTG MODEL PLANTS
EMISSION REDUCTIONS AND COST EFFECTIVENESS
OF HYBRID WATERBORNE COATING SYSTEM . . .
EMISSION REDUCTIONS AND COST EFFECTIVENESS
OF FULL WATERBORNE COATING SYSTEM ....
EMISSION REDUCTIONS AND COST EFFECTIVENESS
OF ADD-ON CONTROL DEVICES
Page
6-26
6-29
6-30
6-32
6-34
6-35
vixi
-------
DRAFT
3723/650395
2/14/95
1.0 INTRODUCTION
V
The Clean Air Act Amendments (CAAA) of 1990 require that
State implementation plans (SIP's) for certain ozone
nonattainment areas be revised to require the implementation of
reasonably available control technology (RACT) for control of
volatile organic compound (VOC) emissions from sources for which
EPA has already published Control Techniques Guidelines (CTG's)
or for which the U. S. Environmental Protection Agency (EPA) will
publish a CTG between the date of enactment of the amendments and
the date an area achieves attainment status. Section 172(c)(1)
requires nonattainment area SIP's to provide, at a minimum, for
"such reductions in emissions from existing sources in the area
as may be obtained through the adoption, at a minimum, of
reasonably available control technology ..." As a starting point
for ensuring that these SIP's provide for the required emission
reduction, EPA in the notice at 44 FR 53761 (September 17, 1979)
defines RACT as: "The lowest emission limitation that a
particular source is capable of meeting by the application of
control technology that is reasonably available considering
technological and economic feasibility." The EPA has elaborated
in subsequent notices on how States and EPA should apply the RACT
requirements (see 51 FR 43814, December 1989; and 53 FR 45103,
November 8, 1988).
The CTG's are intended to provide State and local air
pollution authorities with an information base for proceeding
with their own analyses of RACT to meet statutory requirements.
The CTG's review current knowledge and data concerning the
technology and costs of various emission control techniques.
Each CTG contains a "presumptive norm" for RACT for a specific
1-1
-------
DRAFT
3723/650395
2/14/95
source category, based on EPA's evaluation of the capabilities
and problems specific to that category. Where applicable, EPA
recommends that States adopt requirements consistent with the
presumptive norm. However, the presumptive norm is only a
recommendation. States may choose to develop their own RACT
requirements on a case-by-case basis, considering the economic
and technical circumstances of an individual source. It should
be noted that no laws or regulations preclude States from
requiring more control than recommended as the presumptive norm
for RACT. A particular State, for example, may need a more
stringent level of control in order to meet the ozone standard or
to reduce emissions of a specific toxic air pollutant.
This CTG is 1 of at least 11 CTG's that EPA was required to
publish within 3 years of enactment of the CAA amendments. It
addresses RACT for control of VOC emissions from wood furniture
coating and cleaning operations. This document is currently in
draft form and is being distributed for public comment. Public
comments will be reviewed and incorporated as judged appropriate
before EPA finalizes the CTG.
Unlike traditional development of CTG's for which a
determination of RACT involves the identification and extensive
analyses of a list of options, the determination of presumptive
RACT .for the wood furniture industry was negotiated under the
Federal Advisory Committee Act with members of industry,
environmental groups, States, and local agencies. Included in
this chapter is a brief description of the regulatory negotiation
process, a discussion of the process that led to the decision to
negotiate presumptive RACT, and a brief discussion of the
regulatory negotiation process for the wood furniture industry.
1.1 THE REGULATORY NEGOTIATION PROCESS
In a regulatory negotiation, a well-balanced group
representing the industry to be regulated, public interest
groups, state and local governments, and the EPA form a federally
chartered advisory committee to negotiate the requirements of a
rule. A neutral facilitator is used to convene the committee and
to manage its meetings. In a regulatory negotiation, decisions
1-2
-------
DRAFT
3723/650395
2/14/95
are made by consensus, not by majority vote. Consensus is
defined by the committee prior to the start of its deliberations,
however, it is generally defined as an agreement by all parties
that they can live with the provisions of the rule.
There are several advantages to the regulatory negotiation
process. The process allows the interested, affected parties a
onore direct input into the drafting of the regulation, thus
"ensuring that the rule is more sensitive to the needs and
.restrictions of all parties. The regulatory negotiation
committee can draw on the diverse experience and creative skills
of the committee members to address problems encountered in
crafting the regulation. The group together may be able to
propose solutions to difficult problems that no one member could
have thought of on his/her own.
1.2 DEVELOPMENT OF THE CTG THROUGH REGULATORY NEGOTIATION
In the fall of 1989, EPA began developing the CTG for the
wood furniture industry. The EPA sent out surveys to wood
furniture manufacturers, wood furniture coating suppliers,
application equipment vendors, and manufacturers of add-on
controls. They also visited several wood furniture manufacturing
plants. The information collected from these efforts was used to
develop a draft CTG. Drafts of Chapters 1 through 4 of the CTG
were released in October of 1991 and the status of the CTG and
rt-
the basis for selecting the RACT options were presented at a
meeting of the National Air Pollution Control Techniques Advisory
Committee (NAPCTAC) in November of 1991. A determination of RACT
was not made by EPA at this point in time.
In the spring of 1991, the industry began preparation of its
own report that evaluated VOC emissions control technologies for
the wood furniture and cabinet industries. The report was
prepared by an independent contractor and was sponsored by the
American Furniture Manufacturers Association, the Business and
Institutional Furniture Manufacturers Association, the Kitchen
Cabinet Manufacturers Association, and the National Paint and
Coatings Association. The report evaluated the technical
feasibility and the costs of control technologies for reducing
1-3
-------
DRAFT
3723/650395
2/14/95
VOC emissions from the industry. An extensive analysis of the
economic impacts of the control technologies was also included as
a part of the report. The report did not present a
recommendation for RACT.
As the draft CTG and the industry report were being
completed, EPA also began work on a national emission standard
for hazardous air pollutants (NESHAP) for the wood furniture
industry. Title III of the Clean Air Act Amendments of 1990 gave
EPA the authority to establish national standards to reduce air
toxics from sources that emit such pollutants. Section 112(b) of
the CAAA included a list of hazardous air pollutants (HAP) that
were to be regulated by NESHAP. Because the wood furniture
manufacturing industry is a source of many of these pollutants,
it was included on the list of source categories for which a
NESHAP was to be developed. By the time the draft CTG and the
industry report were released, EPA had already begun gathering
information to be used in the development of a NESHAP for the
industry.
In January of 1992, EPA met with industry representatives to
discuss the industry report and the status of the CTG and NESHAP.
The industry expressed their concern that the requirements of the
CTG and the NESHAP might not be consistent with each other.
Because the development of the CTG was ahead of the NESHAP, the
industry was concerned that they would invest in one set of
technologies to address the CTG requirements and then have to
invest later in different technologies for the NESHAP. In
response to their concerns, EPA presented industry with the
option of determining both the presumptive norm for RACT and the
requirements of the NESHAP using a consensus-building approach.
The EPA indicated that this approach could consist of continued
informal meetings between EPA and the industry or it could
consist of a formal regulatory negotiation in which the industry,
EPA, and other interested parties form a Federal Advisory
Committee with the goal of reaching agreement on both the
presumptive norm for RACT and the requirements of the NESHAP.
1-4
-------
DRAFT
3723/650395
2/14/95
In April of 1992, the industry informed EPA that they wished
to explore the option of using a regulatory negotiation approach
to develop the CTG and the NESHAP for the wood furniture
industry. The EPA agreed to pursue the possibility of using a
regulatory negotiation approach to develop the CTG and the
NESHAP. During the winter of 1992/1993, EPA met with
representatives of the industry, trade Associations, coating
suppliers, States, and environmental groups to discuss issues,
share information, and assess whether a regulatory negotiation
would be appropriate for the industry. Two exploratory meetings
were held for these purposes. After the exploratory meetings,
three public meetings were held in the spring and early summer of
1993 to continue to discuss issues associated with regulatory
development. After publishing in the Federal Register on
June 23, 1993, a notice of establishment of the regulatory
negotiation committee (58 FR 34011), the first official
regulatory negotiation meeting was held in July 1993. The
Committee included representatives from industry, including small
business, States, environmental and public health groups, and an
EPA representative. Table 1 presents the list of committee
members and their affiliations.
Formal meetings and informal workshops were held over the
next several months to identify and resolve the many issues
associated with determining the presumptive norm for RACT for the
wood furniture manufacturing industry. The Federal Advisory
Commitee reached consensus on a framework and principles in
November 1994. The U. S. Environmental Protection Agency is
responsible for issuing the CTG, and has agreed to use the
agreed-upon framework and principles as the basis for the CTG.
The wood furniture industry is described in Chapter 2 and
emission control techniques are discussed in Chapter 3. The
development of model plants and the associated emission estimates
are described in Chapter 4. A detailed discussion of the
requirements of the presumptive norm for RACT that were agreed
upon by the Committee is included in Chapter 5, while Chapter 6
1-5
-------
DRAFT
3723/650395
2/14/95
TABLE 1.
WOOD FURNITURE NESHAP REGULATORY NEGOTIATION
COMMITTEE MEMBERSHIP
Members
Freeman Allen
Terry Blacka
Jack Burgess
Gerry Currier
William Deal
John DeVido
William Dorris
Jack Edwardson
Paul Eisele
Jon Heinrich
Gary Hunt
Alan Klimek
John Lingelbach
Brian Morton
Peter Nicholson
Susan Perry
Andy Riedell
David Rothermel
William Sale
Mike Soots
Richard Titus
Janet Vail
Stephen Willcox
Susan Wildau
John Zeltsman
Affiliations
Sierra Club
PA Department of Environmental Resources
Pridgen Cabinet Works (Small Business)
AKZO Coatings
Bernhardt Furniture Company (Office Furniture)
Aqualon (Resins)
Lilly Industries (Coatings)
U. S. Environmental Protection Agency
MASCO Corporation
WI Department of Natural Resources
NC Office of Waste Reduction
NC Department of Environment, Health, and Natural
Resources
Facilitator
NC Environmental Defense Fund
Rohm and Haas (Resins)
Business and Institutional Furniture Manufacturers
Association
PPG Industries (Coatings)
Stylecraft Corporation (Small Business)
Broyhill Furniture (Residential Furniture)
Kincaid Furniture (Residential Furniture)
Kitchen Cabinet Manufacturers Association
West MI Environmental Action Council
American Lung Association of NC
Facilitator
Architectural Woodwork Institute (Small Business)
aLeft the State of Pennsylvania in December 1993 and is now with Rettew
Associates in Lancaster, Pennsylvania.
l-i
-------
DRAFT
3723/650395
2/14/95
presents the environmental and cost impacts of those
requirements.
1-7
-------
DRAFT
3471/650395
2/23/95
: 2.0 INDUSTRY DESCRIPTION
2.1 INDUSTRY STRUCTURE
The structure of the wood furniture industry is presented in
Table 2-l.1"3 There are nine Standard Industrial Classification
(SIC) codes which cover what was analyzed for the development of
the Control Techniques Guideline for the "wood furniture"
industry. The nine SIC codes include Wood Kitchen Cabinets; Wood
Household Furniture (except upholstered); Wood Household
Furniture (upholstered); Wood Television, Radios, Phonograph, and
Sewing Machine Cabinets; Household Furniture Not Classified
Elsewhere; Wood Office Furniture; Public Building and Related
Furniture; Wood Office and Store Fixtures, and Furniture and
Fixtures Not Elsewhere Classified. A more detailed description
of the products included in these industries is provided in
Table 2-1. Three of the SIC codes, 2519, 2531, and 2599, include
the manufacture of nonwood products. However,, the CTG will apply
only to those products manufactured of wood and wood products
(including particle board, reed, rattan, wicker, etc.) Table 2-2
presents the relative number of facilities in each of the nine
SIC codes (based on the 1987 Census data).1"3 Facilities in SIC
codes that manufacture furniture that can be labeled as wood
household or residential constitute approximately 34 percent of
the total and are concentrated in western North Carolina; wood
kitchen cabinet manufacturers represent about 29 percent of the
total and are concentrated in Pennsylvania and the Midwest.
Facilities in SIC codes that manufacture products that can be
labeled as business or office furniture represent 24 percent of
furniture manufacturing facilities and these facilities are
concentrated in Michigan.4 The number of wood furniture
2-1
-------
DRAFT
3471/650395
2/23/95
•o
H
W
p
U
jr*
^
CO
«
CO
^
M
Ixl
H
D
(±4
D
O
i
H
i
(S
W
H
««
*^
1
•s
5
i
IS
s
0
0
1
o
tf
JS
E
2
"3
to
"5
(2
^
|
"8
S
—
i
CO
1
1
0.
s
'o.
•s
1
1
U
S3
1
s
8
—
8
a"
1
a
CO
CO
Vi
CO
oo
8
Cabinets (to be bu.U-in)
Cabinets (factory made)
Vanities (bathroom and other)
Wood kitchen cabinets
-*•
•t
1
S
8
S
g
CO
8
a
eo
s;
(N
00
CO
CO
s
^-
Beds, bookcases, buffets, chairs, chests, coffee
tables, cradles, cribs, dressers, rockers,
secretaries, stools, tables
g
Wood household fumitu
except upholstered
—
»
8
g
00
CO
1
a
|
o
s
-
<0
^
s
s
r~
Chain, couches, davenports, living room
furniture, rockers, sofas
t
Wood household fumitu
upholstered
fS
a
g
**
8
OO
*0
I
--
1
s
00
s
s
Phonograph cabinets and cases, radio cabinets
and caies, sewing machine cabinets and cases,
stereo cabinets, television cabinets
Wood television, radios
phonograph and sewing
machine cabinet*
r~
a
1
.0
8
***
g
«*
1
£
^
CM
55
~"
Bassinets, camp furniture, reed and rattan,
other wicker furniture, chairs, cabinets, garden
and lawn furniture
Household furniture not
elsewhere classified
Ov
SQ
8
CO
g
V*
CO
8
fl
8
ro
1
_M
CO
CO
§
Benches, bookcases, cabinets, chairs, desk*,
filing boxe*, furniture, stools, table*
Wood office furniture
-
o"
J
<
B
v
o-
I
a.
2-2
-------
DRAFT
3471/650395
2/23/95
TABLE 2-2. WOOD FURNITURE SIC CATEGORIES
1-3
SIC
code
2434
2511
2512
2517
2519
2521
2531
2541
2599
Industry
Wood kitchen cabinets
Wood household furniture, except
upholstered
Wood household furniture, upho'lstered
Wood television, radios, phonograph, and
sewing machine cabinets
Household furniture, not elsewhere
classified
Wood office furniture
Public building and related furniture
Wood office and store fixtures,
partitions, shelving, and lockers
Furniture and fixtures, not elsewhere
classified
Percentage
of total
facilities51
29
23
9
b
b
5
4
15
13
fBased on 12,671 establishments for the nine SIC codes.
than 1 percent.
manufacturing facilities by EPA region is presented in Table 2-3.
The largest number of facilities, 2,721, are located in
Region IV, which includes the southeast States; Region IX, which
includes California, has 2,007 facilities.1"3
As shown in Table 2-1, the wood furniture industry is
comprised primarily of small plants; 86 percent of the facilities
have fewer than 50 employees. In comparison, large facilities
constitute only 3 percent of all wood furniture facilities. Wood
furniture facilities with more than 20 employees are concentrated
in North Carolina and California.4 Small facilities are usually
batch operations, are not generally automated, and have a
comparatively low level of inhouse technical expertise. Large
facilities are usually highly automated, continuous operations.
Furniture Design and Manufacturing magazine ranks the top
300 wood furniture plants every year by total annual sales
(referred to as the FDM 300) .5 The 1990 FDM 300 overall ranking
assigns Steelcase No. 1, Masco No. 2, Interco No. 3, and Herman
2-3
-------
DRAFT
3471/650395
3/1/95
TABLE 2-3. WOOD FURNITURE FACILITIES BY EPA REGION
1-3
Reqion I
Connecticut
Maine
Massachusetts
New Hampshire
Rhode Island
Vermont
Recrion II
New Jersey
New York
Reqion III
Maryland
Pennsylvania
Virginia
West Virginia
Recrion IV
Alabama
Florida
Georgia
Kentucky
Mississippi
North Carolina
South Carolina
Tennessee
Reqion V
Illinois
Indiana
Michigan
Minnesota
Ohio
Wisconsin
Reqion VI
Arkansas
Louisiana
New Mexico
Oklahoma
Texas
Total
facilities21
147
20
272
52
•ll
31
533
447
748
1,195
141
448
229
10
828
203
868
318
98
167
690
79
298
2,721
351
313
283
219
325
232
1,723
117
23
72
34
468
714
Facilities with
20 employees or
more
35
7
72
14
5
13
146
65
1,195
1,260
30
149
81
2
262
69
134
82
31
90
353
24
123
906
104
131
91
49
81
69
525
44
3
8
11
135
201
2-4
-------
DRAFT
3471/650395
3/1/95
TABLE 2-3. (continued)
Recrion VII
Iowa
Kansas
Missouri
Nebraska
Reaion VIII
Colorado
North Dakota
South Dakota
Utah
Region IX
Arizona
California
Nevada
Reaion X
Idaho
Oregon
Washington
Total
facilities3
53
52
.166
28
299
156
18
10
91
275
190
1,789
28
2,007
25
178
259
462
Facilities with
20 employees or
more
25
20
52
9
106
26
5
2
28
61
42
527
6
575
2
31
48
81
aNo data available for States not listed.
for the following SIC codes: 2434, 2511,
2521, 2531, and 2541.
Includes information
2512, 2517, 2519,
2-5
-------
DRAFT
3471/650395
2/23/95
Miller No. 4. (The 1991 ranking placed Herman Miller as No. 3
and Interco as No. 4). The 1990 FDM 300 also ranks the top
10 companies in three categories of wood furniture, including
residential, office/institutional, and kitchen cabinet furniture
manufacturers. These companies, and their corresponding annual
sales, are presented in Table 2-4 (the 1991 ranking was not
broken down by industry segment and is therefore not presented).
Masco Corporation, which manufactures both household/residential
furniture and kitchen cabinets, is the parent company of many
well-known companies including Merillat Industries, Henredon
Furniture Industries, Fieldstone Cabinetry, and Universal
Furniture. Interco Corporation, which makes
household/residential furniture, includes Broyhill Furniture,
Ethan Allen, and The Lane Company, among others. Of kitchen
cabinet manufacturers, Merillat is believed to control the
(• ••?
largest portion of the market, approximately 10 percent. ' No
single company is believed to control more than 5 to 6 percent of
the household/residential furniture market.
The "wood furniture industry" is commonly grouped as
household/residential furniture, office/business furniture, and
kitchen cabinet furniture. Facilities that produce these types
of furniture may be grouped together throughout the discussion in
this chapter. These are intended to be general labels that
provide basic information about a facility's final product and
that identify the use and destination of the final product; the
generalizations are not intended as descriptive classifications
of the manufacturing process. For example, manufacturers within
the household/residential group may use a variety of different
raw materials and manufacturing methods. Differences would be
apparent in finish application methods, finishing sequences,
types of wood or wood product used, and types of finishes used.
The household/residential, office/business, and kitchen cabinet
groupings are qualitative descriptions and were not used in
categorizing the industry for control technique analysis.
There are many different grades and styles of furniture.
The three grades of furniture are often described by the industry
2-6
-------
DRAFT
3471/650395
6/22/95
TABLE 2-4. 1990 FDM 300 TOP 10 FURNITURE MANUFACTURERS5
Market
Residential
Kitchen cabinet
Office/institutional
Rank
1
2
3
4
5
6
7
8
9
10
1
. 2
3
4
5
6
7
8
9
10
1
2
3
4
5
6
7
8
9
10
Name
Masco Corp.
Interco
Ohio Mattress Co.
La-Z-Boy Chair Co.
Bassett Furnitxnre, Industries,
Inc.
Ladd Furniture
Simmons USA
Thomasville Furniture Industries,
Inc.
Mohasco Corp.
Klaus sner Furniture Industries
Masco Corp.
Triangle Pacific Corp^.
WCI Cabinet Group
American Woodmark Corp.
Aristokraft
KraftMaid Cabinetry, Inc.
Wood-Mode Cabinetry
Rivera Cabinets
HomeCrest Inc.
The St . Charles Companies
Steelcase, Inc.
Herman Miller, Inc.
Haworth, Inc.
HON Industries, Inc.
Kimball International, Inc.
Knoll International
All steel, Inc.
Virco Manufacturing Corp.
Westinghouse Furniture Systems
Shelby William Industries, Inc.
Annual
sales,
million $
l,200a
l,100b
700b
553b
466b
450b c
425b
417a
400a
250b
300a
185b c
180b
160b
>130b
<100b c
85a
80b
60a
58a
l,800b
793b
>500b
500a c
475b
275a c
220b c
183a
170b
169b
fBased on 1988 sales data.
bBased on 1989 annual sales data.
cEstimated.
2-7
-------
DRAFT
3471/650395
2/23/95
as high-end, medium-end, and low-end. Generally, high-end
furniture is constructed of solid wood and wood veneers and has
the wood grain showing through the finish. The finishing process
includes multiple finishing steps and is labor intensive. Low-
end furniture, on the other hand, is often made of medium density
fiberboard (MDF) with some plastic components and some natural
wood. Also, the piece often has either a colored or printed wood
grain finish, and the finishing process is less labor intensive.
Medium-end furniture may be made of some combination of MDF and
solid wood and may or may not show the natural wood grain. The
cost of higher end furniture is more expensive due to the quality
of materials used and the slow, labor intensive production
process.4
For the same production level (or the same number of
furniture pieces), the VOC emissions are greater for high-end
furniture compared with those emitted from lower end furniture.
The manufacture of high-end furniture often entails a series of
finishing steps, up to 15 steps with multiple applications of
some finishing steps, while low-end furniture involves fewer
finishing steps (in some instances as few as one). More
finishing steps are performed for each piece of higher end
furniture than for low-end furniture, and therefore more VOC
solvent is used. The difference in VOC emissions between plants
with the same production levels makes it difficult to predict
emissions from a particular plant based on production.4 Though
the low-, medium-, and high-end furniture designations are used
frequently by the industry, they are qualitative descriptions and
therefore were not used in categorizing the industry.
2.2 FINISHING PROCESS
The finishing process used in the wood furniture industry
consists of some combination of finish application, sanding and
rubbing, and drying in ovens and/or flashoff areas. Finishing
application techniques include spray application and flatline
finishing techniques and in some instances, hand application
techniques. Wood furniture finishing basically consists of
applications of a series of color coats (stains, toners, etc.)
2-8
-------
DRAFT
3471/650395
2/23/95
and clear coats (washcoat, sealer, topcoat, etc.). The furniture
piece may be sanded, rubbed, or polished and may pass through
drying ovens or flashoff areas.
In the wood furniture finishing process, the finishes
applied penetrate the wood and become an integral part of the
€inal product. The finishes enhance the qualities and the look
of the wood, especially for high-end furniture. Many different
types of wood, fiberboard, and particleboard are used, and
finishes react differently with each; a finishing step in a
finishing sequence must be compatible not only with the wood
substrate but also with the successive finishing steps. In the
wood furniture industry, each type of finish used for a
particular step within a finishing sequence is unique in color,
solids content, VOC content, and carrier solvent; successive
finishes must be formulated as part of a complimentary finishing
system. A single limit on VOC level applicable to all finishes
is difficult to require given the uniqueness of each finish type
within a finishing sequence.
Geographic location and seasonal changes affect the
finishing material formulation used. Finishes required for use
in dry, cool climates are different from finishes necessary for
hot, humid climates. Often times, the necessary finish
formulation may change seasonally within a single plant. The VOC
content and composition is adjusted to account for changes in the
drying time and the overall ease of application of each finish in
relation to ambient temperature and the humidity.4
Some furniture facilities may operate more than one 8-hour
shift per day. Finishing operations, however, usually only occur
during the day shift. In some facilities, the finishing area is
in a separate room, apart from the woodworking operations. In
others, finishing occurs in a separate area within the same room
as woodworking activities. The finishing process is often labor
intensive, especially for some types of furniture manufacturing
processes.
In small facilities the furniture is sometimes moved between
stations manually. In most facilities, however, the furniture is
2-9
-------
DRAFT
3471/650395
2/23/95
moved mechanically along the finishing line; the furniture may be
moved by in-floor tow lines, overhead monorails, or by conveyor
belt (mostly for flatline finishing). Tow-lines are chains or
cables mounted in or on the floor, which move a pallet along the
finishing line. The pallets can rotate and can be automatically
disengaged from and reengaged to the tow-line to allow pauses, as
needed. Some facilities move the furniture on pallets that are
hung from overhead chain conveyors. Belt, roller, and slat
conveyors are also used. Many facilities use a combination of
these methods to transport the furniture along the finishing
line.
Wood furniture can either be finished and then assembled, or
assembled and then finished. In Europe, most furniture design is
such that the individual components that make up a piece tend to
be flatter and more uniform than those used in furniture
manufactured in the United States. For this reason, furniture in
Europe is often finished before assembly. Furniture manufactured
in the United States, however, is generally made up of
irregularly shaped, nonflat components, and most United States-
made furniture is assembled and then finished (this is true
mostly for household/residential and office/business). The
exception is kitchen cabinets that are manufactured in the United
States, which are frequently finished before assembly.
The application methods, the types of finishes, and the
finishing sequences used in wood finishing are discussed in the
following sections.
2.2.1 Finish Application Methods
There are various finish application techniques used in the
wood furniture industry. The two principal methods used are
flatline finishing and spray application. Flatline finishing is
used to finish pieces that are generally flat. For nonflat
pieces, preassembled pieces, or pieces with many recesses, this
application method is generally not used. Brushing and dipping
are feasible application methods in these instances, but spray
application is the most prevalent method used to finish nonflat
parts. In the wood furniture industry, spray application
2-10
-------
DRAFT
3471/650395
2/23/95
accounts for 87 percent of finish application whereas flatline
finishing accounts for 13 percent.
2.2.1.1 Flatline Application. If components are finished
before assembly and are flat or relatively flat, "flatline"
simple finishing processes can be used. In flatline finishing,
the furniture pieces are transported by conveyor and are finished
by spray finishing, roll coating, curtaiu coating, or dip
coating.4'9 The industry denotes these as "continuous coaters"
Because the excess coating (that which does not remain on the
part) is constantly recirculated to the coating reservoir and
then reused. Fifty-five percent of flatline finishing is
performed by dip coating; roll and curtain coating each account
for 14 percent^9.* It is not known how the remaining flatline
finishing is performed. (Subsequent references to flatline
finishing in this discussion will refer to roll-, curtain-, or
dip-type coating of furniture pieces.)
Roll coating involves the transfer of finish to a flat piece
by a roller or series of rollers. Curtain coating involves
passing a flat piece through a cascade, or curtain, of finishing
material. In dip coating, the piece is finished by passing
through a container (vat) of finishing material and by submerging
or partially submerging and withdrawing the piece.
2.2.1.2 Spray Application. Since the majority of wood
furniture manufactured in the United States consists of nonflat
pieces, finishes are usually spray-applied. The spray
technologies that can be used include conventional air, airless,
air-assisted airless (AAA), electrostatic, the UNICARB® spray
system, and high-volume low-pressure (HVLP).
The conventional air spray technique uses compressed air (at
pressures greater than 10 pounds per square inch at the point of
atomization) to atomize the finishing materials as they are being
sprayed. Airless spraying involves atomizing the finish by
forcing it through a small opening at high pressure. The liquid
coating is not mixed with air before exiting the nozzle. Air-
assisted airless spray uses an airless spray unit with a
2-11
-------
DRAFT
3471/650395
2/23/95
compressed air jet to finalize breakup and help shape the spray
pattern of the finish material.
Electrostatic finishing has long been used in the
metalworking and automobile industries specifically to finish
metal products. In the wood furniture industry, electrostatic
spraying has had somewhat limited use, mostly by cabinet and
chair manufacturers. Finishing is performed by spraying
negatively-charged finish particles onto grounded wood products.
If the wood piece has a sufficient moisture content to make it
conductive, it can be electrostatically sprayed without
pretreatment. However, some wood must be pretreated to make it
conductive so that it will draw the negatively charged finish to
its surface. Some of these pretreatments can be mixed with water
to act as a carrier; some pretreatment materials, however, may
contain VOC.
The UNICARB® system is a patented system for spray finishing
developed by Union Carbide. A finishing material normally
contains both coalescing (slow-evaporating) and diluent (fast-
evaporating) solvents. The UNICARB* technology replaces the
diluent solvents from the finish mixture with liquid carbon
dioxide (C00)- The C00/coalescing solvent finish mixture is used
£* £»
to finish the wood furniture products with an airless spray gun.
When the finish leaves the spray nozzle, the carbon dioxide in
the mixture immediately flashes; the paint, which still contains
coalescing solvents, continues eriroute to the piece. The
deposited paint then flows and cures in the conventional way.
High-volume low-pressure spraying involves the use of a high
volume of air delivered at an effectively low pressure to atomize
a finish into a pattern of low-speed particles. The use of low
pressure can result in decreased overspray, which translates into
less finish usage and thus, less VOC emissions. Not all HVLP
systems are alike. The most important distinction is between the
two basic air supply designs. One type of HVLP system converts
80 to 100 pounds per square inch (lb/in.2) shop air to 10 lb/in,2
or lower. The other type of HVLP system uses a turbine generator
to supply high volumes of air at low pressure.
2-12
-------
DRAFT
3471/650395
2/23/95
According to a turbine-based HVLP system vendor, the
turbine-based units can offer several advantages.10 Some turbine
units supply a heated air stream. In some instances, this heated
air can improve coating flowability and speed drying. However,
the airstream temperature is not always controllable, and
depending on the finishing material characteristics and
environmental conditions, the heated air. stream is not always
^desirable. Because the turbine units do not use plant air, the
HVLP systems are not affected if the existing shop air lines are
not working at full capacity. The turbine units can be designed
to supply air at a certain pressure, usually around 10 lb/in. .
With these turbine units, it is not possible to achieve pressures
greater than the design pressure (which is low). By limiting the
available pressure, emissions can be minimized. The nonturbine
•^
HVLP systems convert shop air at 80 to 100 lb/in. to the lower
pressure required by the HVLP gun. Because the shop air is
available at pressures exceeding 10 lb/in.2, enforcing a
10 lb/in.2 limit can be difficult.
Disadvantages to the turbine HVLP units have also been
identified.11 In some instances, turbine systems offer
insufficient pressure to provide effective atomization with
higher viscosity materials. If less than 10 lb/in.2 is supplied
to the HVLP gun, poor.atomization may result unless the finish is
cut with solvents to lower the viscosity. A disadvantage of HVLP
systems in general is that the HVLP systems are reportedly not
always able to apply finishes as quickly as the other spray
techniques. However, an air assisted airless HVLP gun has been
developed. The air pressure is limited to 10 lb/in.2, but
reportedly the use of higher fluid pressures enables the guns to
supply finishes at rates comparable to airless and air assisted
airless spraying.12
,2.2.2 Finishing Materials
The wood furniture finish is applied in a series of steps.
There is great variety in the number, type, and order of
finishing steps that are applied. Different types of the seven
different finishes described below are available, including
2-13
-------
DRAFT
3471/650395
2/23/95
conventional low-solids lacquers and relatively higher-solids
conversion finishes, polyurethane finishes, and unsaturated
polyester/unsaturated polyacrylate (UPE/UPA) finishing materials.
The types of wood furniture finishes used in the U.S., Europe,
and Japan are presented in Table 2-5.13
TABLE 2-5. FINISHING MATERIALS USED IN THE WOOD
FURNITURE INDUSTRY13
Region
USA
Europe
Japan
Percent
Lacquers
75
29
32
Conversion
finishes
15
17
17
Polyurethane
finishes
4
32
30
UPE/UPA
finishes21
6
22
20
aUnsaturated polyester/unsaturated polyacrylate finishes.
In the United States, lacquers (mostly nitrocellulose-based)
are used by approximately 75 percent of the wood furniture
industry (commonly household/residential furniture).
Nitrocellulose lacquers have been used in the wood furniture
industry for many years; they are easy to use (forgiving), quick
drying, easy to repair, and familiar. Approximately 15 percent
of the wood furniture industry uses conversion finishing
materials (mostly acid-catalyzed finishes).14 To date,
polyurethane and unsaturated polyester and unsaturated
polyacrylate finishing materials have seen limited use in the
U.S.
In Europe, lacquers are not used as extensively as
polyurethane finishes, as seen in Table 2-5, Approximately
32 percent of the wood furniture industry in Europe uses
polyurethane finishing materials, 29 percent uses lacquers,
22 percent uses unsaturated polyester/unsaturated polyacrylate
finishes, and 17 percent uses urea or melamine resin-based
conversion finishes. The breakdown of finish usage is similar in
Japan.13 The lacquers used by the European wood furniture
industry are used primarily by the residential wood furniture
manufacturers. The kitchen cabinet industry in Europe uses two-
2-14
-------
DRAFT
3471/650395
2/23/95
component polyurethane systems and unsaturated polyester/
polyacrylate systems to a wider extent than the European
furniture industry because they require additional chemical and
mechanical resistance. Acid-curing conversion finishes are also
used by the European kitchen cabinet industry, but their use is
^decreasing (possibly over concern with the associated
"formaldehyde emissions).14 .
? The basic steps in wood furniture finishing (in
generally-used order) and their purposes are as follows:
1. Stain.15"25 Adds initial color, evens out color and
accents the natural wood grain. Stains usually have a very low
solids content (less than 5 percent by volume). Includes
nongrain raising (NGR) stains such as equalizers, prestains, sap
stains, and body stains; no-wipe stains and toners (discussed
below). Nongrain raising stains are dye-type stains that are
intended to give clarity and depth to the wood finish. Dye-type
stains consist of dyes that are dissolved in methanol. The dye
is completely dissolved in the methanol, so it does not
contribute to the solids build on the furniture. No-wipe stains
are pigmented stains that are sprayed on and not wiped that
contain a small amount of oil, pigment, and solvent. No-wipe
stains are used to accent the wood grain, provide color
uniformity, and provide for color retention.
Toner is a type of stain that evens out the color of the
initial application of stain. Toners contain higher solids than
initial stains. Toners contain nitrocellulose or vinyl binders,
dissolved in solvent. Toners are not wiped, and are often
pigmented.
2. Washcoat.15"25 Low-solids (usually 2 to 13 percent by
volume) finishing material used to assist in filling or color
uniformity, to aid in adhesion, and partially seal the wood from
subsequent staining operations. Washcoat also prepares the wood
surface for sanding after stain application. Some facilities buy
sealer in bulk, and dilute their sealer to make washcoat. There
are three main types of washcoat materials: standard
nitrocellulose, vinyl or modified vinyl types, and vinyl-
2-15
-------
DRAFT
3471/650395
2/23/95
modified/conversion types. Advantages of nitrocellulose
washcoats include quick drying, easy sanding, and clarity. Vinyl
and vinyl-modified washcoats consist of nitrocellulose and vinyl
and provide better toughness and adhesion than pure
nitrocellulose washcoats; however, some clarity is sacrificed.
The "conversion" or precatalyzed-type washcoats also provide good
adhesion and toughness, and are good for*open pore woods.
Because they react in place, they are impervious to solvents
contained in subsequently applied sealers and topcoats.
3. Glaze/filler.15"^5 Usually highly-pigmented wiping
stains that contain oil and are used in finishing furniture where
open pore woods such as oak and mahogany are used. Sometimes,
relatively closed-pore woods such as cherry are also filled.
Glazes and fillers are usually supplied as heavily pigmented,
high-solids, low-VOC materials, which are reduced on the job. As
supplied, the solids contents of glazes and fillers are in the
75 percent solids by volume range. Once reduced, the solids
contents usually range from 10 to 45 percent by volume. Glazes
and fillers are usually spray applied, then wiped into the wood.
4. Sealer.15"25 Usually a nitrocellulose-based lacquer.
Vinyl or vinyl-modified sealers and catalyzed sealers (including
acid-cured alkyd amino vinyl sealers) are also available, and
provide advantages similar to those of their washcoat
counterparts. Primary purposes of sealers are to provide
adhesion, enable sanding, to increase build, and to seal the wood
and establish a foundation for artistic enhancement. Solids
contents typically range from 10 to 30 percent by volume.
5. Highlight.15"25 Color coat that is applied sparingly to
accent and give character to the wood. Includes shading and
padding stains as well as spatter. Highlight is usually manually
applied using brushes, sponges, or rags. Distressing of
furniture to obtain a desired finish could also be done at this
point in the finishing sequence, Solids contents vary from less
than 1 to 49 percent solids by volume. Generally low solids
contents (less than five percent by volume).
2-16
-------
DRAFT
3471/650395
2/23/95
6. Topcoat.15"25 A clear coat whose function is to protect
the color coats, enhance the beauty of the furniture, and provide
a durable final finish. Typical solids contents range from 13 to
30 percent solids by volume. There are four categories of
topcoats: standard nitrocellulose topcoats, acrylic topcoats,
catalyzed topcoats, and conversion varnishes. The advantages of
nitrocellulose lacquers are that they pr9vide the best clarity,
pick up little dirt, dry quickly, and are easy to wipe off and
repair. Acrylic lacquers are used over white or pastel finishes
as protection from common household products. They can also be
applied over nitrocellulose topcoats for color retention. The
clarity of acrylic lacquers is not as good as the nitrocellulose
lacquers.
Catalyzed topcoats, like catalyzed sealers, are available in
one- and two-pack form. The one-pack coatings are precatalyzed
and contain nitrocellulose resins and a smaller percentage of
urea resin. Because only a small amount of catalyst is added, it
can take up to 3 to 4 weeks after application until the coating
is completely cured, although it dries to the touch much sooner.
The shelf life of precatalyzed coatings is more than 6 months.
The two-pack coatings consist of two packs, one contains
urea or melamine-based resins, and the other contains the
catalyst. The two components must be mixed before use. More
catalyst is added to two-pack catalyzed coatings, so cure time is
short (on the order of minutes or hours). Two-pack catalyzed
coatings have a limited "pot life" after mixing (from l day to
more than a week).
Conversion varnishes do not dry as quickly as nitrocellulose
topcoats, and are difficult to spot repair, with washoff also
being difficult or impossible. Acid-cured alkyd amino conversion
varnishes are used extensively in the wood furniture industry.
Conversion varnishes, like 2-pack coatings, have a limited pot
life.
2-17
-------
DRAFT
3471/650395
2/23/95
2.2.3 Finishing Sequences
The finishing sequence for wood furniture finishing
operations includes various finish application steps, as well as
intermediate sanding, rubbing, and polishing and drying steps.
Drying of the furniture piece is performed between finishing
steps by flashoff (ambient drying with or without forced air)
and/or oven drying. Finishing sequences.vary considerably from
plant to plant, with some manufacturers using more or less steps
than other manufacturers. The finishing sequence varies based on
a number of factors, including the piece that is being finished,
the desired finish quality, and the finish application method.
The finishing sequences provided are intended to be
representative of operations in the wood furniture industry.
This section discusses three typical finishing sequences: short
spray finishing sequence; long spray finishing sequence; and
roll, curtain, and dip finishing sequence. A summary of the
various finishing sequences is presented in Table 2-6.
TABLE 2-6. TYPICAL FINISHING SEQUENCES4
Short spray finishing
Sap/equalizing stain
Air dry
Prestain toner/penetrating stain
Air dry
Sealer
Air dry
Oven
Sand
Topcoat
Air dry
Oven
Long spray finishing
Sap/equalizing stain
Air dry
Prestain toner/penetrating stain
Air dry
Washcoat
Air dry
Sand
Glaze/filler
Wipe
Air dry
Oven
Sealer
Air dry
Oven
Sand
Highlight
Air dry
Topcoat
Air dry
Oven
Roll, curtain and dip finishing
Stain
Air dry
Sealer
Air dry
Oven
Sand
Topcoat
Air dry
Oven
A wide range of wood furniture products may be finished
using the same finishing sequences; for this reason, multiple
2-18
-------
DRAFT
3471/650395
2/23/95
segments of the industry may have the same finishing sequence.
In addition, the same type of furniture may be finished using
different types of finishing sequences. For example, some
residential furniture, SIC code 2511, may be finished using the
short spray finishing sequence and some may be finished using a
long spray finishing sequence.
* 2.2.3.1 Short Spray Finishing Sequence.4 As seen in
Table 2-6, a typical finishing sequence for short spray finishing
involves spray application of stain, (e.g., equalizing stain
followed by a toner) sealer, and topcoat. Wood furniture
facilities that finish products by short spray finishing
sequences occur in nearly all of the industry's SIC codes, as
seen in Table 2-7.
TABLE 2-7.
WOOD FURNITURE INDUSTRY STRUCTURE BY FINISHING
SEQUENCE4
Finishing sequence
Short spray finishing sequence
Long spray finishing sequence
Roll finishing sequence
SIC
2434
2511
2512
2519
2521
2531
2541
2599
2511
2517
2519
2521
2531
2434
2517
2521
2531
2541
2599
codes
- Kitchen Cabinets
- Residential Furniture
- Uphol stered
- Furniture, n.e.c.
- Office Furniture
- Public Building Furniture
- Store Fixtures
- Furniture and Fixtures, n.e.c.
- Residential Furniture
- Radio, Television Cabinets
- Furniture, n.e.c.
- Office Furniture
- Public Building Furniture
- Kitchen Cabinets
- Radio, Television Cabinets
- Office Furniture
- Public Building Furniture
- Store Fixtures
- Furniture and Fixtures, n.e.c.
2.2.3.2 Long Spray Finishing Sequence.4 A representative
long spray finishing sequence consists of spray application of
multiple stains, followed by washcoat, glaze/filler, sealer,
highlight, and topcoat. Facilities that finish furniture with a
long spray finishing sequence can be in market segments
represented by the five SIC codes seen in Table 2-7.
2-19
-------
DRAFT
3471/650395
2/23/95
2.2.3.3 Roll. Curtain. Dip Finishing Sequence.4 Use of the
roll, curtain, and dip finishing sequence also occurs in six SIC
code industries, as listed in Table 2-7. A typical finishing
sequence for roll, curtain, and dip finishing includes
application of stain, sealer, and topcoat.
2.3 EMISSION SOURCES
2.3.1 Industry Source Definition «
The CTG for wood furniture finishing and cleaning operations
will apply to the nine SIC codes for the wood furniture industry
that were identified in Table 2-1.1'-3 In addition to these nine
SIC codes that were included in the CTG analysis, a State may, in
developing their own rule, include other processes that they
believe are best described as a wood furniture finishing
operation.
Three of the applicable SIC codes, 2519, 2531, and 2599,
involve operations associated with nonwood products. The
SIC Code 2519 includes household furniture not classified
elsewhere; SIC Code 2531 includes public building and related
furniture; SIC Code 2599 includes furniture and fixtures not
elsewhere classified. It is important to note that the CTG only
covers the wood furniture finishing operations associated with
those SIC codes. For example, SIC code 2531 includes facilities
manufacturing seats for automobiles and buses. These facilities
will not be covered by the CTG. The CTG for wood finishing
operations does apply to finishing rattan and wicker. The VOC
emissions from a wood furniture manufacturing facility resulting
from operations other than finishing, cleaning, and washoff are
not covered by the CTG for wood furniture coating. For example,
if a wood furniture manufacturing facility is involved in gluing
operations, the CTG would not apply to VOC emissions from the
gluing operations.
2.3.2 Emission Sources
The following discussions apply to the majority of finishing
operations, in which separate areas such as spray booths and
ovens have separate ventilation. There are many potential VOC
emission sources in a wood furniture manufacturing facility.
2-20
-------
DRAFT
3471/650395
2/23/95
However, four primary VOC emission sources are associated with
wood furniture finishing operations. These sources include spray
booths, flashoff areas, ovens, cleaning operations, and washoff
operations. An additional, although comparatively minor, source
of VOC emissions is the actual finished product. These sources
are further discussed below.
: i. Spray booths. In the wood furniture industry, finishing
materials are usually applied in booths; various types of spray
.application equipment are used for spray finishing techniques and
various types of roller, curtain, and dip coating application
equipment are used for flatline finishing techniques. (Booths
for both spray finishing techniques and flatline finishing
techniques will be generally referred to as "spray booths" in
this discussion.) The booths are commonly maintained at ambient
conditions. The spray booth type, size, exhaust flowrate, and
particulate control methods may vary widely within the wood
furniture industry. The types of booths that are used in the
wood furniture industry include manual and automatic spray
booths. The average size booth within the industry is 2.5 meters
(m) high, 5.2 m wide, and 3.0m deep (8.1 feet [ft] high, 17 ft
wide, and 9.9 ft deep). The spray booth exhaust rates range from
42.5 cubic meters per minute (m3/min) to 2,160 nvVmin
(1,500 standard cubic feet per minute [scfm] to 76,300 scfm); the
average exhaust rate is 527 m3/min (18,600 scfm). Table 2-8
shows the average spray booth characteristics for the overall
industry and for various segments of the industry. Particulate
control of overspray is commonly achieved with either dry filters
or water curtains.
The majority of spray booths are operated using manual
finishing techniques; approximately 84 percent are operated by
manually finishing products and 16 percent apply finishes with
automatic finishing methods.^ Automatic spray booths are often
smaller in size than manual spray booths, and exhaust rates from
automatic spray booths are significantly lower than those from
manual booths. Average dimensions for manual finishing booths
are 2.4 m by 5.8 m by 3..Q m (8.0 ft by 19 ft by 9.9 ft), compared
2-21
-------
DRAFT
3471/650395
2/23/95
TABLE 2-8. SPRAY BOOTH CHARACTERISTICS'
Industry Segment
Manual booths
Automatic booths
Short spray finishing
Long spray finishing
Roll, curtain, dip finishing
Overall industry
Average dimensions,
m (ft)
2.4x5.8x3.0 (8.0x19x9.9)
3.0x2.6x3.7 (10x8.5x12)
2.5x5.8x3.0 <8. 3x19x10)
2.3x4.6x2.8 (7.7x15x9.2)
1.5x3.4x1.9 (5.0x11x6.2)
2.5x5.2x3.0 (8.1x17x9.9)
Average exhaust,
m3/min (scfm)
609 (21,500)
66.3 (2,340)
583 (20,600)
629 (22,200)
453 (16,000)
527 (18,600)
with 3.0 m by 2.6 m by 3.7 m (10 ft by 8.5 ft by 12 ft) for
booths with automatic spraying operations. The average booth
exhaust from manual finishing operations is 609 m3/min
(21,500 scfm) and the average exhaust from booths with automatic
finishing operations is 66.3 m3/min (2,340 scfm) .9
Booth dimensions for short spray finishing and long spray
finishing sequences are similar, as shown in Table 2-8. The
average dimensions of booths used for the roll, curtain, and dip
finishing sequence are smaller than those used for short and long
spraying. The exhaust for the short spraying sequence is
583 m3/min (20,600 scfm) and for the long spraying sequence is
629 m3/min (22,200 scfm). The exhaust flowrate for the roll,
curtain, and dip finishing sequence is 453 m3/min (16,000 scfm),
somewhat lower than for short and long spraying sequences.9
Spray booth characteristics may depend on whether the
components are finished and then assembled or are assembled then
finished. The spray booths used to finish furniture products
that are first assembled and then finished are mostly open,
i.e., all sides are open except the backside. The booth design
is open to accommodate entrance and exit of larger pieces. In
segments of the industry where manufacturers finish components
before assembly, the booths are generally fully enclosed except
for slots in the sides of the booth, The unassembled pieces are
much smaller than assembled components, so the pieces can enter
and exit the booths on conveyors through these slots.
2-22
-------
DRAFT
3471/650395
2/23/95
Many spray booths are equipped with dry filters, typically a
paper material, to control participates. In the past, water
curtains had been used to control particulates. However, since
the spent water had to be disposed as a hazardous waste,
.hazardous waste disposal costs had to be considered. As these
-costs increased, the cost effectiveness of water curtain
.filtration decreased. Therefore, most n^ew and modified spray
gbooths in the wood furniture industry that use filters are
^equipped with dry filters. However, some water-wash spray booths
are still in use.
2. Flashoff areas. Flashoff areas, where solvent is
allowed to volatilize from the finished piece, are located either
between spray booths or between a spray booth and an oven. These
areas are used to allow solvent evaporation and partial curing
prior to final cure in the oven or, in some instances, are used
in lieu of an oven. Some flashoff areas have forced air
circulation and are referred to as forced-flashoff areas. Most
flashoff areas do not have a separate exhaust. A portion of the
emissions from a flashoff area located in between a booth and an
oven will be exhausted through the booth and oven; the amount
exhausted through the booth and oven depends on the total length
of the flashoff area. The length of flashoff areas varies
significantly by facility, and even within a^facility. A
flashoff area that is not followed by an oven is often longer
than one that is located in between a booth and an oven.
3. Ovens. Ovens are used between some finishing steps to
cure the finish prior to the next step in the finishing sequence.
Many types of ovens are used in the wood furniture industry.
-Most are steam heated using either a wood- or coal-fired boiler;
others are gas-fired. Turbulators and high velocity ovens are
frequently used. Infrared (IR) or ultraviolet (UV) ovens are
also used, but their use in the wood furniture industry is
limited at this time. The parameters for the ovens can also vary
considerably. Oven temperatures can range from less than 32.2°
to 191°C (90.0° to 375°F) depending on the type of finishing
material used, the piece-being finished, and the oven residence
2-23
-------
DRAFT
3471/650395
2/23/95
time; the average temperature for ovens is 58.9°C (138°F).
Residence time ranges from l to 60 min, with an average of
13 min. The exhaust rate from ovens also varies and can range
between 21.2 and 552 m3/min (750 and 19,500 ft3/min). The
average exhaust rate from ovens in the wood furniture industry is
133 m3/min (4,690 scfm).9
4. Cleaning, dilution, and washoff.operations.2^ As
discussed previously, solventborne nitrocellulose lacquers are
the predominant type of finishing materials used by the wood
furniture industry today. The resins in such finishes are
relatively "difficult" to dissolve, so a high-solvency-rated
solvent must be used in their formulation. Similarly, thinning
of these finishing materials requires the use of the same solvent
or one with equivalent solvency. This solvent is generically
referred to as "lacquer thinner." The current standard practice
is to use lacquer thinner for both incidental thinning of
premixed finishes and for cleaning and washoff. Advantages of
the lacquer thinner include its compatibility with the finishing
materials and the ease with which it removes cured nitrocellulose
lacquers.
In wood-finishing operations, industrial solvents are used
predominantly for cleaning application equipment. In addition to
application equipment cleaning, cleaning solvent can also be used
to clean out piping, clean booths and rails, strip cured finishes
from wood parts or machinery, and periodically clean centralized
finishing material storage and distribution (pump room)
equipment. They are also used to strip finishes from finished
pieces that do not meet specifications. This process is called
washoff, and it represents a significant portion of cleaning
solvent usage by the industry. Although a major use of cleaning
solvents in some finishing industries, surface preparation does
not require solvents in the case of wood furniture finishing.
Application equipment must be cleaned every time there is a
color change, every time there is a change in finishing material
type (for smaller operations with limited equipment and few
booths), and usually before the equipment is to be idled for a
2-24
-------
DRAFT
3471/650395
2/23/95
period of time (e.g., at the end of the day). For spray finish
application, equipment cleaned with solvents includes spray guns,
feed lines, and finish reservoirs (where applicable). In the
case of roll, curtain, and dip coating operations, the rollers,
spray bar nozzles, and finish material containers must be cleaned
periodically to maintain application quality as well as to change
.colors. .
t Spray guns have traditionally been cleaned by sending pure
or reused solvent through the gun and atomizing the solvent into
the booth ventilation system. Recognizing that this results in
excessive emissions of solvent, some operators cut off the
atomizing air to the spray gun and pump the cleaning solvent
through the gun,into a container. This procedure can be followed
provided the gun is the type that does not depend on the flow of
the atomizing air to pump the finish (or cleaning solvent)
through the mechanism. Alternately, the cleaning procedure may
involve soaking the entire gun in solvent in a wash tank or
bucket. This guards against the possibility that small amounts
of finishing material inadvertently missed during the cleaning
will cure and clog the small orifices of the gun. Cleaning
solvent is often reused within a facility and eventually recycled
in-house or sent out for recycling/disposal.
Generally, spray booth cleaning does not,.require significant
amounts of solvent. Usually, a strippable coating is applied to
the spray booth walls so that when solids buildup reaches a
certain limit, the strippable coating together with the solids
can be removed, minimizing the need for solvents.27 Similarly,
the spray booth exhaust filters are disposed of as solid waste
when they become clogged with coating solids. The use of
cleaning solvents for removal of finish overspray and drips is a
minor use.
In regard to the use of industrial solvents for finishing
material dilution, the majority of facilities do not dilute
finishing materials in-house; finishes are ready to use as
purchased. However, in some instances, finishes are diluted to
decrease their viscosity and improve their sprayability and
2-25
-------
DRAFT
3471/650395
3/1/95
performance. Various factors are considered in determining how
much dilution is required, i.e., the dilution ratio. In some
instances, the dilution ratio remains constant, regardless of
conditions, while in other instances, the extent of dilution is
dependent on seasonal conditions such as temperature and humidity
and may also vary according to the material being diluted. For
example, a facility may dilute sealers bv\t not topcoat. The VOC
contents of finishes presented in Chapter 4.0 represent finishing
materials as they are applied; any dilution has been taken into
account.
5. Final Wood Product. In addition to the above major
emission sources for wood furniture finishing operations, the
finished dried furniture may be a minor emission source. The
finished piece may have small quantities of solvent that
eventually volatilize. However, the amount of VOC emissions from
this source are expected to be very minor, most likely
representing less than l percent of the total VOC emissions. ^
2.3.3 VOC Emission Summary
The annual consumption of solvents by paint and coating
industries has been estimated by SRI International for the
National Paint and Coatings Association, Inc. (NPCA). A
summary of the estimated solvent consumption for the various
paint and coating industries is provided in Table 2-9. Because
the solvents used in wood furniture finishing operations do not
typically react with or become part of the finished product, the
assumption has been made that solvent consumption is
approximately equal to solvent emissions. Furthermore, because
the majority of the solvents consumed by the wood furniture
industry are considered VOC's, solvent usage is approximately
equal to VOC emissions. While this assumption provides a
reasonable estimate of overall industry VOC emissions, it is
still important to note that there are some coatings used by the
wood furniture industry which form VOC's as reaction by-products
from a curing process that involves a chemical reaction (as
opposed to only by solvent evaporation). In addition, there are
some coatings in which not all of the VOC's contained in the
2-26
-------
DRAFT
3471/650395
3/1/95
TABLE 2-9. SOLVENT CONSUMPTION IN PAINTS AND COATINGS
ORIGINAL EQUIPMENT MANUFACTURERS (OEM), 1989
(Million of pounds)
Market
Solvent
consump t iona
Original Equipment Manufacturers (OEM)
Wood furniture and fixtures
Wood flat stock •
Metal furniture and fixtures
Containers and closures
Sheet, strip, and coil
Major appliances
Other appliances
Automotive
Trucks and buses
Railroad
Other transportation
Machinery and equipment
Electrical, insulation
Paper, foil, and film
Other products finishes
OEM total
Architectural total
Special purpose total
Thinner and miscellaneous total
PAINT and COATINGS TOTAL
270
6
85
191
71
41
23
131
33
7
13
159
59
40
256
1,398
614
659
1,682
4,349
aOf the 256 million pounds of solvent consumed by the Other
Product Finishes market, 250 million pounds are considered
VOC's. Similarly, of the 659 million pounds consumed by the
Special Purpose market, 638 million pounds are considered
VOC's, and of the 1,682 million pounds consumed in Thinner
and Miscellaneous coatings, 1,659 million pounds are
considered VOC's.
2-27
-------
DRAFT
3471/650395
3/1/95
coating evaporates; some of the VOC's may chemically react to
form the dry film. Both polyester and some ultraviolet (UV)
coatings used by the wood furniture industry contain styrene
monomer, which reacts to form the coating. Some of the styrene
is emitted during the application and curing of the coating. As
indicated in this table, the wood furniture and fixture industry
consumes more solvent than any other industry listed. Other
industries that consume large amounts of solvent include the
containers and closures, automotive, and machinery and equipment
industries.
The breakdown of solvent usage by the wood furniture
industry is provided in Table 2-10. As indicated in this table,
the most frequently used solvent is toluene, followed by xylenes,
alcohols, ketones, and acetates.
29
TABLE 2-10. WOOD FURNITURE INDUSTRY SOLVENT USAGE--198929
(Millions of pounds)
Solvent
Aliphatic hydrocarbons
Toluene
Xylenes
Other aromatics
Butyl alcohol
Ethyl alcohol
Isopropyl alcohol
Other alcohols
Acetone
Methyl ethyl ketone
Methyl isobutyl ketone
Ethyl acetate
Butyl acetates
Other ketones and esters
Glycol ethers and ether esters
TOTAL
Wood furniture
8.6
71.5
40.4
9.2
27.5
27.7
15.4
2.0
3.0
15.0
19.8
7.8
14.3
2.8
4.7
270
2.4 EXISTING REGULATIONS
2.4.1 Introduction
The review of existing VOC regulations for wood furniture
finishing is helpful in defining potential control strategies and
2-28
-------
DRAFT
3471/650395
3/1/95
their effectiveness. The bulk of the research into existing wood
furniture regulations was done in 1990, and revisions were made
baaed on the latest available revised versions of the
regulations, as of January 1995. This list of regulations should
not be considered an exhaustive list of all State and local wood
furniture regulations. Nine areas identified as having existing
regulations (as of January 1994) are Illinois, Indiana,
Massachusetts, New Jersey, the New York City Metropolitan area,
Pennsylvania, and California's Bay Area, South Coast, and San
Diego County Air Pollution Control Districts. Each regulation
applies to furnishings made of solid wood, wood composition, wood
material, and/or simulated wood material. The Massachusetts, New
York City, San Diego, Bay Area, and South Coast regulations also
apply to the coating of wood products. Exemptions include
musical instruments, refinishing, replacement, and custom
furniture operations for the Bay Area regulation, flat wood
panels for the Massachusetts regulation, and classic guitars
until January 1, 1996, and refinishing, replacement, and custom
furniture operations until July 1, 1996 for the South Coast
regulation. The regulations use various strategies to limit VOC
emissions from wood furniture finishing operations. These
strategies include requiring the use of certain application
methods, such as airless, air-assisted airless, HVLP, and
electrostatic spraying, as well as roller coating, dipping, and
brushing. Other regulations require the use of lower-VOC content
or nonphotochemically reactive finish materials or the use of
add-on controls such as incinerators and carbon adsorbers. Some
of the regulations allow combinations of the above strategies to
achieve compliance.
2.4.2 Summary of Existing Regulations^°"41
The key features of the nine existing wood furniture
finishing regulations are summarized in Table 2-11. The
regulations generally apply to both existing and new facilities.
All of the nine regulations contain applicability criteria
in terms of finishing material use or VOC emission cutoffs. The
applicability criteria used in the San Diego, New Jersey, Bay
2-29
-------
D
si1
3
V)
o
H
O
H
H
Q
O
O
|2
1
t
<2
1
y^
CO
&
1
<
A
D
O
w
cd
.
TH
,_!
1
fVJ
H
9
E-<
1
3
•g
M
i
8
£><
G 1
•as
£1
|s
22
•0
S .§
u ~ E
IQU
Bay Area,
California
•|
"x
c
1
c
S
sT
V
*-*
1
w
1
c
g
San Diego C
California
S
OS
as
o 2
m r~
oo
C
£
jO
P
<
M
^
£
s
•a
4>
i
** o
*> Z^
5?
V
£
to
£
Existing
sources
g
><
j.
>^
S
£
>
«
w
4>
W
4>
i
z
3
!
• o,
iO
A|>
_-5
^ e
• o
» *s
•c •
> J
?
1
o
•«
~s
||
^ X
5s
o
*T T*
^ •
ja cl
<*> O
E x
§ --a
•g g S
.5 C cl5 e
.E S a 7 -2
a a s s s
21 111
"c »*- ^ « 2
** ° S .So
iiil ^i
o , g
|.2
si
81
VI t>
i|
'JB
|t
<" u
W
S
%
s
,
Q
W
*
«O
A|
£
8
M
4>
tn
V
s.isii|CBj8w
Al^-i!"^ S's'stiVw
1 1 gStf .|'i| &jf^«
V 2 H A| § w '5 A S A| | A|
to
O
V
c c
O V
1^1
O.5 3
O. *> O*
< E a
g
>•
H
£
5
„
M
0
M
4)
M
V
W)
4)
I »
0 0
o -^
u .3
o
z
o-C H
•"egg > • T?
!|!|«8jf ^
f~ '"""""" g .§ s"^
s=4'I
-«.— Q.o«o88«e
g,
J.-5 -
|pl
Si §.-«
He-a8|s .-j
°- .. S S •• = § o.|
UifJIlll
COOU«OOtf«C -
1
o
o
o
oglsi s
> " ~ "8 - ^
aglgfl 1
|
ll
8 S-
o e
2-30
-------
•a
a)
c
-H
JJ
C
o
u
ta
4
•
2
|
0 S
•g^
g ^
zS
s
S M
•c J
.
H
a!
.a
§
S>
"a
t}
0.
c
'•3
JC
J*
C
•••
Z
^jj
«
t=
t
g
u
o «
s|
IB
a
e ,
ill
flit
iS 8 1$
o
g>g l_
?" JJ "g • 3 §
llfflll
S
•8
.H
c
s
.i;
<
73
•5
O
o
5
S2-J
%R Cu
Bo E
a c«i v
S Al 0
Z
1.1
1 1
c2 S
•H -Q T3 "^'S'2'2 *S^
41 4> *» t* V •
Z >< >• >•>•>•>• > >
XI
* i i
V v- **•
i. ° « *§
•SIS' 1
S | « S S S S o S S S
^^o^ >• ^^-Z^ >•>"
o v S SSSv " S
Z >- >• >• >- > > > >•
o S S S S S C SS
o Z >• > >•>•>•>• >->•
O « 4> 0VOV •) 4>
^> Z >• >• >•>•>•>« >•>-
o o o SSSS S S
Z Z Z >•>•>•>« >•>-
"2-0 .2
c •- - i
III 1 | 1| i -s .s. ^ if . -
= gf "< < < '5 iS BO > Q 55 S- < 5
i
1
I
"5
•5
Q.
O
t
e.
1
*M
d.
O
1
5
>•
"8
1C
'8
&
0
•8
1C
"8
&
I
M
4)
•a
•a1
a.
o
e
M
4)
i s
i 3
§ £S^
X! &J
~ ? K
a js £
2-31
-------
•o
-H
4J
C
O
O
H
H
i
CN
i
a
u
S
s
New York City
Metropolitan Are*
1 .a
•e'l-s
Jts *s
S<3
*r *~
<£
•''i
CQ u
"S
"x
c
a.
S
.S
•p
c
|
^
'5
ES
C
1
o
O m
»1
Q£
13
V
2
_ 8
•a-s's'
'« S?'i«
J «— O
-is-g
Q i 3
Specified cotting
VOC contents
•*«1
i|e| =
I 1 1 M 'S
1 ll > i
g
o
Z
e
•8-2 -
4 g"i
n o o
u g >. »
ll-iSil
S |5 1 -| 3
5 ° c £ V "
<^ o C OQ u o
e
2W_
s-g E
«> c
* £s
*.!==
3"ef 5 « £
> « S >• >• z
33 1
*o "o
E E
§3 _ 3
12 E 8
S3"* «f*^ S o
>• oo > S >- x
J3 2 £
>• >• >«
* & * S"
S? « n 9 « c
O\ ki fj Ov i> i>
S 5-ip « 9-!^ v o
>• S « >• S^ >• Z
S"S £
o g
* &8
«S =
jf « S « « 0
>• o o >• >• Z
S 8*
2vo 3 C
K So
CU«-i Ci,™
jo 5 u
•fcO ^ ^ wO ^
8 1| I St!
^"V^J*!^"^ ^ Z
c O v o
.2 c O 30^-
I c-~ •? a ^-s,"!- s s &
« ofr fee e-^g-a-sE
.§ -Eg | -s | | g g S -a
** u"S 3° u-s'S'SSo
S,
w
.2
e ^
§ =
.-§ g>
i*H
*• 2- s o
i !! w 2
•S o
2'5-S
l-gl'I =
2-33
-------
DRAFT
3471/650395
3/1/95
Area, and South Coast regulations is in terms of amount of
finishing material used on a per hour, per day, or per year
basis. Potential and/or actual VOC emissions resulting from wood
furniture finishing operations are used to determine
applicability in the Illinois, Indiana, Massachusetts, New York,
.and Pennsylvania regulations. It is difficult to compare the
applicability criteria of the regulation^ since the bases vary.
Converting finishing material use to emissions, or vice versa,
would require several assumptions regarding VOC content of
finishes, operating hours, etc.
All of the regulations, except New York City's, contain
restrictions concerning allowable finish application method
requirements. The regulations generally specify application
methods that are believed to achieve greater transfer
efficiencies than air or airless spray. If an application method
has a higher transfer efficiency, less finishing material will be
needed and thus, VOC emissions will be lower. Initially, some of
the regulations provided transfer efficiencies for a variety of
application methods. However, because the transfer efficiency of
an application method can vary based on many factors, including
the size and shape of the piece being coated, and because there
is no EPA-accepted method of measuring transfer efficiency, the
lists of transfer efficiencies were removed from most of the
regulations.
Of the areas addressing specific application methods,
airless and air-assisted airless spraying are allowed under all
but San Diego's regulation, provided certain criteria are met.
Electrostatic spraying is allowed under all the regulations.
Roller coating, brushing, wiping, and dipping are acceptable
under all the regulations. (Pennsylvania's regulation does not
specify wiping.) High-volume low-pressure spraying is specified
as an allowable method under all of the California areas'
regulations, in Illinois' regulation, and in Pennsylvania's
regulation. It was not specified as an allowable method under
the other area regulations because in the past it has not been
used widely in wood furniture coating operations. The
2-33
-------
DRAFT
3471/650395
3/1/95
Massachusetts regulation does not indicate specific allowable
coating application methods that may be used.
Repair coating operations are allowed less-stringent
application method and transfer efficiency (T/E) requirements
under Illinois', Indiana's, and Pennsylvania's regulations. An
exemption for coatings used in small amounts is contained in the
Illinois, Indiana, and Massachusetts regulations. The San Diego,
Bay Area, and South Coast regulations also contain cleanup
operation restrictions to limit VOC emissions.
Alternative compliance methods are allowed under all the
regulations except Pennsylvania's. Each alternative compliance
program works differently and can be quite complex. Under the
alternative compliance plans, add-on controls can be used, in
conjunction with or instead of required application methods and
coatings.
The baseline level to be used for calculating equivalent
emissions for alternative compliance plans varies for the
regulations. Under the Illinois regulation, the emissions
resulting from the use of an application method with a transfer
efficiency of 65 percent for all operations (except repair coats,
which require a 30 percent transfer efficiency), and the use of
complying coatings throughout the facility, represent baseline
emissions. Massachusetts' and San Diego's baselines are the same
as Illinois' except that there is no repair coat exemption. New
Jersey's baseline definition is similar to those for San Diego
and Illinois. Baseline under Indiana's regulation is represented
by use of required application methods for all coating
operations. Baseline emissions under the Bay Area regulation are
those that result from the use of airless spraying for all
coating operations, assuming that compliant coatings are used.
The South Coast regulation defines baseline emissions as those
resulting from the use of compliant coatings (required as of
January l, 1989) for all coating operations, applied at a
transfer efficiency of 65 percent. South Coast's regulation,
however, does not allow credit for any emission reductions
resulting from the use of an application method with a transfer
2-34
-------
DRAFT
3471/650395
3/1/95
efficiency greater than 65 percent. This emissions reduction
credit was excluded because transfer efficiency is difficult to
measure and thus, resulting emissions reductions would be
difficult to quantify. Baseline emissions for New York City are
those that would result from the use of coatings with VOC
contents specified in the regulation.
Table 2-12 presents the VOC content.limitations associated
with the eight regulations that contain such restrictions. San
Diego, Bay Area, and South Coast all have a phased approach.
Under the San Diego regulation, one set of VOC-content limits
applied through January 1, 1995, when more stringent limits
became effective. There are four different phases to Bay Area's
regulation and three phases to South Coast's regulations.
2-35
-------
DRAFT
3471/650395
3/1/95
D
1
D
•n
f)
fc
H
a
H
1
H
D
D
O
i
C/}
0
H
^f
LIMIT;
CONTENT
o
g
*
CJ
H
i
cs
W
i
O
s
1
rict, California
Bay Area Dist
j
New York
City Metro-
politan Are*
1^1
.and
«r 9/1/95
O m
On and
after 7/1/90
I
On and after
7/1/94
On and after
7/1/92
On and after
8/1/91
I
j
New lenwy"
j
Sui Diejo
Cwmly,
California
S
$
A. applied, 1
n> voc/pi
-., 1
A. applied,
let* water
and excluded
VOC
j
f
"H
—Lett waler
1
S
As applkd, lei
S
VOC limiUlions are
not oonuirwd
in regublkm
Minus water
Al applied, le»s
water and exempt
compound*
As applied, less
water and
exempt
oompounds
VOC conteni
limitations, Ib/jal
.
5
s
**!
c*
|
C
c
**i
s
vi
s
ttO
w^
o-
vi
vq
(N
<0
V
l| Clear topcoat
^
,,
V
^
p
©
jjr,
O
V
f?
si
p
V
r-;
TJ
p
1
p
I
i
i
5
p
p
V
p
p
,
f;
1 Semi trans pa rent
wiping and
1 (Luint stains
,,
V
«
•0
§
O
S
p
v
4.0 (6.7)
c-_
oc
•c
4.0 (4.0)c d
II Semi tfana parent
I spray stains and
II loners
II Opaque {n>und
II 00*1* and
||enuncU
^
vi
w
ri
p
C
c
s
vi
p
s
vt
p
p
vi
p
5.0 (2,3)°
PipntnteKl
oaatinfcs
a
5
0
n
|
#?
fj
3
|
g
•o
vi
4.6 (4.6)°
|| Clear MO len
„
•»
V
S
c7
V
V
fj
iZ
p
v»
H
00 *O
2
.1 a
1 1 3
|II
M
^
n
V
1
t
I
V
2.9 (2.9)c
y,
R
b
0
rx
1
!l
p
r;
c
2
c
vi
s
c
w
vi
I*.
r-
.5
a
I
2
„
1
„
vi
^
5.7 (2.3)°
11
1!
O
ci
VV
.1
1
*•£
2-36
-------
DRAFT
3471/650395
3/1/95
2.5 REFERENCES FOR CHAPTER 2
1. U.S. Department of Commerce, Bureau of the Census, 1987
Census of Manufacturers, Industry Series MC87-I-24B,
January 1990.
_-2. U.S. Department of Commerce, Bureau of the Census, 1987
Census of Manufacturers, Industry Series MC87-I-25A,
March 1990.
»
-.3. U.S. Department of Commerce, Bureau of the Census, 1987
*> Census of Manufacturers, Industry Series MC87-I-25B,
April 1990.
4. ENSR Consulting and Engineering. An Evaluation of VOC
Emissions Control Technologies for the Wood Furniture and
Cabinet Industries. Sponsored by American Furniture
Manufacturers Association, Business and Institutional
Furniture Manufacturers Association, Kitchen Cabinet
Manufacturers Association, and National Paint and Coatings
Association. January 1992.
5. Chazin, M., editor. The FDM 300. Furniture Design and
Manufacturing. February 1990. pp. 20-158.
6. Telecon. Caldwell, M.J. Midwest Research Institute, with
Titus, R., Kitchen Cabinet Manufacturers Association.
June 18, 1990. Discussion of the cabinet industry.
7. Telecon. Smith, L., Midwest Research Institute, with
Taylor, R., American Woodmark Corporation. June 18, 1990.
Discussion of American Woodmark's facilities.
8. Telecon. Caldwell, M.J., Midwest Research Institute, with
Runyan, L., American Furniture Manufacturers Association.
November 29, 1990. Discussion of furniture market.
9. Memorandum. Rasor, S., MRI, to Strum, M., EPA/ESD/CPB.
Summary of Responses to the Information Collection Request
for the Wood Furniture Industry. January 28, 1994.
10. Survey response and attachments from Can-Am Engineered
Products, Inc., to Caldwell, M., Midwest Research Institute,
March 15, 1990. Response to information request.
11. The DeVilbiss Company. HVLP: High-Volume Low-Pressure.
Brochure. Toledo, OH. Publication No. F-817-A. 1989,
14 pp.
12. Contact Report. Caldwell, M. J., Midwest Research
Institute, with Kish, S., Graco, Inc. August 12, 1991.
Discussion of spray systems and their use with waterborne
coatings.
2-37
-------
DRAFT
3471/650395
3/1/95
13. Riberi, B., "UV-curable Unsaturated Polyester Systems for
the Industrial Finishing of Furniture." Paint & Coatings
Industry, Vol. 6, No. 7, October 1990.
14. Telecon, Caldwell, M.J., Midwest Research Institute, with
Riberi, B., Mobay Corporation. August 27, 1990.
Clarification of information provided on Section 114
information request response.
15. Survey response from PPG Industries, Inc., to Farmer, J.,
EPA/ESD. May 8, 1990. Response to Section 114 information
request.
16. Survey response and attachments from Reliance Universal,
Inc., Division of Akzo Coatings, to Farmer, J., EPA/ESD.
May 11, 1990. Response to Section 114 information request.
17. Survey response and attachments from The Lilly Company to to
Farmer, J., EPA/ESD. May 14, 1990. Response to Section 114
information request.
18. Survey response and attachments from The Valspar Corporation
to Farmer, J., EPA/ESD. May 10, 1990. Response to
Section 114 information request.
19. Survey response and attachments from Guardsman Products,
Inc., to Farmer, J., EPA/ESD. May 10, 1990. Response to
Section 114 information request.
20. Survey response and attachments from Amity Quality
Restoration Systems, Inc., to Farmer, J., EPA/ESD. May 13,
1990, Response to Section 114 information request.
21. Schrantz, J., editor. EPA Glossary. Industrial Finishing.
August 1989. pp. 45-59.
22. Telecon. Caldwell, M. J., Midwest Research Institute, with
Tucker, R., Guardsman Products, Inc. January 29, 1991.
Discussion of wood furniture finishing sequences and other
aspects of the wood furniture industry.
23. Memorandum. Christie, S., Midwest Research Institute, to
Catlett, K., EPA/ESD/CPB. Summary of Wood Finishing Seminar
conducted in Grand Rapids, Michigan, from March 4-5, 1991.
March 12, 1991. (Presentation by J. Kelbel, Guardsman
prodxicts.) pp. 8-12.
24. Domsey, S. Woodworker's guide to conventional finishes.
Furniture Design and Manufacturing. January 1988.
pp. 54-57.
25. Chemcraft Sadolin International, Inc. Wood Finishes
Brochure. Walkertown, North Carolina.
2-38
-------
DRAFT
3471/650395
3/1/95
26. Memorandum. Christie, S., Midwest Research Institute, to
Catlett, K., EPA/ESD/CPB. Preliminary Assessment of
Industrial Solvent Use in Wood Furniture Coating Operations.
January 28, 1991.
27. Alternative Control Techniques--Control of Volative Organic
Compound Emissions from Industrial Cleaning Solvents.
February 1994. EPA-453/R-94-014.
28. H. Van Noordwyk, Acurex Corp. Reducing Emissions From the
Wood Furniture Industry with Waterborne Coatings. Prepared
for the Environmental Protection Agency. EPA-600/2-80-160.
July 1980.
29. SRI International. The U.S. Paint Industry Data Base.
Prepared for The National Paint and Coatings Association,
September 1990.
30. Memorandum from Caldwell, M. J., Midwest.Research Institute,
to Catlett, K., EPA/ESD/CPB. Summary of Existing
Regulations. March 6, 1990.
31. Telecon. . Christie, S., Midwest Research Institute, with
D. Belik, Bay Area Air Quality Management District.
January 24, 1991. Wood Coatings Regulation.
32. Telecon. Beall, C., Midwest Research Institute, with
C. Lee, Bay Area Air Quality Management District.
December 13, 1991. Wood Coatings Regulation.
33. Telecon. Beall, C., Midwest Research Institute, with
J. Ross, Illinois Environmental Protection Agency.
December 17, 1991. Wood Furniture Rule.
34. Telecon. Beall, C., Midwest Research Institute, with
T. Jones, Indiana Department of Environmental Management.
December 18, 1991. Wood Furniture and Cabinet Coating Rule.
35. Telecon. Beall, C., Midwest Research Institute, with
G. Walker, New Jersey Department of Environmental
Protection. December 11, 1991. Wood Furniture Coating
Regulation.
36. Telecon. Beall, C., Midwest Research Institute, with
K. Heiss, San Diego County Air Pollution Control District.
December 13, 1991. San Diego Wood Products Coating rule.
37. Telecon. Christie, S., Midwest Research Institute, with
R. Oja, South Coast Air Quality Management District.
November 2 and 6, 1990. Transfer Efficiency Test Protocol
Development Program.
2-39
-------
DRAFT
3471/650395
3/1/95
38. Telecon. Beall, C., Midwest Research Institute, with
M. Price, South Coast Air Quality Management District.
December 11, 1991. Wood Furniture Coating Regulation.
39. Telecon. Beall, C., Midwest Research Institute, with
D. Ono, South Coast Air Quality Management District.
December 11, 1991. Implementation of the Wood Furniture
Coating Regulation.
40. Telecon. Beall, C., Midwest Researgh Institute, with
A. Latif, South Coast Air Quality Management District.
January 7, 1992. Spray Gun Cleaning Requirements for Wood
Furniture Coating Operations.
41. Telecons. Caldwell, M.J. with Illinois Environmental
Protection Agency, Indiana Department of Environmental
Management, South Coast Air Quality Management Division, Bay
Area Air Quality Management Division, San Diego Air Quality
Management Division. October 25, 1994. Changes to Wood
Furniture Regulations.
2-40
-------
DRAFT
3527/650395
2/21/95
3.0 EMISSION CONTROL TECHNIQUES
r.
This chapter discusses volatile organic compound (VOC)
emission control techniques that could potentially be used for
wood furniture finishing and cleanup operations. The control
techniques addressed in this chapter have been divided into four
categories: add-on control devices, lower VOC coatings, emerging
technologies, and pollution prevention.
3.1 ADD-ON CONTROL DEVICES
Add-on control devices are addressed within two categories:
combustion control devices and recovery devices. Combustion
control devices are defined as those devices used to destroy the
contaminants, converting them primarily to carbon dioxide (Q^)
and water. The combustion control devices evaluated within this
section include thermal incineration with recuperative and
regenerative heat recovery and catalytic incineration.
Recovery devices are used to collect VOCVs prior to their
final disposition, which may include VOC recovery, destruction,
or disposal. One recovery device that is addressed in this
section is carbon adsorption in conjunction with regeneration of
the carbon bed by steam or hot air. In either scenario, the
VOC's may be recovered or disposed of following regeneration.
Another system discussed is a proprietary system that uses
oxidant-ozone counterflow wet scrubbing and granular-activated
carbon adsorption with cold oxidation regeneration. Also within
the recovery devices section, information regarding carbon
adsorption with final destruction of VOC's by incineration is
provided.
Following the discussion of add-on control devices, wood
furniture finishing line modifications that could be implemented
3-1
-------
DRAFT
3527/650395
2/21/95
in conjunction with add-on controls are described. The finishing
line modifications discussed include those that would reduce the
volume of air sent to the control device and/or improve the
efficiency of capturing the VOC's to be sent to the control
devices. Specific finishing line modifications identified in
this section include recirculation of spray booth exhaust and
conversion of the finishing room into a t^otal enclosure. The
feasibility of applying these methods to wood furniture finishing
operations is also addressed.
3.1.1 Combustion Control Devices
Combustion is a rapid, high-temperature, gas-phase reaction
in which VOC's are oxidized to C02, water, sulfur oxides (SOX),
and nitrogen oxides (NOX). If combustion is not complete,
partial oxidation products, which may be as undesirable as the
initial VOC's, could be released. In order to avoid such
occurrences, excess air (above the stoichiometric requirement) is
used. More complete process descriptions are provided below for
each type of combustion control device.1
In addition to the process descriptions, control device
efficiency and the applicability of the control device to wood
furniture finishing operations are discussed for each of the
combustion control devices identified in this section.
3.1.1.1 Thermal Incineration.
3.1.1.1.1 Thermal incineration process description.
Thermal incineration is a process by which waste gas is brought
to adequate temperature, and held at that temperature for a
sufficient residence time for the organic compounds in the waste
gas to oxidize.2 The constituents of the waste streams generated
by wood furniture finishing operations will be converted to C02
and water in the presence of heat and sufficient oxygen.
A schematic diagram of a typical thermal incineration unit
is provided in Figure 3-1. Primary components of the thermal
incineration unit include a fan, a heat recovery device, the
combustion chamber, and the exhaust stack. The heat recovery
device is used to preheat the incoming waste stream so that less
auxiliary fuel is required in the combustion chamber. This type
3-2
-------
DRAFT
3527/650395
2/21/95
AUXILIARY FUEL Qgf
AUXILIARY AIR Q3
€MISSION SOURCE
-^ DILUTION AIR
SECONDARY
ENERGY
RECOVERY
•STACK
Figure 3-1. Thermal incinerator--general case
3-3
-------
DRAFT
3527/650395
2/21/95
of heat recovery is known as primary heat recovery and can
generally be described as either recuperative or regenerative.
If the exhaust stream is of sufficient temperature and/or heating
value so that little or no auxiliary fuel is needed, heat
recovery may not be cost effective and thus may not be
implemented. However, when auxiliary fuel is required, heat
recovery can be used to minimize energy qosts. Each type of heat
recovery is discussed in more detail in Section 3.1.1.1.3.
In order for the thermal incinerator to achieve the desired
destruction efficiency, certain key parameters must be
controlled. These parameters include the combustion airflow
rate, the waste stream flow rate, auxiliary fuel requirements,
residence time, combustion chamber operating temperature, and the
degree of turbulence between the air and combustible materials.
Residence time is the time required for the initiation and
completion of the oxidation reactions. Operating temperature is
a function of the residence time, the oxygen concentration, the
type and concentration of the contaminant involved, the type and
amount of auxiliary fuel, and the degree of mixing. The
destruction efficiency for a particular contaminant is a function
of the operating temperature and residence time at that
temperature. A temperature above 816°C (1500°F) will destroy
most organic vapors and aerosols. Turbulence, or the
mechanically induced mixing of oxygen and combustible material,
can be increased by the use of refractory baffles and orifices to
force adequate mixing in the combustion chamber. Alternatively,
mixing can be enhanced by the use of over-fire air, the injection
of air into the combustion zone at a high velocity, or by a
forced air draft,3
3.1.1.1.2 Standard operating conditions. Thermal
incinerators generally operate at a temperature ranging between
650° and 870°C (1200° and 1600°F) and require a minimum residence
time of 0.3 seconds in the combustion zone.4 Most thermal units
are designed to provide no more than 1 second of residence time
to the waste gas in the combustion chambers.5 Thermal
incinerators can be designed to control flow rates in excess of
3-4
-------
DRAFT
3527/650395
2/21/95
2,832 cubic meters per minute (m3/min) (100,000 cubic feet per
minute [ft3/min]). The VOC concentration of waste streams
controlled via thermal incineration can be from the part per
million (ppm) range to 25 percent of the lower explosive limit
.(LED • The VOC concentrations typically cannot exceed 25 percent
iEL for safety and insurance reasons.
3.1.1.1.3 Heat recovery. Heat recovery is a method of
.reducing energy consumption of the incinerator or some other
process operation. Primary heat recovery describes the process of
preheating the incoming waste stream to the incinerator by
transferring heat from the incinerator exhaust so that less
auxiliary fuel is required in the combustion chamber. Secondary
heat recovery refers to the exchange of heat in the exhaust
leaving the primary heat recovery device to some other medium
that is used in plant processes.
Primary heat recovery can be accomplished using recuperative
or regenerative devices. The waste gas preheater shown in
Figure 3-1 could be a recuperative heat exchanger. As shown in
this figure, a heat exchanger is used to transfer heat to the
incoming waste stream from the incinerator exhaust stream. In a
recuperative heat exchanger, heating of the incoming stream by
the incinerator effluent is a continuous, steady-state process.
Types of heat exchangers that are typically used for recuperative
heat recovery include plate-to-plate and shell-and-tube. The
type of heat exchanger that is chosen is based on the waste gas
flow rate, the desired heat exchange efficiency, the temperature
of the incinerator exhaust stream (used for preheat), and
economics. Recuperative heat exchangers can recover 70 percent
of the energy in the incinerator exhaust gas, thereby reducing
fuel, the primary operating cost, by 70 percent.6
An incinerator employing regenerative heat recovery is
presented in Figure 3-2. Figure 3-2 illustrates a two-chamber
design in which process exhaust air is purified in a conventional
.combustion chamber but uses two beds of ceramic material to
recover thermal energy. The process exhaust passes through a bed
of ceramic heat sink material that was left hot at the end of a
3-5
-------
DRAFT
3527/650395
2/21/95
MODE A'
AUXILIARY AIR
EMISSION SOURCE
STACK
CERAMIC PACKING
HEATING GAS
CERAMIC PACKING
COOLING GAS
COMBUSTION
CHAMBER
AUXILIARY
FUEL
STACK
EMISSION
SOURCE
AUXILIARY
AIR
CERAMIC PACKING
COOLING GAS
CERAMIC PACKING
HEATING GAS
I AUXILIARY
FUEL
COMBUSTION
CHAMBER
MODEB
Figure 3-2. Regenerable-type thermal incinerator.
3-6
-------
DRAFT
3527/650395
3/2/95
preceding cycle. As the air passes over the ceramic, it extracts
heat from the bed. This leaves the ceramic bed cool at the end
of the cycle and raises the air temperature to near the desired
thermal destruction temperature (combustion chamber temperature).
Additional heat to achieve the destruction temperature is
-.obtained by firing natural gas, propane, or fuel oil into the
combustion chamber. The airstream leaving the combustion chamber
passes through the other ceramic bed, which was left cool during
the preceding cycle. The ceramic bed absorbs the heat from the
airstream, leaving the ceramic bed hot at the end of this cycle
and the exit airstream relatively cool.
The inlet and discharge airstreams are reversed, so that the
ceramic beds absorb and reject heat from the airstream on a
cyclical basis.
When the cycle reverses and the ceramic bed at the inlet
becomes the bed at the outlet, there is still some contaminated
air left in the ceramic bed chamber. In order to attain the
maximum overall destruction efficiency from a regenerative
thermal incinerator, it is necessary to displace the volume of
contaminated air in the inlet heat sink chamber into the
combustion chamber before extracting the high-temperature
combustion air through it. A system designed to "purge" the
chamber is provided in a three-chamber design. In this system
the same type of absorption/rejection of heat occurs, but the
third chamber allows time between inlet and discharge cycles to
purge each chamber at the end of an inlet cycle.
Regenerative heat recovery systems can recover 95 percent of
the energy in the incinerator exhaust gas, with a comparable
reduction in fuel, the major operating cost.6
3.1.1.1.4 Thermal incinerator efficiency. Studies indicate
that a well designed and operated commercial incinerator can
achieve at least a 98 percent destruction efficiency (or an
outlet concentration of 20 ppm) of organics. This destruction
efficiency corresponds to incinerators that are operated at 871°C
(1600°F) with a nominal residence time of 0.75 second.7
3-7
-------
DRAFT
3527/650395
2/21/95
3.1.1.1.5 Applicability to wood furniture finishing exhaust
streams. Thermal incinerators can be used to control waste
streams containing various organic compounds and thus are
technically feasible for controlling emissions from wood
finishing operations. The compounds typically contained in wood
furniture finishing exhaust streams (aromatic hydrocarbons,
ketones, acetates, and alcohols) are al&9 present in exhaust
streams from other industries and have been demonstrated to be
readily converted to innocuous compounds using thermal
incineration technology. Based on information gathered from the
surveys sent to industry, thermal incineration is being used to
control VOC emissions in the kitchen cabinet and business
furniture manufacturing segments.
The exhaust stream from conventional wood furniture
finishing operations is characterized as a dilute concentration
of VOC in a high-volume airflow. The costs associated with
control of a dilute air stream can be very high due to
supplemental fuel requirements. (Details regarding costs are
provided in Chapter 5). However, incorporating heat recovery
into the thermal incineration design can minimize supplemental
fuel requirements and associated costs. The quantity of process
exhaust (e.g., airflow) from wood furniture finishing operations
can be reduced by recirculating the exhaust from spray booths, as
discussed in Section 3.1.3, or by reducing airflow through the
use of air curtains.
3.1.1.2 Catalytic Incineration.
3.1.1.2.1 Catalytic incineration process description.
Catalytic incineration is comparable to thermal incineration in
that VOC's are heated to a temperature sufficient for oxidation
to occur. However, with catalytic incineration, the temperature
required for oxidation is considerably lower than that required
for thermal incineration because a catalyst is used to promote
oxidation of contaminants. The catalyst is imposed on a large
surface containing many active sites on which the catalytic
reaction occurs. Platinum is the most widely used catalyst;
palladium is also commonly used.^ Because the metals used as
3-8
-------
DRAFT
3527/650395
2/21/95
catalysts are expensive, only a thin film is applied to the
supporting substrate. A commonly used supporting substrate is
ceramic.
Figure 3-3 is a schematic of a typical catalytic
.1 incineration system. As indicated in this figure, components of
.the system include a fan, a preheat burner, a combustion mixing
.-chamber, a catalyst chamber, a waste gas, preheater (recuperative
-heat recovery device), secondary heat recovery, and a stack. The
kpreheat burner is used to heat the incoming waste stream to the
required oxidation temperature, usually between 149° and 482°C
(300° and 900°F) for catalytic incineration.10 The mixing
chamber is used to thoroughly mix the hot combustion products
from the preheat burner with the exhaust waste stream. This
ensures that the stream sent to the catalyst bed is of uniform
temperature. The combustion reaction then takes place at the
catalyst bed. The catalyst bed may be a fixed bed or a fluidized
bed consisting of individual pellets enclosed in a screened unit.
The recuperative heat recovery device (if incorporated) is a
shell-and-tube or plate-to-plate heat exchanger. A heat recovery
device is used if supplemental fuel requirements are expected to
be high.10
Many parameters affect the performance of a catalytic
incineration system. The primary factors include operating
temperature, space velocity (inverse of residence time), VOC
concentration and species, and catalyst type and susceptibility
to contaminants.10 The optimum operating temperature depends on
the type of catalyst, as well as the concentration and type of
VOC's. Space velocity is defined as the volume of gas entering
the catalyst bed divided by the volume of the catalyst bed.
Space velocity depends on operating temperature. However, in
general, as space velocity increases, destruction efficiency
decreases.10 The amount and type of VOC determine the heating
value of the waste stream and thus the amount of supplemental
fuel required to maintain the desired operating temperature.
The type of catalyst that is used is determined by the VOC
compounds in the waste stream. Particulates and catalyst poisons
3-9
-------
DRAFT
3527/650395
2/21/95
UJ
O
DC
O DC
CO <
IS
CO t=
uj o
U
1
o*
co
CO DC
< UJ
UJ
O
!_ EC
So
o
j_ D:
< 01
Q- O
t
0s"
O
AJ
rt
k
0)
C
-H
O
U
-H
rH
rt
OJ
ftf
U
m
i
n
0)
Vi
Cn
03
a
_j
UJ
Z)
LL
X
3-10
-------
DRAFT
3527/650395
2/21/95
in the waste stream can affect the efficiency of the catalyst and
its lifetime. Some materials that are considered catalyst
poisons include heavy metals (mercury, lead, iron, etc.),
silicon, sulfur, halogens, organic solids, and inert
particulates.10 Particulates and poisons reduce the activity of
the catalyst site, minimizing sites available for the oxidation
reaction. These materials can also mask, plug, or coat the
.catalyst surface, thereby eliminating available catalyst sites.
3.1.1.2.2 Standard operating conditions. The catalyst bed
in catalytic incinerators generally operates at temperatures
ranging between 149° and 482°C {300° and 900°F), with
temperatures rarely exceeding 538°C (1000°F). The contact time
required between the contaminant and the catalyst so that
complete oxidation occurs is normally 0.3 second. The excess air
requirements for catalytic incineration units are usually only
1 to 2 percent higher than the stoichiometric requirements. •1:L
Catalytic incinerators can be designed to control waste gas flow
rates up to about 1,416 m3/min (50,000 ft3/min). The VOC content
of the waste stream may be in the part-per-million range up to
25 percent LEL.
3.1.1.2.3 Catalytic incinerator efficiency. A well
operated and maintained catalytic incineration unit can achieve
destruction efficiencies of 98 percent, comparable to thermal
incineration units. The destruction efficiency would decrease in
the presence of the catalyst poisons and particulates described
above.12
3.1.1.2.4 Applicability to wood furniture finishing
operations. Factors to consider in determining if catalytic
incineration is suitable for controlling VOC emissions from wood
furniture finishing operations include the waste gas flow rate,
the concentration of contaminants, and the presence of catalyst
poisons and particulates. Catalytic incineration units can be
designed to control the high-volume, low-concentration waste
streams from wood furniture finishing operations. As with
thermal incineration units, heat recovery and volume reduction
techniques are necessary to decrease the size of the unit
3-11
-------
DRAFT
3527/650395
2/21/95
required and associated capital and operating costs. Particulate
matter in the waste stream would have to be removed using
filtration to prevent fouling of the catalyst bed. (This
filtration would be in addition to the dry filters already used
on the majority of existing spray booths.) In general, catalyst
poisons would not be present in the waste stream from wood
furniture finishing operations unless large quantities of
halogenated materials are used (for example, halogenated cleaning
materials) and their emissions controlled through the catalytic
incinerator. Based on information obtained during the regulatory
negotiation effort, there is presently at least one business
furniture manufacturer using a fluidized-bed catalytic
incinerator to control VOC emissions.
A potential concern associated with using catalytic
incineration is the variability of the wood finishing waste gas
flow rate and VOC concentration. A constant gas flow rate and
concentration is recommended for optimal operation. The VOC's
contained in the exhaust flow from wood furniture coating
operations vary in composition and concentration, depending upon
which spray booths are being used and which coatings are being
sprayed, as well as the on/off nature of the spraying operation
itself as pieces pass through the booth. One vendor felt that
any application that involves many different types of pollutants
or particulates, or the potential for change in the types of
pollutants could significantly decrease the catalyst life.13'19
3.1.2 Recovery Devices
Volatile organic compounds in a waste gas stream can be
collected through adsorption of the contaminants onto a porous
bed. The contaminants can then be recovered, if desired, by
desorption of the bed with steam or hot air. After desorption,
or regeneration, contaminants can be condensed and recovered or
disposed of. Alternatively, after regeneration by hot air,
contaminants can be sent to an incinerator for destruction. This
section discusses the use of activated carbon adsorption systems
followed by steam and hot air regeneration, carbon adsorption in
3-12
-------
DRAFT
3527/650395
2/21/95
conjunction with incineration, and activated carbon adsorption
used in conjunction with oxidant/ozone wet scrubbing.
The efficiency of carbon adsorption systems and their
applicability for controlling emissions from wood furniture
finishing operations are also discussed below.
3.1.2.1 Carbon Adsorption.
3.1.2.1.1 Carbon adsorption process description. The
carbon adsorption process used to control VOC emissions from
waste gas streams can be subdivided into two sequential
processes. The first process involves the adsorption cycle, in
which the waste gas stream is passed over the adsorbent bed for
contaminant removal. The second process involves regeneration of
the adsorbent bed, in which contaminants are removed using a
small volume of steam or hot air, so that the carbon can be
reused for contaminant removal.
Adsorption is the capture and retention of a contaminant
(adsorbate) from the gas phase by an adsorbing solid (adsorbent).
The four types of adsorbents most typically used are activated
carbon, aluminum oxides, silica gels, and molecular sieves.
Activated carbon is the most widely used adsorbent for air
pollution control and is the only type of adsorbent discussed in
this section.20 Both the internal and external surfaces of the
carbon are used as adsorption sites. Diffusion mechanisms
control the transfer of the adsorbate from the gas phase to the
external surface of the carbon, from the external surface of the
carbon to internal pores, and finally to an active site in the
pores. Adsorption depends on a mass transfer gradient from the
gas phase to the surface. Van der Waals forces attract the
adsorbate to the carbon. Because adsorption is an exothermic
process, some method of heat removal from the carbon may be
necessary, depending on the amount of contaminant being removed
from the gas phase.21
Regeneration is the process of desorbing the contaminants
from the carbon. Regeneration of"the carbon bed is usually
initiated prior to "breakthrough." Breakthrough, as the name
implies, is that point in the adsorption cycle at which the
3-13
-------
DRAFT
3527/650395
2/21/95
carbon bed approaches saturation and the concentration of
organics in the effluent stream begins to increase dramatically.
If the carbon bed is not regenerated, the concentration of VOC's
in the effluent will continue to increase until it is equal to
that of the inlet; i.e., the carbon is saturated. ^ Regeneration
can be accomplished by reversing the conditions that are
favorable to adsorption--by increasing the temperature and/or
reducing the system pressure. The ease of regeneration depends
on the magnitude of the forces holding the VOC's to the surface
of the carbon. The most common method of regeneration is steam
stripping. Low-pressure, superheated steam is introduced into
the carbon. The steam releases heat as it cools; this heat is
then available for adsorbate vaporization. Another regeneration
method is the use of hot, inert gas or hot air. With either
steam or hot air regeneration, the desorbing agent flows through
the bed in the direction opposite to the waste stream. This
desorption scheme allows the exit end of the carbon to remain
O Q
contaminant - free. •"
In a regeneration process, some adsorbate, known as the
"heel," may remain in the carbon after regeneration. The actual
capacity of the carbon is referred to as the working capacity and
is equal to the total capacity of the carbon less the capacity
taken by the heel.^2
Adsorption units that are commonly used to remove
contaminant from waste gas streams include the following:
1. Fixed or rotating regenerable carbon beds;
2. Disposable/rechargeable carbon canisters;
3. Traveling bed carbon adsorbers;
4. Fluid bed carbon adsorbers; and
5. Chromatographic baghouses.
Of the five adsorption systems listed above, the first two are
most commonly used for air pollution control. The
disposable/rechargeable canisters are used for controlling low
flow rates (less than 3 m^/min (100 ft3/min) and would not be
used to control the high-volume flow rates typical of wood
furniture finishing operations. Only the fixed-bed, regenerable
3-14
-------
DRAFT
3527/650395
2/21/95
carbon adsorption system is discussed in this section. 4 Carbon
adsorption systems that use a rotating bed are addressed in
Section 3.1.2.2 and in Chapter 5.
A fixed-bed, regenerable carbon adsorption system is
presented in Figure 3-4. The components of the carbon adsorption
^system include:
l. A fan (to convey the waste gas p.nto the carbon beds) ;
'- 2. At least two fixed-bed carbon adsorption vessels;
3. A stack for the treated waste gas outlet;
4. A steam valve for introducing desorbing steam;
5. A condenser for the steam/contaminant desorbed stream;
and
6. A decanter for separating the VOC condensate and water.
In the system depicted in Figure 3-4, one carbon vessel is being
used for adsorption while the other is being regenerated. Both
vessels will alternate in the adsorption and regeneration modes.
The steam is used to regenerate a vessel and is then sent to a
condenser. The condensate is a water/VOC mixture. The decanter
can be used to separate the condensate into a water stream and a
condensate stream. Depending on its measured toxicity, the water
may be treated or discharged to the sewer. The condensed
organics can be recycled (if usable), used as a fuel, or disposed
of.
3*
In lieu of using steam for regeneration, hot air or a hot
inert gas could be employed. After regeneration, the desorbing
stream would then consist of an air or gas stream with a high VOC
concentration. This air or gas stream could then be sent to an
incinerator for final destruction of VOC's. A carbon
adsorption/incineration system is discussed in detail in
Section 3.1.2.2.
Several factors affect the amount of material that can be
adsorbed onto the carbon bed. These factors include type and
concentration of contaminants in the waste gas, system
temperature, system pressure, humidity of waste gas, and
residence time.22
3-15
-------
DRAFT
3527/650395
2/21/95
(DRYING/COOLING AIR)
f
WASTE GAS
(FROM SOURCE)
STEAM -«*»-
B
(DRYING/
COOLING AIR)
E
-tx>-
STEAM
OUT
IN
STEAM-VOC
VAPOR
COOLING
WATER
TOTAL
CONDENSER
VOC
CONDENSATE
(TO STORAGE;
PROCESSING)
1
OUTLET
GAS
WATER
(TO TREATMENT/
SEWER)
(TO STACK)
Figure 3-4.
Typical two-bed, continuously operated fixed-bed
carbon adsorber system.
3-16
-------
DRAFT
3527/650395
2/21/95
The type and concentration of contaminants in the waste
stream determine the adsorption capacity of the carbon.
Adsorption capacity is defined as the pounds of material adsorbed
per pound of carbon. In general, adsorption capacity increases
.with a compound's molecular weight or boiling point, provided all
Bother parameters remain constant. There is also a relationship
Between concentration and the carbon adsorption capacity. As
concentration decreases, so does the carbon capacity. However,
the capacity does not decrease proportionately with the
concentration decrease. Therefore, carbon capacity still exists
at very low pollutant concentration levels.22
Operating temperature also affects adsorption. Adsorption
efficiency decreases with increasing temperature. At elevated
temperatures, the vapor pressure of the contaminants will
increase, reversing the mass transfer gradient. Contaminants
would then be more likely to be desorbed back into the gas phase
than to be retained on the carbon. At lower temperatures, the
vapor pressures are lower, favoring retention of the contaminants
by the carbon.25
The system pressure also influences the adsorption
effectiveness. Increases in the gas phase pressure promote more
effective and rapid mass transfer of the contaminants from the
gas phase to the carbon. Therefore, the probability that the
contaminants will be captured is increased.25
The relative humidity or moisture content of the gas phase
affects the adsorption efficiency. Although water vapor is not
preferentially adsorbed over the contaminants, the presence of
water vapor in the gas phase has been demonstrated to have a
^detrimental effect on the adsorption capacity of the carbon.
However, the effect of humidity or moisture in the gas phase is
insignificant for VOC concentrations greater than 1,000 ppm and
during the initial startup of the adsorption cycle (the carbon is
drier). Indeed, some moisture content in the gas phase can be
beneficial. For instance, when high concentrations of
contaminants with high heats of adsorption are present, the
temperature of the carbon bed may rise considerably during
3-17
-------
DRAFT
3527/650395
3/2/95
adsorption due to the exothermic nature of the process. The
•)•}
presence of water may minimize the temperature rise. ^
Residence time has a minor effect on the adsorption
efficiency. The contaminants require sufficient contact time
with the active sites of the carbon to allow enough time for mass
transfer to occur. This is especially true if there are many
molecules (high-concentration streams) cqmpeting for the same
sites. Residence, or contact, time of the contaminants with the
active sites can be increased by using larger carbon beds, but
then the pressure drop across the system increases, resulting in
increased operating costs. ^
3.1.2.1.2 Standard operating conditions. Fixed-bed carbon
adsorption units have been sized to handle flow rates ranging
from several hundred to several hundred thousand ft /min. There
is no obvious practical limit to flowrate because multibed
systems operate with multiple beds in simultaneous adsorption
cycles. The VOC concentrations of the waste streams controlled
by carbon adsorption units can range from the part per billion
level to as high as 20 percent of the LEL. Adsorption systems
typically operate at ambient pressure and temperatures ranging
between 25° and 40°C (77° and 104°F),24
3.1.2.1.3 Carbon adsorption ef£iciency. Carbon adsorption
recovery efficiencies of 95 percent and greater have been
demonstrated to be achievable in well designed and well operated
units.26-28 The performance of the carbon adsorption unit is
negatively affected by elevated temperature, low pressure, high
humidity, etc. as previously discussed.
3.1,2.1,4 Applicability to wood furniture finishing exhaust
streams. Wood furniture finishing exhaust streams are
characterized as high-volume, low-concentration exhaust streams.
Typical contaminants may include but are not limited to aromatic
hydrocarbons, ketones, acetates, and alcohols. Exhaust streams
are usually at ambient temperature and pressure. Relative
humidity of the streams varies depending on the process and
location of the plant.
3-18
-------
DRAFT
3527/650395
2/21/95
Based on the characterization of the wood furniture exhaust
streams, carbon adsorption would be technically feasible to
control the VOC emissions from finishing operations. As with the
other add-on control options, air volume reduction techniques
should be explored to decrease capital and operating costs.
Also, particulate control is important to prevent fouling of the
carbon bed. If a specific plant is conqerned with the relative
Jiumidity of the waste stream, dehumidification options such as
refrigeration should be evaluated. The contaminants that are
typical of wood furniture finishing process exhaust (aromatic
hydrocarbons, ketones, acetates, and alcohols) can be adsorbed to
an activated carbon bed. Some alcohols, such as methanol, are
not adsorbed as readily as the other contaminants. Carbon
adsorption vendors indicated that a carbon adsorption system
designed for an exhaust stream containing methanol would probably
be more expensive.29"31 Ketones exothermically polymerize on the
carbon bed. A system designed for ketones must ensure the
airflow through the bed is sufficient to remove the heat of
reaction so that the bed temperature is not significantly
affected. Humidity can help keep bed temperatures low.
^Nonetheless, special operating conditions and provisions to
suppress bed fires may be required when ketones are present.
Plant-specific studies would be necessary to determine the
capacity of carbon required and the recommended regeneration
cycle.31'32
Based on discussions with several add-on control vendors, it
was determined that carbon adsorption followed by steam
regeneration (and subsequent condensation of the solvent) is not
an appropriate technology for controlling VOC emissions from wood
furniture finishing operations. Carbon adsorption followed by
condensation is best suited for applications involving only a few
different solvents, and there are many different solvents
contained in the variety of coatings used by the wood furniture
industry.18'33 Condensing and distilling many different solvents
is complicated, and the purity of such distilled solvents limits
their use. Because the condensate from a carbon adsorption/
3-19
-------
DRAFT
3527/650395
3/1/95
condensation system would most likely still be a mixture of
solvents, it would not be suitable for reuse in the coatings. It
could potentially be used as a fuel onsite, but because waste-
wood boilers are usually present at wood furniture facilities and
an abundant supply of wood waste is available, the additional
fuel may not be needed. The market value of the fuel is not
expected to be significant.^4 It would b,e necessary, therefore,
in some instances, to dispose of the condensate, which could be
costly. For these reasons, carbon adsorption followed by steam
regeneration was not analyzed further.
3.1.2.2 Carbon Adsorption/Incineration. As discussed in
Section 3.1.2.1, carbon adsorption units that are used to remove
VOC's from waste gases can be subsequently regenerated using
steam or hot air. In streams containing a variety of VOC's,
solvent purification is not always cost effective. Disposal
costs can also be substantial. When desorption is performed
using hot air, an alternative final disposition is incineration.
There are systems currently available that use synthetic polymer
adsorbents such as that used in the Polyad or Purus Systems, or
zeolite as found in the Hunter's Zeol System. However, because
carbon has been used extensively as an adsorbent in the past, in
this section, the use of incineration in conjunction with carbon
adsorption systems is discussed. The process description, system
efficiency estimates, and an assessment of the applicability of
the system to wood furniture finishing operations are provided
below.
3.1.2.2.1 Carbon adsorption/incineration process
description. A carbon adsorption system in which the desorption
stream is sent to an incinerator operates on the principles of
adsorption and combustion, which have previously been discussed.
Basic system components, include the following:
1. System fan to convey the waste stream to the carbon
adsorber;
2. Carbon adsorption unit for collecting contaminants;
3. Inlet air fan for air to be used in regeneration;
3-20
-------
DRAFT
3527/650395
2/21/95
4. Heat exchangers for preheating air for regeneration and
prior to introduction to the incinerator;
5. Carbon adsorption unit being regenerated;
6. Thermal or catalytic incinerator for VOC destruction;
and
7. Exhaust stack for treated (incinerated) exhaust.
» During system operation, the process exhaust stream is
directed through the carbon adsorption bed, the contaminants are
collected on the carbon, and the treated stream is exhausted out
a stack. Prior to breakthrough of the carbon, the gas flow is
switched to a fresh carbon adsorption bed and the used bed is
regenerated. Some designs incorporate a rotary wheel, which
contains the-adsorbent. The wheel constantly rotates, so that at
any time half the adsorbent is adsorbing and half is being
regenerated. In the fixed-bed and rotary designs, ambient air is
directed through a heat exchanger to be preheated (by the
incinerator exhaust) to a temperature sufficient for
regeneration. The heated air is used to desorb contaminants from
the carbon bed. The desorption air is sent through another heat
exchanger to be further heated and then introduced into the
incinerator where the contaminants are destroyed. The
incinerator exhaust is directed through the two heat exchangers;
heat from the incinerator exhaust preheats the^ outside air and
the stream sent to the incinerator.
With the carbon adsorption/incineration system, contaminants
from a volume of waste gas are first collected on the carbon bed.
A much smaller volume of air (approximately one-tenth the
original volume) is used for regeneration and sent to the
incinerator. The incinerator used for VOC destruction is much
smaller than the unit that would have been required for the
initial waste gas volume. Also, the waste stream sent to the
incinerator has a higher heating value, so that less auxiliary
fuel may be required. Finally, with incineration, the VOC's are
destroyed. With carbon adsorption alone, proper disposal of the
water/VOC stream must be considered.
3-21
-------
DRAFT
3527/650395
2/21/95
3.1.2.2.2 Standard operating conditions. The standard
operating conditions that were identified for carbon adsorption
units also apply in this case. The carbon adsorption/
incineration systems can handle a broad range of flow rates and
VOC concentrations and are especially suited to weaker streams at
100 ppm VOC and below where conventional systems are most
expensive to operate. •
3.1.2.2.3 Carbon adsorption/incinerator efficiency. A
well-designed, -operated, and -maintained carbon adsorption/
incineration system can achieve an overall destruction efficiency
of 97 percent. Higher efficiencies have also been reported.^7'35
3.1.2.2.4 Applicability to wood furniture finishing exhaust
streams. As discussed previously, carbon adsorption and
incineration are technically feasible technologies for the
control of the contaminants present in wood furniture finishing
exhaust streams. The use of these two technologies together is
also technically feasible. The technology is especially well-
suited to applications like the wood furniture industry, which
has high-volume, low-concentration exhaust streams with many
different solvents present. This technology is currently being
used to control VOC emissions in the business furniture
manufacturing industry segment.
3.1.2.3 Enhanced Carbon Treatment System. Terr-Aqua Enviro
Systems has developed an air pollution control system that is
referred to as an ultraviolet (UV)-oxidation air pollution
control system. Depending on the contaminants involved and the
sources, the specific system designs include aqueous-phase
scrubbing and activated carbon adsorption. Oxidant generated on-
site, as required, is used to neutralize captured organics on a
continuous basis. The resultant exit streams (air and water, as
applicable) contain only carbon dioxide and water. °
3.1.2.3.1 Enhanced carbon treatment process description.
The UV-oxidation technology uses UV light plus ozone and other
oxygen-based oxidants to create smog and complete the process of
oxidation. Some of the specific equipment designs and process
3-22
-------
DRAFT
3527/650395
2/21/95
techniques are proprietary and the subject of patent
applications. Basic system components include:
1. Two-stage prefilter to remove particulate;
2. Photolytic reactor, which uses UV light and oxidant to
begin destruction of the VOC's;
\- 3. Aqua reactor, where the exhaust is scrubbed with
ozonated water and soluble VOC's collect, in the water;
4. Water recycling tank, where the VOC's are removed from
the water;
5. Carbon adsorber units, which remove the remaining VOC's
from the airstream; and,
6. Activated oxygen generators.
Operation of the system can be described as follows. A
typical system collects the exhaust from paint booths, ovens,
etc. and ducts it to the system where a two-stage prefilter
collects particulate from the airflow. From there the air passes
through the photolytic reactor, where it is exposed to tuned
frequency UV light and injected with oxidant. At this point in
the process, the molecular structure of the VOC's is starting to
break down. Next, the effluent stream is scrubbed with ozonated
-water in the aqua reactor. Many of the VOC's are water soluble
and will collect in the water. The water is then heavily
oxidized in the water, recycle tank for an extended period of
time, which completes the oxidation of the VOC's to carbon
dioxide and water. The process water is then recycled back to
the aqua reactor.
After the aqua reactor, the effluent air stream goes through
a coalescer, which removes micron-level water droplets and wetted
^articulate entrained in the airstream. The air then goes into
one of two (or more) carbon beds where the remaining organic
material is removed. These beds are alternated every 24 hours,
.or as required. One bed stays on-line to collect VOC's while the
other bed is sealed and fed oxidant to regenerate the carbon.
-This regeneration is the last step of converting the remaining
VOC's to carbon dioxide and water.36"39
3-23
-------
DRAFT
3527/650395
2/21/95
3.1.2.3.2 Standard operating conditions. The standard
operating conditions that were identified for carbon adsorption
units also apply in this case. Critical components in the UV-
oxidation system design are modular in design, thereby
accommodating various airflow requirements, from a few
1,000 ft3/min to as large as necessary. The largest Terr-Aqua
UV-oxidation system in operation is designed to control
approximately 2,549 m3/min (90,000 ft3/min). The UV-oxidation
systems are well suited for streams that contain multiple
solvents; unlike a conventional steam-regenerated adsorption
system, it does not generate a mix of solvents requiring
disposal. No secondary wastes are created.36"39
3.1.2.3.3 Enhanced carbon treatment efficiency. A well
maintained UV-oxidation system can achieve removal and
destruction efficiencies in the 95 to 99 percent range.37
3.1.2.3.4 Applicability to wood furniture finishing exhaust
streams. The UV-oxidation air pollution control system is a
feasible control technology for the control of VOC's. Three
Terr-Aqua UV-oxidation systems have been installed at aircraft
painting facilities operated by General Dynamics; the first
system was installed in 1986. As of January 1995, there is only
one installation at a furniture plant. A Terr-Aqua system
designed to handle 90,000 scfm of exhaust began operating at a
large residential furniture plant in November 1991.40'41
3.1.3 Methods of Minimizing Control Costs--Volume Reduction
3.1.3,1 Recirculation. As previously discussed, exhaust
streams from wood furniture finishing operations are generally
high-volume and low-concentration streams. In wood finishing
operations, volume reduction techniques should be explored for
three reasons, each of which has merit to the plant owner for
economic reasons: (l) to reduce air flow sent to an add-on
control, (2) to concentrate the air stream to be sent to the add-
on control device, and/or (3) to reduce makeup air requirements.
First, prior to buying add-on controls, any reduction in the
exhaust air volume from spray operations allows the purchase of a
smaller control unit. Second, the exhaust stream would be more
3-24
-------
DRAFT
3527/650395
3/2/95
concentrated with the potential for savings in the auxiliary fuel
required. (Thus, both capital and operating costs associated
with the add-on control device could potentially be reduced.)
Third, reduced exhaust air volume reduces makeup air
^requirements; the energy required for heating and cooling the air
would decrease, as would the overall energy cost. This section
discusses recirculation of spray booth exhaust as a volume
reduction technique. Spray booth design modifications and the
applicability of recirculation to wood furniture finishing
operations are also addressed in this section.
Recirculation is used as a volume reduction technique to
reduce the volume of makeup air required in a spray booth and/or
the volume of air sent to an add-on control device. In
recirculation, part of the discharge air from the spray booth is
recycled. The remaining air is exhausted to the atmosphere or to
an add-on control device. Makeup air is supplied at the rate at
which air is exhausted to the atmosphere (or control device) from
the booth.
The amount of air that can be recirculated is limited by the
maximum VOC concentration allowed in the booth. In a manned
.spray booth, the VOC concentration in the booth must remain below
the permissible exposure level (PEL). The Occupational Safety
and Health Administration (OSHA) allows the use of recirculation
in manned booths, provided the VOC concentration does not exceed
the PEL. According to OSHA representatives, the VOC
concentration must be measured as soon as recirculation is
implemented. The VOC concentration must be measured again if a
process modification occurs that could initiate a change in spray
booth operations.43'43
The OSHA standard governing spray booths was based on an old
National Fire Protection Association (NFPA) standard. (NFPA
No. 33-1969 is cited in OSHA regulations). The NFPA standard was
revised in 1990, but the revised NFPA standard has not been
formally incorporated into the OSHA regulations. The current
version of NFPA No. 33 (1990) allows spray booth recirculation if
the air is continuously monitored and automatic shutdowns are
3-25
-------
DRAFT
3527/650395
2/21/95
provided.44 Though OSHA currently allows the use of recircula-
tion, as described above, the revised NFPA code has not been
formally incorporated into the OSHA regulations.
In an automatic spray booth, the VOC concentration in the
booth must be less than 25 percent of the LEL, pursuant to
insurance company requirements. The NFPA requires an LEL monitor
if the VOC concentration is expected to exceed 20 percent of the
LEL.45 The OSHA representative indicated that most spray booths
are equipped with alarms that are activated if the VOC
concentration exceeds 25 percent of the LEL.42
Recirculation may only be feasible if the design of the
spray booths that are currently used in finishing operations is
modified. The following subsection briefly describes the types
of booths currently used in the wood furniture industry and
discusses how those booths may need to be modified to incorporate
recirculation.
3.1.3.2 Spray Booth Design Modifications. Paint spray
booths currently used by wood furniture manufacturers vary
according to the coating application method used, as discussed in
Chapter 2. Booths in which coatings are applied manually are the
most common. They are mostly open and require large volumes of
ventilating air. Booths in which coatings are applied using
automatic equipment are also used, and these booths are usually
more enclosed. In order to incorporate recirculation, the design
of the more open booths would need to be modified. The same
booth modifications could be performed for both manual and
automatic coating operations, with either spray application or
flat line finishing.
As was discussed in Chapter 2, a typical manual spray booth
is 2.4 m (8.0 ft) high, 5.8 m (19 ft) wide, and 3.0 m (9.9 ft)
deep, with three open sides. An example of such a booth is
depicted in Figures 2-1 and 2-2. The coatings may be applied
manually by a worker using spray guns. The booth is ventilated
by a side draft such that the air moves past the worker, over the
piece, and through filters to remove overspray and is exhausted
3-26
-------
DRAFT
3527/650395
2/21/95
out the booth stack to the atmosphere. Typically, dry filters
are used, although some water wash booths are still used.
The OSHA regulations concerning spray finishing operations
state that the total air volume exhausted through a spray booth,
At a minimum, shall be such as to dilute solvent vapor to at
ieast 25 percent of the LEL of the solvent being sprayed. The
.regulation also provides a table indicating the minimum required
Velocities into spray booths, as a function of the type of spray
operation (manual or automatic) and spray application method
(electrostatic or nonelectrostatic). For manual spray operations
using air-operated guns, a minimum design airflow velocity of
30 meters per minute (m/min) (100 feet per minute [ft/min]) is
recommended, though velocities in the range of 23 to 38 m/min
(75 to 125 ft/min) are in compliance.4° Based on an average
ventilating air rate of 609 nrVmin (21,500 scfm) and a filter
cross-sectional area of 14.1 m2 (152 ft2) (2.4 m x 5.8 m [8.0 ft
x 19 ft]), the average side draft velocity for manual spray
booths is 43.0 m/min (141 ft/min).9
Both manual and automatic spray booths could be enclosed by
minimizing the openings for the piece to enter and exit to the
,greatest extent possible. The limiting factor will be the size
of the largest piece being finished and the space required for
the conveying system t(hooks, pallets, etc.). ^^he auto industry
minimizes the openings by using masks or silhouettes that mount
in the booth opening to accommodate differently sized and shaped
pieces. Also, the front of the booth, where the worker stands,
could potentially be further enclosed. To meet OSHA
requirements, the minimum air velocity must be maintained across
the entire length of the booth in which the worker could
potentially operate. By minimizing the opening in the front of
the booth, the ductwork required for recirculation could be
installed. The extent of volume reduction is a function of the
extent to which the booth openings can be minimized while
maintaining the minimum required velocity across the worker.
3.1.3.3 Classic Systems' CamBooth.47 Classic Systems is a
company that has .since *gone out of business that developed a
3-27
-------
DRAFT
3527/650395
2/21/95
unique design called the CamBooth spray booth, herein referred to
as CamBooth. Although the company apparently is no longer
operating, the CamBooth technology is described in this section
to demonstrate the types of modifications that can be made to a
spray booth to incorporate recirculation. The company indicated
the CamBooth can reduce the volume of exhaust air by
approximately 80 percent compared to a conventional spray booth.
The basic design of the CamBooth involves the use of air
curtains; the worker stands outside of the booth and sprays
through the air curtain. The air curtain provides a barrier
between the worker and the solvent emissions inside the booth
resulting from spraying coating on the piece.
The CamBooth booth can be designed to be from 2.4 to 7.3 m
(8 to 24 ft) long. The booth features downdraft design with
filters located on the floor of the booth to control the
overspray. The face velocity across the filters is between
38 and 61 meters per minute (125 and 200 feet per minute). The
total exhaust rate from the Cambooth is from 71 to 170 m^/min
(2,500 to 6,000 scfm), depending on the length. The CamBooth
spray booth operates at a slight negative pressure; the makeup
air flow is less than the exhaust rate. According to Classic
Systems, the air curtains minimize dirt problems typically
associated with operating at negative pressure.
The booth design can also include an adjacent, enclosed
flash tunnel. As with the spray booth, air curtains separate the
air inside the flash area from the outside air. The design is
such that if an abatement device is used, the exhaust from the
flash tunnel can be sent to the control device. Because the
exhaust rate from the CamBooth is so much lower than conventional
booths, the reduction in makeup air requirements decreases makeup
air heating and cooling costs. Also, because the volume of air
exhausted from the booth is low, the capital and operating costs
of an add-on control device are reduced.
Advantages of the CamBooth spray booth include the reduced
makeup air requirements, the low exhaust volume, and the air
curtain design. The low exhaust volume reduces the capital and
3-28
-------
DRAFT
3527/650395
2/21/95
operating cost of an add-on control device. The air curtain
design separates the worker from the VOC emissions. Thus, the
VOC concentrations inside the booth can exceed the normal
permissible exposure limit (PEL). Therefore, if an add-on
control device were used in conjunction with the CamBooth, a more
concentrated stream could be sent to the control device,
resulting in lower auxiliary fuel requirements in the case of an
Incinerator, or greater adsorbent capacity in the case of an
adsorber.
A disadvantage of the CamBooth, is that in some instances it
unacceptably limits the worker's access to the piece. A
demonstration of the CamBooth spray booth was provided at a large
household/residential furniture manufacturer^ The furniture
manufacturer felt that the CamBooth spray booth was not
applicable for finishing large three-dimensional pieces. During
the demonstration, the spray operator reportedly broke the air
curtain (stuck his head through the curtain) in order to reach
the back side of the three-dimensional part.48 Training of the
worker may eliminate such problems. If worker training is not
sufficient, it may be possible to modify the design of the
CamBooth to eliminate this problem.
3.1.3.4 Applicability to Wood Furniture Finishing
Operations. Both automatic and manual application booths in the
wood furniture finishing industry utilize spray booth
recirculation.45'49 Recirculation is also used in other
industries performing surface coating operations involving manual
and automatic equipment.50"54 Studies have also been conducted
by EPA to ascertain the feasibility and safety of
recirculation.55'56 Those studies conclude that recirculation
can safely and effectively be used in paint spray booths. Based
on the use of recirculation by furniture manufacturers and on the
studies conducted to date, the incorporation of recirculation
appears feasible for all segments of wood finishing, with
appropriate booth modification.
An existing spray booth can, in some instances, be modified
to incorporate the use of recirculation. However, if an existing
3-29
-------
DRAFT
3527/650395
2/21/95
booth is modified, undesirable rolling turbulence may be created,
resulting in finish quality problems.57 The majority of the
spray booth vendors contacted recommended replacing the existing
booths with new booths that incorporate recirculation into the
original design.54'58"60
The potential impact of incorporating spray booth
recirculation on the insurance premiums fior a facility was
examined. A representative of a company that insures plants in
the wood furniture industry said that there is no simple answer
to the question of what would happen to insurance premiums if a
manufacturer began using a spray booth with air recirculation.
The insurance representative said that the premiums for a
facility are determined by an analysis of the entire plant, not
just a given area. The representative said that some additional
safety precautions, such as installation of an LEL monitor and
possibly sprinklers within the booth, could be required if spray
booth recirculation is used. Decisions regarding requirements
and premiums are site-specific, according to the insurance
representative.61
Some office and cabinet manufacturers have modified the
spray booth designs in their facilities in order to incorporate
recirculation.45 In addition to the facilities already using
modified spray booths, some spray booth vendors have designed
spray booths that utilize smaller volumes of air. These booths
may or may not incorporate recirculation.62'63 These booths have
been and are being tested in facilities that surface-coat and are
discussed in further detail in Section 3.3.
As of May 1992, Classic Systems' CamBooth was being used in
production at one facility, is being installed at two additional
facilities, and was being tested by several others. The CamBooth
was being used at a coating manufacturing facility. The CamBooth
was installed in April 1992 and is used for spraying test
coatings developed by the coating manufacturer.
3.1.4 Total Enclosure of the Finishing Line
The overall control efficiency of an add-on control system
is the product of the capture efficiency of the system and the
3-30
-------
DRAFT
3527/650395
2/21/95
control device destruction efficiency. Therefore, to achieve the
highest overall control, the capture efficiency must be
maximized. Capture efficiency is defined as the fraction of all
VOC's generated that are captured and sent to an add-on control
device. Capture efficiency can be assumed to be 100 percent if
sthe source of VOC is totally enclosed (e.g., spray booth, flash
area, etc.). This section describes a total enclosure, provides
the EPA criteria for verifying that an enclosure is total, and
discusses the applicability of total enclosures for wood
furniture finishing lines.
3.1.4.1 Total Enclosure Description/Criteria. A total
enclosure is a structure that completely surrounds a source of
emissions such that all VOC emissions exhaust through a duct to a
control device.
The EPA has developed the following criteria for verifying
f-C
if an enclosure is a total enclosure. 3
1. Any natural draft opening (NDO) is at least four
equivalent opening diameters from each.VOC-emitting point. An
NDO is defined as any permanent opening in the enclosure that
remains open during operation of the facility and is not
-.connected to a duct in which a fan is installed;
2. The total area of all NDO's does not exceed 5 percent of
the surface area of the enclosure's four walls., floor, and
ceiling;
3. The average facial velocity (FV) of air through all
NDO's is at least 3,600 meters per hour (m/hr) (200 ft/min). The
direction of air through all NDO's is into the enclosure; and
4. All access doors and windows whose areas are not
.included in No. 3, above, are closed during routine operation of
the process.
Procedures for determining NDO's and FV are provided in the
EPA enabling document, The Measurement Solution--Using a
Temporary Total Enclosure for Capture Efficiency Testing.^
3-31
-------
DRAFT
3527/650395
3/2/95
3.1.4.2 Applicability to Wood Furniture Finishing
Operations. A total enclosure may be set up over an individual
booth or oven or over an entire finishing line. Alternatively,
an entire finishing room may function as a total enclosure.
Establishing a total enclosure for an individual
booth/oven/flashoff area may be difficult given the current
method of wood furniture finishing. The,wet piece leaves the
booth, and the solvent in the coating material flashes off in an
open area prior to entering the oven. In some facilities, the
conveyor loops back and forth to provide increased flash/dry
time. In many facilities, expansions have resulted in very
little unused space. Therefore, space constraints in the
finishing area may prohibit enclosing portions of the finishing
line or the finishing line in its entirety. One solution may be
to have the entire finishing room function as a total enclosure.
An entire finishing room could function as a total enclosure
if it meets the criteria,--i.e., all booths and ovens were
exhausted to a VOC control device and there were no other exhaust
points from the room. The room would have to be maintained at a
slight negative pressure; the volume of makeup air supplied under
pressure must be less than the volume of air exhausted. Open
windows and doors would be considered NDO's. A total enclosure
must be designed to maintain VOC levels below OSHA limits in all
areas of the plant.
3.2 LOWER VOC FINISHES
Volatile organic compound emissions from wood furniture
finishing operations can be reduced by using coating materials
that contain fewer VOC's. Currently in wood furniture finishing
operations, VOC emissions result from the application and
subsequent evaporation of finishing materials. Efforts have been
made to develop and introduce finishing materials for the wood
furniture industry that contain fewer VOC's. The EPA has
published a report on current and emerging technologies that can
reduce VOC emissions from the coating industry.66 The lower VOC
coatings that are currently available or reportedly will be
available in the near future are discussed in this section, and
3-32
-------
DRAFT
3527/650395
3/6/95
the VOC reductions that these materials offer are identified.
The types of finishing operations for which these coatings could
potentially be used are also discussed. Finally, the advantages
and disadvantages of these lower VOC finishing materials are
identified.
3.2.1 Use of Lower VOC Finishing Materials
The finishing material descriptions, provided in this section
Include the finish formulation, the VOC content of the finish,
percent solids by weight, and some general finish
characteristics. By comparing the VOC content of the
conventional finish material currently used by the wood furniture
industry with the VOC content of the lower VOC finishes, and
assuming the same quantity of solids is applied (except for
nonfilm-forming low-solids finishes), an estimate of potential
VOC emission reductions associated with each finish is provided.
Alternative finishing systems in which some of the steps involve
lower VOC finishes are presented for the different model plants
in Chapter 5. Waterborne,and higher solids coatings, the lower
VOC finishes focused on for the model plants, are discussed in
this section.
The VOC emission reductions identified in this chapter have
been calculated based on the switch from nitrocellulose-based
finishes to the new finishing system. Because^ the new finishing
systems are model plant-specific, the VOC emission reductions
presented in Chapter 6 are more likely to represent actual plant
emission reductions than the VOC emission reductions presented in
this chapter.
The types of finishing materials currently used for wood
furniture finishing in general have been identified in Chapter 2.
Finishing materials include stain, washcoat, glaze/filler,
sealer, highlight, and topcoat. The sealers and topcoats, or
lacquers, constitute the majority (approximately 65 percent) of
finishing materials used. The lacquers are clear coats and, in
"the conventional formulations, are nitrocellulose products. The
stain materials are alcohol-based and do not contain
nitrocellulose. ,While lower VOC finishes have been developed for
3-33
-------
DRAFT
3527/650395
2/21/95
nearly all finish types, the most commonly used lower VOC
finishes are those for the clear coat steps. Thus, the focus of
this section is on the clear coats. Therefore, when conventional
nitrocellulose coatings are discussed, only the lacquers (clear
coats) are actually being considered. Lower-VOC stain materials,
which reduce the VOC content by replacing some of the alcohol
with water, are also being used by the industry.
Lower VOC coatings that could replace the traditional
nitrocellulose products include waterborne and higher solids
coatings. Higher solids coatings include catalyzed, ultraviolet
(UV) - curable, polyester, polyurethane, and those modified for
the UNICARB® and VOC Control® coatings systems. A description of
the traditional nitrocellulose products and the lower VOC
finishes are provided below. In the following descriptions, the
VOC contents are provided in: (1) grams of VOC per liter of
finishing material, less water, less negligibly photochemically
reactive compounds (g/L-water) (pounds of VOC per gallon of
finishing material, less water, less negligibly photochemically
reactive compounds tIb/gal-water]) and (2) grams of VOC per gram
of solids used (g/g solids) (pounds of VOC per pound of solids
used [Ib/lb solids]). The solids content is expressed as percent
solids by weight.
3.2.1.1 Nitrocellulose-Based Finishes. Nitrocellulose-
based finishes are the most widely used finishes in the wood
finishing industry today.^7 The primary components of these
materials are cellulosic resins, film-forming resins,
plasticizers, and solvent. Nitrocellulose is the cellulosic
resin that is most widely used. It is prepared by nitration of
cellulose with nitric acid. ® The nitrocellulose serves as a
binder in the finish material. The film-forming resins are
thermoplastic and are characterized by their low resistance to
heat and solvents. The plasticizers contained in the finishes
can be esters or oils. Solvents are selected depending on
required application, manner of drying, and other conditions.
Some solvents, such as acetone and ethyl acetate, are included in
the formulation due to their high evaporation rate because they
3-34
-------
DRAFT
3527/650395
2/21/95
serve to shorten the flashoff time. Other solvents, such as
esters and glycol ethers, serve as active solvents to dissolve
the nitrocellulose. Finally, solvents such as butyl acetate and
xylene are selected for their low evaporation rate to prevent
^premature drying and the associated problems of bubbling and
blistering.69'70
Nitrocellulose-based finishes are rvonconvertible finishes.
*That is, film formation and drying occur via solvent evaporation;
•no chemical reaction, or curing, takes place. Nitrocellulose-
based finishes are categorized as fast-drying. They are
relatively easy to spray. Because of the low solvent resistance
of the thermoplastic resins and nitrocellulose in the
formulation, nitrocellulose finishes are easily dissolved, and
thus pieces finished with nitrocellulose finishes are both easy
to damage and relatively easy to repair.70'71 Their function is
both to give the pieces the desired aesthetics and to protect the
substrate.
The average VOC content of nitrocellulose-based lacquers is
approximately 727 g/L-water (6.1 Ib/gal-water) and 4.0 g/g solids
(4.0 Ib/lb solids). The solids content of nitrocellulose-based
lacquers is approximately 20 percent by weight.72"77
3.2.1.2 Waterborne Finishes. Waterborne finishes are
finishes in which water is the main solvent oar dispersing
*7fl
agent./0 There are distinct differences between the various
waterborne formulations that are available. Based on the types
of polymers used in the formulation, waterborne finishes may be
water emulsions, solutions, or colloidal dispersions.78'80 The
various polymers determine the cured film properties of the
finish. However, there is one common feature: each type employs
water as the major solvent or carrying liquid for polymers.79"80
Waterborne finishes formulated with water-emulsion polymers
are true emulsions; the polymers are discrete water-insoluble
spherical particles of high molecular weight uniformly dispersed
in water. Waterborne finishes that are considered solutions are
formulated with copolymers (referred to as water-reducible
polymers in some industry publications) that are formed in a
3-35
-------
DRAFT
3527/650395
2/21/95
polymerization reaction occurring in a water-miscible solvent
such as alcohol. The polymers have polar groups that allow
water-reducibility and, thus, true solutions of polymers in
water. Waterbome finishes known as colloidal dispersions
contain colloidal dispersion polymers (referred to as water-
soluble polymers in some industry publications). These polymers
are materials in which particles of a medium molecular weight
(not as high as the emulsion polymers) are dispersed in water.
The colloidal dispersion polymers have polar groups, thus
allowing some degree of solubility. The colloidal dispersion
formulations are not true solutions but are also not true
emulsions because there is some degree of solubility of the
polymers in the solvent.80
Each type of waterborne finish, like all finishes, exhibits
different film properties depending on the type of polymer in the
formulation. The water-emulsion formulations are of a higher
molecular weight and therefore offer advantages in the areas of
durability and chemical and stain resistance.79'80 Water-
reducible formulations offer high gloss, clarity, and good
application properties. However, their film is not as durable as
that of the water-emulsions, and the viscosity and properties of
the finishes are very dependent on molecular weight.79 The
water-soluble formulations exhibit properties of the water-
emulsion and water-reducible formulations. The water-soluble
finishes offer high gloss and good application properties and are
also durable and chemical- and stain-resistant.79
Waterborne finishes can be formulated for air/force drying
or for baking, depending on the binders in the formu-
lation,72'79'81 Waterborne finishes may cure in the same manner
as the solventborne finishes. Curing occurs through oxidative or
thermosetting cross-linking reactions. Waterborne finishes may
also cure via latex coalescence.79'81 Latex coalescence occurs
when a polymer is dissolved in solvent, then dispersed in water.
Either the solvent or water then evaporates, leaving a polymer
dispersed in solvent or water. As the remaining liquid
evaporates, the pressures force the polymer to coalesce. No
3-36
-------
DRAFT
3527/650395
3/1/95
polymerization takes place; these are a special form of
nonconvertible finishes.
The VOC content of waterborne finishes varies substantially.
Waterborne finishes are usually not free of VOC. Cosolvents are
added to allow adequate coalescence and film formation, as well
" R">
as color penetration for pigmented materials.^ Based on the
survey information, waterborne finishes .have a VOC content of
approximately 328 g/L-water (2.7 Ib/gal-water.) The VOC content
based on solids ranges from approximately 0.3 to 0.8 g/g solids
(0.3 to 0.8 Ib/lb solids). The average solids content of the
waterborne finishes in the surveys is 24 percent by
weight.77'82"88 Southern California Edison Company conducted a
study in 1993 to identify the availability of waterborne finishes
with a VOC content of less than 275 g/L-water (2.3 Ib/gal-water).
Finishes were evaluated on the basis of physical performance and
aesthetics and compared to solventborne finishes. The finishes
QQ
tested did not contain exempt solvents. y Based on the VOC
content of nitrocellulose-based finishes, the waterborne finishes
represent 75 to 88 percent reduction in VOC emissions per weight
of solids applied. However, a plant's overall VOC emission
reduction depends on the number of finishing steps for which
waterborne finishes can be used.
3.2.1.3 Higher Solids Finishes. Higher,solids finishes are
— _. ^^t,
common in various segments of the wood furniture industry. The
higher solids finishes consist of catalyzed, ultraviolet (UV)-
curable, polyurethane, polyester, those modified for the UNICARB®
system, and those in Akzo's VOC Control® system. Based on
equivalent solids applied, the higher solids coating results in
.lower VOC emissions than traditional finishes. A description of
the various higher solids finishes is provided below.
3.2.1.3.1 Catalyzed finishes. The most common catalyzed
finishes used in the wood furniture industry today are the acid-
catalyzed finishes. The film-forming resins contained in these
finishes are usually a urea-formaldehyde or melamine-formaldehyde
prepolymer, in admixture with an alkyd resin that serves as a
plasticizer. The catalysts that are used in these finishes vary.
3-37
-------
DRAFT
3527/650395
3/1/95
Common catalysts contained in the acid-catalyzed finishes include
sulfuric acid and p-toluenesulphonic acid.71 Catalyzed finishes
can be in a one-pack or two-pack form. The one-pack finishes are
precatalyzed. They contain nitrocellulose resins and a smaller
percentage of the urea resin. Also, only a small amount of
catalyst is added. Thus, cure time is long; it is usually 3 to
4 weeks until full curing occurs. Eventually, the finishes will
cure in the container. The pot life is usually 2 to 3 months.
The two-pack finishes must be mixed before use. The two-pack
finishes are formulated with urea or melamine resins. More
catalyst is contained in these than in the one-pack. Thus,
curing time is short. The main advantage of the one-pack form is
that the user does not have to be concerned with weighing and
mixing constituents prior to application. However, the two-pack
products are considered to have superior properties as compared
to the one-pack products.71'72
Catalyzed finishes are convertible finishes; film formation
occurs through curing (polymerization) of the resins rather than
drying.72 The finish is cured through a chemical reaction, the
rate of which is controlled by the amount of catalyst in the
finish. Depending on the coating formulation and the amount of
catalyst used, reaction by-products may include alcohol,
formaldehyde, and water.^° Acceptable catalyzed finishes yield a
cured film that is hard, tough, scratch- and impact-resistant,
and resists water, alcohol, and common household chemicals.71
The VOC content of the catalyzed clear coats used by the
industry today is approximately 547 g/L-water (4.6 Ib/gal-water)
with solids content of 48 percent solids by weight. 27f^"1 The
VOC content based on solids is 1.1 g/g solids (1.1 Ib/lb solids).
Based on the VOC content of the nitrocellulose-based finishes,
the catalyzed finishes represent a 62 percent VOC emission
reduction per weight of solids applied. Therefore, a facility
would reduce VOC emissions by 62 percent for each finishing step
that could be converted to catalyzed finishes. However, as
previously stated for the waterborne finishes, actual VOC
3-38
-------
DRAFT
3527/650395
3/6/95
emission reductions for a particular facility are a function of
the number of steps for which catalyzed finishes can be used.
Conversion varnishes are a type of catalyzed coating that
are used in the wood furniture industry. Conversion varnishes do
not dry as quickly as nitrocellulose finishes, and are difficult
to repair. Conversion varnishes, like two-pack catalyzed
finishes, have a limited shelf life. .
The VOC content of the conversion varnishes used by the
industry today is approximately 600 g/L-water (5.0 Ib/gal-water),
with a solids content of about 35 percent by weight. The VOC
content based on solids is approximately 1.9 g/g solids
(1.9 Ib/lb solids).72"77'91 Based on the VOC content of
nitrocellulose-based finishes, conversion varnishes represent a
43 percent VOC emission reduction per weight of solids applied.
However, the total emission reduction depends on the number of
finishing steps that are switched to conversion varnishes.
3.2.1.3.2 Ultraviolet-curable finishes. Radiation curing
is a technology that utilizes electromagnetic radiation energy to
affect chemical and physical change of organic finish materials
by the formation of cross-linked polymer networks.88 One type of
radiation used is UV light. The primary components of UV-curable
finishes are multifunctional polymers (acrylates, acrylated
oligomers), monofunctiqnal diluent monomers, and the
photoinitiators. The photoinitiator absorbs the UV light and
initiates free radical polymerization, the curing process.88 The
diluent serves as a viscosity modifier for the finish, enabling
the finish to be applied to the substrate. It is similar to a
solvent in this regard. In traditional UV finishes, however,
most of the diluent also polymerizes and becomes part of the
coating film.80 However, the diluent in the finish that does not
reach the piece and, thus, is not incorporated into the final
film, is emitted.
Ultraviolet-curable finishes are convertible finishes; the
curing process is via polymerization. The curing process for
UV-curable finishes is very fast. As the substrate is exposed to
UV radiation, the photoinitiator absorbs the light and initiates
3-39
-------
DRAFT
3527/650395
3/1/95
near-instant polymerization. Polymerization, or curing, of the
material is rapid, providing a final film that is stain-,
scratch-, and mar-resistant.71'92 Because the curing is so
rapid, finished pieces can immediately be stacked. Other
properties of the UV-cured film include heat resistance,
durability, and good build.
Ultraviolet-curable finishes do not,typically contribute
substantial VOC emissions (due to the polymerization process
discussed above) and often are considered to contain up to
100 percent solids since 100 percent of the components react to
form the coating. Some UV-curable finishes are formulated such
that some conventional solvent that volatilizes is added along
with the diluent monomer. The VOC content of these materials is
approximately 458 g/L-water (3.8 Ib/gal-water) and
0.15 g/g solids (0.15 Ib/lb solids); they are approximately
87 percent solids by weight.77'82"84'86"88 The UV-curable
finishes represent approximately an 83 percent reduction in VOC
emissions per weight of solids applied. However, as previously
stated, these emission reductions depend on the number of
finishing steps used by a facility that switches from
nitrocellulose to UV-curable finishes.
3.2.1.3,3 Polyester finishes. Two types of polyester
finishes are available for use in the wood furniture finishing
industry. The first type is the styrene-derived polyester. This
type of polyester uses styrene as a solvent and reactant for
unsaturated alkyd resins contained in the finishes. The styrene-
derived finishes contain a dryer, also known as an accelerator or
promoter, typically a heavy metal such as cobalt. Curing can
occur through a catalytic reaction, or through exposure to UV
radiation. To cure the finishes via a catalytic reaction, an
organic peroxide is added to serve as a catalyst.70 The styrene-
derived polyesters can be supplied in a two-pack or three-pack
form. In the three-pack form, the dryer and catalyst are added
by the user. In the two-pack form, the dryer is already in the
finish formulation and the catalyst is added.71
3-40
-------
DRAFT
3527/650395
3/1/95
The second type of polyester finishes is the acrylic
polyesters. These finishes contain cross-linking acrylics and
solvents such as esters, ketones, and aromatic hydrocarbons.
Some of the cross-linking acrylics are modified by styrene and
are considered special types of the styrene-derived polyesters.
lAs with the styrene-derived polyesters, curing can occur via a
catalytic reaction by organic peroxides or through exposure to
sradiant energy.70 The cured films of both types of polyester
finishes are characterized as high-build, fast-drying, durable,
and heat-, chemical-, and mechanical-resistant materials.71
Polyester finishes are very difficult to repair once cured.
Therefore, minimizing the amount of dirt in the finishing room is
critical to minimizing, rejects. Because of this, clean room
environments eire strongly recommended for polyester finish
applications.82•83
The styrene-derived polyester finishes are typically
100 percent solids. The VOC's, such as styrene, which are
present in the finish formulation, become part of the cured film.
However, a small portion of such materials may not cross-link and
therefore may result in some VOC emissions. The acrylic
polyesters have a VOC content of approximately 402 g/L-water
(3.4 Ib/gal-water) and 0.21 g/g solids (0.21 Ib/lb solids) and a
solids content of 80 percent by weight .77/ 82/ **.4' 87 Based on the
VOC content of nitrocellulose-based finishes, polyester finishes
represent approximately an 83 percent reduction in VOC emissions
per weight of solids applied. However, a facility is not likely
to use polyester materials for all of its finishing steps.
Therefore, overall emission reductions would be less.
3.2.1.3.4 Polvurethane finishes. Polyurethane finishes are
formed through the reaction of a polyhydric alcohol with an
isocyanate cross-linking resin. The isocyanates in the
formulation may include toluene diisocyanate, naphthalene
diisocyanate, or hexamethylene diisocyanate. The polyhydric
alcohol could be glycerol, pentaerythritol, or others.70»93
There are three classifications of polyurethane finishes
depending on the formulation or cure process: (1) one- component
3-41
-------
DRAFT
3527/650395
3/2/95
products, (2) two-component products, and (3) moisture-cured
materials. The one-component and two-component products are
different in their formulations. A one-component product is a
urethane alkyd, which contains no free isocyanate. The
two-component products are the most common and produce a finish
by cross-linking a polyester resin with an isocyanate. The
moisture-cured product is a special one-component product, based
on the way the coating is cured, as discussed below.93
The two-component polyurethane finish products are
convertible finishes; film formation occurs through
polymerization. The finish material is cured through a chemical
reaction taking place between the binders in the product and
binders in the hardener.71 Film formation of one-component
polyurethane finishes may occur through polymerization or through
moisture curing. Moisture-cured finishes are not fully cured
through polymerization. However, they are not nonconvertible
finishes such as the nitrocellulose-based finishes described
above. Final curing of the moisture-cured finishes occurs when
moisture in the environment reacts with free isocyanate groups to
form the dry film. The curing rate of the moisture-cure finishes
cannot be controlled and can require several months for final
cure.7^1 The final cured film of all the different types of
polyurethane finishes is durable. It is resistant to chemicals,
scratches, and abrasion. Polyurethane products are characterized
as good for polishing, providing a high-gloss finish.71
Polyurethane finishes, like polyester, are difficult to
repair once they have cured. Because the cured polyurethane film
is resistant to solvents, repairs involve mechanically removing
the cured coating through abrasion. Due to the difficulty of
repair and the final finish achievable once repaired,
polyurethane coated pieces are rarely repaired extensively.
Therefore, it is critical to minimize the amount of dirt in the
finishing room. If dirt gets on a wet nitrocellulose lacquer, it
can often be rubbed out after the lacguer has dried. However,
polyurethane finishes are not rubbed; it is not possible to
remove dirt from cured polyurethane finishes by rubbing. For
3-42
-------
DRAFT
3527/650395
3/1/95
this reason, finish suppliers indicate a clean room environment
is highly desirable when applying polyurethane finishes.82'83
The VOC content of the currently available polyurethane
finishes ranges from about 239 to 792 g/L-water (2.0 to
6.6 Ib/gal-water) and range from 0.25 to 2.33 g/g solids (0.25 to
2.33 Ib/lb solids). The solids content of polyurethane finishes
ranges between 30 and 80 percent by weight.69'77'82'84 As
compared to the nitrocellulose-based finishes, polyurethane
finishes represent from approximately a 27 to 92 percent
reduction in VOC emissions per weight of solids applied. A
facility would reduce VOC emissions by this amount for each
finishing step that was converted to use polyurethane finishes
from using nitrocellulose-based finishes. However, a facility's
overall VOC emission reduction would depend on the number of
finishing steps for which polyurethane finishes could be used.
3.2.1.3.5 UNICARB® System Finishes. The UNICARB® finishing
system was developed by Union Carbide as a way to apply
conventional finishes that minimizes the quantity of VOC-
containing solvent required. The general concept behind the
UNICARB® system is that some of the solvent used for spraying the
conventional clear coats is replaced by C02. Thus, the UNICARB®
system involves modified finishes and a somewhat modified
application method, as described in Chapter 2. This section
provides information regarding VOC content and solids content of
the finishes formulated for use with the UNICARB® system.
The UNICARB® finishes are specially formulated. They
contain polymers and high boiling-point solvents that are mixed
with liquid C02 immediately prior to being sprayed. As a rule of
'thumb, 1 pound of CO2 "replaces" 1 pound of solvent in the
conventional finishes. The same resins that are used in
conventional (nitrocellulose-based) finishes are used in the
UNICARB® finishes. UNICARB® finishes are spray-applied and dried
in the same manner as conventional (nitrocellulose-based)
finishes. "^
The UNICARB® finishes are only available in clear coat
formulations. The VOC ..content of these formulations is
3-43
-------
DRAFT
3527/650395
3/1/95
approximately 643 g/L-water (5.4 Ib/gal-water) and 1.4 g/g solids
(1.4 Ib/lb solids). The solids content of the UNICARB® finishes
is approximately 41 percent solids by weight.77'82'84'85 The VOC
content of the UNICARB® finishes represents approximately a
48 percent reduction in VOC emissions per weight of solids
applied, compared to their traditional nitrocellulose-based
counterparts. However, actual overall VOC emission reductions
are a function of the number of finishing steps for which
UNICARB® finishes can be used.
3.2.1.3.6 VOC Control® System.94 The VOC Control®
finishing system was developed by Akzo Nobel Coatings, Inc. The
VOC Control® system finishes are higher-solids
nitrocellulose-based sealers and topcoats. The finishes are
heated and then applied using an application system developed by
Graco. The Graco system can be either air assisted or air
assisted airless, and uses "ultra-high" pressures to atomize the
higher-solids finishes.
The higher solids content of the VOC Control® system
finishes allows, in some instances, for the user to eliminate
finishing steps; by applying more solids during each step, steps
can be eliminated.
The VOC content of the VOC Control® system sealers is less
than 1.9 g/g solids (1.9 Ib/lb solids), and that of topcoats is
less than 1.8 g/g solids (1.8 Ib/lb solids). The solids content
of the VOC Control® finishes ranges from 30 to 50 percent by
weight. As compared to conventional nitrocellulose-based
finishes, VOC Control® finishes represent about a 41 to
44 percent reduction in VOC emissions per weight of solids
applied. A facility would reduce VOC emissions by this amount
for each finishing step that was converted to VOC Control® system
finishes. However, a facility's overall VOC emission reduction
would depend on the number of finishing steps for which VOC
Control® system finishes are used.
3-44
-------
DRAFT
3527/650395
3/1/95
3.2.2 Applicability of Lower-VOC Finishes to Wood Furniture
Finishing Operations
i
As previously mentioned, nitrocellulose-based finish
materials are extensively used in the wood furniture finishing
industry. Attempts are being made to reformulate finishing
materials, as described above, so that lower-VOC materials can be
used. Some of the lower VOC coatings may not apply to all
aspects of the wood finishing industry. Therefore, this section
identifies the industry segments able to use each of the lower
VOC finishes and discusses the shortcomings of the finishes that
prevent their more widespread use.
3.2.2.1 Waterborne Finishes. Waterborne finishing
materials are .currently being used by some furniture
manufacturers. The potential exists for waterborne finishes to
be used by all segments of the wood finishing industry. However,
the waterborne finishes currently available are better suited to
certain applications than others. For example:
1. Open-pore woods are considered easier to finish with
waterborne finishes than filled pores;82'84
2. Darker woods sometimes appear cloudy when finished with
waterborne finishes, though the clarity has improved over the
ft?
last 10 years;0
3. Waterborne finishes do not have the rubbability of
nitrocellulose lacquers, and the finish is therefore not as
glossy where a glossy finish is required; and
4. Waterborne finishes may require a modified drying method
(increased airflow and temperature).82'83
Some facilities may be able to use waterborne finishes for
.some finishing steps but not all. According to finish material
suppliers, in certain applications only solventborne stains and
washcoat can be used because of the problems of grain
raising.82"88 Grain raising is a swelling of the fibers in the
wood due to the absorptance of a liquid, such as water. Grain
raising causes the surface of the wood to look and feel rough.
Waterborne topcoats are available and are used by many segments
of the wood furniture industry.82"88
3-45
-------
DRAFT
3527/650395
3/2/95
3.2.2.2 Catalyzed Finishes. Catalyzed finishes (primarily
conversion varnishes) are currently used by kitchen cabinet and
office/business furniture manufacturers because of the durable
finish that these finishes provide. Catalyzed finishes are also
used in the manufacture of knock-down furniture.71 However,
catalyzed finishes are presently not used much in the manufacture
of traditional household/residential furniture because the
catalyzed finishes do not provide the same appearance as the
nitrocellulose-based finishes. Technically, catalyzed finishes
could be applied to household/residential furniture and would
provide a more durable and stain-resistant surface than the
traditional nitrocellulose-based lacquers. The consumer would
have to weigh the positive and negative aspects of furniture
finished with the two chemistries. If, however, the purpose of
the changeover to catalyzed finishes is only VOC emission
reduction, other alternative finishes provide more substantial
emission reductions.
3.2.2.3 Ultraviolet-Curable Finishes. Ultraviolet-curable
finishes are currently used in various segments of the wood
finishing industry.95 Ultraviolet-curable finishes can be
applied using spray equipment, roll coaters, or curtain coaters.
Therefore, the potential exists for UV-curable finishes to be
used on case goods as well as flat pieces, and progress in this
direction has been made and is discussed in Section 3.3.3.
However, curing of three-dimensional pieces remains difficult
because all of the finish material must be exposed to the UV
radiation. Problems arise in curing recessed surfaces that do
not get direct exposure to the radiation.83 Therefore, the
majority of UV-curable finishes that are used in the wood
furniture industry are on flat line operations (although some
Q f\
chair finishing is being done using UV-curable finishes).^D Many
studies are being conducted in the area of three-dimensional UV-
curing so that UV-curable materials may experience more
widespread use in the future.
Ultraviolet-curable finishes are feasible and demonstrated
for finishing operations in which the pieces are flat, with no
3-46
-------
DRAFT
3527/650395
3/1/95
significant carvings or recessed areas. There are two types of
UV-curable finishes. One type is applied via a curtain coater,
roll coater, or similar flat line apparatus. The UV-curable
finishes applied by these methods typically are almost
100 percent solids with a VOC content close to
zero.77' 82-84, 86-88 ip^ other main type of UV-curable finishes
are applied using conventional spray application equipment.
* As discussed previously, the VOC content, percent solids,
and material cost of the sprayable UV-curable finishes are
approximately the same as the VOC content percent solids, and
cost of the polyester and polyurethane finishes.77'82"84'86"88
The cost parameters that need to be considered in the conversion
are also the-same. However, with UV-curable finishes, the
additional cost of UV ovens needs to be considered. (Polyesters
and polyurethanes can be catalyzed with curing enhanced by
conventional ovens.)82"84'86 Because converting from sprayable
solventborne finishes to sprayable UV-curable finishes is
expected to be more expensive for a facility than converting to a
pe/pu system, and the associated emission reduction would be
approximately the same, the use of sprayable UV-curable finishes
was not analyzed further.
3.2.2.4 Polyester Finishes. Polyester finishes are similar
to polyurethanes in their uses and their limitations. The film
properties of the polyester finishes are good; they provide good
build and good chemical-, mechanical-, and heat resistance.69
Polyester finishes, like polyurethane finishes, require a clean
room environment, which can be very expensive and difficult to
maintain; have a short pot life; and are difficult to repair.71
3.2.2.5 Polyurethane Finishes. Polyurethane finishes are
used in some segments of the wood finishing industry.
Polyurethane materials can be spray-applied or applied by curtain
or roll coat, and are cured in the conventional manner.
Polyurethane finishes are characterized by a high-gloss look,
which may not be desirable to certain segments of the wood
furniture industry. Other limitations that may impair its
3-47
-------
DRAFT
3527/650395
3/1/95
widespread use include the need for a clean room environment, the
short pot life (1 to 6 hours), and the difficulty in repairing.71
Polyurethane finishes are based on polyisocyanates, which
are manufactured from diisocyanate monomers, which link to form
the polyisocyanate chains.97,98 A common misunderstanding
regarding the manufacture and use of polyisocyanates is in the
use of monoisocyanates. Monoisocyanates ,are very volatile and
very toxic. However, monoisocyanates are not used in
manufacturing polyisocyanates nor are they a byproduct of the
manufacturing process.97,99-101
The level of worker protection required when using finishes
containing polyisocyanates depends on the concentration of
polyisocyanates in the air. The OSHA regulations regarding
respirators state that air purifying respirators can be safely
used at concentrations up to 10 times the threshold limit value.
Above this concentration, supplied air respirators must be
used. 7 A manufacturer of diisocyanates and polyisocyanates
recommends using supplied-air respirators when using polyurethane
finishes unless sufficient air monitoring data have been
collected to make an alternate decision.97'102 Further worker
protection can be achieved by engineering controls, primarily
spray booth design and ventilation to keep the concentrations
below the exposure limits.98 In all use of polyurethane
finishes, protection of eyes and skin should be ensured through
the use of safety glasses and permeation-resistant gloves
(preferably of butyl rubber)."
Based on available information, it is possible to safely use
polyurethane finishes in wood furniture finishing operations.
Spray booths should be designed to minimize the concentration of
isocyanates. Some level of respiratory protection should always
be worn; the exact type of protection depends on actual
measurement of isocyanate levels. Eye and skin protection must
always be worn.
3.2.2,6 UNICARB® Finishes. As of October 1994, the
UNICARB® finishing system has been purchased by one
household/residential furniture manufacturer and is being used in
3-48
-------
DRAFT
3527/650395
3/1/95
full production applying topcoat on a chair line. This line was
used to conduct an evaluation of product quality, waste
reduction, and economic issues for the UNICARB® system in a
May 1994 report.103 Testing has been conducted "by a piano
manufacturer, and a residential furniture manufacturer that makes
occasional furniture, though no purchase agreements with these
facilities have been reached.105'106 ,
.,. The solids content of UNICARB® finishes is approximately
twice that of conventional solventborne finishes. Therefore, in
some instances, a coating step can be eliminated if a facility
switches to UNICARB®. For instance, if a facility applies two
coats of topcoat using conventional finishes, only one coat of
UNICARB® topcoat may be required. Whether a finishing step can
be eliminated depends on the desired build and other site-
specific factors.
In UNICARB® finishes, the faster solvents are replaced with
supercritical C02. Since the faster solvents are no longer
present, drying time may increase. The increase in drying time
required, if any, depends on the exact finish formulation and
site-specific conditions.
3.2.2.7 VOC Control® Finishes. The VOC Control® finishing
system is being used by more than ten wood furniture
manufacturing facilities. Akzo's Nobel's VOC Control® finishing
system is currently being used in both high- and low-end
furniture manufacturing operations. According to the Akzo Nobel
Coatings representative, the use of the VOC Control® system by
the wood furniture industry is growing rapidly.^4
Because the VOC Control® finishes are higher solids finishes
than their conventional counterparts, use of the system can
eliminate finishing steps. Therefore, the system offers the most
advantages to an operation that currently applies several lacquer
coats, because some of the applications can be eliminated.
Conversely, the system would not be as adaptable to an operation
that had a limited number of finishing steps because elimination
of finishing steps may not be practical.^4
3-49
-------
DRAFT
3527/650395
7/12/95
According to the Akzo Nobel Coatings representative, due to
the high solids content of the VOC Control* finishes, drying time
may increase in some instances.94 Any potential increase in
drying time would depend on the site-specific conditions and the
exact finish formulation.
3.2.3 Advantages and Disadvantages of Lower VOC Finishes
Each type of coating discussed in thp.s chapter has
advantages and disadvantages associated with its use. Based on a
survey of wood furniture finish suppliers, Table 3-1 presents a
comparison of the suppliers' opinions concerning the properties
of each finish type.82"88 The information provided includes the
finish properties only. The ranking of finish properties in
Table 3-1 reflects the opinions of finish suppliers and probably
represents desirable qualities from the standpoint of finish
suppliers and wood furniture manufacturers. The importance of
the various qualities to a consumer may be different.
As indicated in Table 3-1, finish suppliers feel that
advantages of nitrocellulose finishes, conventional as well as
higher solids, include the appearance of the finish, the ease of
application and drying of the finish, and the ability to remove
the finish and thus repair deficiencies in the near-finished
product. According to the survey respondents, a disadvantage of
the nitrocellulose finish is its durability, which is not as good
as other types of finish materials.
The nitrocellulose UNICARB® finishes offer the same
advantages and disadvantages. An additional disadvantage that
may be associated with UNICARB® finishes is an increase in the
amount of drying time required. However, any potential increase
in drying time may be offset by eliminating a finishing step.
There may be a disadvantage associated with the UNICARB® system
because at present, only one manufacturer makes the application
system for the wood furniture industry, and only two finish
manufacturers are presently formulating UNICARB® finishes for the
wood furniture industry.
According to survey respondents, advantages of the
waterborne finishes include their resistance to yellowing and to
3-50
-------
DRAFT
3527/650395
7/12/95
00
00
1
04
CO
; w
H
i&
%%
2 o
n) ®*
J W
K H
B*
* i \j
55
0°
^s
W 9
5* ^\
s°
. w
r* w
^S
Qj
™&
|CQ
CO
H
!5
H
C
1
U
V.
O
^
O
5
p
u
§
1
2,
Ui
O
I
2
1
i
c5
|
V
>
D
E
§
•S
JJ
^
0
J2
"3
"o
Z
'roperties
HM
'"
^*
CM
CM
CM
CO
» Workability
CO
to
CO
CM
eo
CM
CO
'5
(C
K-
o
o
CO
to
to
CM
CO
eo
CM
f\
» Resistance to extrenw
temperatures
CO
CO
CO
CO
eo
CM
CM
» Durability
CO
CM
CO
CO
eo
CM
CM
2
i
CM
eo
eo
CM
eo
CM
CM
J\
> Mechanical resistance
CO
CO
CO
CO
CM
-*
• Chemical resistance
CM
CM
CM
CM
CM
en
CM
00
c
» Resistance to yellowi
to
""
~*
fM
—
CM
CO
1
I
V)
CO
•""^
"*
,-c
—
fs|
en
0
2
en
""*
"""
*~
—
CM
CO
85
O
1
0
J
'£
CM
^
CO
CO
CM
CM
M
i
3
to
<
•
CO
CM
to
CM
(s^
eo
> Application by spray
equipment
3
^
N
*"*
to
«— *
*•«
CM
b
£
8
c
» Application by curtai
Z
CM
*""*
«M
CO
CM
eo
—
§
• Application by roll c<
to
01
*~*
«"*
—
CM
CO
> Ambient cure
CO
CM
CO
to
~
C4
en
s:
|
1
u
to
CM
CM
to
—
CM
CO
M
I
u
o
8
3-51
-------
DRAFT
3527/650395
7/12/95
extreme temperatures. Also, the waterborne finishes are
satisfactory in terms of the finish quality, finish application
and cure, and the ability to wash off/repair. A disadvantage of
the waterborne finishes is the difficulty in applying them using
a fan or curtain coater, due to their inability to hold together
well. Waterborne finishes are more susceptible to breaks in the
fan or curtain. According to one finish .supplier, adding
surfactants may minimize or eliminate this problem.82 Another
disadvantage that may be associated with waterborne finishes is
the requirement for increased drying capacity, and the potential
for grain raising.
As indicated in Table 3-1, the main advantages of the UV-
curable finishes are their durability, their ability to be
applied by several methods, and their resistance to chemicals,
temperature, and yellowing. Disadvantages of these finishes to
the wood furniture manufacturer include their inability to wash
off/repair, the curing difficulties that may be associated with
the finish, and the limited experience of the manufacturers with
the use of the finishes on case goods.
The advantages and disadvantages of the urea or melamine
catalyzed, polyester, and polyurethane finishes are similar to
those of the UV-curable finishes. However, the urea and melamine
catalyzed, polyester, and polyurethane finishes offer additional
advantages in that they are satisfactory for use on case goods
and are more easily cured. Disadvantages of polyester and
polyurethane finishes to the furniture manufacturer include their
being difficult to work with and repair, the requirement for a
clean room environment, and the potential need for increased
worker protection.
3.3 EMERGING/SPECIALIZED TECHNOLOGIES
Several technologies currently in the developmental stages
could potentially apply to the wood furniture industry. These
technologies are in the areas of spray booth design, curing
methods, and add-on control devices. The spray booth design
discussed in this section is the Mobile Zone design, which
reduces the volume of air exhausted. The curing method discussed
3-52
-------
DRAFT
3527/650395
7/12/95
in this section is three-dimensional UV curing. Developments in
this area would facilitate the use of UV-curable finishes on case
goods. Finally, biofiltration, an add-on control technology that
is used in other countries for both odor and VOC control, is
discussed.
-3.3.1 Mobile Zone Spray Booth62'106'107
Mobile Zone Associates has developed a device which, when
installed on a spray booth, enables the worker(s) to spray
finishes from a partially enclosed mobile work platform. The
worker stands inside a moving "cab," the movement of which is
controlled from inside the cab by the worker. Within the Mobile
Zone cab, fresh ventilating air passes across the painter from an
open "moving..window" at his or her rear. The remaining section
of the mobile work platform is ventilated using recirculated air.
The Mobile Zone design contrasts with a conventional spray booth,
in which the entire length of the booth is supplied with fresh
ventilating air. Through the use of the moving window, the
ventilating air requirements for the worker are greatly reduced.
The fresh makeup air requirements of the mobile zone are equal to
the flow through the window, greatly reduced compared to
conventional booths. The reduction in makeup air requirements
would reduce heating and cooling costs, as well as capital and
operating costs of an add-on control device.
The Mobile Zone system was tested in a commercial job shop
finishing operation that uses solvent-thinned paint. The testing
involved finishing flat panels. The facility's conventional
spray booth was modified by the addition of the Mobile Zone.
Design, fabrication, and installation of the mobile zone was
conducted under an EPA Small Business Innovation Research (SBIR)
grant. The testing program indicated that the Mobile Zone
allowed the company to reduce the spray booth exhaust flow rate
by 90 percent.
The Mobile Zone is considered an emerging technology for
several reasons. The Mobile Zone system was used commercially
for a short time by a metal working operation that has since
ceased finishing operations. As of February 1995, the system is
3-53
-------
DRAFT
3527/650395
7/12/95
not presently being used anywhere commercially. Finally, the
Mobile Zone is considered an emerging technology for the wood
furniture industry because testing thus far has occurred on a
overhead conveyor line; most furniture manufacturers employ
pallet lines, which run along the ground. Mobile Zone Associates
indicated that it thought the system could be used on a pallet
line. However, this may not be the best application for the
system.
3.3.2 Three-Dimensional Ultraviolet Curing
Ultraviolet-curable finishes are frequently used by flat
line furniture finish operations. The pieces are flat, so curing
in a conventional UV-cure oven is straightforward. Although
UV-curable finishes are also applied to case goods (nonflat
pieces), the UV curing process with such pieces is much more
difficult. In order for a UV-curable finish to cure, all finish
must be exposed to the UV light. The lamps in the UV oven must
be situated to ensure exposure to all areas of the case goods,
including recessed areas, carvings, etc. The UV lamp locations
would need to be set for each type of case good depending on its
configuration. Because furniture manufacturers typically produce
many different types of case goods on a single line at any time,
realignment of the UV lamps for each situation on such a line is
not feasible. However, if a manufacturer produced a single piece
continuously for a length of time, the lamps could be arranged
for that configuration. Then another type of piece could be
produced for a length of time, after the lamps were adjusted.
Some three-dimensional UV ovens have been designed for
specialized applications. Typically, these applications involve
the consistent finishing of one type of piece (i.e., one chair
design). In such applications, the UV lamp configuration does
not require realignment with the introduction of each piece. For
the majority of case goods finishing operations, however, three-
dimensional UV curing is considered an emerging technology.
Finish suppliers, oven manufacturers, and furniture manufacturers
continue to conduct research in this area.
3-54
-------
DRAFT
3527/650395
7/12/95
3.3.3 Biof iltration108"113-
Biofiltration is a control technology in which contaminated
exhaust air is sent through a biofilter for contaminant removal.
The biofilter consists of organic matter, such as tree bark and
compost, the pores of which are filled with water. In the water
phase, biologically active micro-organisms are present, partly
free-floating in the water and partly attached to the organic
matter.
The mechanism of the biochemical process consists of a
combination of adsorption, absorption, and biological
degradation. As the exhaust air travels through the biofilter,
pollutant removal from the gas phase occurs in two ways. By Van
der Waals forces, some pollutant molecules in the waste air are
adsorbed by the organic matter. Some of these molecules transfer
from the gas phase to the water phase by means of absorption. To
maintain the adsorption and absorption capacity of the biofilter,
the activity of the aerobic micro-organisms is necessary. The
micro-organisms oxidize the contaminants to water, CC^ and,
depending on the contents of the exhaust stream, NOX and SOX.
The micro-organisms are sustained by the addition of moisture,
oxygen, and nutrients in the exhaust stream. The used nutrients
are recycled; once the micro-organisms die, the living micro-
organisms consume them to obtain the nutrients. Eventually,
however, the filter material is exhausted. In normal operations,
the biofilter beds usually last between 2 and 5 years. When the
bed is spent, it can be disposed of readily, e.g., used in
agricultural applications.
The micro-organisms used in a biofilter are specific to the
'type(s) of pollutants being controlled. The temperature and
humidity of the biofilter must be precisely maintained to protect
the micro-organisms and thus ensure proper pollutant removal. If
multiple pollutants are present in the exhaust stream, several
biofilters with varying micro-organisms may be required. It is
difficult to maintain a single biofilter with multiple micro-
organisms, since the temperature and humidity requirements of the
different micro-organisms may differ. These pollutant-specific
3-55
-------
DRAFT
3527/650395
7/12/95
requirements make biofilters best suited to applications with
consistent exhaust streams with relatively few types of
pollutants. The exhaust streams from wood furniture finish
operations vary in volume and concentration and contain a wide
variety of pollutants.
Biofiltration is a proven odor-control technology that has
long been used in sewage treatment facilities and other
industrial processes. Biofilters are typically used to control
small-volume exhaust streams. Odor-control efficiencies of
95 percent and greater have been reported for biofiltration
units. In some installations, the odors being controlled are
caused by the presence of VOC's in the exhaust stream.
Therefore, the biofiltration technology could be expected to
control VOC's as well as odor. However, data concerning the VOC
control efficiency of biofilters are only now becoming available.
The relationship between odor and/or VOC control efficiency and
pollutant concentration may not be linear. Therefore,
conclusions regarding VOC control efficiency await closer review
of data now becoming available from foreign installations.
Biofilters have been developed by Bio Clean AB of Sweden and
introduced for use in the U.S. by Ahlquist & Hunters
Technologies, Inc. The Bio Clean filters have been in commercial
use in Sweden since 1989 for applications such as odor removal
from wastewater facilities and slaughterhouses and VOC removal
from paint manufacturing, various painting operations, and
fiberglass boat manufacturing. Their filters can achieve VOC
removal efficiencies of better than 95 percent.
Biofiltration is considered an emerging technology for
controlling VOC emissions from wood furniture finishing
operations. Biofilters are recommended for small-volume exhaust
streams with consistent concentrations of a few types of
compounds. Exhaust streams from furniture manufacturers are
characterized as large-volume exhaust streams containing a wide
variety of VOC's of varying concentrations. The large volume
exhaust would require very large biofilters, and the space
requirements could be substantial. The wide variety of VOC's may
3-56
-------
DRAFT
3527/650395
7/12/95
require multiple beds with different micro-organisms. Each bed
would have to be maintained at slightly different conditions.
Another factor that could hamper the use of biofiltration in the
wood furniture industry at this time is the limited VOC control
efficiency data that is currently available.
-31.4 MINIMIZATION OF FINISH/SOLVENT USAGE AND EVAPORATION
Volatile organic compound emissions ^can also be reduced by
ainimizing the opportunity for evaporation of finishing and
cleaning materials as well as by minimizing the use of these
materials. A variety of work practices, designed to minimize the
use and evaporation of finishing and solvent materials, are
required by presumptive RACT, and these requirements are
discussed in Section 3.4.1. Additional work practices that could
be used to further reduce «VOC emissions from finishing and
cleaning operations, but are not required by presumptive RACT,
are discussed in Section 3.4.2.
3.4.1 Required Work Practices
The work practices that are required as part of presumptive
RACT are summarized in Table 3-2. The practices listed in this
table must be followed by all facilities subject to RACT. These
requirements are discussed in the following sections.
3.4.1.1 General requirements for finishing. Cleaning, and
Washoff.
VOC Storage. Materials containing VOC are often stored in
containers that are left open, allowing the volatiles to
evaporate and be emitted through room ventilation to the
atmosphere. The Work Practice Group agreed that a
straightforward, inexpensive method of reducing emissions from
VOC storage would be to cover all containers storing finishing,
cleaning, and washoff materials when not in use.
VOC Transfer. In wood furniture plants, finishing,
cleaning, and washoff materials are pumped from storage
containers to spray guns through piping. Because leaks are
likely to occur whenever materials are transferred, the Work
Group agreed that requiring sources to check this equipment for
3-57
-------
DRAFT
3527/650395
7/12/95
TABLE 3-2. WORK PRACTICE REQUIREMENTS -- PRESUMPTIVE RACT
A. Finishing. Cleaning, and Washoff
Covered storage of finishing, cleaning, and washoff
materials.
Inspection and maintenance program must be developed
and implemented to minimize leaks (monthly
inspection frequency, repairs within 15 days).
Conventional air spray guns prohibited in most
circumstances.
B. Cleaning and Washoff Operations
Gun/line cleaning
Cleaning solvent must be collected in a container
that can be closed.
Cleaning solvent containers must be closed when not
in use.
Spray booth cleaning
Use of organic solvents for spray booth cleaning is
prohibited except in limited circumstances
(conveyors that carry pieces through booth and
continuous coaters and their enclosures can continue
to be cleaned with solvent, as can the metal filters
in spray booths, 1.0 gallon per booth limit to clean
stained areas when replacing strippable spray booth
coating).
Furniture washoff
Cover washoff tanks when not in use.
Minimize dripping by tilting and/or rotating piece.
General cleaning/washoff activities
Cleaning and washoff accounting system
— Log of quantity and type of solvent used for washoff
and cleaning, the number of pieces washed off, and
reason for washoff.
— Record quantity of spent solvent generated from each
activity and its ultimate fate.
— Calculate net cleaning and washoff solvent usage
quantities, accounting for disposal and recycling of
spent solvent, monthly.
C. General Work Practice Requirements
Operator training program (train new employees upon
hiring and retain all employees annually)
Implementation Plan must be developed and maintained
to demonstrate compliance with work practice
requirements.
3-58
-------
DRAFT
3527/650395
7/12/95
leaks was reasonable. To implement the leak inspection program,
sources will be required to develop and implement an Inspection
and Maintenance plan that requires the inspection of each piece
of equipment used to transfer or apply finishing materials and
solvents; a schedule for inspection; reporting of the inspection
results and any repairs that were made to the equipment, and the
timeframe between identifying the leak and performing repairs.
The Work Practice Work Group agreed upon the concept of an
Inspection and Maintenance plan, but never discussed what the
inspection frequency or repair response time should be. The
Agency decided that a monthly inspection frequency is appropriate
to accomplish the goal of reducing leaks from transfer and
application equipment. To ensure that action would be taken if
leaks were detected, repairs must be made within 15 calendar
days, with a first attempt at repair made within 5 calendar days.
Improved Finishing Material Application Methods. The most
common method of applying finishing materials in the wood
furniture industry is through the use of spray guns. Spraying of
finishes can be very wasteful. The amount of finish wasted can
be sizable. In some industries, tests have shown that 80 percent
or more of the finish directed at a substrate is wasted and
becomes a solid waste expense due to disposal costs. In certain
applications, some spray guns can be more efficient than others
in that the quantity of finishing material lost as overspray is
less. The amount of finishing material that is saved through use
of improved application techniques varies considerably by
facility and application. Differences in the shape of the piece
being finished, airflow rates, line speed, and operator technique
translate into differences in the amount of overspray. In recent
years, the concept of transfer efficiency (the amount of finish
that ends up on the piece, as a percentage of the total finish
used) has been formally recognized and studied at great length.
The regulatory negotiation committee agreed that highly
efficient transfer methods are desirable, but also agreed that
the data supporting one type of application equipment over
another were conflicting except in one instance; almost all data
3-59
-------
DRAFT
3527/650395
7/12/95
suggest that conventional air guns are the least efficient
transfer method. Therefore, presumptive RACT prohibits the use
of conventional air spray guns in most instances.
The VOC emission reduction achieved through improved
application techniques is difficult to quantify. A study
performed by Pacific Northwest Pollution Prevention Research
Center indicated that transfer efficiency,is a function of both
operator experience and the type of gun (among other factors).112
Based on this study, it was arbitrarily estimated that
alternative application techniques reduce finish usage, and
thereby emissions, by approximately 10 percent. The company has
economic motivation (although there is limited evidence that it
has influenced industry in the past) for maximizing transfer
efficiency. Costs associated with finishing material purchases,
filter media disposal, and other waste disposal would decrease if
improved application techniques were used.11 The high costs of
toxic waste disposal may ultimately provide the incentive for
change.
3.4.2 Reduction in Cleaning Material Usage
As discussed in Chapter 2, industrial solvents are currently
used in the wood furniture industry for equipment cleaning, and
to a lesser extent, spot repair, rewetting, and dilution of
finish materials. Some VOC-containing cleaners will most likely
still be used for equipment cleaning even in facilities that
switch to lower-VOC finishing materials. There are a number of
options available to reduce the VOC emissions from cleaning
material usage in the wood furniture industry. These include
work practice modifications, use of alternative cleaning
materials, and add-on capture and control devices. Each of these
options is discussed in the following paragraphs.
3.4.2,1 Work Practice/Administrative Modifications. From
an industry perspective, the lowest-impact approach to reducing
VOC emissions resulting from cleaning material use is to change
work practices to minimize the opportunities for emissions. No
change in solvents is involved, so no compromise in cleaning
efficacy is required. Emissions of VOC from cleaning materials
3-60
-------
DRAFT
3527/650395
7/12/95
can be limited by restricting the movement of air across
containers of solvent and by limiting the amount of solvent that
is intentionally exposed to air. Thus, the use of training and
safety programs to inform employees of the dangers and ecological
risks and to teach good work practices are required. In
addition, closed containers with soft-gasketed, spring-loaded
closures for storing, transporting, and dispensing cleaning
materials are essential. Containers of cleaning materials
saturated with cleaning materials (rags, towels, etc.) must be
closed tightly so that the solvent does not evaporate. In turn,
these materials must be disposed of in a way that does not result
in evaporation of the solvents (e.g., incineration). To further
reduce VOC emissions, small parts must be cleaned in a closed
device to minimize evaporation. Products are on the market that
are specifically designed to clean spray guns without the need
for spraying the solvent into the air (see Table 3-3) .114-H7
One of these units, the Gun Washer/Recycler, made by Herkules
Equipment Corporation, involves internal and external cleaning of
the gun in an enclosed vessel. External cleaning is accomplished
by soaking the gun in the solvent; internal cleaning is
accomplished inside the enclosed vessel by pumping solvent
through the gun. The cleaning solvent collects in the vessel,
the solids are allowed to settle out, and the solvent is then
reused. The Solvent Manager, made by Solvent Management, and the
Lighthall unit, developed by Lighthall Enterprises, allow just
the cleaning solvent resulting from internal cleaning of the gun
to be captured in a removal cap as opposed to being sprayed into
the air. The captured solvent can then be reused.
Another approach to changing work practices to limit
cleaning material VOC emissions is an administrative control used
successfully in the fiberglass-reinforced plastic industry.117
In accordance with the administrative control, a limited amount
of cleaning material is issued to each worker during a shift.
This automatically limits the total solvent consumption but also
requires each worker to carefully monitor solvent use so that the
3-61
-------
DRAFT
3527/650395
7/12/95
TABLE 3-3. COMMERCIALLY AVAILABLE SPRAY GUN
WASHING UNITS114"117
Model
GW/R (Gun Washer Recycler)
The Solvent Manager
The Lighthall
Manufacturer
Herkules Equipment Corporation
8320 Goldie Street
Walled Lake, MI 48088-1298
Solvent Management
15 Normanhurst Avenue
Bournemouth BH8 9NN
U.K.
Lighthall Enterprises
934 Bay Street
Santa Cruz, CA 95060
required cleaning is accomplished without impairing product
quality.
Another method of changing work practices to limit solvent
VOC emissions is the use of a recordkeeping system to help
management track the use of solvent within a plant and ensure
that used solvents are properly tracked to disposal.
3.4.2.2 Use of Alternative Cleaning Materials.118"120 A
second approach to reducing VOC emissions resulting from cleaning
operations is to use cleaning materials that have been
reformulated to minimize or eliminate the solvent content. The
VOC emissions may also be reduced if less volatile solvents are
used in lieu of the highly volatile materials used in the lacquer
thinners. Because the reformulated cleaning material is no
longer the same solvent that is contained in the finishes, the
reformulation approach may have the disadvantage of requiring
some process changes to eliminate risks of cross contamination of
the cleaning material with the finish material. However, this
approach has an advantage in that no additional work practice
modifications need be incorporated to prevent evaporation.
Volatile organic compound emissions are inherently reduced if the
cleaning material has a lower VOC content because a high-boiling-
point (low-volatility) solvent that is exposed to air movement
will evaporate very little. A "slow-drying" solvent of this type
3-62
-------
DRAFT
3527/650395
7/12/95
will eventually evaporate when exposed to the air, as, for
example, when a thin film is left on a wiped surface. But casual
activities, such as pouring or agitating the surface of a wash
basin of solvent, will not result in a high evaporation rate.
The use of reformulated solvents for gun cleaning would also
result in lower emissions than those resulting from use of the
finish solvent, as long as the used solvent is collected and
contained. However, use of a "slow-drying" solvent for gun
cleaning may necessitate the use of a hot airstream that is
directed through the gun for quicker drying. Table 3-4
summarizes some low-volatility alternative solvents that have
only recently been widely marketed.
TABLE 3-4. LOW-VOLATILITY ALTERNATIVE SOLVENTS118'120
Compound
n-Methyl-2-
pyrrolidone
Dibasic
ester
Shipshape™
Propylene
glycol
ethers
Boiling
point, °C
202
N/A
N/A
120-242
Manufacturer
GAP
Arco
Chemical
DuPont
GAP
Arco
Chemical
Remarks
Low-toxicity replacement
for methylene chloride for
cleaning, stripping, and
degreasing
Substitute for acetone for
polyester resin cleanup
Substitute for acetone for
polyester resin cleanup
Solvents for waterborne and
high -sol ids coatings
N/A = exact information not available
Another type of alternative cleaning material is an aqueous,
detergent-type cleaner, which would result in very little VOC
emissions. This type of cleaner is chemically incompatible with
the solventborne finishing systems currently used. Thus, there
is the risk of cross contamination during activities such as gun
or paint-line cleaning. However, such a material may be
plausible for gun cleaning, in conjunction with drying of the
internal mechanisms of the gun, by using a hot airstream to
eliminate residual cleaning materials. Also, there may be
3-63
-------
DRAFT
3527/650395
7/12/95
opportunities in general cleaning operations where such aqueous
materials could be substituted. Solvent cleaners are often used
more as a matter of convenience (because of availability) than
because of any rigid efficacy requirements in general cleaning
situations.
These aqueous detergent-type cleaners may be compatible with
waterborne finish systems that are being developed in response to
more stringent regulations. A related alternative general
cleaning process is the use of high-pressure water (water
blasting) to remove cured or partially cured finishes from
equipment. The mechanism of cleaning is by abrasion, rather than
by chemical interaction, so that the technique would be limited
to spray booths and related application equipment.
3.4.2.3 Add-On Control Devices. A third approach to
reducing VOC emissions from cleaning operations is the use of
add-on controls, which first capture airborne VOC and then
recover or destroy it. In some large operations this approach
may be feasible if cleaning operations were conducted in a
central location. In this case, the proper hoods and ventilation
systems could be installed to capture the vapors and route them
to a control device. Similarly, if the finishing line itself has
emission control devices installed, it may be possible to conduct
cleaning operations in the finishing booths with the ventilation
systems operating, so that vapors from cleaning could be handled
by the same control devices that normally handle the finishing
emissions.
3.4.3 Washoff Operations
Washoff is the practice of removing coating from a piece of
furniture. The main reason for washoff is because the finish
does not meet company specifications. By washing off the
finishes, the substrate can be refinished. Washoff is typically
accomplished by dipping the furniture into a tank containing
organic solvent; the same solvents used for cleaning are usually
used for washoff.
To minimize the VOC emissions resulting from washoff
operations, the Work Practice Work Group decided on several
3-64
-------
DRAFT
3527/650395
7/12/95
required work practices. As with finishing and other cleaning
operations, the work group agreed that covering washoff tanks
when they are not in use would limit emissions. Also, sources
can minimize dripping by tilting and/or rotating the piece to
drain as much solvent as possible.
7 In general, cleaning and washoff practices are not well
documented by sources. For example, most sources do not know the
quantity of solvent used for cleaning and washoff operations, how
many pieces are washed off, and the fate of spent solvent from
cleaning and washoff operations. The Work Practice Work Group
agreed that one of the first steps in reducing emissions is to
know the quantity of solvent used for the various operations, and
therefore presumptive RACT requires all facilities subject to
RACT to implement a cleaning and washoff solvent accounting
system. Such an accounting system will minimize solvent usage
and will enable a facility to analyze their number of pieces
washed off to improve their operation. Under the cleaning and
washoff solvent accounting system, sources have to (1) maintain a
log of the quantity and type of solvent used for washoff and
cleaning, the number of pieces washed off, and the reason for the
washoff; and (2) record the quantity of spent solvent generated
from each activity. The net cleaning and washoff solvent usage
quantities, accounting for disposal and recycling of spent
solvent, must be calculated monthly, and copies of the logs must
be made available upon request.
The Work Practice Work Group and the regulatory negotiation
committee as a whole agreed that an accounting system should be
required. The Committee believed that the accounting system would
be an important first step for facilities to develop a broad-
based, multimedia pollution prevention plan.
The Committee believed that once the accounting system is in
place, the burden of maintaining it would not be too great.
Although implementation of a cleaning and washoff solvent
accounting system is expected to reduce VOC emissions, the
expected reduction in emissions has not been quantified, nor has
the associated cost.
3-65
-------
DRAFT
3527/650395
7/12/95
3.5 REFERENCES FOR CHAPTER 3
1. Bethea, R. M. Air Pollution Control Technology. New
York, Van Nostrand Reinhold Company. 1978. p. 395.
2. Brunner, C. R. Hazardous Air Emissions from
Incineration. New York, Chapman and Hall. 1985.
p. 92.
3. Ref. 1, pp. 401-402.
4. Ref. 1, p. 405.
5. Prudent Practices for Disposal of Chemicals from
Laboratories. National Academy Press. Washington,
D.C. 1983.
6. Seiwert, J.J. Regenerative Thermal Oxidation for VOC
Control. Smith Engineering Company. Duarte, CA.
Presented at Wood Finishing Seminar--Improving
Quality and Meeting Compliance Regulations.
Sponsored by Key Wood and Wood Products and Michigan
State University. Grand Rapids. March 5, 1991.
27 pp.
7. Memorandum and attachments from Farmer, J. R., EPA,
to Distribution. Thermal Incinerator Performance for
NSPS. August 22, 1980. 29 pp.
8. Radian Corporation. Catalytic Incineration for
Control of VOC Emissions. Park Ridge, NJ, Noyes
Publications. 1985. pp. 4-5.
9. Ref. 1, p. 421.
10. Ref. 7, pp. 12-24.
11. Ref. 1, p. 425.
12. Telecon. Caldwell, M. J., Midwest Research
Institute, with Minor, J., M & W Industries.
June 20, 1991. Catalytic incineration.
13. Survey response and attachments from Smith Engineering
Company to Wyatt, S., EPA/ESD. May 16 and June 21, 1991.
Response and follow-on information pertaining to add-on
control survey.
14. Telecon. Caldwell, M.J., Midwest Research Institute, with
Mcllwee, R., Smith Engineering Company. June 25, 1991.
Clarification of information provided in add-on survey
response.
3-66
-------
DRAFT
3527/650395
7/12/95
15. Telecon. Caldwell, M.J., Midwest Research Institute, with
Mcllwee, R., Smith Engineering Company. August 13, 1991.
Destruction efficiency of thermal incineration systems.
16. Survey response and attachments from M&W Industries, Inc.,
to Wyatt, S., EPA/ESD. June 13, 1991. Response to add-on
control survey.
•"17. Telecon. Caldwell, M.J., Midwest Research Institute, with
Minor, J., M&W Industries, Inc. June 20, 1991.
Clarification of information provided in add-on survey
response.
18. Survey response and attachments from Met Pro Corporation to
Wyatt, S., EPA/ESD. May 13, 1991. Response and follow-on
information pertaining to add-on control survey.
19. Telecon. Caldwell, M.J., Midwest Research Institute, with
Kenson, Dr. R., Met Pro Corporation. June 17, 1991.
Clarification of information provided in add-on survey
response.
20. Ref. 1, pp. 375-376.
21. Ref. 1, p. 366
22. Calgon Corporation. Introduction to Vapor Phase
Adsorption Using Granular Activated Carbon, pp. 11-1
through 11-16.
23. Ref. 1, pp. 382-387.
24. Ref. 5, pp. 4-1 through 4-44.
25. Ref. 1, pp. 380-382.
26. Crane, G. Carbon Adsorption for VOC Control. U. S.
Environmental Protection Agency. Research Triangle
Park, NC. January 1982. p. 23.
27. Kenson, R.E. Operating Results from KPR Systems for
VOC Emission Control in Paint Spray Booths. Met-Pro
Corporation. Harleysville, PA. Presented at the CCA
Surface Finish '88 Seminar and Exhibition. Grand
Rapids, MI. May 18, 1988. 10 pp.
28. VIC Manufacturing. Carbon Adsorption/Emission
Control. Minneapolis, MN.
29. Telecon. Catlett, K., EPA/CPB, with Sengupta, P.,
Vara International. December 16, 1991. Control of
alcohols using carbon adsorption.
3-67
-------
DRAFT
3527/650395
7/12/95
30. Telecon. Beall, C., Midwest Research Institute, with
Kenson, R., MetPro, Inc. January 3, 1992. Control
of alcohols using carbon adsorption.
31. Telecon. Caldwell, M. J., Midwest Research
Institute, with Bhushan, D., Durr Industries.
June 25, 1991. Effect of alcohols and ketones on
carbon adsorption performance.
32. Radian Corp. Adsorption for contro}. of VOC
emissions: Theory and full scale system performance.
Prepared for U. S. Environmental Protection Agency.
EPA Contract No. 68-02-4378. June 6, 1988.
33. Telecon. Caldwell, M. J., Midwest Research Institute, with
Weissert, M., Calgon Carbon Corporation. June 25, 1991.
Clarification of information provided in add-on survey
response.
34. Telecon. Caldwell, M. J., Midwest Research Institute, with
Blocki, S., ABB Flakt Alpha. June 5, 1991. Clarification
of information provided in add-on survey response.
35. Calgon Carbon Corporation. CADRE VOC Control
Process. Pittsburgh, PA. 1987.
36. Brochure and attachments from Jackson, T., Terr-Aqua Enviro
Systems, Inc., to Catlett, K., EPA/CPB. Received
February 14, 1992. Information regarding Terr-Aqua's
UV-oxidation system.
37. Shugarman, L. Ultraviolet/Activated Oxygen - A New Air
Pollution Control Technology Comes of Age. Terr-Aqua
Enviro Systems, Inc. Fontana, California. Presented at
the 84th Annual Meeting, Air and Waste Management
Association, Vancouver, British Columbia. June 16-21,
1991.
38. Telecon. Caldwell, M. J., Midwest Research Institute, with
Shugarmann, L., Terr-Aqua Enviro Systems, Inc. June 20,
1990. Future installation of Terr-Aqua UV-oxidation system
at a furniture plant in California.
39. Telecon. Caldwell, M. J., Midwest Research Institute, with
Jackson, T., Terr-Aqua Enviro Systems, Inc. November 1,
1990. Status of Terr-Aqua installation at a furniture
plant.
40. Telecon. Caldwell, M. J., Midwest Research Institute, with
Jackson, T., Terr-Aqua Enviro Systems, Inc. April 22,
1992. Status of Terr-Aqua installation at a furniture
plant.
3-68
-------
DRAFT
3527/650395
7/12/95
41. Telecon. Parker, A., Midwest Research Institute, with
Jackson, T., Terr-Aqua Enviro Systems, Inc. January 31,
1995. Update on Terr-Aqua installations in the wood
furniture industry.
42. Telecon. Christie, S., Midwest Research Institute,
with Bodie, J., Occupational Safety and Health
Administration. March 18, 1991. Recirculation.
343. Telecon. Christie, S., Midwest Research Institute, with
Kanth, S., Occupational Safety and Health Administration.
April 16, 1991. Recirculation.
"44. Memorandum. Conray, D., EPA Region I, to Catlett, K.,
EPA/CPB. December 19, 1991. Review of draft CTG -
"Control of Volatile Organic Compound Emissions from Wood
Furniture Finish Operations."
45. Telecon. Christie, S., Midwest Research Institute, with
Bombay, B., Kraftmaid Cabinetry. November 29, 1990.
Recirculation.
46. Occupational Health and Environmental Control.
29 CFR 1910.94(c)(6)(i) and (ii). July 1, 1991.
47. Telecon. Christie, S., Midwest Research Institute,
with Campbell, C., Classic Air Systems. June 12,
1991. Campbell Spray Booth.
48. Letter. Deal, W., and Dorris, W., Joint Industry
Steering Committee, to Jordan, B., EPA/ESD.
December 5, 1991. Comments of the Joint Industry
Steering Committee on the NAPCTAC package and
presentation.
49. Telecon. Christie, S., Midwest Research Institute, with
J. Bauersox, Wood Mode, Inc. November 15-16, 1990.
Clarification of survey response.
50. Letter and attachments from Shepich, T.J., OSHA, to
Wyatt, S., EPA/ESD. January 16, 1990.
Recirculation.
51. Telecon. Christie, S., Midwest Research Institute,
with Gregory, W., BMY Corporation. February 26,
1991. Recirculation.
52. Telecon. Caldwell, M., Midwest Research Institute, with
D. Bhushan, Durr Industries. November 5, 1990. Spray
booth circular.
53. Telecon. Christie, S., Midwest Research Institute, with
J. Minor, M&W Industries. December 20, 1990. Spray booth
recirculating with add-on control systems.
3-69
-------
DRAFT
3527/650395
7/12/95
54. Telecon. Christie, S., Midwest Research Institute, with
Nowack, W., Industrial Technology Midwest. February 26,
1991. Description and costs of recirculating spray booths
55. Norton, L. E., R. J. Bryan, and D. P. Becvar.
(Engineering-Science, Inc.). Evaluation of a Paint
Spray Booth Utilizing Air Recirculation. Prepared
for the U. S. Environmental Protection Agency.
Cincinnati. Publication No. EPA-600/2-84-143.
August, 1984. 67 pp. t
56. Ayer, J. (Acurex Corporation). Split-flow Exhaust
Recirculation for the Economic Control of VOC
Emissions from Paint Spray Booths. Prepared for
U. S. Environmental Protection Agency. Research
Triangle Park, NC. Paper No. 90-104.3 for
Presentation at the 83rd Annual Meeting of Air and
Waste Management Association. June 24-29, 1990.
12 pp.
57. Letter. Runyan, L., American Furniture Manufacturers
Association, to Catlett, K., EPA/CPB. January 14,
1992. Response to request for information dated
January 14, 1992, regarding JISC comments on
preliminary draft CTG.
58. Telecon. Caldwell, M. J., Midwest Research
Institute, with Taylor, R., Durr Industries, Inc.
August 8, 1991. Regenerative incinerator idling and
recirculating spray booths.
59. Telecon. Caldwell, M. J., Midwest Research
Institute, with Miller, D., George Koch Sons, Inc.
August 7, 1991, Clarification of information
provided in add-on survey response.
60. Telecon. Caldwell, M.J., Midwest Research Institute,
with Nowack, W., Industrial Technology Midwest.
August 7, 1991. Recirculating spray booths.
61. Telecon. Beall, C., Midwest Research Institute, with
Febo, F., Allendale Insurance Company. January 2 and
3, 1991. Impact of various control options on
insurance premiums.
62. Mobile Zone Associates. Mobile Zone Spray Booth for
Reduction of VOC Contaminated Air, Prepared for
U. S. Environmental Protection Agency. Research
Triangle Park, NC. Contract No. 68-D9-0122.
April 12, 1990. 17 pp.
3-70
-------
DRAFT
3527/650395
7/12/95
63. Memorandum from Christie, S., Midwest Research
Institute, to Catlett, K., EPA/ESD. March 12, 1991.
Summary of Wood Finishing Seminar-Improving Quality
and Meeting Compliance Regulations. Sponsored by
Wood and Wood Products and Michigan State University.
37 pp.
64. Telecon. Caldwell, M. J., Midwest Research
^ Institute, with Ellis, T., Classic Air Systems.
May 11, 1992. Status of CamBooth. ,
>65. U. S. Environmental Protection Agency. Enabling
Document. The Measurement Solution--Using a
Temporary Total Enclosure for Capture Efficiency
Testing. Publication No. EPA-450/4-9-020. Final
Draft. August 1991.
66. Battelle and Eastern Research Group, Inc. Guide to Cleaner
Technologies: Organic Coating Replacements. Prepared for
U. S. Environmental Protection Agency. Cincinnati, OH.
September 1994. Publication No. EPA/625/R-94/006.
67. Beels, G.J. Industrial Finishing 1991 Market Study.
Industrial Finishing. December 1990. pp. 22-25.
68. SRI International. U. S. Paint Industry Data Base.
Prepared for the National Paint and Finishes
Association. Washington, D.C. September 1990.
227 pp.
69. Winchester, C.M. Waterborne Nitrocellulose Wood
Lacquers with Lower VOC. Aqualon Company.
Wilmington, DE. Presented at the Higher-Solids,
Waterborne and Powder Finishes Symposium.
February 6-8, 1991. 19 pp.
70. Domsey, S. Woodworker's Guide to Conventional
Finishes. Furniture Design & Manufacturing.
January 1988. pp. 54-57.
71. Chemcraft Sadolin International Inc. Wood Finishes.
Brochure. Walkertown, NC.
72. Survey response from PPG Industries, Inc., to
Farmer J., EPA/ESD. May 8, 1990. Response to
Section 114 information request.
73. Survey response and attachments from Reliance
Universal, Inc., Division of Akzo Finishes, to
Farmer, J., EPA/ESD. May 11, 1990. Response to
Section 114 information request.
3-71
-------
DRAFT
3527/650395
7/12/95
74. Survey response and attachments from The Lilly
Company to Farmer, J., EPA/ESD. May 14, 1990.
Response to Section 114 information request.
75. Survey response and attachments from The Valspar
Corporation to Farmer, J., EPA/ESD. May 10, 1990.
Response to Section 114 information request.
76. Survey response and attachments from Guardsman
Products, Inc., to Farmer, J., EPA/ESD, May 10,
1990. Response to Section 114 information request.
77. Memorandum. Rasor, S., Midwest Research Institute, to Wood
Furniture Project File. Summary of Data from Wood
Furniture Information Collection Request. October 12,
1994.
78. Brantley, M. (E-Z-Go, Division of Textron). VOC
Emission Reduction Implementation. Prepared for the
Society of Manufacturing Engineers. Dearborn,
Michigan. Paper No. FC89-611. October 1989.
pp. 4-5.
79. Ballaway, B. New Developments in Waterborne
Finishes. Industrial Finishing. December 1989.
pp. 24-25.
80. Detrick, G. F. and K. Kronberger. Addressing the VOC
Issue in Industrial Finishes. American Paint and
Finishes Journal. September 11, 1989. pp. 42-52.
81. Del Donno, T. A. Waterborne Finishes Outlook Bright.
Industrial Finishing. December 1988. pp. 28-33.
82. Contact Report, Caldwell, M. J., and Christie, S.,
Midwest Research Institute, with Tucker, R.,
Guardsman Products, Inc. March 28, 1991. Lower-VOC
finishes.
83. Contact Report. Caldwell, M. J., and Christie, S.,
Midwest Research Institute, with Reidell, A., PPG
Industries, March 21, 1991. Lower-VOC finishes.
84. Survey response and attachments from Guardsman
Products, Inc., to Wyatt, S., EPA/ESD. May 30, 1991.
Response to finish suppliers questionnaire.
85. Survey response and attachments from the Lilly
Company to Wyatt, S., EPA/ESD. June 7, 1991.
Response to finish suppliers questionnaire.
86. Survey response and attachments from PPG Industries,
Inc., to Wyatt, S., EPA/ESD. June 3, 1991. Response
to finish suppliers questionnaire.
3-72
-------
DRAFT
3527/650395
7/12/95
87. Survey response and attachments from Sadolin, Inc.,
to Wyatt, S., EPA/ESD. May 24, 1991. Response to
finish suppliers questionnaire.
88. Survey response and attachments from the Valspar
Corporation to Wyatt, S., EPA/ESD. May 29, 1991.
Response to finish suppliers questionnaire.
89. Hornung, J. R. (Southern California Edison Company). Test
Results of Rule 1136 Coatings Project. Prepared for South
Coast Air Quality Management District. December 1993.
78 pp.
90. Letter. Fujimoto, K., Consultant, to J. Berry, EPA/ESD.
June 14, 1994. Results of Method Analysis.
91. Telecon. Christie, S., Midwest Research Institute,
with Tucker R., Guardsman Products Inc. May 10,
1991. Catalyzed finishes.
92. Schmidt, H. UV Curing for Flatline and 3-D
Production. Superfici U.S. Kennersville, NC.
Presented at the Wood Finishing Seminar. Grand
Rapids, MI. March 5, 1991. 18 pp.
93. Bean, J. E. Finishing Handbook. London, Sawell
Publications. 1988. p. 172.
94. Telecon. Caldwell, M., Midwest Research Institute, with
G. Currier, Akzo Finishes, Inc. October 19, 1994. Akzo's
"VOC Control" Systems.
95. Letter and attachments from Rechel, C. J., RadTech
International, to Edwardson, J. A. and J. Berry, EPA/ESB.
October 13, 1993. Potential for reduction of emissions by
the use of UV curable finishing systems.
96. Loewenstein Dip Continues. Industrial Finishing.
69:14-15. May 1993.
97. Telecon. Beall, C., Midwest Research Institute, with
O'Block, S., Miles, Inc. January 22, 1992. Toxicity
and safe handling of isocyanates.
98. Mobay Corporation. Hexamethylene Diisocyanate Based
Polyisocyanates - Health and Safety Information.
Pittsburgh, PA. February 1991. 13 pp.
99. Telecon. Beall, C., Midwest Research Institute, with
0'Block, S., Miles, Inc. January 24, 1992. The
toxicity of the components in polyurethane finishes.
100. Mobay Corporation. Some Plain Talk About Safe Use of
Polyurethane Finishes. Pittsburgh, PA. 4 pp.
3-73
-------
DRAFT
3527/650395
7/12/95
101. Mobay Corporation. Isocyanates-Questions and Answers
About Use and Handling. Pittsburgh, PA. August
1991. 26 pp.
102. Mobay Corporation. Polyurethane Finishes--
Performance, Quality, Safety. Pittsburgh, PA. 1989.
12 pp.
103. Heater, K. J., A. B. Parsons, and R. F. Olfenbuttel
(Battelle Memorial Incorporated). Project Summary:
Evaluation of Supercritical Carbon Dioxide Technology to
Reduce Solvent in Spray Coating Applications. Prepared for
U. S. Environmental Protection Agency, Washington, DC
Publication No. EPA/600/SR-94/043. May 1994. 3 pp.
104. Telecon. Caldwell, M. J., Midwest Research
Institute, with Morgan, R., Union Carbide. April 23,
1992. Status of UNICARB® installations.
105. Telecon. Caldwell, M., Midwest Research Institute, with
T. West, Union Carbide. October 24, 1994. Status of
UNICARB® in the Wood Furniture Industry.
106. Letter and attachments from Putsche, V., ENSR, to
Christie, S., Midwest Research Institute. April 18,
1991. Mobile Zone.
107. Telecon. Parker, A., Midwest Research Institute, with
W. Brown, Mobile Zone Associates, February 13, 1995.
Status of commercial installations for Mobile Zone System.
108. K. I. Lipton, Inc. Marketing Communication. Gist-
Brocades Yeast Plant Applies Biotechnology to Solve
East Brunswick Odor Problem. Doylestown, PA.
109. Product Information. Ahlquist & Munters Technologies, Inc.
Undated. Discussing biofilters and commercial
installations.
110. Paul, P. G. New Developments in Biofiltration.
Comprimo Corporation. Presented at the 22nd ACHEMA
Exhibition--Congress. Frankfurt. June 5-11, 1988.
8 pp.
111. Leson, G. Biofiltration: An Innovative Air
Pollution Control Technology for VOC Emissions.
Journal of the Air and Waste Management Association.
£1:1045-1054. August 1991.
112. Schecter, R. N., and G. Hunt. Case Summaries of
Waste Reduction by Industries in the Southeast.
July 1989. p. 11.
3-74
-------
DRAFT
3527/650395
7/12/95
113. Transfer Efficiency and VOC Emissions of Spray Gun and
Coating Technologies in Wood Finishing. Pacific Northwest
Pollution Prevention Research Center. Seattle, WA. 1992.
114. Herkules Equipment Corporation, product brochure.
Gun Washer and Recycler. Form GWR-1086. Canada.
^115. SRC, product brochure. The Solvent Manager.
Document SM/002.
*
116. Lighthall Enterprises, product brochure. The
Lighthall. Santa Cruz, CA. October 1987.
117. Memorandum from Vaught, C., Midwest Research
Institute, to Evans, L., EPA. July 23, 1990.
Industrial uses of cleanup materials--Industry uses
investigation.
118. Arco Chemical, product brochure. NMP data sheet.
Newtown Square, PA. 1990.
119. GAP advertisement. Industrial Finishing, p. 44.
November 1990.
120. DuPont, product brochure. High-boiling-point
solvents.
3-75
-------
DRAFT
3792/650395
7/11/95
4.0 MODEL PLANTS AND EMISSIONS ESTIMATES
This chapter describes the model plants selected to
characterize the wood furniture industry, the corresponding
emissions estimates, and the methodology used to determine these
estimates. The model plants describe finishing operations and
are intended to be representative of existing facilities. The
majority of the existing facilities have no VOC controls on their
finishing operations; therefore, model plants represent
uncontrolled finishing operations. The model plants have been
developed to represent the wood furniture industry as a whole;
they do not necessarily represent every possible facility. The
model plants will be used to evaluate the environmental, cost,
economic, and energy impacts of control options on the affected
sources.
This chapter describes the model plants in detail, and
presents the methodology used to estimate model plant emissions.
Model plants are described in Section 4.1; overall categories,
finish application methods, finishing sequence, model plant
sizes, finish usage, and finishing parameters are discussed.
Emissions estimates are described in Section 4.2, and a list of
references is provided in Section 4.3.
4.1 MODEL PLANTS
Development of the model plants has been based primarily on
information from a study sponsored by the wood furniture industry
and data collected from responses to the Agency's information
collection requests (ICR's).1'2 The wood furniture industry's
study evaluates VOC control technologies applicable to wood
furniture finishing and estimates the costs of these controls.
The ICR's were sent by the Agency to wood furniture manufacturers
4-1
-------
DRAFT
3792/650395
7/11/95
in all segments of the industry. There are several key
parameters that must be considered in order to conceptualize the
models to be used. The type of finish application method, the
finishing sequence, and the size of the model plant are of
primary importance.
Seventeen model plants have been developed to characterize
wood finishing operations. The model plants are divided into
five main categories: short spray finishing sequence; long spray
finishing sequence; roll, curtain, and dip coating (referred to
as roll); upholstered furniture manufacturing; and kitchen
cabinet manufacturing. These categories are classified by
general finishing application technique; of the five categories,
four use spray application methods and one uses flatline
finishing application (roll, curtain, and dip coating). Spray
application finishing is further classified as either short spray
or long spray finishing sequences. Three of the categories,
short spray finishing sequence, long spray finishing sequence,
and roll, curtain, and dip finishing sequence, represent plants
in multiple market segments or SIC codes. Two or the categories,
manufacturing of upholstered furniture and kitchen cabinets, are
short spray sequences that are each specific to one single
industry or SIC code. Table 4-1 identifies the SIC codes
represented in each of the five main categories.
Each of the categories is further divided by size on the
basis of finish usage (extra small, small, medium, and large),
except the category representing manufacturers of upholstered
furniture, These facilities are typically small in terms of the
amount of finish used.
The seventeen model plants that were developed based on the
five categories are described in Table 4-2. Finish application
method, finishing sequence, and plant size are identified. This
table also identifies other important model plant characteristics
such as the number of finishing steps, the number of spray booths
per finishing line, the type of topcoats used, and the number of
finishing lines for each modeJ plant The following sections
4-2
-------
DRAFT
3792/650395
7/11/95
TABLE 4-1. CHARACTERISTICS OF MODEL PLANT CATEGORIES
Model plant category
Short
Long
Roll
Upholstered
furniture
Kitchen cabinets
Model plant No.
la
1
2
3
4a
4
5
6
7a
7
8
9
10
11 a
11
12
13
SIC codes/ furniture type
2511 -Residential Furniture
25 19 -Furniture, n.e.c.
2521-Office Furniture
2531 -Public Building Furniture
2 541 -Store Fixtures
•
2511 -Residential Furniture
2517 -Radio, Television Cabinets
2519 -Furniture, n.e.c.
2521-Office Furniture
2531-Public Building Furniture
2434 -Kitchen Cabinets
2517 -Radio, Television Cabinets
2521-Office Furniture
2531-Public Building Furniture
2541 -Store Fixtures
2512 -Upholstered
2434 -Kitchen Cabinets
4-3
-------
DRAFT
3792/650395
7/11/95
§
r
f.
—
9
S
Applirtlion
meUi
-------
DRAFT
3792/650395
7/11/95
describe the overall model plant categories, the finishing
sequences, model plant sizes, and coating parameters. The
rationale for the categorization is presented in the following
sections.
4.1.1 Finish AppXjcajpioQ Method
The model plant categories are identified as either spray
finishing application or roll coating application operations.
Four of the five categories of model plants spray apply finishes;
one category of the model plants employs flatline application
methods (roll coat, curtain coat, or dip coat). Spray
application finishing is assumed to be performed with
conventional spray guns using compressed air to atomize finishes.
Conventional spraying techniques are applicable to a wide range
of common finishing needs, including the finishing of nonflat,
irregularly shaped furniture pieces, both before and after
assembly. Flatline finishing use, however, is relatively limited
because pieces must be relatively flat for roll, curtain, and dip
coating methods to be used most effectively. Wood furniture
manufacturers that finish the components and then assemble the
product may be able to use roll, curtain, and dip coating methods
only for some of the components. Furniture producers that
manufacture ready-to-assemble furniture (with flat components)
can also use flatline finishing.
4.1.2 Finishing Sequence
Finishing sequences have been defined for both flatline and
spray type application methods. The distinction between short
and long finishing sequences for spray application finishing
operations has been made for the model plants because the use of
lower-VOC finishes may affect the two types of spray finishing
operations differently. No further categorizations are necessary
for roll, curtain, and dip application methods.
A short finishing sequence is defined as one or two
applications of stain, followed by one application each of
sealer, and topcoat.1 A long finishing sequence consists of the
following finish application steps: a total of two or more stain
applications, washcoat, glaze/filler, sealer, and highlight, and
4-5
-------
DRAFT
3792/650395
7/11/95
three topcoat applications.1 The finishing sequence for roll/
curtain, and dip coating application consists of one application
each of stain, sealer, and topcoat (three finishing steps)-1
Kitchen cabinets, represented by model plants lla through 13, are
also finished with a short finishing sequence. (They are
typically finished with a different type of sealer and topcoat so
they are included in a separate category.*) Sanding and drying
operations occur in between the finishing steps for each of the
finishing sequences.
The long finishing sequence requires two or more topcoat
application steps, while the other categories require only one
topcoat application. Extra small and small furniture finishing
facilities are assumed to have one finishing line each and medium
and large facilities are assumed to have two finishing lines.
The number of spray booths for each finishing line is also
provided in Table 4-2.
The actual sequence used at a facility may very well differ
from those described. In these instances, the regulatory agency
must evaluate the operation from the standpo; it- of the finishing
sequence used and the final finish requirements.
4.1.3 Model Plant Sizes
Model plant sizes and process parameters were developed
based on the model plants described in the furniture industry's
VOC control technology study. Finish parameters, including VOC
content, density, solids content, and relative usage rates, are
based on industry's model plants.l The model plant types
developed by the wood furniture industry in its study, however,
are specific to one size plant; to ensure that this CTG's models
represent all sizes within the industry, the wood furniture
industry's model plants 2, 8, and 10 were scaled up or down,
based on total finishing material usage, to create other sizes of
plants within a category In addition, another model plant type
was developed and sized for roll coating See Table 4-3 for a
summary of the industry and earlier draft CTG model plants.
4.1.3.1 Coating Usagje. Finishing material use for each of
the model plants is presented in Table 4-2.1 Finish usage values
4-6
-------
DRAFT
3792/650395
7/11/95
TABLE 4-3.
SUMMARY OP INDUSTRY AND EARLIER DRAFT CTG
MODEL PLANTS1'3
Model
plant
No.
1
2
3
4
5
6
7
8
9
10
11
12
No. Of
employees
No. of finishing
steps
Industry model plants
10-238
250-455
284-484
120-217
325-389
140
800
105-212
159-225
123-549
108-215
258-375
10-14
<, - 10
Print <, « 9
Finish <, - 10
15+
<, - 9
<, - 6
Print - 8
Finish - 5
4
<, - 4
3
<, - 7
<, - 7
VOC emissions
from finishing,
Mg/yr
95
321
375
42
286
66
368
111
117
349
30
88
Earlier draft CTG model plants
1
2
3
4
5
6
7
8
9
10
11
<100
100-249
>249
<100
100-249
>249
<100
100-249
>249
100-249
>249
6
6
6
10
10
10
3
3
3
3
3
45
204
454
45
204
454
45
204
454
204
454
4-7
-------
DRAFT
3792/650395
7/11/95
are used in estimating VOC emissions and the costs of control
options.
4.1.3.2 VOC Usage. The total VOC usage provided in
Table 4-2 for the model plants includes all VOC from finishing
and cleaning operations. In general, VOC emissions from finishes
are based on the VOC content of the finishes, which is measured
using test Method 24. For the majority of finishes that cure by
the evaporation of solvents from the film, all of the VOC is
presumed to evaporate to the atmosphere: i.e., VOC usage equals
VOC emissions.
The VOC usage for finishing operations (minus cleaning
solvents) was used to define the different sizes of model plants.
Each size model plant represents a range of usage within the
industry. Extra small plants use between 25 and 65 tons per year
of VOC, small plants use between 65 and 160 tons per year, medium
plants use between 160 and 325 tons per year, and large plants
use more than 325 tons per year.1'^ The range of VOC usage
applicable for each model plant is shown in Table 4-4.
Size designations are based on VOC Uoage, not finishing
material usage. The same volume of total finish usage provides
differing levels of VOC usage for the five categories of model
plants. The combination of coating steps in the finishing
sequence varies with each category (for example, stain, stain,
sealer, and, topcoat for the short spray sequence versus stain,
sealer, and topcoa'r. for roll, curtain, and dip coating) , and the
VOC usage associated with the same quantity of total finish usage
for each category would vary. Another important factor that
accounts for the differing VOC usage levels is that the VOC
content of the finishing materials used for the same type of
finishing step (stain, for instance) varies from category to
category.
Whether a plant with 17? 'cons per year of VOC usage from
finishing operations is truly "small" in the sense of the level
of production is not important here. The plant size designations
are made for the purpose of comparing plants with comparable
4-8
-------
DRAFT
3792/650395
7/11/95
TABLE 4-4.
RANGES OF VOC USAGE AND EMPLOYMENT DATA FOR
MODEL PLANTS
Model plant
category
Short
Long
Roll
Model Plant No.
la
1
2
3
4a
4
5
6
7a
Finishing VOC range,
tons
25-65
65-160
160-325
>325
25-65
65-160
160-325
>325
25-50
SIC Code
2511
2519
2521
2531
2541
A
2511
2519
2521
2531
2541
2511
2519
2521
2531
2541
2511
2519
2521
2531
2541
2511
2517
2519
2521
2531
2511
2517
2519
2521
2531
2511
2517
2519
2521
2531
2511
2517
2519
2521
2531
2534
2517
2521
2531
2541
Employee range
20-99
20-99
50-99
50-99
50-99
100-249
100-249
100-499
100-249
100-499
250-499
250-499
500-999
2S500
>500
> 1,000
>500
> 1,000
20-99
20-99
20-99
50-99
50-99
100-249
100-249
100-249
100-499
100-249
250-499
250-499
250-499
500-999
250-499
>500
>500
>500
> 1,000
>500
20-49
20-99
50-99
50-99
50-99
4-9
-------
DRAFT
3792/650395
7/11/95
TABLE 4-4. (continued)
Model plant
category
Roll (cont'd)
Upholstered
furniture
Kitchen
cabinets
Model Plant No.
7
8
9
10
lla
11
12
13
Finishing VOC range,
tons
50-150
150-300
>300
>25
25-50
50-100
100-250
>250
SIC Code
2534
2517
2521
2531
• 2541
2534
2517
2521
2531
2541
2534
2517
2521
2531
2541
2512
2434
2534
2434
2434
Employee range
50-99
100-249
100-499
100-249
100-499
100-249
250-499
500-999
250-499
500-999
>250
>500
> 1,000
>500
> 1,000
> 100 to 250
20-49
50-99
100-249
>250
4-10
-------
DRAFT
3792/650395
7/11/95
emission reduction potential. Actual plant emissions may lie
anywhere in the size ranges indicated.
4.1.3.3 Cleaning Solvent Usage. The usage of VOC solvents
for cleaning operations is provided in Table 4-2 for each model
plant. Based on information obtained from industry, it was
estimated that 10 percent of the total volume of "coating
materials" purchased is industrial solvents used for cleaning
purposes.2 Cleaning operations can occur throughout the plant,
but the majority of cleaning operations associated with wood
furniture finishing operations occur in or near the spray booths.
Using an average cleaning material VOC content of 6.9 Ib VOC/gal,
VOC usage resulting from cleaning operations were estimated and
are shown in Table 4-2.
4.1.3.4 Number of Employees. The number of employees also
varies with each size model plant and encompasses a fairly wide
range for some of the sizes. The range of employees varies among
SIC codes for a particular size plant within a model plant
category. It is important to remember that model plant size is
not specifically related to the number of employees; employee
numbers are provided for later use in nationwide emission
calculations in Chapter 6. Extra small plants have between 20
and 99 employees, small plants have between 50 and 499 employees,
medium plants employ between 100 and 999 workers, and large
plants employ greater than 500 workers.1'2 Employment
information is shown in Table 4-4 for each SIC code for each
sized model plant.
4.1.4 Finish Parameters
Finishing material parameters have been identified for each
of the five model plant categories. The finish parameters are
presented in Table 4-5 for each type of finishing material
typically used by the model plant facilities. The average VOC
content (Ib VOC/gal and Ib VOC/lb solids) and solids content for
the finishing materials used in each of the model plant catego-
ries including stain, toner (a type of stain), washcoat, filler/
glaze, sealer, highlight, and topcoat, are shown.1 The VOC
content refers to the volatile organic compound content, in grams
4-11
-------
DRAFT
3792/650395
7/11/95
TABLE 4-5. FINISHING MATERIAL CHARACTERISTICS
Short
Long
STAIN
VOC content, g/L (Ib/gtl)
VOC content, Ib/lb solid
Solids content, % by weight
TONER (Another stsin)
VOC content, g/L (Ib/g*l)
VOC content, Ib/lb solid
Solids content, % by weight
791 (6.6)
160
0.60
779 (6.5)
17
5.7
791 (6.6)
160
0.60
779 (6.5)
17
5.5
WASHCOAT
VOC content, g/L 0b/g»l)
VOC content, Ib/lb solid
Solids content, % by weight
FILLER/GLAZE
VOC content, g/L Ob/gal)
VOC content, Ib/lb solid
Solids content, % by weight
SEALER
VOC content, g/L (lb/gal)
VOC content, Ib/lb solid
Solids content, % by weight
NA
NA
NA
NA
NA
NA
731 (6.1)
4.6
17.9
779 (6.5)
11
7.6
479 (4.0)
1.0
50.9
731 (6.1)
4.7
17.6
Roll
815 (6.8)
110
0.82
•
NA
NA
NA
Upholstered
furniture
Kitchen
cabinets
791 (6.6)
160
0.60
779 (6.5)
17
5.7
791 (6.6)
130
0.75
NA
NA
NA
NA
NA
NA
NA
NA
NA
623 (5.2)
2.0
33.1
NA
NA
NA
NA
NA
NA
731 (6.1)
4.6
17.9
NA
NA
NA
NA
NA
NA
671 (5.6)
3.4
23.0
HIGHLIGHT
VOC content, g/L Qb/gsl)
VOC cement, Ib/lb solid
Solids content, % by weight
NA
NA
NA
791 (6.6)
51
1.9
NA
NA
NA
NA
NA
NA
NA
NA
NA
TOPCOAT
VOC center,' - g/L (lb/gal)
VOC content, ib/lb solid
Solids content, % by weight
719 (6.0)
3.6
21.9
7)9(6.0)
3.8
20.9
599 (5.0)
1.7
36.6
719 (6.0)
3.6
21.9
599 (5.0)
1.9
35.0
4 -1.2
-------
DRAFT
3792/650395
7/11/95
of VOC per liter of coating less water (g/L-water). Negligibly
phot©chemically reactive compounds are included with the water.
The relative VOC emissions for each model plant category are
presented in Table 4-6. The largest portion of relative
emissions may result from a different finishing step in the
finishing sequence for each model plant category. Stain
application is the major contributor to emissions for both the
roll, curtain, and dip coating and kitchen cabinet finishing
categories, at 39 percent and 38 percent, respectively. In the
short finishing sequence, sealer application, which accounts for
44 percent of emissions, is the major contributor to VOC
emissions; emissions from the sealer step in the upholstered
furniture category account for 44 percent of total VOC emissions.
The VOC emission attributable to the application of topcoat
accounts for 37 percent of total VOC emissions for the long
finishing sequence. For stain, sealer, and topcoat, the three
most prevalent coating steps for the model plants, the relative
emissions remain within a fairly small range over the five
categories.
TABLE 4-6. RELATIVE PERCENTAGE OF VOC EMISSIONS
Model plant
category
Stain
Toner
Washcoat
Filler/glaze
Sealer
Highlight
Topcoat
Short
19%
1
.
-
44
-
36
Long
26
3
8
1
16
9
37
Roll
39
-
.
.
25
.
36
Upholstered
19
1
.
.
44
.
37
Kitchen
cabinets
38
.
.
.
28
-
34
4.2 EMISSIONS ESTIMATES
Total VOC coating emissions, broken down by finishing step
and by emission point, and cleaning solvent VOC emissions are
discussed in the following sections.
4-13
-------
DRAFT
3792/650395
7/11/95
4.2.1 Emissions by Finishing Step
For all of the finishing materials used in defining the
model plants, all of the VOC contained in the coatings is
presumed to evaporate to the atmosphere. Because the VOC
contained in the coatings used in the furniture industry
generally does not become part of the finish during curing, this
assumption is thought to be reasonable. «The VOC contents in
Table 4-5 were used in conjunction with the total finish usage of
each material for each model plant to determine the VOC emissions
from each finishing step. The emission summary is presented in
Table 4-7. As can be seen in Table 4-7, the majority of the
emissions from furniture finishing operations for each model
plant category are from stain and topcoat application.
4.2.2 Emi ss ions by Emis s i on Point
Volatile organic compound emissions from finishing
operations occur at three primary points in the finishing
process: the spray booths, the flashoff (air dry) areas, and the
ovens. Volatile organic compound emissions also result from
cleaning operations, including equipment cleaning and general
cleaning operations. A comparatively small source of emissions
is the finished piece, which may still contain small amounts of
solvent that eventually volatilize. Total emissions from the
finished piece (once all finishing operations are completed) are
expected to be less than l percent, of the total VOC emissions.4
The magnitude and distribution of the VOC emissions from
finishing and cleaning opprations are discussed, beiow.
The relative distribution oi VOC emissions among the spray
booths, flashoff areas, and ovenw varies among plants. Finish
formulation affects the emissions distribution. For example, if
a finish containing mostly low-boiling solvents is applied in a
spray booth, the solvents will evaporate quickly, and relatively
more emissions will occur in the hootb and flashoff areas than
would occur if a 1'inish ',\'Lth higb boiling solvents was used. The
distribution of emissions is alsc affected by the layout of the
finishing line and the finishing sequence used. The relative
positions and design of 'che booths, flashoff areas, and ovens can
4-14
-------
DRAFT
3792/650395
7/11/95
m
c
o
OJ
CO
I
o
H
CO
CO
H
O
g
O
OJ
o
u
S
§
Si
n
en
cu
t4
I
s
g
g
s
Model pl
c«tecoiy
ing
4-15
-------
DRAFT
3792/650395
7/11/95
affect the relative emissions. The length of the flashoff area
can also affect the emissions distribution. Finishing sequences
for typical furniture facilities were described previously in
Chapter 2. Not all spray booths are followed by both an air dry
(flashoff) area and an oven; in many instances, there is only a
flashoff area in between two spray booths, without an oven. In
such instances, the emissions would be distributed just between
the booth and flashoff areas.
Although the distribution of VOC emissions among the booths,
flashoff areas, and ovens varies with finish formulation and
plant layout, overall average emissions distributions have been
developed based on previous studies and conversations with add-on
control equipment suppliers. These emission distributions are
discussed below. The actual VOC emissions from each emission
point are also a function of the amount of VOC that is captured
and exhausted to the atmosphere or an add-on control device.
Therefore, an estimate of the percentage of VOC that is exhausted
is provided following the emission distribution discussion.
The study conducted by industry indicates that emissions
from spray booths represent from 84 to 97 percent ol the total
VOC emissions,1'4"6 More or less emissions may occur in the
spray booths depending on the properties of VOC solvents used for
individual finishing steps. Because stains contain many low-
boiling solvents, relativel/ more emissions (95 to 97 percent)
were estimated to occur in the stain spray booth, whereas the
sealer and topcoat spray booth emissions were estimated to be
84 to 87 percent of the total, The study estimated that from
90 to 94 percent of washcoat emissions occur an the spray booth.1
Flashoff areas are located either between spray booths or
between a spray booth and an oven. Some or all of the solvent
remaining on the recently sprayed piece evaporates in the
flashoff area. Based on industry studies, it was estimated that
in a booth, flashoff, oven sequence, between 3 and 11 percent of
i:he total VOC emissions are emitted in flashoff areas. If the
flashoff area is not followed by an oven, essentially all of the
remaining solvent is expected to evaporate in the flashoff area.
4-16
-------
DRAFT
3792/650395
7/11/95
Thus, in such instances, flashoff emissions are expected to be
approximately 5 to 16 percent of the total VOC emissions.1'4"6
Ovens are sometimes used to cure the finish prior to the
next step in the finishing process. Previous studies indicate
that approximately 2 to 5 percent of the total VOC finishing
emissions occur in the oven.4"6 The ovens used by many furniture
manufacturers that finish pre-assembled pieces are enclosed
tunnels with open ends where the pieces enter and exit the oven
on a belt.
In a typical furniture finishing room, there are no roof
vents. The only finishing room exhausts are those from the spray
booths and ovens. The total exhaust often exceeds the makeup
inflow rate, which results in the finishing room being maintained
at a negative pressure relative to the outside. Because the
exhaust flowrates of the spray booths are generally quite large,
and because the flashoff area is located either in between two
booths or in between a booth and an oven, the majority of the
flashoff emissions are expected to be exhausted through the
booths and ovens. Even in an operation with a long flashoff
area, most of the flashoff emissions are expected to eventually
be exhausted through the booths and/or ovens, since they are
generally the only forced exhaust points.
Since the ovens are mostly enclosed, most of the VOC
emissions generated in the oven are expected to be exhausted from
the oven to the atmosphere. Though spray booths are more open
than ovens, the booths are the only (other than the ovens) forced
exhaust from the building and thus, most of the VOC emitted in
the booths is expected to be exhausted out the booth exhaust.
Where the emissions from the flashoff areas is exhausted depends
on the relative locations of the booths and ovens. For purposes
of this CTG, it is estimated that approximately 90 percent of the
total VOC emissions released in the spray booths, ovens, and
flashoff areas combined are exhausted from the facility through
the exhaust system, based on engineering judgement.
Approximately 10 percent of the total VOC emissions are estimated
4-17
-------
DRAFT
3792/650395
7/11/95
to leave the finishing area through openings such as doors and
windows.
The majority of cleaning operations occur in or near the
spray booths. As discussed previously, cleaning solvent usage is
10 percent of the total volume of "coating materials" purchased.
The assumption is made that all VOC cleaning solvent used is
emitted. .
The distribution of finishing and cleaning solvent emissions
is presented in Table 4-8; finishing emissions are provided by
coating type and emission point. Table 4-8 presents the
emissions that are exhausted through the booths and ovens, which,
as previously discussed, represents approximately 90 percent of
the finishing emissions (minus cleaning solvents). The other
miscellaneous 10 percent of finishing emissions released through
doors and windows are also shown. This table provides a
breakdown of emissions by finishing step for every size model
plant in each of the five model plant categories. Because it is
assumed that staining operations involve just a spray booth and a
flashoff area, with no oven, stain emissions are distributed
between the booth and flashoff areas. Emissions from cleaning
solvent operations, 10 percent of the total volume of "coating
materials" purchased, are also presented for each model plant.
4-18
-------
DRAFT
3792/650395
7/11/95
V.
(D
G
O
§
H
g
CQ
H
05
H
CO
H
P
CO
§
H
CO
CO
H
S
w
1
ffl
1
1
1^1
—
&
t
a
r*
-
B
**
o
-
•0
t-
,5
*
«
V
.
**
«
r*
-
•i
c.
U
S «B
P 58
* 28
o! •• •"•
°. °. o
> s*
— o> e.
R T4 «
» — ••
s 5s
5 58
£ "• S
O Ox O*
•0 - «O
R 2S
01 •«. 3
«•> V *
n 3a
» *^ t^
t -f
III
Hill
2
Z
g
z
3 33
Si
<
z
<
5 n =
» d «*
« d M
& = -
d d "*
2 **
1 S ^
d do
d do
e
s
tf -
II:-
H « is '» H
JS
^
z
^^j
z
s
s
<
1
1
a» «
« «
2 5 =
*: 3 *!
«o d »
« R »^
r< d N
Z
Z
z
z
S
S
>= .->
lilli
s
s
2
z
s
2
z
£
z
«O T? v4
V o •»
S d«
S 28
M d —
«n vi o
•* O «rt
d do
2
5
^
^
s
H —
ll|?-
« | a i a
EO M *» o
0 S » H
. 3«
a 58
a 5s
*
* Si
. 3S
a "a
F- mm
•n *t O
Y v% *n
2 2 -
n g o
«o 1 ^
M « «
« n «
2 "2
«t ***•*»
** VJ **»
** d "*
1 =5
S 2§
s 2*
2 Dt:
g
§
t ^
11?-
Ilili
^
^
<
<
*
2
5
z
£
z
s 3s
2 HS
•» p «•>
» eJ r-
5 «:•
r* o «n
^
<
*
z
„
i,il
till!
§ =5
s 2?
8 S*
« ««
" 0*
= 58
S =3
S "P
a a a
^1 » ®
s Ss
« 5S
- « «
•*
O «d O
s 5s
» a«
2 !• 2
6
I
t ~
,u*
llill
»
«
o
***
r«
'
a
t^
*r
s
8
•0
•o
R
8
2
3
I
g
1
1
4-19
-------
DRAFT
3792/650395
7/11/95
4.3 REFERENCES FOR CHAPTER 4
1. ENSR Consulting and Engineering. An Evaluation of VOC
Emissions Control Technologies for the Wood Furniture and
Cabinet Industries. Prepared for the American Furniture
Manufacturers Association, Business and Institutional
Furniture Manufacturers Association, Kitchen Cabinet
Manufacturers Association, and the National Paint and
Coatings Association. January 1992.
«
2. Memorandum. Rasor, S., MRI, to Strum, M., EPA/ESD/CPB.
Summary of Responses to the Information Collection Request
for the Wood Furniture Industry. January 28, 1994.
3. Control of VOC Emissions from Wood Furniture Coating
Operations-Draft Chapters 1 through 5 of Control Techniques
Guideline. U. S. Environmental Protection Agency, Research
Triangle Park, NC. October 1991.
4. H. Van Noordwyk, Acurex Corp. Reducing Emissions from the
Wood Furniture Industry with Waterborne Coatings. Prepared
for the Environmental Protection Agency. EPA-600/2-80-160.
July 1980.
5. Telecon. Christie, S., Midwest Research Institute, with
Novak, w.f Industrial Technology Midwest. February 26, 1991
Spray booth recirculation and emissions.
6. Telecon. Caldwell, M.J., Midwest Research Institute, with
Shugarman, L., Terr-Aqua Enviro Systems. February 28, 1991.
Emissions distribution in wood furniture plants.
"'. Memorandum, Christie, S., Midwest Research Institute, to
Catlett, K., EPA/ESD/CPB. Preliminary Assessment of
Industrial Solvent Use in Wood Furniture Coating Operations.
January 28, 1991.
4-20
-------
DRAFT
3561/650395
6/22/95
5.0 SELECTION OF RACT
This chapter discusses the selection of reasonably available
control technology (RACT) to control volatile organic compound
(VOC) emissions from wood furniture manufacturing operations.
The process through which RACT was selected and the other
regulatory activities that affected RACT selection are discussed
in Section 5.1. The selection of specific guidelines such as the
reference control technologies, work practice standards, and
compliance provisions are discussed in Sections 5.2, 5.3, and
5.4, respectively. Finally, small business issues that were
considered in selecting RACT are identified in Section 5.5.
As is discussed further in Chapter 7, the RACT guidelines
presented in this document are simply a framework for State and
local regulatory agencies. These agencies will promulgate the
specific regulations that sources will be required to implement
to meet RACT. Possible ways for agencies to codify RACT
guidelines are discussed in Chapter 7, and a model rule is
presented in Appendix B.
The environmental and cost impacts associated with RACT are
provided in Chapter 6, along with the impacts associated with
other alternatives that were not selected as RACT.
5.1 BACKGROUND
The determination of RACT for the wood furniture
manufacturing industry was concurrent with a national emission
standards for hazardous air pollutants (NESHAP) that is also
being developed for the industry. The NESHAP is a regulation
that will control emissions of hazardous air pollutants (HAP)
listed in Section 112(b) of the Clean Air Act, as required by
Sections 112(c) and (d) of the Act. Control of HAP is achieved
5-1
-------
DRAFT
3561/650395
6/22/95
by requiring major sources to implement maximum achievable
control technology (MACT) . Although the CTG and the NESHAP
pertain to controlling VOC's and HAP, respectively, a source
could potentially be affected by both. For example, some of the
HAP are also VOC's; a major source of HAP that is located in a
nonattainment area and that emits HAP that are VOC's would have
to comply with the NESHAP and, if it emit£ above the CTG cutoff,
would also have to comply with the RACT imposed by the State
regulatory agency. In selecting RACT, the EPA considered this
potential overlap.
As discussed in Chapter l, both RACT and the requirements of
the NESHAP were selected within the framework of a regulatory
negotiation. In trying to reach an agreement on the presumptive
norm for RACT, the Committee looked at several factors. In
particular, they focused on technologies that they deemed to be
reasonable for all segments of the wood furniture industry at the
present time. In developing coating emission limitations, they
also considered the impact of the work practice standards. After
much discussion, the Committee agreed upon a combination of
emission limitations and work practice standards they believed
represented RACT for the wood furniture industry.1
The reniaining sections oi this chapter provide a summary of
RACT and discuss the rationale the Committee used in selecting
the requirements that form the basis for RACT.
5.2 SELECTION OF REFERENCE CONTROL TECHNOLOGIES
The presumptive norm that forms the basis for RACT consists
of reference control technologies and work practice standards.
The selection of work practice standards is presented in
Section 5.3. Through the regulatory negotiation process, the
Committee decided that two reference control technologies should
form the basis of RACT These technologies are either
(1) waterborne topcoats, or (2} higher solids sealers and
topcoats, as identified in Table 5-1, As indicated in this
table, State agencies should apply RACT to sources located in
ozone nonattainment areas (except extreme nonattainment areas)
that emit or have the potential to emit. 25 tons per year
5-2
-------
DRAFT
3561/650395
6/22/95
(tons/yr) or more of VOC's. The RACT requirements should be
applied to sources in extreme nonattainment areas that emit or
have the potential to emit 10 tons/yr or more of VOC's.
TABLE 5-1. REFERENCE CONTROL TECHNOLOGIES TO MEET RACT3
*
Coating type
1 . Topcoats ; or
2. Topcoats and sealers
sealer
topcoat
acid- cured alkyd amino vinyl
sealers
acid- cured alkyd amino conversion
varnish topcoats
Allowable VOC
content ,
kg VOC/kg solids
(Ib VOC/lb solids)
0.8
1.9
1.8
2.3
2.0
aRACT requirements apply to all sources located in nonattain-
ment areas (other than extreme areas) that emit or have the
potential to emit 25 tons/yr or more of VOC's. Sources
located in extreme areas must meet the RACT requirements if
they emit or have the potential to emit 10 tons/yr or more
of VOC's.
Once the Committee decided that RACT should include the use
of waterborne topcoats or higher-solids sealers and topcoats, a
specific format for identifying allowable emissions from these
technologies had to be chosen. In recommending a format for
RACT, the following factors were considered:
1. The format must accommodate multiple compliance
techniques for the various industry segments;
2. Given the large number of small businesses in this
source category, the format must ensure that the cost of
compliance is not excessive;
3. The format must assure that an equivalent level of
control is achieved by all affected sources;
4. The format must facilitate enforcement by regulatory
agencies; and
5-3
-------
DRAFT
3561/650395
6/22/95
5. If possible, the format should be consistent with the
format selected for the MACT standards because a source could
potentially be subject to both RACT and MACT.
The possible formats considered include: (1) a limit on
emissions of VOC per kilogram (pound) of coating solids; (2) a
percent reduction format; (3) a limit on emissions of VOC per
liter (gallon) of coating, less water; and (4) a limit on
emissions of VOC per liter (gallon) of coating solids. For all
formats limiting VOC content, the VOC content should be
calculated as applied to account for in-house dilution of
coatings purchased from an outside source.
The format selected by the Committee (and included in the
model rule in Appendix B) is a limit on the kilograms (pounds) of
VOC emitted per kilogram (pound) of coating solids (kg VOC/kg
solids (lb VOC/lb solids]). Another possible format, percent
reduction, was not selected because several disadvantages to this
format were identified. Primarily, the percent reduction that
will result from implementing RACT will vary from facility to
facility. This is especially the case when refoi nulated coatings
are used in lieu of conventional add-on controls. To implement a
global percent reduction format, baseline conditions at each
affected source would have to be assessed. At an uncontrolled
facility, this would not be a problem; baseline conditions would
be the current emission rate {although exactly which year
represents "typical" for baseline ovay not be straightforward) .
The percent reduction would be applied to this uncontrolled rate
to calculate the controlled VOC emission rate required by the
rules implementing RACT. Problems with the percent reduction
format arise?; however, if a facility has implemented control
strategies prior to being subject *.o RACT. If the same baseline
year is selected for both the ''neon trolled and controlled
facility, the controlled facility .vould have to ultimately
control a greater quantity of VOC emissions f.han the uncontrolled
facility. Cn some instances, however, a percent reduction format
offers advantages Fox exampl-, a percent reduction format
-------
DRAFT
3561/650395
6/22/95
allows sources the flexibility to choose any control method
feasible for their situation.
A limit on the kilograms (pounds) of VOC contained in a
liter (gallon) of coating (kg VOC/liter [Ib VOC/gal]), less
water, was also considered. A similar format was considered for
the MACT standard but was eliminated because it does not give
ample credit to sources that substitute non-HAP VOC for HAP in
their coatings. Another format considered was one expressed as
kg VOC/liter solids (Ib VOC/gal of solids). For both RACT and
MACT, however, a disadvantage to this format is that there is no
EPA test method currently available for accurately measuring the
volume of solids in a coating. As stated above, consistency
between MACT and RACT is desired and therefore neither format (kg
VOC/liter [Ib VOC/gal]) of coating or kg VOC/liter (Ib VOC/gal)
of solids was selected for RACT.
Once the format was selected, the actual emission limits
associated with the coating technologies had to be selected.
Based on data presented by the industry, the major suppliers of
wood furniture coatings who participated in the negotiation
supply waterborne topcoats with VOC contents ranging from 0.3 to
0.8 kg VOC/kg solids (Ib VOC/lb solids). Due to variations in
ambient conditions, additional solvent is sometimes added to the
waterborne coatings, raising the VOC content of the as-applied
coatings. The committee therefore chose 0.8 kg VOC/kg solids (Ib
VOC/lb solids) as a reasonable VOC limit for waterborne topcoats.
For higher-solids sealers and topcoats, the Committee
decided that different coating limits were appropriate depending
on the type of sealer and topcoat used by a facility. As
discussed in Chapter 2, residential furniture manufacturers
typically use nitrocellulose sealers and topcoats. These
conventional coatings have a solids content ranging from 15 to
20 percent by weight. Office furniture manufacturers typically
use acid-catalyzed sealers and topcoats. The solids content of
these coatings ranges from 20 to 30 percent solids. Finally,
kitchen cabinet manufacturers typically use vinyl sealers and
5-5
-------
DRAFT
3561/650395
6/22/95
conversion varnishes with a solids content ranging from 25 to
35 percent by weight.
The Committee decided that there were no higher solids
sealers and topcoats available to the entire wide range of
finishing sequences that were readily usable by the existing
processes and met the performance specifications of the vinyl
sealers and conversion varnishes. Therefore, they agreed on a
limit of 2.3 kg VOC/kg solids (Ib VOC/lb solids), as applied, for
acid-cured alkyd amino vinyl sealers. For acid-cured alkyd amino
conversion varnishes, they agreed on a limit of 2.0 kg VOC/kg
solids (Ib VOC/lb solids), as applied. These values are roughly
equivalent to coatings with a solids content of 30 percent by
weight.
For all other sealers and topcoats, the Committee decided on
limits of 1.9 kg VOC/kg solids (Ib VOC/lb solids) and 1.8 kg
VOC/kg solids (Ib VOC/lb solids), as applied, respectively.
These values roughly correspond to coatings with a solids content
of 32 to 35 percent by weight.
5.3 SELECTION OF WORK PRACTICE STANDARDS
In selecting RACT and the requirements for the NESHAP, the
Committee recognized that VOC and HAP emissions could be further
reduced by implementing work practice standards. The work
practices selected for the proposed NESHAP and as part of RACT
are basically the same One difference is that there are
-additional work practices in the NESHAP which are particularly
concerned with the use of specific materials due to their
potential effects on health and the environment. The work
practices that are included as part of RACT are concerned solely
with reducing VOC's.
The Committee believed that there were reasonable work
practices to reduce VOC emissions from both coating operations,
cleaning operations, and washoff operations,
5.3.1 Coat ing JDperations
Specifically, three areas in which VOC emissions from
coating operations could be reduced through work practices were
identified: VOC storage, VOC transfer, and coating application,
5-6
-------
DRAFT
3561/650395
6/22/95
Work practices for each of these areas are discussed below and
summarized in Table 5-2.
5.3.1.1 VOC Storage. Materials containing VOC are often
stored in containers that are left open, allowing the VOC to
evaporate and be emitted through room ventilation to the
atmosphere. A straightforward, inexpensive method of reducing
emissions from VOC storage would be to use normally closed
containers, that is, to cover all VOC storage containers when not
in use. This practice has already been implemented at some
facilities. In addition to reducing VOC emissions to the
atmosphere, this work practice has the added benefit of reducing
worker exposure to VOC and creating a cost savings by reducing
evaporative losses.
5.3.1.2 VOC Transfer. In wood furniture coating
operations, coating is pumped from its storage container to the
spray gun through piping. The most likely locations for leaks to
occur in such a transfer system are from the pumps and at the
coating application equipment juncture. The Committee agreed
that requiring sources to check these areas for leaks was
reasonable. To implement the leak inspection program, sources
should develop an inspection and maintenance (I&M) plan that
requires the inspection of each piece of equipment used to
transfer or apply finishing materials or solvents. The inspec-
tion may be a visual inspection only, but it must be conducted at
a minimum frequency of once per month, with repairs to leaking
equipment made within 15 calendar days unless new equipment must
be ordered. Also, the plan should identify the procedures to be
followed in the event that a pump or coating application
equipment malfunctioned such that a VOC release could occur.
This work practice includes some minimum criteria that are
necessary for an I&M program to be effective. For example, the
Committee believed that a monthly inspection frequency would be
appropriate to accomplish the goal of reducing leaks from pumps
and coating application equipment. More frequent monitoring may
be burdensome; smaller shops would not have the personnel to
perform the inspections and larger shops would be devoting a
5-7
-------
DRAFT
3561/650395
6/22/95
TABLE 5-2. WORK PRACTICE STANDARDS TO MEET RACT
Emission source
Work practice
Finishing operations . .... .
Transfer equipment leaks
Storage containers, including mixing
equipment
Application equipment
Develop written inspection and maintenance plan to address
and prevent leaks. The plan must identify a minimum
inspection frequency of I/month and procedures for
addressing malfunctions.
When such containers are used for VOC or
VOC-containing materials, keep covered when not in use.
Discontinue use of conventional air spray guns.*
Cleaning operations
Gun/line cleaning
Spray booth cleaning
Washoff tanks/general cleaning
- Collect cleaning solvent into a closed container.
- Cover all containers associated with cleaning when not
in use.
- Use strippable spray booth coating with a VOC content
of no greater than 0.8 kg VOC/kg solids Ob VOC/lb
solids).
- Do not use solvents unless cleaning conveyors or metal
filters, or refurbishing the spray booth.
- Keep washoff tanks covered when not in use.
- Minimize dragout by tilting and/or rotating part to drain
as much solvent as possible and allowing sufficient dry
time.
- Maintain a log of the quantity and type of solvent used
for washoff and cleaning, as well as the quantity of
waste solvent shipped offsite, and the fate of this waste
(recycling or disposal).
- Maintain a log of the number of pieces washed off, and
the reason for the wash off.
Miscellaneous
Operator training
Implementation plan
All operators shall be trained on proper application,
cleanup, and equipment use. A training program shall be
written and retained onsite.
Develop a plan to implement these work practice standards
and maintain onsite.
aConventional air guns will be allowed in the following instances:
- when they are used on conjunction with coatings that emit less than 1 kg (lo) VOC per kg Ob) of
solids used;
- for touchup and repair under limited conditions;
- when spray is automated;
- when add-on controls are employed,
- if the cumulative application is less than 5 percent of the total gallons of coating applied; or
* if the permitting agency determines that it is economically or technically infeasible to use other
application technologies,
5-8
-------
DRAFT
3561/650395
6/22/95
significant portion of time to monitoring the many pumps and
coating stations. The monthly inspection frequency is further
supported by other EPA regulatory actions.2 The leak detection
and repair program identified in Subpart H of the hazardous
organic NESHAP (HON) (57 FR 62608) also requires monthly
inspection of pumps. To ensure that action would be taken if
leaks were detected, the I&M plan should.require that repairs be
made within 15 calendar days, with a first attempt at repair made
within 5 calendar days. Again, the EPA's decision is supported
by previous regulatory action; the HON and the NESHAP for coke
oven batteries both require this same repair timeframe.2'3
The I&M plan must also somehow address equipment
malfunctions. In the model rule in Appendix B, this is
accomplished by requiring that the I&M plan include a malfunction
plan. Such a plan has its basis in the startup, shutdown,
malfunction plan required by § 63.6(e) of the General Provisions
to 40 CFR Part 63.4 As discussed in Chapter 7, the State or
local regulatory agency may pursue a different method for
addressing malfunctions, as long as it achieves the same goal of
requiring a facility to address equipment malfunctions.
5.3.1.3 Coating Application. Another aspect of wood
furniture coating operations that was evaluated was the type of
coating application equipment used. There have been numerous
studies comparing the transfer efficiency of one type of
application equipment with that of another type. Transfer
efficiency is the amount of coating that actually is applied to a
surface compared to the total amount of coating used for the
application process. The higher the transfer efficiency, the
less coating that is used and the less coating that is lost as
overspray (sprayed coatings that miss the piece). Overspray
eventually dries, releasing VOC's, and becomes a solid waste
source for the facility. Thus, by increasing transfer
efficiency, both air emissions and solid waste are reduced.
Traditionally, the EPA's position on transfer efficiency has
been one that advocates the use of more efficient transfer
methods, but EPA contends that emission reductions resulting from
5-9
-------
DRAFT
3561/650395
6/22/95
these methods cannot be generally quantified for every coating
situation or easily monitored on a continuous basis, and, thus,
sources cannot receive emission credits for improving transfer
efficiency. To deal with this issue, the Committee explored a
work practice which would require the use of technologies
believed to result in more efficient application of coating. To
encourage innovation in application equipment, the work practices
include an equipment requirement that does not require the use of
specific application equipment but limits the use of conventional
air guns because they are the least efficient transfer method.
Exempted situations may include one in which a source is using
low-VOC coatings (less than 1 kg VOC/lb solids [1 Ib VOC/lb
solids]) or add-on control devices; transfer efficiency is not
critical in these situations. Also, if the use of air guns is
limited to specialty operations but more efficient application
methods were used for the majority of coating, the environmental
impact of using conventional air guns would be minimal. The
specific exemptions to the conventional air spray gun prohibition
are provided in Table 5-2.
Operator training on coating application is also a required
work practice. By training the operators on proper equipment
operation, transfer efficiency will increase, resulting in a
reduction of VOC emissions to the atmosphere. This work practice
is discussed further later in the chapter.
5.3,2 Cleaning and Washoff Operations
As discussed in Chapter 2, cleaning activities that occur at
wood furniture manufacturing operations include cleaning of spray
guns., lines conveying coatings from storage to the spray guns,
and spray booths. The Committee also agreed on work practices
for washoff operations. Washoff involves the use of solvents to
remove coating from furniture, In determining the work practices
to be selected for cleaning and washoff operations, the Committee
considered work practices that were being performed in the source
category to limit emissions from these activities.
The Committee concluded that there were reasonable work
practices in use by existing facilities in the source category to
5-10
-------
DRAFT
3561/650395
6/22/95
limit emissions from each major cleaning and washoff activity:
gun/line cleaning, spray booth cleaning, and furniture
washoff/general cleaning activities. These work practices are
summarized in Table 5-2 and are discussed below.
5.3.2.1 Gun/Line Cleaning. The cleaning of spray guns and
of lines that carry the coating from storage to the spray guns is
a common practice in wood furniture operations. Cleaning is
necessary so that dried resins or other materials do not build up
in the lines or spray equipment. The frequency of cleaning
varies by plant, depending on the different types of coating
sprayed with a given gun, the extent to which a gun is used, and
other plant-specific factors. Typically, a gun is cleaned each
time it is used to spray a different coating. If a gun is
dedicated to one type of coating (e.g., topcoat), cleaning
frequency may be reduced. The practice of dedicating a gun to a
particular coating type is not common, however, especially at
smaller shops that have fewer spray stations.
One cleaning operation work practice included in RACT
requires that solvent used for cleaning be collected into a
closed container. For example, if a line is flushed, the
cleaning solvent could be collected into a container with a lid
that has an opening of sufficient size for the line to fit in;
the rest of the container could be covered. Such a container
could be prefabricated onsite, or purchased from an outside
vendor, at a minimal cost to the plant. Another work practice
that is included in RACT and that could be easily implemented is
the use of normally closed containers, that is, covering cleaning
solvent containers when not in use. As discussed for VOC storage
containers associated with coating operations, such a practice is
straightforward and inexpensive to implement.
5.3.2.2 Spray Booth Cleaning. The work practices
identified as part of RACT require the use of strippable spray
booth materials with a VOC content no greater than 0.8 kg VOC/kg
solids (Ib VOC/lb solids). A strippable spray booth material is
one that is applied to spray booth walls; coating overspray is
collected on the material, and the material is regularly stripped
5-11
-------
DRAFT
3561/650395
6/22/95
off and disposed of. Therefore, only small quantities of solvent
are needed to clean the spray booth walls. The work practices
prohibit the use of solvents for spray booth cleaning except in
limited circumstances because facilities could easily convert to
using strippable spray booth materials that eliminate the use of
solvents for this purpose. The Committee recognized that there
were instances in which it was unreasonable to prohibit solvent
use for cleaning. Specifically, it was agreed that conveyors
carrying furniture or furniture components through the spray
booth could continue to be cleaned with solvent. Likewise, metal
filters, such as those that are located at the back of the spray
booth and are used to prevent particulate matter from entering,
require solvent cleaning. The Committee was not aware of
substitute materials that could be used for cleaning this
equipment, or of any strippable coating such as the coating that
is available for the spray booth walls. Additionally, industry
representatives pointed out that small tears and holes may be
generated in the strippable booth coating during the
manufacturing process. In these cases, some stainipg of the
spray booth walls may occur. The Committee agreed that sources
could use small quantities of solvent, no more than 3.8 liters
(1.0 gallon) per booth, to clean these areas when the strippable
coating was being replaced.
5.3 .2 . .3 Furniture Washoff /General Cleaning Activities. The
final area of concern for which a work practice has been
identified as the procedure known in the industry as washoff.
Washoff is the removal of the coatings from a piece of furniture
or a furniture component because the quality of the finish does
not meet company specifications By washing off the coatings,
the substrate can be refinished. Washoff is typically
accomplished by dipping the furniture into a tank containing
solvent, The Committee agreed that, there were some measures that
sources could implement, that are reasonable and that would
minimize emissions from washoff activities. A.S with coating and
other cleaning operations, it was agreed that, wash tanks could be
covered when they are not in use to limit solvent emissions.
S -12
-------
DRAFT
3561/650395
6/22/95
Also, sources could minimize "dragout" by tilting and/or rotating
the piece to drain as much solvent as possible and allowing
sufficient drip time. Dragout is the solvent that remains on a
part after it is removed from the washoff tank; this solvent
evaporates and is eventually emitted through room ventilation to
the atmosphere. Minimizing dragout would therefore minimize
emissions. ,
During the Committee's discussions, it was apparent that
cleaning and washoff practices are not well documented by
sources. For example, most sources do not know the quantity of
solvent used for cleaning and washoff operations, how many pieces
are washed off, the reason for washoff, and the fate of spent
solvent from cleaning and washoff operations. Tracking washoff
practices will focus attention on quality control issues.
Tracking may result in quicker identification of process problems
which will reduce efforts on refinishing and save money on
materials and labor. A reduction in refinishing will also mean
better working conditions due to less washoff emissions. The
Committee also agreed that one of the first steps in reducing
emissions is to know the quantity of solvent used for the various
operations onsite. Only then can a source identify operations
that are perhaps wasteful or inefficient. Therefore, the Work
Group proposed that the work practices include a tracking system
plan through which sources would:
1. Maintain a log of the quantity and type of solvent used
for washoff and cleaning, the number of pieces washed off daily,
and the reason for the washoff; and
2. Record the quantity of spent solvent generated from each
activity, and its ultimate fate either onsite or offsite.
The cleaning and washoff solvent usage quantities could be
calculated and reported at some pre-established frequency. The
model rule in Appendix B identifies monthly calculations and
reporting of these monthly quantities.
5-13
-------
DRAFT
3561/650395
6/22/95
5.3.3 General Work Practice Requirements
After reviewing the work practices included in RACT, the
Committee concluded that in order for the work practices to be
successfully implemented, employees that would actually have to
carry them out should be involved in their implementation.
Therefore, an operator training program is included as a required
work practice. The Committee believed that operator training was
especially important for new employees and therefore recommends
that new employees be trained upon hiring. Any rule implementing
this requirement should be flexible and allow sources to develop
programs that work best for their facility or that could be
coordinated with existing training programs. At a minimum,
however, this work practice requires that the employee training
program address coating application, cleaning, and washoff
techniques that minimize emissions; proper equipment operation;
methods to reduce solvent usage; and proper management of cleanup
wastes. The work practice also requires that employees be
retrained on an annual basis.
Finally, the Committee recognized that a source should
maintain a plan to implement the work practices included in RACT.
Therefore, the work practices include the development of an
Implementation Plan that describes how sources plan to comply
with the work practice requirements on an on-going basis. Based
on the work practices included in RACT, the Committee believed
that any Implementation Plan should include, at a minimum, the
following:
1. Checklists to document that:
all storage containers are covered where not in use;
solvents are not being used for spray booth cleaning
except when metal filters or conveyors are being cleaned or the
spray booth is being refurbished;
conventional air spray guns are not in use except for the
specific situations identified;
cleaning solvent from gun/line cleaning has been
collected into a closed container;and
the washofi: tank is covered when not in use;
5-14
-------
DRAFT
3561/650395
6/22/95
2. An I&M plan as discussed above;
3. A tracking system for washoff and cleaning solvents as
discussed above; and
4. The operator training program discussed above.
The Work Practice Implementation Plan would be followed and
maintained onsite to demonstrate ongoing compliance, and made
available at the request of the Agency at; any time.
5.4 SELECTION OF COMPLIANCE PROVISIONS
In discussing the compliance provisions, the Committee
decided only on some general requirements regarding compliance.
The Committee, for example, believed that any rule codifying RACT
should allow the use of reference control technologies, as well
as other technologies that may be equivalent to the reference
control technologies in terms of air emission control. Examples
of how a rule could accomplish this are discussed in Chapter 7.
The Committee also agreed that, when reference control
technologies are used, compliance should be accomplished through
reporting and recordkeeping, with reporting occurring on a
semiannual basis. Specifically, reports should include certified
product data sheets that provide the VOC content of a coating in
kg VOC/kg solids (Ib VOC/lb solids), as applied. If the data
sheet provided by the coating supplier identifies the VOC content
in kg VOC/kg solids (lb VOC/lb solids) and the facility then
dilutes the coating, the facility must account for this dilution
and report the VOC content of the coating that is actually
applied, not the VOC content of the coating as purchased.
In summary, the compliance provisions contained in the rule
that implements RACT should include:
1. Methods that allow compliance through the use of
reference control technologies as well as other control methods
that can be demonstrated as equivalent;
2. The means by which alternate methods are demonstrated as
equivalent;
3. Compliance through reporting and recordkeeping, with
reporting occurring on a semiannual basis; and
5-15
-------
DRAFT
3561/650395
6/22/95
4. When reference control technologies are used, compliance
through reports of the VOC content of coatings, as applied, in
kg VOC/kg solids (Ib VOC/lb solids).
The model rule presented in Appendix B allows facilities to
use one of three methods, or a combination of the three methods,
to comply with the requirements of the model rule. These include
use of compliant coatings, use of an add-«on control device, or
use of an averaging approach. The model rule provides detailed
guidance on monitoring, recordkeeping, and reporting requirements
associated with each of these compliance methods.
5.5 SMALL BUSINESS CONSIDERATIONS
Because of the large number of small businesses that could
potentially be impacted by regulation of the wood furniture
industry, the Committee considered carefully the impact of each
aspect of presumptive RACT on small businesses. The regulatory
negotiation Committee included two small wood furniture
manufacturers and a representative of a trade association
consisting primarily of small businesses. A Small Business Work
Group wat; formed to specifically address small business issues.
In evaluating compliance options, the Committee tried to
ensure that the compliance options would impose a minimum burden
on small businesses. For example, presumptive RACT does not
require f;he use of contr.oi devices that require a significant
capital investment and impose aA unfair burden on small
businesses that typically have trouble raising capital. In
addition, the Committee tried to ensure that the recordkeeping
and reporting requirements of the proposed standards were not
beyond the resources of -small businesses.
The Committee also evaluated whether the proposed work
practice standards presented any particular problems to small
businesses, Some members felt i:hat developing an operator
training program might pose some problems to small businesses.
Rather than exempt small businesses trom what the Committee feels
is a key work practice, Lhe Committee decided to recommend that
small business work together to deve1op a training program. The
Committee also suggested that large businesses that already have
5 16
-------
DRAFT
3561/650395
6/22/95
training programs in place could share the key components of
those programs with small businesses. Finally, the Committee
recommended that State small businesses assistance programs
assist small businesses in developing their training program.
The Small Business Work Group made several recommendations
to the Committee, including a recommendation that the EPA draft a
document that would provide guidance to email businesses on how
to obtain a Federally-enforceable limit on their potential to
emit and recordkeeping requirements that might be associated with
the limit. In addition, small business representatives proposed
that the EPA draft a memorandum responding to questions developed
by the Small Business Work Group pertaining to area sources that
become major sources.
The EPA, California Air Pollution Control Officers
Association, and the California Air Resources Board (CARS) have
completed a model rule for use by the California Air Pollution
Control Districts. Because the rule should prove to be an
inexpensive and efficient means of limiting the potential
emissions of thousands of sources, the EPA believes that parts of
the rule may be helpful- for other States to review and consider.
The proposed rule is designed to place smaller sources under
annual emissions limits which restrict their potential to emit
and thus their exposure to major source requirements of the Clean
Air Act. The rule ensures compliance through a series of
recordkeeping and reporting requirements which are tapered to
reduce burdens as source size decreases. The rule applies only
to sources that agree to limit their emissions to 50 percent or
less of the major source threshold. Sources with emissions above
this level must either comply with all applicable major source
requirements or secure a source-specific. Federally-enforceable
Air Pollution Control District permit that properly limits
emissions to below major source thresholds. Therefore, the rule
is designed to provide smaller sources with a Federally-
enforceable means of limiting their potential emissions.5
The Small Business Work Group also recommended that the EPA
discuss in the preamble to the NESHAP the benefits of general
5-17
-------
DRAFT
3561/650395
6/22/95
permits for small businesses and encourage their use where
appropriate. The Agency agreed and a discussion of general
permits is included in the NESHAP preamble. The Small Business
Work Group also recommended that the EPA, in conjunction with the
State of North Carolina Small Business Ombudsman Office, develop
an information outreach program to serve as a resource for small
wood furniture manufacturers. The Agency, has agreed to work with
the North Carolina Small Business Ombudsman Office to develop
this program.
5.6 REFERENCES FOR CHAPTER 5
l. Memorandum and attachment from Lingelbach, J., and S.
Wildau, CDR Associates, to Wood Furniture Regulatory
Negotiation Committee Members. October 27, 1994. Final
Document and Signature Document,
2. Code of Federal Regulations. 40 CFR Part 63. Subparts F,
G, H, and I. National emission standards for hazardous air
pollutants (NESHAP) from synthetic organic chemical
manufacturing industry equipment leaks. Promulgated
April 22, 1994.
3. Code of Federal Regulations. 40 CFR Part 63. Subpart L.
National emission standards for hazardous air pollutants for
coke oven batteries. Promulgated October 27, 1993.
4. Code of Federal Regulations. 40 CFR Part 63. Subpart A.
National emission standards for hazardous air pollutants for
source categories --General Provisions. Promulgated
March 16, 1994.
5. Memorandum and attachments from Seitz, J.S, and
R.I. Van Heweler, EPA, to Director, Air, Pesticides, and
Toxics Management Division, Regions I and IV. et al.
January 25, 1995, Options for Limiting the Potential to
Emit (PTE) of a Stationary Source Under Section 112 and
Title V of the Clean Air Act.
5-18
-------
DRAFT
3528/650395
7/12/95
6.0 COST, ENVIRONMENTAL, AND ENERGY IMPACTS
This chapter addresses the cost, environmental, and energy
impacts of the RACT requirements for finishing and cleanup
operations presented in Chapter 5. Typically, this chapter
addresses the impact of each of the control options presented in
Chapter 3. However, as discussed in Chapters 1 and 5, the
presumptive norm for RACT for the wood furniture industry was
developed through a negotiation process. Although options other
than those agreed upon by the regulatory negotiation committee
were discussed during the negotiation process, a detailed
analysis of the impacts of those options was not prepared.
Therefore, this chapter will focus on the impacts of the RACT
requirements agreed upon by the Committee.
The EPA recognizes the need for States to have information
on other control options and their impacts. The costs presented
in this chapter are extrapolated from the costs developed for an
earlier draft version of the CTG and a report prepared by the
industry that addressed options for controlling VOC emissions
from wood furniture finishing operations and the costs of those
options.1'2 Both the earlier version of the draft CTG and the
industry report were begun before the industry and EPA agreed to
negotiate the recommended RACT requirements. Therefore, both
contain costs for other RACT options, although they are based on
different model plants than the model plants presented in
Chapter 4.
Section 6.1 of this chapter discusses the cost associated
with each of the elements of the presumptive RACT requirements.
Section 6.2 presents the total cost of meeting the presumptive
RACT requirements by model plant, and Section 6.3 presents the
6-1
-------
DRAFT
3528/650395
7/12/95
nationwide costs and emission reductions for facilities in
nonattainment areas and the ozone transport region. Section 6.4
presents the environmental and energy impacts of the presumptive
RACT requirements on the industry. Section 6.5 presents the
costs of other control options based on data from EPA's earlier
version of the draft CTG and industry's report. Section 6.6
presents a listing of the chapter references.
6.1 COST OF THE RECOMMENDED RACT OPTIONS
As discussed in Chapter 5, the RACT options agreed to by the
Committee include limitations on the VOC content of the coatings
that are used, a set of work practice standards which include
restrictions on the type of application equipment that can be
used, and other practices to reduce emissions from finishing,
cleaning, and washoff operations. This section will discuss the
costs associated with each of these requirements.
6.1.1 Limitation on VOC Content of Coatings
There are two technologies that the industry can use to meet
the RACT requirements for coatings. A facility may choose to use
(1) waterborne topcoats (or other topcoats with a VOC content
less than or equal to the limit for waterborne topcoats), or
(2} higher solids sealers and topcoats. The costs to the
facility will vary according to the technology presently being
used as well as the technology they choose to use to comply with
RACT.
One characteristic common to both of the RACT coating
options presented here, and to most lower VOC coating systems, is
that the coatings have a higher solids content than conventional
solventborne coatings In instances where the quantity of solids
applied to the piece (the build) determines how much coating is
used, an increase in solids content results in a decrease in
coating usage. This is the case tfiuh filler, sealer, and topcoat
materials In instances where the degree of color penetration
{rather chan build) determines how much coating is used, a higher
solids content does not automatically result in decreased coating
usage, This is the case with stains, washcoat, and highlight
materials. In general, a facility switching to coatings that
6-2
-------
DRAFT
3528/650395
7/12/95 ,
meet either of the RACT options will decrease their annual
coating usage.
Following is a discussion of the costs associated with each
of the RACT options for coatings. All costs are presented in
1991 dollars.
6.1.1.1 Higher Solids Sealer and Topcoat. The only
quantifiable cost to the industry for converting to higher solids
sealers and topcoats -is an increase in coating cost. In
developing the costs for higher solids sealers and topcoats, it
was assumed that the cost of the coating increases as the solids
content increases. Based on information collected by EPA in
developing the Automotive Plastic Parts CTG, the cost of the
higher solids coating is equivalent to the ratio of the solids
content of the higher solids coating to the baseline coating,
plus 20 percent, multiplied by the cost of the baseline coating.3
For example, if the baseline coating contains 2 Ib solids/gal and
the higher solids coating contains 4 Ib solids/gal, then the cost
of the higher solids coating will be 2.2 times the price of the
baseline coating. Because a facility will use 50 percent less of
the higher solids coating, the net effect is a 20 percent
increase in coating cost. There may be other costs associated
with the use of higher solids sealers and topcoats that can not
be quantified, such as increased drying time. An increase in
drying time would require modification of finishing lines and
would lower productivity in terms of units produced in a given
period of time.
6.1.1.2 Waterborne Topcoats. Although facilities may meet
the 0.8 Ib VOC/lb solids limitation on topcoats using
technologies other than waterborne coatings, the costs associated
with meeting the limit are based on facilities converting to
waterborne topcoats. There are four major components included in
the cost of converting to waterborne coatings including an
increase in coating cost, increased drying capability,
modifications to existing paint circulation systems, and material
storage. The cost of each of these components is discussed in
detail in the following paragraphs.
6-3
-------
DRAFT
3528/650395
7/12/95
6.1.1.2.1 Coating costs. Facilities converting to
waterborne topcoats will use approximately 20 percent less
coating than baseline, due to the higher solids content of these
waterborne coatings. However, there is still a net increase in
coating cost because waterborne coatings cost more per gallon
than the conventional solventborne coatings. According to the
report prepared by industry, the average post of all conventional
solventborne coatings used by the industry is $7.50 per gallon
while the average cost for waterborne coatings is $13.00 per
gallon.4 In calculating the cost of converting to waterborne
topcoats, the cost of the waterborne topcoats was assumed to be
$13.00 per gallon and the cost of all other coatings was assumed
to be $7.50 per gallon.
6.1.1.2.2 Additional drying capability. Based on input
from coating material suppliers, the use of waterborne coatings
will require increased drying time, unless process modifications
are made. These modifications may include additional ovens,
increases in airflow rate, decreases in line speed, or increases
in conveyor length. For the purposes of this analysis, it was
assumed that increased drying requirements will be met by the
addition of drying ovens.
According to vendor information, if a wood furniture
manufacturer were to replace an oven, or obtain an additional
oven, they would most likely purchase a turbolator oven.5'^'7
These types of ovens offer a hjgher airflow rate than
conventional convection ovens: 566 cubic meters per minute
(rtrVmin) [20,000 cubic feet per minute (ft3/min)] compared to
85 m3/min (3,000 ft3/min) for conventional ovens. This higher
airflow rate translates into increased drying capability. The
vendors estimated the total installed capital cost of a new
20 foot turbolator oven at $48,600. A facility's operating costs
will also increase with the addition of new ovens. Annual fuel
and electricity costs for a turbolator oven are approximately
$3,500 per oven.
In developing costs it was assumed that a new oven was
required for all waterborne topcoat steps. For example,
6-4
-------
DRAFT
3528/650395
7/12/95
facilities in the long spray model plant type, model plants 4, 5,
and 6, have three topcoat applications, so it was assumed that
they will need three new ovens. If a model plant has multiple
lines, as do model plants 5 and 6, then an oven is needed for
each topcoat application on each line. The exception to this is
for the model plants representing the very small facilities, for
example, model plant 4a. It was assumed*that these facilities
will only need one oven because they do not have tow lines or
conveyors. Pieces are rolled into the spray booths on carts,
finished, and then manually moved to the next spray booth.
Multiple applications of the same coating step are often made in
the same booth. Therefore, facilities in these model plants are
likely to apply one topcoat step, place the piece in the oven to
be dried, apply the next topcoat step, and place the piece back
in the same oven.
6.1.1.2.3 Paintcirculation systems. Facilities using
waterborne coatings need to use passivated stainless steel
delivery systems and mix tanks. In developing the cost of the
required systems it was assumed that the very small and small
model plants pump their coating materials directly from a drum
(located at the spray booth) to the spray gun, that is, they do
not have a central mix room. For the medium and large model
plants it was assumed that a central pump room is used to supply
all coating materials to the spray booths. For costing purposes,
each booth is assumed to be an average of 200 feet from the mix
0
room.
For the very small and small model plants to use waterborne
topcoats, the equipment used to transfer the coatings from the
drum to the spray gun must be stainless steel. For these plants
a modular passivated stainless steel paint delivery system is
necessary. The components of this system include the following:
- stainless steel storage drum;
- fluid pump;
- drum cover elevator assembly;
- fluid regulator;
- fluid filter/strainer;
6-5
-------
DRAFT
3528/650395
7/12/95
- fluid and air hoses;
- valves; and
- oil/water extractor for air supply.
Based on an average of vendor costs, the above modular
stainless steel system has an estimated total installed capital
cost of $9,100 per unit.9'11 The 55 gallon stainless steel drum
from which the coating material is pumped, was assumed to be
provided by the coating supplier.
For medium and large facilities, new passivated stainless
steel paint circulation systems are necessary. Modifications are
required in the mix room, at the spray booths, and with the
material transfer lines. Changes in the mix room are required to
accommodate waterborne coating material storage and agitation of
the material, and for pumping and regulating coating materials.
Based on vendor information, the following components are
required in the mix room:
- stainless steel mix tank;
- fluid pump;
- agitator and lid assembly;
- hoses, regulators;
- back pressure valve with gauge; and
- filter/valves (to isolate filter)
Eased, on an average of costs supplied by vendors, the
estimated installed capital cost of the mix tank is $25,600 and
the total installed capital, cost of the mix tank assembly
(agitator, pumps, valves, hoses) is $8,800.9"11 In developing
model plant costs, it was assumed that one mix tank and mix tank
assembly was required for each finishing line.
Equipment, modifications are also required at the spray booth
if waterborne coatings are used. For medium and large
facilities, the-, following stainless steel equipment will be
required at each spray booth:
- fluid valves;
• fluid regulator;
- fluid hose to gun;
- paint; heater;
6-6
-------
DRAFT
3528/650395
7/12/95
- air hose; and
- oil/water extractor for air supply.
Based on an average of cost information supplied by vendors,
the total installed capital cost of the above equipment, except
for the paint heater, is $1,400.9'10 The paint heater is
supplied separately at a total installed capital cost of $1,850.
The above equipment is required at each booth using waterborne
coatings.
In addition to mix room and spray booth equipment, the
material transfer lines circulating between the mix room and
spray booths would also need to be passivated stainless steel.
Based on information supplied by vendors, the installed capital
cost of stainless steel piping (304 grade or better) suitable for
transferring coatings is estimated as $20/foot pipe.12'13
6.1.1.2.4 Material storage. According to industry
representatives and furniture manufacturers, conventional
solventborne coating material storage procedures vary according
to the size of the facility.14"21 Based on the information
supplied by these sources, facilities in the very small and small
model plants are assumed to store all coating materials in
55-gallon drums. Medium and large facilities store their color
coats (stains, glazes, and highlights) in 55-gallon drums, but
they store their solventborne clear coats (washcoat, sealer, and
topcoat) in bulk tanks outside.
A very small or small facility converting to waterborne
topcoats will not have to change their storage procedures. The
coatings will continue to be stored in the containers in which
they are shipped. However, a medium or large facility converting
to waterborne topcoats will have to change their storage
procedures. Waterborne coatings are susceptible to freezing so
they can not be stored outside unless they are in a heated
building. They are also more susceptible to contamination, so
bulk storage is risky. Therefore, in developing costs, it was
assumed that medium and large facilities converting to waterborne
topcoats will have to purchase a 2-hour fire-rated building to
store drums of waterborne coatings.
6-7
-------
DRAFT
3528/650395
7/12/95
The total installed capital cost of the storage facilities
is a function of the quantity of material to be stored. These
costs were provided by vendors on a per drum basis.22" Based
on an average of costs provided by vendors, it was estimated that
the installed capital cost of waterborne material storage is
$380 per drum. The number of drums requiring storage was
calculated for each model plant using the, total amount of
waterborne topcoat used by the model plant per year and assuming
a monthly turnover rate. To allow for increased production, it
was assumed that the building will be large enough to hold a
20 percent excess in capacity.
6.1.2 Application Equipment Requirements
There are three cost components associated with the
application equipment requirements. These are the cost savings
resulting from the decrease in coating usage, the capital costs
of the application equipment, and an increase in labor costs for
some plants.
As discussed in Chapter 5, presumptive RACT will require the
industry to use application technologies other than conventional
air spray. Conventional air spray can only be used for the
limited circumstances discussed in Chapter 5. The presumptive
RACT requirements do not mandate the application technology to be
used. Airless, air assisted airless, high volume low pressure
•'HVLP), electrostatic, dipping, and roll/curtain coating are all
application technologies that can be used. Most facilities are
expected to move to HVLP application equipment to meet the
requirements because it is generally considered to be more
efficient than the other spray technologies, and it is not as
limited in the applications for which it can be used as other
technologies such as roll/curtain coating.25 Therefore, the
costs of the application equipment requirements are based on the
industry switching to HVLP application equipment.
It is difficult to measure transfer efficiency because there
are so many factors in addition to the type of application
equipment that are involved. Therefore, it is difficult to
assign a percentage reduction in coat:ing usage resulting from a
6-8
-------
DRAFT
3528/650395
7/12/95
change in application technology. The industry report assigned a
20 percent reduction in coating usage for facilities switching
from conventional air to HVLP equipment.25 The Pacific Northwest
Pollution Prevention Research Center sponsored a testing program
for evaluating the transfer efficiency of different types of
application equipment under various scenarios. This report
showed that the difference in transfer efficiency between HVLP
•
and conventional air ranged from 0 percent to more than
30 percent.26 In evaluating the cost of a facility changing from
conventional air to HVLP application technology, it was assumed
that coating usage will decrease 10 percent.
According to information supplied by vendors, the average
cost of an HVLP spray gun is $400 installed.27'28 In calculating
the cost to the industry it was assumed that two guns will be
purchased for each spray booth. The exception is for facilities
using waterborne topcoats. As discussed in Chapter 5, the
Committee agreed to exempt these coatings, and others with a VOC
content less than 1 kg VOC/kg solids (1 Ib VOC/lb solids), from
the application equipment requirement. Therefore, facilities
that convert to waterborne topcoats to meet the coating
requirements of RACT will not have to switch to other application
technologies to apply those coatings.
In addition to the capital cost of the application
equipment, a facility may need additional spray booth operators
to apply some coatings with HVLP application equipment. High
volume low pressure spray guns have a slower delivery rate than
conventional air guns. This slower delivery rate can be a
problem when applying stains because they are formulated with
faster evaporating solvents. To overcome this problem, a
facility may need an additional operator for the stain booths.
In developing the costs associated with a facility switching to
HVLP spray equipment, it was assumed that all medium and large
facilities will require two additional spray booth operators for
the stain booths. It was assumed that smaller facilities will
not require additional operators because many of these facilities
6-9
-------
DRAFT
3528/650395
7/12/95
do not have tow lines and those that do typically move at lower
speeds than the lines at medium and large facilities.
6.1.3 Work Practice Standards
The Committee agreed to a number of work practice standards
to reduce VOC emissions from finishing, cleaning, and washoff
operations. While it is assumed that these work practice
standards will result in a decrease in coating, cleaning, and
washoff solvent usage and will likely result in an overall
savings to the facility, there is not enough data available to
quantify either the reduction in emissions or costs associated
with most of these standards. The exception is for the operator
training requirements. Following is a discussion of the costs
associated with these requirements.
As with the application equipment requirements, the
reduction in coating usage that can be achieved by training spray
booth operators and other employees that use solvent is difficult
to quantify. However, the report from the Pacific Northwest
Pollution Prevention Research Center shows that well trained
•jpray booth operators can achieve higher transfer efficiencies
with comparable spray equipment.26 The Center compared the
transfer efficiency achieved by expert painters with that
achieved by novice painters. In almost every case, the expert
painter achieved a higher transfer efficiency using the same
equipment, with the difference ranging from 0 percent to almost
30 percent. For this analysis, it was assumed that spray booth
operator training
-------
DRAFT
3528/650395
7/12/95
manufacturing facility are involved in assembly operations or
provide clerical support. These employees do not use solvents
and will not require training. While new employees may require
more than 8 hours of training, it was assumed that these
employees already receive some basic training so no more than an
additional 8 hours of training will be required.
For facilities represented by the r9ll/curtain coat model
plants, it was assumed that there will be no reduction in coating
usage from the operator training requirements because these
facilities do not use spray application equipment. However,
employees in these facilities will still have to be trained
because they handle coatings and solvents. The training
requirements will reduce emissions, but the reduction has not
been estimated because of a lack of available data. In
estimating the costs of training, it was assumed that 50 percent
of the employees at these facilities will have to be trained, but
the training will be less comprehensive than training at other
facilities and will only require 4 hours per year.
6.2 MODEL PLANT COSTS
The first step in evaluating the costs of the presumptive
RACT requirements by model plant is to determine which option
each model plant type is likely to use to meet the VOC content
limitations on the coatings. As discussed earlier and in
Chapter 5, a facility can choose to use topcoats with a VOC
content less than 0.8 kg VOC/kg solids (0.8 Ib VOC/lb solids) to
meet the presumptive RACT requirements for coatings or they may
choose to use higher solids sealers and topcoats with VOC
contents less than or equal to 1.9 and 1.8 kg VOC/kg solids
(1.9 and 1.8 Ib VOC/lb solids), respectively. For facilities
using conversion varnishes and vinyl sealers the limits are
2.0 and 2.3 kg VOC/kg solids (2.0 and 2.3 Ib VOC/lb solids),
respectively. Although each facility subject to the presumptive
RACT requirements can choose the approach best suited to their
product requirements, it is expected that some types of
facilities are more likely to choose to use waterborne topcoats
and some are more likely to choose higher solids sealers and
6-11
-------
DRAFT
3528/650395
7/12/95
topcoats. In developing the model plant costs, it was assumed
that some model plant types will use waterborne topcoats to meet
the presumptive RACT requirements for coatings and some will use
higher solids sealers and topcoats to meet the requirements.
In developing the cost of the VOC limitation on coatings by
model plant, it was assumed that facilities in the short spray,
roll/curtain coat, and kitchen cabinet model plant types will use
higher solids sealers and topcoats to meet the RACT requirements.
The majority of kitchen cabinet manufacturers already use vinyl
sealers and conversion varnishes so it was assumed that they will
choose to meet the RACT requirements by using topcoats with a VOC
content less than or equal to 2.0 kg VOC/kg solids (2.0 Ib VOC/lb
solids) and sealers with a VOC content less than or equal to
2.3 kg VOC/kg solids (2.3 Ib VOC/lb solids). The conversion
varnishes used by these facilities already meet the 2.0 kg VOC/kg
solids (2.0 Ib VOC/lb solids) limit, so the only cost and
emission reduction for these facilities resulting from the
coating limitations will come from reformulating their sealers to
meet the 2.3 kg VOC/kg solids (2.3 Ib VOC/lb solids) limit.
Facilities in the roll/curtain coat model plants already use
sealers and topcoats that meet the higher solids limits of 1.8 kg
VOC/kg solids (1.8 Ib VOC/lb solids) for topcoats and 1.9 kg
VOC/kg solids (1.9 Ib VOC/lb solids) for sealers. Therefore,
these facilities will incur no cost in meeting the VOC limits for
chese coatings.
Facilities in the short spray model plant uype can choose to
meet the VOC limitation on coatings by using waterborne topcoats,
or their equivalent, or higher solids sealers and topcoats. In
developing costs, it was assumed that these facilities will
choose to meet the RACT requirements for coatings by
reformulating to higher solids sealers and topcoats. Many of the
facilities represented by the short spray model plant type
already use slightly higher solids coatings than those used by
the long spray facilities. Manufacturers cf office furniture and
public building furniture, (SIC codes 2521 and 2531), typically
use acid-catalyzed coatings that are higher in solids than the
6-12
-------
DRAFT
3528/650395
7/12/95
conventional nitrocellulose lacquers used by much of the
industry, manufacturers of store fixtures use higher solids
basecoats and enamels. These facilities need coatings that are
tougher and more resistant to chemicals and scratching, and the
higher solids coatings provide these characteristics. Therefore,
it is likely that these facilities will meet the presumptive RACT
requirements for coatings by converting ^o higher solids
coatings, and the costs and emission reductions were calculated
using this assumption.
It was assumed that facilities represented by the long spray
and upholstered model plant types will choose to use waterborne
topcoats to meet the presumptive RACT requirements for coatings.
Several of the facilities manufacturing upholstered furniture
that responded to EPA's survey had already moved to waterborne
coatings. These facilities are likely to convert to waterborne
coatings because they would not experience some of the same
problems of other facilities. As discussed earlier, waterborne
coatings dry more slowly than solventborne coatings. This slower
drying is less likely to be a problem in facilities manufacturing
upholstered furniture because most of these facilities are like
small facilities in that the pieces to be finished are moved
manually from booth to booth, rather than on a tow line or
automated conveyor. Therefore, the additional drying time that
is required for waterborne coatings is not as much of a problem
for upholstered furniture operations as it is for facilities with
automated lines. Therefore, the costs and emission reductions
for upholstered furniture facilities were calculated assuming
they switch to waterborne topcoats.
Facilities represented by the long spray model plant
currently use nitrocellulose sealers and topcoats that are lower
in solids than the sealers and topcoats used by the other model
plant types. Conversion to higher solids sealers and topcoats
may be more difficult for them than for the model plant types
already using higher solids coatings. In addition, the higher
solids coatings may not provide them with the required
aesthetics. Therefore, these facilities are expected to convert
6-13
-------
DRAFT
3528/650395
7/12/95
to waterborne topcoats to meet the presumptive RACT requirements,
and the costs and emission reductions were calculated using this
assumption.
Table 6-1 presents the costs for the model plants converting
to higher solids sealers and topcoats to meet the VOC limitation
on coatings. Table 6-2 presents the costs for the model plants
converting to waterborne topcoats to meet, the limits. The total
annual costs and the cost effectiveness for each model plant are
presented in Table 6-3.
The total capital cost in Table 6-3 is based on the total
capital cost of HVLP guns, total capital cost of additional
drying capacity, total capital cost of the paint circulation
system, and total capital cost of coating material storage. The
total annualized capital cost is based on a 10 year lifetime and
10 percent interest. The total operating cost is based on labor
cost, incremental annual coating cost, incremental fuel and
electric cost for ovens, incremental disposal cost for waterborne
coatings, and taxes, insurance, and administrative costs
(4 percent of total capital cost). The total annual cost is the
sum of the total operating cost and the total annualized capital
cost, Costs to implement the presumptive RACT requirements for
the model plants range from a cost savings of more than $900/Mg
to a cost of over $3,600/Mg,
6.3 NATIONWIDE IMPACTS OF PRESUMPTIVE RACTS
Nationwide cost impacts and emission reductions were
estimated for the presumptive RACT options. The CTG will only
apply to wood furniture facilities located in ozone nonactainment
areas and in the ozone transport region. Therefore, to calculate
nationwide cost impacts and emission reductions, the total number
of facilities located in nonat:i;ainment areas and the ozone
transport region was estimate]. In developing the distribution
of facilities in nonattainmeiit. areas and the ozone transport
region, a relationship between the total number of employees and
the size of the facility was developed. Table 6-4 presents the
distribution of plants by model plant number for plants in
nonattainment areas and the ozone transport- region. This table
6-14
-------
DRAFT
3528/650395
7/12/95
CO
E-«
W
O
U
vo
H
•J
I
lc
U
O
1
m
C.
V
0
"""'
^
o>
M
-
^
S!
m
c?
o
^f
—
4*
i
c
S o
n V
Low-VOC coatine co
Incremental annual
§ g s
s * "
282
oo K —
§, P "*
^— ik
*rt ^) (S
2 v>
s w
f ° 8
z z z
< < <
z z z
z z z
z z z
1 g g
V» O 1**
e, -
f? o «
5 R F:
•not-
^ (*••
0? O >O
00 9
e
0^ 0 0
o* ***•
^5 tn
* I
S .1 S3
8 S ^
Application equiomer
Incremental annual
Labor cost, $"
Total capital cott o
2 S
£ S
1 i
S 2
»3 ^
c** tn
O O
e 5?
«n »n
^J ^5
O Vt
«1
° §
0 JJ
ci
I S
S s
f 5
O^ **O
fff 1-
00 3
£. «^«
e? "*
S «n
|
g
(Operator training cod
Incremental annual
Ubor cott, $b
I
•s
s
«
1
i
•g
S
I
I
«*•
O
1
&.
£
I
I
.1
E 3
I
£
'1
IJ
6-15
-------
DRAFT
3528/650395
7/12/95
TABLE 6-2. COST BY MODEL PLANT FOR PLANTS CONVERTING TO
WATERBORNE TOPCOATS*
Low-VOC coatinc costs
Incremental annual coating
cost, $
Incremental disposal cost-
waterborne coatings, $
Total capital cost of additional
drying capacity, $
Incremental fuel and electric
cost for ovens, $
Total capital cost of paint
circulation system, $
Total capital cost of coating
material storage, $
Application equipment costs
Incremental annual coating
cost, $
Labor cost, $"
Total capital cost of HVLP
guns, S
Operator training costs
Incremental annual coating
cost, $
Labor cost, $^
Model plant
4a
11,056
632
48,600
3,470
9,100
0
(4,391)
0
5,184
(4,455)
5,375
4
26,060
1,489
145,800
10,410
27,300
0
(10,350)
0
6,048
(10,498)
12,447
5
75,416
t
4,309
291,600
20,820
121,044
17,100
(29,925)
141,400
14,688
(30,371)
26,591
6
110,559
6,317
291,600
20,820
121,044
25,080
(43,898)
141,400
14,668
(44,537)
42,432
10
21,640
1,078
48,600
3,470
9,100
0
(8,438)
0
2,592
(7,410)
8,911
aAll costs are presented in 1991 dollars.
''Includes operating labor at $8.50/hr, supervisory labor equivalent to 15 percent of operating
$l7/hr, and overhead at 60 percent of total labor.
labor at
6-16
-------
DRAFT
3528/650395
7/12/95
TABLE 6-3. MODEL PLANT CONTROL COSTS FOR PRESUMPTIVE RACT3
Model
plant
la
1
2
3
4a
4
5
6
7a
7
8
9
10
lla
11
12
13
Total capital
cost, $
3,456
3,456
7,776
7,776
62,884
179,148
444,432
452,412
0
0
0
0
60,292
2,592
2,592
5,184
5,184
Total
Minufili/fcd
capital cost,
$b
492
492
1,107
1,107
8,955
25,511
63,287
64,423
0
0
0
0
8,586
369
369
738
738
Total
operating
cost, $/yr
5,103
11,765
95,114
109,835
14,202
36,724
226,057
251,230
2,687
6,223
13,295
21.216
21,663
(4,466)
(15,868)
30,718
17,387
Total annual
cost,$/yr
5,595
12.257
96,221
110,942
23,157
62,234
289,344
315,653
2,687
6.223
13,295
21,216
30,221
(4,097)
(15,499)
31,456
18,126
Total VOC
reductions,
Mg/yr
18.1
36.2
108.3
158.2
11.7
27.6
79.8
117.1
0.0
0.0
0.0
0.0
19.1
5.8
17.2
42.4
66.0
Cost
effectiveness,
$/Mg
309
337
887
701
1,979
2,255
3,626
2,6%
N/A
N/A
N/A
N/A
1,584
(706)
(901)
742
275
aAll costs are presented in 1991 dollars.
bAnnualized capital cost based on a 10 year lifetime and 10 percent interest (a capital recovery
factor = 0.1424).
6-17
-------
1
j
e*
Q
i
JH
CQ
W
S
1
g
H
£
S
o
s
2
H
CO
£H
5
n.
w
t"^
f-4
M
52
t— >
n
o
o
,™
0
H
t"
CO
H
rv*
IK
t4
H
t
-.0
u-1
a
_,g
£ 8 «
* S
*o.
<•_ ...
P s *1
o .2 ^
0. TJ.
" o
« O 60
o. o. S
. E 2
0 0
£•
E 1
1 1J
1
i u
5o
!
1
g
o •=
o -
> &
""
L .
c
"E.
"o
•g
co en en en en
O — — — in
8 £ 8 R8
eo r^ en eo en
en O t** es o
en *n ^ oo co
oo •*• oo r* f>
cs en es cs NO
>n •» TJ- 10 ON
g- gj g; §; g;
o o o o o
»n wi ir, jo «Q
•n
^l
C5
ON cn -* t- «s
8IC8r58
?J^22??
^^^3i
•n en Ov «s «g
w«*
CT^ Os 5^ ^ $v
^5 ^5 ^5 ^K VM)
illll
s
1
VO
VI 0 — M 0
8£8 ?8
ON ^^
O O g O O
5aS8l
Vi
«r>
r< cs cs M
o o o o o
— t- ON «-" —•
NO
C5
T
ON — en *» —
»n —
88528?
o\ ~* •*- *• ~-
«^> r^ o oo o*
o ^o *o ^
oo c^ P** ^^ c*i
oo
-------
•o
o
AJ
C
O
o
g
O v tn
*5<
i**
£ "S.
1 U
*o - 5 S
• «3 S
zi °
u S
55 "5.
^•s 8.
o *5 _fe*
o O
•S g
03 £
"5. s S
o g
z g
c
o> *i
S S-"0"
„ « °°
"M* §
z
c
IK
ii
UJ
o
1
U
S/5
in
c
O °
o „-
> Op
§
§
G.
'a
O — O «-• O
88JC8S
o — o — o
I**1 t^* O oo OA
%o %o m ^r
jnc.O.n.n
vo^cn^ox
ON ON ON ON ON
Ox Ox Ox ON ON
O O O O O
«r> In In «n «n
»s cs r« cs (S
eo co n \o
c*t t** ^r> o to
ON ON ON ON ON
"*t ON ON ON ON
06066
»s «n
S
JQ
a
Ox -. — — 00
888£8
•
o\ •- — — oo
vo tn «n Ox o
OO (S Ox
-------
•o
o
G
•H
4J
C
o
u
ff
M
Ill
"E.
-ii
1 c "i
£ -i.12
ill
E !>•- i
li!"
u i
B-B. c
c "2 o.
§ ° ~
C c
•— o
£ E
§ -| °g
. '« «
z §
*• c
c
1 1*-
a ,0 to
"MS
C U
z
o
£>Ko
.2 60
D. C
E 2
uu
•a
8
u
CO
CD
u 1
si
c
"E.
"o
"^
s
8
*~
en
rf
00
—
5
•"^
0\
8
*"
*~i
oo
es
oo
a.
s
8
*r
cs
0
8
w=^
-
8
00
V".
°
A
5
r<
8
A
>
J3
f s
ll
s|
•'.
o J
55 .,
• 5J> <5
b-° •"
s!<£
•a S 2
i ^ ""*
5 "S ui
lis
II-S
€3 *® "«tf
* 06 T3
u. .S 2
0 I s
«*j= 2
tin u
d «J*
* S
Is
*o "S
E £
«£ 2
'8'5U
"^•a
«i
t- §
o "- c
o •R oo ^.
2 2-i s
•s i s -
8j|i
t- | g
=la!
6 -20
-------
DRAFT
3528/650395
7/12/95
was developed using the distribution of facilities in EPA's data
base, the 1987 Census of Manufactures data base that provides
information on plant location by county, and EPA's 1991 data base
of attainment and nonattainxnent areas. Plants located in the
ozone transport region, which includes the States of Connecticut,
Delaware, Maine, Maryland, Massachusetts, New Hampshire, New
Jersey, New York, Pennsylvania, Rhode Island, Vermont, and the
consolidated metropolitan statistical area that includes the
District of Columbia and some counties in Virginia are also
included in the table.
The distribution of facilities in Table 6-4 includes only
those facilities that are considered to be large enough, based on
EPA's survey of the industry, to emit greater than or equal to
22.7 Mg (25 tons) of VOC's per year. As discussed in Chapter 5,
the Committee recommended that RACT be applied to facilities that
emit, or have the potential to emit, greater than or equal to
22.7 Mg (25 tons) of VOC's per year. The Committee recommended
that an exception be made for facilities located in extreme
nonattainment areas. For these facilities, the Committee
recommended that RACT be applied to facilities that emit, greater
than or equal to 9.1 Mg (10 tons) of VOC's per year.
6.3.1 Nationwide Emission Reductions
Table 6-5 presents baseline and controlled VOC emissions by
model plant for facilities located in nonattainment areas and the
ozone transport region. Controlled emissions represent the level
of emissions after the application of the presumptive RACT
requirements. The emission reductions achieved by the limitation
on the VOC content of the coatings assumes that some model plant
types will choose to use higher solids sealers and topcoats to
meet the limitation, and some model plant types will choose to
use waterborne topcoats, or their equivalent, to meet the
limitation. In determining the emission reductions achieved by
the coating VOC limitations, it was assumed that plants
represented by the short spray (model plants la - 3), roll/
curtain coat (7a - 9) , and kitchen cabinet (lla - 13) model plant
types would convert to higher solids sealers and topcoats.
6-21
-------
DRAFT
3528/650395
7/12/95
TABLE 6-5. BASELINE AND CONTROLLED VOC EMISSIONS3
Model
plant No.
la
1
2
3
4a
4
5
6
7a
7
8
9
10
lla
11
12
13
Total
Nationwide VOC
emissions
baseline --
total , Mg/yr
7,801
6,631
1,867
1,704
8,951
6,352
2,827
2,073
1,347
1,291
1,030
363
1,401
4,042
4,275
4,089
1,673
57,718
Nationwide VOC
emissions
controlled- -
total, Mg/yr
4,179
3,544
999
910
5,911
4,194
1,867
1,369
1,347
1,291
1,030
363
923
3,232
3,428
3,282
1,342
39,213
Nationwide
reductions in
VOC emissions
from baseline,
Mg/yr
3,622
3,087
868
794
3,040
2,158
960
704
0
0
0
0
478
810
847
807
331
18,505
aEmissious correspond to those plants located in ozone
nonattalnment areas and transport regions. Controlled
emissions represent those after the application of
presumptive RACT,
6-211
-------
DRAFT
3528/650395
7/12/95
Further, it was assumed that plants represented by the long spray
{model plants 4a - 6), and upholstered (model plant 10) model
plant types would convert to waterborne topcoats. These are the
same assumptions that were used in developing the costs for each
model plant. The basis for these assumptions was discussed in
Section 6.2.
As shown in Table 6-5, the presumptive norm for RACT will
reduce VOC emissions from major sources in nonattainment areas
and the ozone transport region by 18,505 Mg (20,335 tons).
Additional reductions may be achieved by application of the work
practice standards, but these potential reductions, with the
exception of reductions associated with the application equipment
and operator training requirements, have not been estimated for
the reasons discussed in Section 6.1.3.
6.3.2 Nationwide Costs
Table 6-6 presents the nationwide costs and cost
effectiveness of implementing the presumptive RACT requirements
to sources that are expected to be subject to RACT located in
nonattainment areas and the ozone transport region. These costs
were calculated using the total annual costs by model plant
presented in Table 6-3 and the distribution of plants by model
plant presented in Table 6-4. The cost of implementing the
recommended RACT requirements to all affected sources in the wood
furniture industry is $20,156,609 and the cost effectiveness is
$l,089/Mg.
6.4 ENVIRONMENTAL AND ENERGY IMPACTS
There are a number of potential environmental and energy
impacts associated with the recommended RACT requirements.
Environmental impacts, including effects on air and water
quality, as well as hazardous wastes, are discussed in
Section 6.4.1. The energy impacts of the recommended RACT
requirements are presented in Section 6.4.2, and other
environmental impacts are discussed in Section 6.4.3.
6.4.1 Environmental Impacts
6.4.1.1 Air Quality Impacts. As discussed in
Section 6.3.1, the application of presumptive RACT by source
6-23
-------
DRAFT
3528/650395
7/12/95
TABLE 6-6. NATIONWIDE CONTROL COSTS FOR PRESUMPTIVE RACT*
Model
plant No.
la
1
2
3
4a
4
5
6
7a
7
8
9
10
lla
11
12
13
Total
Nationwide
control cost,
$
1,119,000
1,041,845
769,768
554,710
5,997,663
4,854,252
3,472,128
1,893,918
126,289
124,460
66,475
21,216
755,525
(569,483)
(759,451)
597,664
90,630
20,156,609
Nationwide
reduction in
VOC emissions,
Mg/yr
3,622
3,087
868
794
3,040
2,158
960
704
0
0
0
0
478
810
847
807
331
18,505
Cost
effectiveness ,
$/Mg
309
337
888
701
1,979
2,255
3,626
2,696
N/A
N/A
N/A
N/A
1,584
(706)
(901)
742
275
1,089
aCosts and emission reductions correspond to applying
presumptive RACT to those facilities in ozone nonattainment
areas and transport regions. All costs are presented in
1991 dollars. Numbers in parentheses indicate a net
savings.
6-24
-------
DRAFT
3528/650395
7/12/95
facilities in nonattainment areas and the ozone transport region
will reduce VOC emissions from the industry by 18,505 Mg/yr
(20,335 tons/yr) from the estimated baseline value of
57,718 Mg/yr (65,426 tons/yr).
As discussed in Chapter 1, the EPA is also developing a
NESHAP for the wood furniture industry and the requirements for
both the CTG and NESHAP were negotiated by the Committee.
Because the work practice standards and the application equipment
requirements are part of both the presumptive RACT requirements
and the NESHAP, for most model plants, the RACT requirements will
not result in HAP emission reductions in addition to those
achieved by the NESHAP. However, the NESHAP will not apply to
most of the very small plants (represented by model plants la,
4a, 7a, and lla), although these plants will be subject to RACT.
Therefore, the presumptive RACT requirements will also reduce HAP
emissions from these plants.
The limitation on the VOC content of the coatings may result
in some decrease in HAP emissions but the decrease can not be
quantified. The majority of the HAP that will be regulated by
the NESHAP are VOC. The NESHAP limits the HAP content of the
stains, washcoats, sealers, and topcoats to 1.0 kg organic HAP/kg
solids (1 Ib organic HAP/lb solids). Therefore, facilities
converting to waterborne topcoats, which have a VOC limit of
0.8 kg VOC/kg solids (0.8 Ib VOC/lb solids) (which is equivalent
to no more than 0.8 kg organic HAP/kg solids (0.8 Ib organic
HAP/lb solids)), will be decreasing their HAP emissions from
their topcoats by at least 20 percent more than required by the
NESHAP. Smaller facilities not covered by the NESHAP that are
subject to RACT and choose to convert to waterborne topcoats will
likely reduce their HAP emissions from topcoats substantially.
Total HAP emissions from facilities converting to higher solids
sealers and topcoats will likely decrease.
6.4.1.2 Water Quality Impacts. No adverse water pollution
impacts are expected to result from the implementation of the
presumptive RACT requirements. For this analysis, it was assumed
that a constantly recirculating coating delivery system will be
6-25
-------
DRAFT
3528/650395
7/12/95
used with waterborne coatings. Thus, the use of waterborne
coatings is not expected to increase flushing of the lines and
will therefore not result in increased wastewater.
6.4.1.3 Hazardous Waste. Both solid and liquid hazardous
waste are generated at most wood furniture manufacturing
facilities. The dry filters used to collect coating overspray
account for the majority of the solid hazardous waste generated.
Although the solids content of lower-VOC coatings is higher, less
of the coating is used, so the frequency of changing these dry
filters is not expected to change if lower-VOC coatings are used.
The liquid hazardous waste generated by a wood furniture
facility consists primarily of spent solvent and coatings. The
work practice standards should reduce the amount of solvent used
and the application equipment requirements should reduce the
amount of coating used, so the presumptive RACT requirements
should result in a decrease in liquid hazardous waste.
6.4.2 Energy Impacts
The additional ovens required for facilities converting to
waterborne topcoats will result in an increase in both
electricity and natural gas use. The increase in energy usage
associated with the conversion to waterborne topcoats is
summarized in Table 6-7.
TABLE 6-7. ENERGY USE ASSOCIATED WITH
WATERBORNE TOPCOATS5"7
Model plant
No.
4a
4
5
6
10
Increase in
natural gas
usage , MMBtu/yr
181,300
163,800
50,400
25,200
17,500
Increase in
electricity
usage, kWh/yr
3,108
2,808
864
432
300
5•4•3 Other Environmental Impacts
The use of waterborne coatings and higher solids coatings
will reduce worker exposure to organic solvents. The worker
6-26
-------
DRAFT
3528/650395
7/12/95
training requirements and work practice requirements such as
closed containers and the limit on the amount of solvent used for
spray booth cleaning should also reduce solvent usage and worker
exposure.
Facilities may choose to use polyester or polyurethane
coatings that meet the VOC content limitations for higher solids
topcoats. These coatings contain small amounts of isocyanates,
so additional safety procedures may be required. If the
appropriate precautions are taken, no additional risk to the
worker is expected to result.
The presumptive RACT requirements require facilities to
purchase additional equipment. This is considered an
irreversible and irretrievable commitment of resources.
Manufacturing stainless steel paint circulation lines, storage
tanks, and ovens will consume steel and other raw materials.
However, compared to the current level of use of these materials
by the industry, this increase in consumption is not considered
significant.
6.5 IMPACTS OF OTHER CONTROL OPTIONS
As discussed earlier, this chapter of a typical CTG
addresses the impacts, both environmental and cost, of a number
of control options. These impacts are then used in making a
determination of RACT for the industry. In addition to
evaluating the impacts of a number of options in order to make a
determination of what the EPA believes is RACT, the analysis of
several options provides States with guidance they can use in
writing their own rules. For example, a particular State may
decide that the presumptive norm for RACT does not result in
sufficient emission reduction from plants in that State. If an
analysis of more stringent options has been conducted by EPA in
developing the CTG, the State can use this analysis to develop a
more stringent rule.
In this case, however, the presumptive RACT requirements
were developed through a negotiation process. During the
negotiation, several other options besides those finally chosen
were discussed, but a complete analysis of the impacts of those
6-27
-------
DRAFT
3528/650395
7/12/95
options was not conducted. While Chapter 3 provides a detailed
discussion of the available control options for the wood
furniture industry, it does not address the industry impacts
associated with implementing those control options.
Before beginning the negotiation of the presumptive norm for
RACT, EPA had already begun development of a CTG for the wood
furniture industry. Drafts of several of, the chapters, including
the cost chapter, had already been completed. The cost chapter
in the earlier draft CTG evaluated the impacts of many of the
control options discussed in Chapter 3. While EPA was developing
the CTG, the industry developed their own report that evaluated
the impacts of control options for reducing VOC emissions from
the industry. Both the earlier draft CTG and the industry report
addressed some of the same control options. The CTG evaluated
the impacts of add-on controls, hybrid and full waterborne
coating systems. The industry report also evaluated the impacts
of add-on controls and hybrid and full waterborne coating
systems.
In order to provide States with some guidance on the
potential impacts of control options other than those selected by
the Committee as the presumptive norm for RACT, a summary of the
impacts of these three additional control options is presented
here. The summary includes both EPA's estimate of the impacts,
as presented in the earlier draft version of the CTG, and
industry's estimate of the impacts, as presented in their report.
In evaluating the summary of the impacts presented here, the
reviewer should note that the model plants used in developing the
impacts for both the earlier version of the draft CTG and the
industry report are different than the model plants presented in
Chapter 4. A summary of the model plants contained in the
industry report is presented in Table 6-8. Table 6-9 presents a
summary of the model plants from the earlier version of the draft.
CTG, The model plants presented in Chapter 4 are based on some
of the model plants presented in the industry report, but they
are scaled to represent a range of facility sizes. The model
plants developed for the earlier version of the draft CTG are
6-28
-------
DRAFT
3528/650395
7/12/95
M5
eo
ts
Jg
eo
VO
o
m
S3
I
I
*~|
ill
•I"! f
ill
zed
llul*
ni
Catalyzed
nitrocellull
|
i
2
1
(S
h
o
(I
VI
II
o. a.
ON
V
vo
-s
•<*
ll
en
CO
I
U>
w
.1
. t5
g &
« §
c e
semb
c
Assemble
•S
-
•S?
is
II
c ~
£S
.•s
1C
S
^
o
i
CO
o
< 1C
-s
« ^
B .0
- i
1
1
o
o
>,
O
ts
§
fS
cs
2
0\
S
f-
i
oo
3
1
g
C
g
C
g
C
Specialized
casegoods
•8
"
Z
vO
Furniture
00
o
Z
ON
*"f
II
II
11
<<- ffl
2 a.
6-29
-------
DRAFT
3528/650395
7/12/95
TABLE 6-9. EARLIER DRAFT CTG MODEL PLANTS1
Model
plant No.
1
2
3
4
5
6
7
8
9
10
11
Type of product
Residential furniture
Residential furniture
Residential furniture
Residential furniture
Residential furniture
Residential furniture
Office furniture and
kitchen cabinets
Office furniture and
kitchen cabinets
Office furniture and
kitchen cabinets
Office furniture and
kitchen cabinets
Office furniture and
kitchen cabinets
No. of
employees
<100
100-249
>249
<100
100-249
>249
<100
100-249
>249
100-249
>249
No. of
finishing
steps
6
6
6
10
10
10
3
3
3
3
3
Type of topcoat
Nitrocellulose lacquer
•
Nitrocellulose lacquer
Nitrocellulose lacquer
Nitrocellulose lacquer
Nitrocellulose lacquer
Nitrocellulose lacquer
Catalyzed
Catalyzed
Catalyzed
Catalyzed
Catalyzed
VOC
emissions
from
finishing,
Mg/yr
45
204
454
45
204
454
45
204
454
204
454
6-30
-------
DRAFT
3528/650395
7/12/95
similar to the model plants presented in Chapter 4, so a
comparison of the impacts is reasonable.
The cost information from the earlier draft CTG and the
industry report is presented for informational purposes.
However, a direct comparison of the costs from the earlier draft
CTG and the industry report must be done cautiously. First, the
model plants evaluated in the two reports, were slightly different
(as can be seen by comparing Tables 6-B and 6-9). For purposes
of this section, costs for "equivalent" model plants are
presented, but it is important to note that model plants in the
two reports are not identical and that judgment was used in
determining "equivalent" model plants. Secondly, the assumptions
made in estimating the costs associated with the use of add-on
controls and reformulated coatings were different in the two
reports. These differing assumptions led to different estimates
of costs. Only total estimated costs and emission reductions are
presented in this section; a detailed discussion of the
assumptions used in developing the costs is not provided. For
additional information concerning the development of these costs,
the reader is referenced to the earlier draft CTG, the industry
report, Appendix C, and a memorandum comparing the two
T ~) 7Q
reports. *••*•**
6.5.1 Hybrid Waterborne
Both the earlier draft version of the CTG and the industry
report evaluated the impacts of the industry converting to a
hybrid waterborne coating system. The number of coating steps in
a hybrid waterborne system that are waterborne depends upon the
finishing sequence. For example, for a short finishing sequence
(stain, sealer, and topcoat) the sealer and topcoat are
waterborne coatings. For a long finishing sequence (stain,
washcoat, filler, glaze, sealer, and multiple topcoat
applications) all coating steps after the washcoat are
waterborne. The industry report and the earlier draft version of
the CTG both indicated that hybrid waterborne was technically
feasible for all of their model plants. Table 6-10 presents the
emission reduction and cost effectiveness for hybrid waterborne
6-31
-------
DRAFT
3528/650395
7/12/95
i
H
EH
8
w
3
LTERBO
§
H
CQ
a
[LI
CO
CO
H
S5
•*^
H
EH
t£~
!• fH
"H
w»
8w
§
*^
CO
o
M
EH
CJ
o
s
o
J_)
CO
CO
H
w
o
H
i
^ -^
1
„
c
i
"E.
"c
c
3>
«s
""
o
ox
eo
f»
*
\r:
es ON
*~
en «O
"> 0^
\0 O
cs
•*r t^
..t
W5 OO
v-:
I O —
' ; V, Vv
""' ~r
\ ^
' t
1 1 c vc
j C «^ "t.0
Vi C f \ U
^ V Jr ^? ^
j=! c O .0 $
gl &< ^ o **
z z
8 i
of
v» cs
cs
»rt «r>
VO •»
*°.
•n o
»o o
eo
•^
•* fn
t/^ QO
^-
*tL £ w>
C 1 '^ 1
e re."
t£ ** 4J*O
• S— > U ^
2
1
1
8
x
1
•o
1
-8
|
g
9
"5.
•M
«
1
C
§
rs
o\
VO
•a
a
CO
1
VO
V)
u
C
•s
X
o
•o
tn
£>
JW
"c.
^_
•c
o
o
t3
Q
&•» c
41 • 5
§ « =
8 §••§
|2l
§i~
sp
T5- c **
Z" a- s
•S 8 £
0 O ~
s*<
« JT.
-------
DRAFT
3528/650395
7/12/95
systems for both the industry and earlier draft CTG model plants.
As shown in the table, a hybrid waterborae system can reduce
emissions by 28 to 85 percent at a cost effectiveness ranging
from a cost savings of $52l/Mg to a cost of almost $13,000/Mg.
6-5.2 Full Waterborne
In a full waterborne coating system, all coatings are
waterbome coatings. The earlier draft (71x3 and the industry
report agree that a full waterborne coating system is not
technically feasible for all model plants. The earlier draft CTG
indicates that a full waterborne system is not technically
feasible for facilities manufacturing residential furniture with
a long finishing sequence. According to the industry report, a
full waterborne system is technically feasible only for model
plants representing facilities with short finishing sequences.
Two of the industry model plants with short finishing sequences
represent facilities that finish and then assemble their
furniture, and two represent facilities that manufacture
miscellaneous wood parts and products.
Table 6-11 presents the emission reduction and cost
effectiveness for a full waterborne system for the model plants
in the industry report and the earlier draft CTG for which the
technology was considered feasible. As shown in the table, the
emission reduction from a full waterborne system ranges from
60 to 93 percent, with a cost effectiveness ranging from
$2,lOO/Mg to more than $9,500/Mg.
6-5.3 Add-On Controls
As discussed in Chapter 3, there are several types of add-on
control devices that can be used by the industry to reduce VOC
emissions from coating operations. These include recuperative
thermal incinerators, regenerative thermal incinerators,
fixed-bed catalytic incinerators, fluidized-bed catalytic
incinerators, and a combination of carbon adsorbers and
incinerators. The industry report evaluated the feasibility and
impacts of each of these options, and concluded that add-on
control devices were technically feasible for each of their model
plants. The earlier draft version of the CTG also evaluated the
6-33
-------
DRAFT
3528/650395
7/12/95
H
I
w
§
OS
i
CO
CO
w
Z
td
H
&
S
*
CO
o
u
p
Z
SYSTE
c/:
Z
o
1-1
o
D)
o
fcQ
o
1-1
CO
C/j
H
e
«
o
1
"c.
li
•o
S
[l
»s
_
o
0\
00
r~
\O
<^v
•*
r~>
—
s §
ir>
•<»• r»
y, R
Ov
< <
Z Z
< <
Z Z
•< <
Z Z
tn «n
°" 00
oo oo
g £
«•»
O Ov
00 JO
t*r
< <
Z Z
< <
Z Z
< <
Z Z
OS OO
v. «s
r<"
oc. o
oo r~.
<••<
00 Ox
oo (n
ri
r - — j--"
Earlier draft CTG '
Percent reduction--
VOC emissions
j Cost effectiveness,
!! s/Mg"
JT
R
•c
o
t.
c
T3
O
|t|
8|1
lfl?
^ e 21
|^ B
c o •-
I s §
ex c *-•
_r e. ?
i * s
O o ~
r -^ <
«" "" rf.
b - J'-i
-------
DRAFT
3528/650395
7/12/95
feasibility and impacts of a number of add-on control devices,
including recuperative and regenerative thermal incinerators,
catalytic incinerators, and a combination of carbon adsorbers and
thermal incinerators. The earlier draft CTG also concluded that
add-on controls were technically feasible for each of their model
plants, although, as in the industry report, some types of add-on
controls were not considered feasible for some model plants.
Table 6-12 presents the emission reduction and cost
effectiveness for add-on control devices taken from the industry
report and earlier draft CTG. The values presented represent the
most cost effective add-on control device for each model plant.
As shown in the table, the emission reduction achieved by add-on
controls ranges from 67 to 98 percent, and the cost effectiveness
ranges from $527/Mg to more than $25,000/Mg.
6-35
-------
DRAFT
3528/650395
7/12/95
N
_j
CO
U
0
fa
D
O
fc
0
Q
<
fa
CO
CO
W
M
B
W
fa
UJ
£H
CO
u
|
CO
o
M
U
D
W
§
M
CO
CO
M
CS
rH
i
W
1
CD
C
S
fc.
°tu
5
2
^
2
OS
00
f"-*
*
W-i
*i-
*"°*
i
I
1
(_
00
r** t**
^
R
» s.
00 V"i
r>
. £
-
•* o
r- ir.
t-~ —
r*
i g
"ni — c S^
£: -5 '« -c
•-1 C .•; u
L" C r • &0
1 15 U
—
< <
z z
v> t—
o> r«
«n
\n •*
Ov ^v
* §
***
in -
-1
«n
oo ^D
**
•*
O^ O^
»Ti
v% *^*
o^ ^~
o
r^
00 V,
OC
wv «--l
5- O
rs
SJ |
fi
os in
00
fi
P .S '• g
C fe * >
« |.2 "5
E1 c «£
K| t~ > O 5>
~
•o
00
>o
!=
c
r:
E
o
8
c *
«
^r v
o c
-------
DRAFT
3528/650395
7/12/95
6.6 REFERENCES FOR CHAPTER 6
1. Control of VOC Emissions from Wood Furniture Coating
Operations - Draft Chapters 1 - 5 of Control Techniques
Guideline. U. S. Environmental Protection Agency. Research
Triangle Park, NC. October 1991.
2. ENSR Consulting and Engineering. An Evaluation of VOC
Emissions Control Technologies for the Wood Furniture and
Cabinet Industries. Prepared for the American Furniture
Manufacturers Association, Business»and Institutional
Furniture Manufacturers Association, Kitchen Cabinet
Manufacturers Association, and the National Paint and
Coatings Association. January 1992.
3. Alternative Control Techniques Document: Surface Coating of
Automotive/Transportation and Business Machine Plastic
Parts. U. S. Environmental Protection Agency, Research
Triangle Park, NC. EPA 453\R-94-017. February 1994.
4. Ref. 2, pp. 7-3, 7-4.
5. Telecon. Christie, S., Midwest Research Institute, with
Miller, D., George Koch & Sons, Inc. August 6, 1991. Oven
costs.
6. Telecon. Christie, S., Midwest Research Institute, with
Rhodes, A., Rhodes Machinery. August 6, 1991. Oven costs.
7. Telecon. Christie, S., Midwest Research Institute, with
DiGibani, C., Binks Manufacturing, Inc. August 6, 1991.
Oven costs.
8. Telecon. Christie, S., Midwest Research Institute, with
Runyan, L., American Furniture Manufacturer's Association.
July 29, 1991. Stainless steel paint circulation systems.
9. Telecon. Christie, S., Midwest Research Institute, with
Moser, R., Binks Manufacturing. August 12, 1991. Stainless
steel paint circulation systems.
10. Letter and attachments from Daignault, C., Nordson
Corporation, to Christie, S., Midwest Research Institute.
August 28, 1991. Stainless steel paint circulation systems.
11. Telecon. Christie, S., Midwest Research Institute, with
Muir, G., Graco, Incorporated. July 24, 1991. Stainless
steel paint circulation systems.
12. Telecon. Christie, S., Midwest Research Institute, with
Oxler, W., U. S. Engineering. August 9, 1991. Stainless
steel paint circulation systems.
6-37
-------
DRAFT
3528/650395
7/12/95
13. Telecon. Caldwell, M. J., Midwest Research Institute, with
Kish, S., Graco Incorporated. August 13, 1991. Stainless
steel paint, circulation systems.
14. Memorandum from Christie, S., Midwest Research Institute, to
Moseley, R., Hickory Chair. Trip report: Observation of
waterborne coatings test.
15. Telecon. Christie, S., Midwest Research Institute, with
Perry, S., Business and Institutional Furniture
Manufacturers Association. July 15, 1991. Coating material
storage procedures.
16. Telecon. Christie, S., Midwest Research Institute, with
Titus, R., Kitchen Cabinet Manufacturers Association.
July 16, 1991. Coating material storage procedures.
17. Telecon. Christie, S., Midwest Research Institute, with
Bombay, E., Kraftmaid Cabinetry, Inc. July 15, 1991.
Coating material storage and transfer procedures.
ifc. Telecon. Christie, S., Midwest Research Institute, with
Butterfield, G.f Merillat, Inc. July 25, 1991. Coating
material storage and transfer procedures.
19. Telecon. Christie, S., Midwest Research Institute, with
Moseley, R., Hickory Chair. July 15, 1991. Coating material
storage procedures,
20. Telecon. Christie, S., Midwest Research Institute, with
Sale, W., Broyhill Furniture Industries. July 15, 1991.
Coating material storage and transfer procedures.
21. Teleccn. Christie, S., Midwesc Research Institute, with
Bublitz, T., Herman Miller, Incorporated. July 29, 1991.
Costing r^ateri^l storage and transfer procedures.
22. Le.^er ard attachments from Schurr, D., Safety Storage,
Inc., tc Christie, S., Midwest Research Institute.
August 34 13SX. Coating material storage costs.
23. Telecon. Christie, £., Midwest Research Institute, with
Stanwyck, W., Precision Quincy Corporation. August 7, 1921
Coating material storage costs,
24. Telecon Christie, S., Midwest Research Institute, with
Osborne, J., Osborne Environmental. August 7, 199".
Coating material storage costs.
25. Re.;, 2, p. 7-
-------
DRAFT
3528/650395
7/12/95
26. Transfer Efficiency and VOC Emissions of Spray Gun and
Coating Technologies in Wood Finishing. Pacific Northwest
Pollution Prevention Research Center. Seattle, WA. 1992.
p. 5.
27. Survey response and attachments from Sinks Manufacturing
Company, to Caldwell, M. J. Midwest Research Institute.
March 29, 1990.
28. Survey response and attachments from Graco, Inc. to
Caldwell, M. J., Midwest Research Institute. March 26,
1990.
29. Memorandum from M. Caldwell, Midwest Research Institute, to
Project file. February 29, 1992. Joint Industry Steering
Committee Report Summary.
6-39
-------
DRAFT
3778/650395
7/12/95
7.0 RACT IMPLEMENTATION
7.1 INTRODUCTION
This chapter presents information for air quality management
agencies to consider in the development of an enforceable rule
limiting volatile organic compound (VOC) emissions from wood
furniture operations. Information is provided on important
definitions, rule applicability, format of standards, performance
testing and monitoring, and reporting and recordkeeping. Where
several options exist for implementing a certain aspect of the
rule, each option is discussed along with its advantages and
disadvantages. In some cases, there may be other equally valid
options. The State or other implementing agency can exercise its
prerogative to consider other options provided that they meet the
objectives prescribed in this chapter.
This guidance is for instructional purposes only and, as
such, is not binding. Appendix B contains an example rule
incorporating the guidance provided in this document. The
example rule provides an organizational framework and sample
regulatory language specifically tailored for wood furniture
operations. The example rule is also not intended to be binding.
The State or other enforcement agency should consider all
information presented in this document along with additional
information about specific sources to which the rule will apply.
The reasonably available control technology (RACT) rule, however.
should address all the factors listed in this chapter and in
Chapter 5 to ensure that the rule has reasonable provisions for
demonstrating compliance and is enforceable.
7-1
-------
DRAFT
3778/650395
7/12/95
7.2 DEFINITIONS
The RACT rule should accurately describe the types of
sources that would be affected and clearly define terms used to
describe the industry or applicable control methods. Example
definitions of pertinent terms are presented in Appendix B for
reference by the enforcement agency when drafting a RACT
regulation for wood furniture operations.. These definitions are
intended to offer guidance to agencies in selecting terms that
may need to be clarified when used in a regulatory context. The
definitions in Appendix B have been compiled using both industry
and EPA sources.
7.3 APPLICABILITY
The recommended RACT described in this document applies to
any facility that finishes wood furniture, or performs cleaning
or washoff associated with wood furniture finishing operations.
The wood furniture industry is described in more detail in
Chapter 2. For purposes of this CTG, wood furniture can be
summarized as:
1. Residential (household) furniture - including
upholstered furniture and casegocds such as beds, bookcases,
chairs, tables, couches, etc., as well as reed and rattan and
other wicker furniture, and garden and lawn furniture;
2. Cabinets including kitchen, bath, stereo, radio,
sewing machine. and television cabinets,
3, Wood office furniture including bookcases, cabinets,
benches, chaiis, desks, tables, and other furniture;
4. Public building and related furniture - including
benches, blackboards, bleachers, chairs and church furniture; and
5. Wood office and store fixtures, partitions, shelving,
and lockers.
The nine SIC codes considered in the CTG analysis are
presented in Chapter 2 and in the model rule.. Any rule based on
the CTG coulc include all 01 a portion of these nine SIC codes.
as well as any ot:her coatiny processes i.he regulatory agency
believes are best depcrited as =. wood . -irniture manufacturing
opera ti or..
-------
DRAFT
3778/650395
7/12/95
This guidance applies to in-house wood finishing processes
located at a manufacturing site. It applies to finishing
operations that involve the prefinishing of individual
components, which may then be assembled elsewhere within the
facility or sent to another facility for final finishing and/or
assembly. It also applies to the finishing of unassembled and
assembled pieces that are manufactured both onsite and offsite.
The guidance only applies to the wood finishing processes--other
processes such as metal coating are not covered. A furniture
finishing line processes wood furniture pieces composed primarily
of wood; however, some of the components of the piece may be
plastic, metal, or other materials which need to be given a
finish appearance of simulated wood. This guidance does apply
where either the piece to be finished requires a simulated wood
appearance or where the finished surface area of the piece to be
finished is mostly wood. Similarly, the guidance does not apply
to other operations that may occur in the facility such as gluing
and particleboard manufacturing.
The emission points covered are the finishing, cleaning, and
washoff operations. The finishing operation includes the
finishing application area, flashoff areas, curing ovens, and
assorted cooldown zones. Emissions can occur throughout the
entire finishing operation. Finishing operation-related cleaning
includes application equipment cleanup, process equipment
cleaning, and spray booth cleaning. Cleaning operations occur
primarily in the application area, though miscellaneous cleaning
operations may occur along any part of the finishing operation.
Washoff operations are also covered by the model rule. Washoff
includes the removal of finishing material from a piece of
furniture that does not meet specifications.
The presumptive norm that has been selected as RACT applies
differently depending on the type of topcoat and sealer that is
used. Sources that use acid-cured alkyd amino conversion varnish
topcoats and acid-cured alkyd amino vinyl sealers have different
requirements for higher-solids coatings than those sources that
use conventional topcoats and sealers. (See related discussion
7-3
-------
DRAFT
3778/650395
7/12/95
in Chapter 5.) Enforcement agencies may choose to evaluate
sources within their jurisdiction to determine the extent to
which sources using conversion varnishes and vinyl sealers
actually differ from those using conventional topcoats and
sealers.
As indicated in the model rule in Appendix B, this guidance
has been developed for affected sources in areas of marginal,
moderate, serious, or severe nonattainment that have the
potential to emit greater than or equal to 25 tons per year
(tons/yr) of VOC's. The guidance is intended to apply to
affected sources in extreme areas, however, if potential VOC
emissions are greater than or equal to 10 tons/yr. The
enforcement agency has the flexibility to apply RACT as deemed
necessary. For example, an agency may apply RACT to all sources
that have the potential to emit greater than or equal to
10 tons/yr of VOC's.
7.4 FORMAT OF STANDARDS
The selected RACT contains two elements: emission standards
limiting the VOC content of coatings and work practice standards.
The VOC content should be calculated as-applied to account for
in-house dilution cf coatings purchased from an outside source.
To incorporate some flexibility, the model rule allows
sources to use either an Averaging approach or add-on air
pollution control equipment to meet the RACT requirement? . To
use an^add-cr.. control device, the source must demonstrate.
through the jse cf a series of calculations, that they are
achieving an emission reduction equivalent to that achieved by
sources using compliant coatings
Sources using an averaging approach must demonstrate that
their emissions are no greater than 90 percent of what they would
be if they were using compliant coat.ingr Section B.4(a)(4) of
the mods! rule provides guidance on how to determine if the
source is achieving the required emission reduction. The model
rule contains extensile guidance fo-> States that decide to allow
averaging as e. method, of demonstratxnr compliance. However,
States have tne optic.;; of r-ot allowjnq an averaging approach to
7-4
-------
DRAFT
3778/650395
7/12/95
be used. They can also place limitations on the averaging
program if they wish to do so. For example, they may limit
averaging to facilities of a certain size, limit the number of
coatings that can be averaged, or they could limit the amount of
time a source could use averaging in anticipation that, in the
future, compliant coatings will be available for every situation.
The baseline for each finishing material included in the
averaging program shall be the lower of the actual or allowable
emission rate as of the effective date of the State's RACT rule.
For example, if the source is already using a 0.3 Ib VOC/lb
solids topcoat, they are not entitled to 0.5 Ib VOC/lb solids
trading credits. Methods used in determining the usage of each
finishing material shall be accurate enough to ensure that the
affected source's actual emissions are less than the allowable
emissions, as calculated using Equation 1 or 2 in B.4(a)(4), on a
daily basis to a level of certainty comparable to that for
traditional control strategies applicable to surface coating
sources.
The recommended RACT also contains many work practices that
are believed to limit emissions from finishing, cleaning, and
washoff operations. Work practices are recommended when
physically measuring emissions from a source is impossible or at
least impracticable. The work practices that were selected as
RACT are practices that are being employed in the source
category, but for which emission limits could not be assigned. A
disadvantage of the format of work practice standards is that it
is difficult to demonstrate equivalence. If a State wishes to
use alternate standards to the work practice standards, the
burden is on the State to demonstrate to the EPA Administrator
that the standards are equivalent.
7.5 COMPLIANCE AND MONITORING PROVISIONS
7.5.1 Comp1iance Provisions
Regardless of the format selected by the enforcement agency,
compliance and monitoring provisions are essential to confirm
that an affected source is in compliance with a rule, and to
determine whether compliance is continuous or intermittent. The
7-5
-------
DRAFT
3778/650395
7/12/95
compliance provisions in the model rule in Appendix B were
developed assuming that the rule would follow the format of a
limit on the Ib VOC/lb solids of specific coatings, but alternate
compliance provisions may be appropriate for standards that are
in a different format. The compliance provisions should account
for the various control methods that affected sources may use to
comply with the rule. For example, in tke model rule,-compliance
provisions are identified depending on whether any of the
following control methods are used: (1) compliant coatings;
(2) averaging; or (3) an air pollution control system consisting
of a capture and control device.
Sources using compliant coatings demonstrate compliance by
maintaining records of the certified product data sheets for the
VOC content of the as-supplied coating and data sheets
demonstrating how the as-applied value for the coating was
calculated. Attachment 3 of the model rule provides guidance to
States on potential compliance provisions for sources using an
averaging approach to comply with the rule. The States should
use this guidance in developing their averaging programs for
submittal to the Administrator for approval. At a minimum,
sources using an averaging Approach must submit the results of
the calculations from inequalities (1) or (2) in
Section E.4(a) '4) of the model rule and data on daily coating
usage and VCC content that support the? calculations.
The ir.ociel rule Tecogni^H.1?, 'chat the overall control
efficiency of an air pollutiou contro] system is dependent upon
both the capture and control efficiency. Therefore, it is
important that any rule contain provisions for determining both.
There are two methods available to determine the capture
efficiency associated with an air pollution control system. One
method, is to perform a capture efficiency test on the capture
system used to direct emissions to the add-on control device. A
second method is to demonstrate Lhat :; capture system meets EFA's
total enclosure criteria, *nd is therefore assigned a capture
efficiency ,.f 100 percent Botl~ uethod-.j arr> presented in the
model rule in th- wood ^urnit..!-^ industry, sources may operate.
-------
DRAFT
3778/650395
7/12/95
individual spray booths or groups of booths within an enclosure,
or they may operate the entire finishing room as an enclosure.
The test methods in the model rule can be applied to any of these
situations.
Depending upon the conditions at a test site, one of the
following test methods from 40 CFR Part 60, Appendix A, should be
used to determine the inlet and outlet VpC concentrations of a
gas stream sent to a control device, and thus, the control
efficiency of the device:
1. EPA Method 18;
2. EPA Method 25; or
3. EPA Method 25A.
The method selected should be based on consideration of the
diversity of organic species present and their total
concentration and on consideration of the potential presence of
interfering gases. Because of the different response factors for
the many organic compounds which may be present either in the
coatings or as a result of the combustion process, EPA Method 25
or 25A, which measure total VOC as carbon, should be used for
determining destruction efficiency of thermal incinerators,
catalytic incinerators, or combined adsorption/thermal
incineration systems when the stream constituents are well known.
However, EPA Method 18 is more appropriate for speciating organic
emissions when the presence of pollutants is more ambiguous.
Because EPA Method 18 is more sophisticated, associated costs are
generally higher.
The following test methods are used in conjunction with the
VOC measurement methods identified above:
1. EPA Methods l or 1A of 40 CFR Part 60, Appendix A,
should be used for velocity traverses;
2. EPA Methods 2, 2A, 2C, or 2D of 40 CFR Part 60,
Appendix A should be used for velocity and volumetric flow rates;
3. EPA Methods 3 or 3A of 40 CFR Part 60, Appendix A,
should be used for O2, and C02 analysis; and
4. EPA Method 4 of 40 CFR Part 60, Appendix A, should be
used for stack gas moisture.
7-7
-------
DRAFT
3778/650395
7/12/95
7.5.2 Monitoring Requirements
Under the amended Act, paragraph (3) to Section 114 (c)
requires enhanced monitoring of stationary sources to indicate
the compliance status of the source, and whether compliance is
continuous or intermittent. The enhanced monitoring provisions
have been codified in 40 CFR Part 64. The model rule in
Appendix B has been developed to account for situations in which
either compliant coatings, averaging, or an add-on control device
are used, and incorporates the concepts of enhanced monitoring.
In this industry, it is likely that the majority of sources will
use compliant coatings to comply with the recommended RACT; add-
on control devices will be used in very limited situations. The
monitoring requirements of the model rule reflect this premise.
The continuous compliance monitoring methods that are
identified in the model rule for sources using add-on control
devices are consistent with previous regulations developed by the
EPA. Agencies responsible for enforcing RACT may choose other
methods as long as they meet the enhanced monitoring provisions
of 40 CFR Part 64. For example, the model rule identifies
continuous parameter monitoring for sources using add-on
controls; specifically, sources using incinerators must
continuous.".y monitor the combustion temperature. It has been
shown that lower temperatures can cause significant decreases in
combust!or. control device efficiency. Temperature monitors wit'r
strip charts and flow indicators are relatively inexpensive and
easy to operate Flow indicator? confirm that the stteams are
being route.! to the incinerators In the model rule, operation
at a combustion temperature less than the value established for
compliance during the initial compliance test for any 3-hour
period constitutes noncompliance with the standard.
Another option would be to require the use of continuous
emission monitors (OEM's) on the irJer. and cutler, gas stream so
that a percent destruction effi;:ienc,v could be continuously
monitored Or, an outlet CEK could be used, with the outlet
concent rat"' ?,n serving as uhe operating parameter to be monitore ;
(the value cf tV'r outlet concentre1-'. on cou3;i not exceed that
7-8
-------
DRAFT
3778/650395
7/12/95
established during the initial performance test). For
incinerators, the EPA believes that temperature monitoring is a
good determination of compliance and is considerably less
expensive than operating CEM's. Another factor that agencies
must consider in establishing compliance provisions is the
averaging time over which compliance will be determined. For
example, in the model rule, sources using, add-on controls must
average the operating parameter value over each 3-hour period to
determine compliance or noncompliance with the standard. In the
model rule, compliance monitoring is identified only for
incinerators and carbon adsorbers because other types of add-on
control devices are not likely to be used for compliance. If an
alternate control device is expected to be used by affected
sources within an agency's jurisdiction, the rule may include
compliance provisions appropriate for that device as well.
The model rule also recognizes that the overall control
efficiency of a control system does not depend only on the
destruction efficiency of the device but on the capture
efficiency as well. The model rule identifies the methods to be
used to demonstrate that the capture efficiency measured during
the initial test is continuously maintained. The provisions
contained in the model rule require monitoring of an operating
parameter that verifies that the capture system is operating at
the same efficiency as it was during the initial compliance test.
The amount of air the fans are directing to the control device
could be used as an indicator of the relative capture efficiency.
Continuous measurement of the airflow from each of the areas
exhausted to the control device (each spray booth, oven, etc.) is
one suggestion. Whichever parameter is measured as an indicator
of capture efficiency, it should be measured during the initial
performance test, a minimum or maximum value established (as
appropriate), and continuous monitoring should be compared to
this value.
As previously stated, most affected sources are expected to
meet the requirements of RACT by using the compliant coatings
that are the presumptive norm. Initial and ongoing compliance
7-9
-------
DRAFT
3778/650395
7/12/95
for these sources are demonstrated through reporting and
recordkeeping requirements. When compliance is achieved through
the use of compliant coatings, EPA believes that reporting and
recordkeeping to demonstrate continuous compliance fulfill
enhanced monitoring requirements. Enforcement agencies may
develop innovative techniques for determining the compliance
status of sources using compliant coatings; these are appropriate
provided they meet the enhanced monitoring requirements of 40 CFR
Part 64.
Attachment 3 of the model rule provides guidance to States
on potential monitoring requirements for sources using an
averaging approach to comply with the rule. The States should
use this guidance in developing their averaging programs for
submittal to the Administrator for approval.
The model rule requires semiannual reporting of a source's
compliance status when compliant coatings are used.
Specifically, sources using compliant coatings or spray booth
materials must submit a semiannual compliance certification that
states that the materials documented in the certified product
data sheet are the ones actually being used. The EPA Has
identified semiannual reporting in the model rule because direct
emission measurement, is not. being required, yet the records and
reports are being used directly for compliance determinations.
Othex~ enforcement agencies should consider the reporting
frequency they consider necessary for determining the compliance
status ot a source, ar.d should also explore how this reporting
will compare winh that required as part of the Title V operating
permit program Small business j.mpacts should also be
considered.
The model rule contains compliance provisions for the work
practice standards as well The EPA thought it necessary to
identify compliance provisions for the work practice standards
because much of the emission reduction thai will be achieved by
the proposed rule is through the work practice standards.
Obviously, direct measurer-lent, of emissions i.s not appropriate
because emission poinrs being cent-rolled by work practices arc
7 -10
-------
DRAFT
3778/650395
7/12/95
the facility certifies that the source is in continuous
compliance. (This concept is discussed in more detail below.)
Sources should also maintain records associated with the
work practice implementation plan, including records showing the
date each operator was trained, records associated with the leak
inspection and maintenance plan, and records associated with the
application equipment requirements. As discussed in Section 7.6,
initial compliance may be demonstrated by submitting the work
practice implementation plan. Continuous compliance may be
demonstrated by sources if they submit a certification statement
that reports that the work practice implementation plan has been
followed as written, whether changes were made and the reasons
for these changes, and any actions that were taken to correct
actions performed contrary to the constraints of the plan.
In the model rule, semiannual compliance certifications are
required for sources that use compliant materials, and for
sources demonstrating compliance with the work practice
implementation plan. The authority for requiring these
compliance certifications is found in paragraph (3) to
Section 114(c), and is analogous to the compliance certification
required by the Parts 70 and 71 operating permit programs.
Therefore, the compliance certification required by this proposed
rule is consistent with other regulatory actions that may also
apply to the affected sources.
Sources that use add-on air pollution control systems to
meet RACT requirements will require different types of reporting
and recordkeeping than sources using compliant coatings.
Enforcement agencies should refer to the General Provisions
(Subpart A) to Part 63 (the MACT standards). These provisions
identify the types of records and reports that are appropriate
when add-on control systems are used and monitoring is required.
For example, these provisions cover performance test reporting;
compliance monitoring system records; startup, shutdown, and
malfunction provisions; reports of exceedances; and summary
reports certifying no excess emissions.
7-12
-------
DRAFT
3778/650395
7/12/95
not point sources that emit through a stack. The model rule
requires all of the recordkeeping associated with work practices
to be included in the work practice implementation plan. The way
continuous compliance is ensured in the model rule is through a
semiannual compliance certification that states that the work
practice implementation plan is being followed.
7.6 REPORTING AND RECORDKEEPING
Each facility subject to RACT requirements should keep
records of certain key parameters that would determine initial
and continuous compliance. To accomplish this, the model rule
requires an initial compliance report, with subsequent compliance
reports submitted on a semiannual basis. Regardless of the type
of reports required by a rule, some basic information should be
conveyed to the enforcement agency. First, the facility should
identify the control method selected to meet the RACT
requirements. Next, the results of any performance testing
should be recorded. Further, the facility should record all
parameters monitored on a routine basis to indicate continued
compliance with the RACT emission limit. These parameters differ
depending on the means by which the RACT requirements are met.
Any exceedances of the monitored parameters also should be
recorded along with any corrective actions taken.
Records should be kept to demonstrate that coating materials
comply with VOC content limits for each regulated category of
material. The affected source should maintain a certified
product datA sheet fox each coating subject to the emission
limitations. They should also maintain records o£ the VOC and
solids content, as applied, of each coating. Sources using an
averaging approach must keep the above records as well as records
of the quantity of each material used, and the emission
calculations that demonstrate equivalence. As stated in
Section 7.6, an initial report may be used to convey the; above
infcrmatic~ to demonstrate initial compliance, and the
information then reported on a semiannual basis to demonstrate
continuous corr.plia/.c'B ^r^. ser-daunua] reports may take the forrr.
of coT.pli?. ce cerfif ical-ons in wMoh a responsible official ar
7 -:
-------
APPENDIX A
CONTACTS
-------
COATING SUPPLIERS
AEXCEL Corporation
7373 Production Drive
Mentor, OH 44061-0780
Mr. Richard Milhem
Akzo Nobel Coating, Inc.
P. O. Box 2124
High Point, NC 27261
Mr. Gerry M. Currier
Mr. Bob Matejka
Alternative Materials
Technology, Inc.
1266 Humboldt Avenue
Chico, CA 95928
Mr. Bill Malligie
Ameron Corporation
P. 0. Box 192610
Little Rock, AR 72219-2610
Mr. Mike Harris
Amity Finishing Products
P. 0. Box 107
Sun Prairie, WI 53590
Mr. George Cash
Avery--Decorative Films Div.
650 West 67th Place
Schererville, IN 46375
Mr. Greg Emily
C. E. Bradley Laboratories, Inc.
P. 0. Box 811
Battleboro, VT 05301
Mr. Rasheed H. Kanaan
Cardinal Industrial Finishes
1329 Potrero Avenue
South El Monte, CA 91733
Mr. Sam Ortolono
Chemcraft Sadolin International,
Inc.
P. 0. Box 669
Walkertown, NC 27051
Mr. Gary Marshall
Crown Metro, Inc.
P. 0. Box 2910
Lenoir, NC 28645
Mr. Greg Sprole
Guardsman Chemicals, Inc.
2147 Brevard Road
High Point, NC 27261-1029
Mr. Ron Tucker
Hood Products, Inc.
P. O. Box 163
Freehold, NJ 07728
Mr. Eric Kasner
James B. Day & Company
Day Lane
Carpentersville, IL 60110
Mr. Steven J. Plumley
Lawrence McFadden Company
7430 State Road
Philadelphia, PA 19136
Mr. Peter Beck
Lilly Industries, Inc.
733 South West Street
Indianapolis, IN 46225
Mr. Bill Dorris
Lilly Industries, Inc.
P. 0. Box 2358
High Point, NC 27261
Mr. Archie Martz
PPG Industries, Inc.
7601 Business Park Drive
Greensboro, NC 27409
Mr. Andy Riedell
Pratt & Lambert
Industrial Coatings Division
16116 East 13th Street
Wichita, KS 67230
Mr. Wallace A. Steele
Radcure, Inc.
217 Freedman Drive
Port Washington, WI
Mr. Keith Clark
53074-0247
Reneer Films Corporation
Old Hickory Road
Auburn, PA 17922
Ms. Wendy Steed
A-l
-------
Snyder Brothers
Avon Street
Toccoa, GA 30577
Mr. Len Snyder
Spruance Southern, Inc.
Old Highway 52 South
Winston-Salem, NC 27107
Mr. David King
U. S. Cellulose
520 Parrott
San Jose, CA
Ms. Jennifer O'Hara
Union Carbide Corporation
39 Old Ridgebury Road L-4
Danbury, CT 06817
Mr. Thayer West
Valspar Corporation
1647 English Road
High Point, NC 27261
Mr. James Bohannon
-------
RESIN SUPPLIERS
Aqualon/Hercules
1313 N. Market St.
Wilmington, DE 19899-8740
Mr. John Devido
Cargill
2301 Crosby Road
Wayzeta, MN 55391
Mr. Al Heitkamp
Ciba Geigy
3 Skyline Drive
Hawthorne, NY 10532-2188
Mr. William Collins
Dow Chemical Company
2040 Willard H. Dow Center
Midland, MI 48674
Ms. Karen Krigbaum
Eastman Chemicals
Eastman Road
Kingsport, TN 37660
Mr. Jeff Powell
ICI Resins
1717 Rivermist Drive
Lilburn, GA 30247
Mr. Edward Elkins
Mobay Corporation
Mobay Road
Pittsburgh, PA 15205-9741
Dr. Bernd H. Riberi
Mobil Oil Corporation
3225 Gallows Road
Fairfax, VA 22037
Mr. Bill Press
PPG Industries
Greensboro Customer Service Lab
7601 Business Park Drive
Greensboro, NC 27409
Reichhold Chemicals, Inc.
525-T North Broadway
White Plains, NY 10603
Mr. Jeffrey Dannerman
Rohm and Haas
Independence Mall West
Philadelphia, PA 19105
Mr. Pete Nicholson
Sanncor Industries
300 Whitney Street
Leominster, MA 01453
Mr. Henry Merken
A-3
-------
FURNITURE MANUFACTURERS
Allied Wood Industries
P. O. Box 1823
Southern Pines, NC 28387
Mr. David Allen
American Woodmark Corporation
Rt. 220 South, Industrial Pk.
Moorefield, WV 26836
Mr. Bob Taylor
Aristokraft, Inc.
1 AristoKraft Square
Jasper, IN 47546
Mr. Dave Hurst
Basset Furniture Industries,
Inc.
Main St., P. 0. Box 626
Bassett, VA 24955
Mr. Mike Nelson
Bemhardt Furaiture Company
P. 0. Box 740
Lenoir, NC 28645
Mr-. Buck Deal
Mr. Dean Reic.
Brovhill Furniture Industries,
Iric"
1 Broyhill Park
Lenoir, NC 2£622
Mr William Sale
Corrections indastr^es
Penitentiary "f New Mexico
Santa Fe, N>1
Mr, It. D. Alexander
Daniei Peters Woodworking
2056 Lock Haven Drive
Roanoke, VA 24019
Mr. Daniel Peters
iiiite Furniture Restoration
P. O. Box 623
Toluca, IL 61369
Mr, Don Scrivr-.er
athan Allen, :_nc.
P. 0. Box 639
Old Fort, NC 287£1-
Mr. Mickey C .'eefe
Fieldstone Cabinetry, Inc.
Highway 105 East
Northvood, IA 50459
Mr. Steve Teunis
Florida Furniture Industries,
Inc.
P. O.'Box 610
Palatka, PL 32177
Mr. Fount Rion, Jr.
Henkel-Harris Company, Inc.
P. O. Box 2170
Winchester, VA 22601
Mr. Rex Davis
Henrendon
P. O. Box 70
Morgantown, NC 28655
Mr. Paul (Buck) Smith
Herman Miller, Inc.
8500 Byron Road
Zeeland, MI 49464
Mr. Paul Murray
HON Industries Technical Center
505 Ford Avenue
Muscatine IA 52761
Mr. Scott Lesnet
Hickory Chair
37 9th St. PI. S.E.
Hickory, NC 28603
Mr. Richard Mosley
Kincaid Furniture Company
P. 0. Box 605
Hudson, NC 28638
Mr. Mike Soots
Mr Rick Penley
Kitchen Kompact
P. 0. Box 868
Jeffersonville, IN 47131
Mr. Walt Gahm
KraftMaid Cabinetry
16052 Industrial Parkway
Middlefield, OH 27711
Mr Byron Bombay
-------
McGuire Furniture
1201 Bryant Street
San Francisco, CA 94103
Mr. Randy Shepard
Masco Corporation
21001 Van Born Road
Taylor, MI 48180
Dr. Paul Eisele, PhD
Merillat Industries, Inc.
P. 0. Box 1946
Adrian, MI 49221
Mr. Gary Butterfield
Mills Pride, Inc.
423 Hopewell Road
Waverly, OH 45690
Ms. Debra Hannah
O'Sullivan Industries, Inc.
1900 Gulf Street
Lamar, MI 64759
Mr. Ralph Williston
Platform Beds, Inc.
400 North First Street
Grants, NM 87020
R. T. Miller
Pulaski Furniture Corporation
P. 0. Box 3431
Martinsville, VA 24115
Pridgen Cabinet Works
Route 2, Box 36
Whiteville, NC 28472
Jack Burgess
Stanley Furniture
Highway 57 West
Stanleytown, VA 24168
Mr. Alex Teglas
Steelcase
P. O. Box 1967/CS-2S08
Grand Rapids, MI 49501
Mr. Phil Schneider
Stow & Davis Wood Division
Cane Creek Industrial Park
Fletcher, NC 28732
Mr. L. T. Ward
Stylecraft Corporation
P. 0. Box 458
Blue Ball, PA 17506
Mr. David Rothermel
Terra Furniture
17855 Arenth Avenue
City of Industry, CA 91744
Mr. Gary Stafford
*
The Bartley Collection, Ltd
3 Airpark Drive
Easton, MD 21601
Mr. Joe Layman
The Knoll Group
Water Street
Bast Greenville,
Mr. Lou Newett
PA 18041
The Lane Company, Altavista
Operations
Box 151
Altavista, VA 24517-0151
Mr. Jon Parish
Thomasville Furniture
Industries, Inc.
P. O. Box 339
Thomasville, NC 27361
Mr. Dave Masters
Vaughn Furniture
P. O. Box 1489
Galax, VA 24333
Mr. Pres Turbyfill
Vintage Piano Company
P. O. Box 51347
Chicago, IL 60651
Mr. John Gonzalves
Virginia House Furniture Corp,
P. O. Box 138
Arkins, VA 24311
Mr. Randall Sparger
Wambold Furniture
6800 Smith Road
Simi Valley, CA 93063
Mr. Mark Trexler
A-5
-------
WCI Cabinet Group
701 South N Street
Richmond, IN 47374
Mr. Bob Livesay
Wood-Mode Cabinetry
1 Second Street
Krearner, PA 17833
Mr. Gronlund
WoodCo Incorporated
5225 Quast Avenue. N.E.
Rodgers, MN 55374
Mr. Rick Wood
WoodMark Manufacturing
No. 4, Sapona Business Park
Lexington, NC 27292
Mr. Ellis Murphy
-------
APPLICATION SYSTEMS VENDORS
Air Power, Inc.
P. O. Box 41165
Raleigh, NC 27629
Mr. Ron Lowe
Apollo Sprayers International,
Inc.
10200 Hemstead Highway
Houston, TX 77092
Mr. Paul McClure
Binks Manufacturing Company
9201 W. Belmont Avenue
Franklin Park, IL 60131
Mr. Rick Camppbasso
CAN-AM Engineered Products, Inc.
30850 Industrial Road
Livonia, MI 48150
Mr. M. H. Bunnell
DeVilbiss Company
300 Phillips Avenue
Toledo, OH 43692
Ms. Nancy Lieber
Graco, Inc.
24775 Crestview Court
Farmington Hills, MI 48335
Mr. Peter Bankert
Graco, Inc.
4050 Olsen Memorial Highway
Minneapolis, MN 55440-1441
Mr. Glenn Muir
Graco, Inc.
9451 W. Belmont
Franklin Park, IL 60131-2891
Mr. Steven Kish
High Point Pneumatics
Box 5802
High Point, NC 27262-5802
Mr. Wayne Roach
Kremlin, Inc.
211 South Lombard
Addison, IL 60101
Mr. Ken Ehrenhofer
Nordson Corporation
1321 Cedar Drive
Thomasville, NC 27360
Mr. John Collett
Nordson Corporation
555 Jackson Street
Amberst, OH 44001
Ms. Cindy Daignault
Paint-0-Matic
Box 1426
Willits, CA 65490
Mr. Ron Budish
Ransburg, Inc.
3939 West 56th Street
Indianapolis, IN 46208
Mr. Loren Simonson
S. A. Services
P. 0. Box 129
Dudley, NC 28333
Mr. Fred McLeod
Speedflo Manufacturing
Corporation
4631 Winfield Road
Houston, TX 77039
Mr. Dave Masterson
Stiles Machinery
3965 44th Street Southeast
Grand Rapids, MI 49508
A. J. Stranges
The DeVilbiss Co.
300 Phillips Ave., P. O. Box 913
Toledo, OH 43692-0913
Mr. John Truschill
Union Carbide Chemicals
6230 Fairview Road
Charlotte, NC 28210-3297
Ms. Renee Morgan
Volstatic, Inc.
7960 Kentucky Drive
Florence, KY 41042
Mr. James Baugh
A-7
-------
Wagner Spray Tech Corporation
1770 Fernbrook Lane
Minneapolis, MN 55447
Mr. Gale Finstad
-------
ADD-ON CONTROL VENDORS
ABB Flakt Alpha
29333 Stephenson Hwy.
Madison Heights, MI 48071
Baron-Blakeslee
2003 North Janice Avenue
Melrose Park, XL 60160
Mr. Sherman McGrew
Calgon Carbon Corporation
P. O. Box 717
Pittsburgh, PA 15230-0717
Mr. Mark Weissert
Combustion Engineering
Andover Road, Box 372
Wellsville, NY 14895
Mr. Brian Cannon
CVM Corporation
402 Vandever Avenue
Wilmington, DE 19802
Ms. Roxanne Pietro
DCI International
1229 Country Club Road
Indianapolis, IN 46234
Mr. Bob Zopf
Durr Industries
40600 Plymouth Road
Plymouth, MI 48170-4297
Mr. Dinesh Bhushan
George Koch Sons, Inc.
10 S. Eleventh Avenue
Evansville, IN 47744
Mr. Don Miller
Global Environmental
P. O. Box 2945
Greenville, SC 29602
Mr. John Hatcher
Hirt Combustion Engineers
931 South Maple Avenue
Montebello, CA 90640
Mr. Chris Oakes
Hoyt Manufacturing Corp.
251-T Forge Road
Westport, MA 02790
Mr. Steven Rooney
Huntington Energy Systems
1081 Briston Road
Mountainside, NJ 07092
Mr. Ray Elsman
Industrial Technology Midwest
P. O. Box 626
Twin Lakes, WI 53181
Mr. William Nowack
M & W Industries
P. O. Box 952
Rural Hall, NC 27045
Mr. Jim Minor
Met-Pro Corporation
160 Cassell Road
Harleysville, PA 19438
Dr. Robert Kenson
Moco Fume Incinerators
First Oven Place
Romulus, MI 48174
Mr. Bill Diepenhorst
Nucon International, Inc
P. 0. Box 29151
Columbus, OH 43229
Mr. Joseph Enneking
Ray-Solve, Inc.
100 West Main Street
Boundbrook, NJ 08805
Mr. Jules Varga
Reeco, Inc.
6416 Carmel Road
Charlotte, NC 28226
Mr. George Yundt
Salem Industries
245 South Mill Street
South Lyon, MI 48178
Mr. Lyman Thornton
A-9
-------
Smith Engineering Company
P. 0. Box 359
Broomhall, PA 19008-0359
Mr. Roy Mcllwee
Stiles Machinery, Inc.
3965 44th Street Southeast
Grand Rapids, MI 49508
A. J. Stranges
Terr-Aqua Enviro Systems, Inc.
700 East Alosta, Unit 19
Glendora, CA 91740
Mr. Lynn Shugarman
Tigg Corporation
Box 11661
Pittsburgh, PA 15228
Mr. John Sherbondy
VARA International, Inc.
1201 19th Place
Vero Beach, FL 32960
Mr. Jerald Mestemaker
VIC
1620 Central Avenue, NE
Minneapolis, KN 55413
Mr. Tom Cannon
Weatherly, Inc.
1100 Sprir.g St.,NW, Suite 800
Atlanta, GA 20305
Mr. RicK, Daeschner
/-. 10
-------
ROVESMMENT AGENCIES
Bay Area Air Quality Mgmnt.
District
939 Ellis Street
San Francisco, CA 94109
Ms. Carol Lee
Mr. Dan Belik
Ms. Sandra Lopez
City of Dallas, Env. Health Div.
320 E. Jefferson, Rm. LL 13
Dallas, TX 75203
Mr. Gary Burlbaw
California Air Resources Board
P. 0. Box 2815
Sacramento, CA 95812
Ms. Linda Nunn
FL Dept. of Environmental
Regulation
2600 Blairstone Rd.-Twin Towers
Tallahassee, FL 32399-2400
Mr. James K. Pennington
GA Department of Natural
Resources
205 Butler St., Suite 1162
Atlanta, GA 30334
Mr. Bill Mitchell
Illinois Environmental
Protection Agency
Div, of Air Pollution Control
2200 Churchill Road
Springfield, IL 62794-9276
Mr. David A. Asselmeier
Mr. John Reed
Indiana Dept. of Environmental
Mgmnt.
105 S. Meridan Street
Indianapolis, IN 46206-6015
Mr. David Mclver
Ms. Ann Heighway
Mr. Andy Knott
Mr. Paul Dubenetzky
Maryland Air Management Division
2500 Broening Highway
Baltimore, MD 21224
Mr. Frank Courtright
MI Dept. of Natural Resources
P. O. Box 30028
Lansing, MI 48909
Mr. Bob Irvine
Mr. Dave Yanochko
Mr. David Ferrier
Mr. Ray Gray
Mr. Greg Edwards
Mr. Tom Julian
Ms. Linda Davis
NC Dept. of Env., Health, & Nat.
Res.
8025 N. Point Blvd., Suite 100
Winston-Salem, NC 27106
Mr. Myron Whitely
NC Dept. of Environment, Health,
& Natural Resources,
P. O. Box 950
Mooresville, NC 28115
Mr. Keith Overcash
NC Dept. of Environment, Health,
& Natural Resources
P. O. Box 27687
Raleigh, NC 27611
Mr. Sammy Amerson
Mr. Bob Wooten
NC Dept. of Environment, Health,
& Natural Resources
Division of Environmental
Management-Air Quality
P. 0. Box 29535
Raleigh, NC 27626
Mr. Alan Klimek
Ms. Joelle Bryan
NC Dept. of Environment, Health,
& Natural Resources
Office of Waste Reduction
Pollution Prevention Program
3825 Barrett Drive
Raleigh, NC 27609
Mr. Gary Hunt
Ms. Sharon Johnson
Mr. David Williams
A-11
-------
NC Office of the Small Business
Ombudsman
3825 Barret Drive
Raleigh, NC 27609
Ms. Edythe McKinney
Ms. Finn Johnson
NJ Dept. of Environmental
Protection
Bureau of Engineering and
Regulatory Support
Trenton, NJ 08625
Ms. Beth Raddy
NJ Dept. of Environmental
Protection
New Source Review
Trenton, NJ 08625
Mr. Mike Sabol
NY State Dept. of Env.
Conservation
50 Wolfe Road
Albany, NY 12233-3254
Mr. Jim Coyle
Occupational Safety & Health
Admin.
200 Constitution Avenue
Washington, D C, 20210
Mr. Joe Bcdie
Mr. Sangi Kant:;
Occupational Safety & Health
Administration
Route 1, Box 259-C
Black Mountain. NC 28711
Mr. Dor. Jackso."
Ohio EFA Southeast District
2195 Front Street
Logan, OH 4312*,
Ms. Susan Clay
Mr, Glen Greenwood
Ohio EPA Northeast Regional
office
2110 East Aurora Road
Twinsburg, OH 44087
Ms. Bridgett Burns
Ohio EPA, Div. of Pollution
Control
1800 Water Mark Drive
Columbus, OH 43266-0149
Mr. Mike Riggelman
Ohio EPA Southwestern District
40 South Main Street
Dayton, OH 45402
Mr. Lawrence Harrell
PA Div. of Environmental
Resources
Bureau of Air Quality
200 Pine Street
Williamsport, PA 17701
Mr. Richard Maxwell
PA Dept. of Environmental
Resources
101 S. 2nd St., 114 Executive
House
Harrisburg, PA 17120
Mr. Krishnan Ramamurthy
San Diego County APCD
9150 Chesapeake Drive
San Diego, CA 92123
Mr. Ben Hancock
South Coast Air Quality Mgmnt.
District
9150 Flair Drive
El Monte, CA 91731
Ms. Jeanine Pandis
Mr- Roger Oja
Texas Air Control Board
6330 Hwy 290 East
Austin, TX 78723
Mr, Lane Hartsock
TN Div. of Air Pollution Control
701 Broadway, Customs House 4th
PI.
Harhville, TN 37247-3101
Mt David Carson
U. S. EPA Region V
23c South Dearborn Street
Chicago, IL 60604
K; F.te-vi Rosenthal
A- i 2
-------
U. S. Environmental Protection
Agency
Emissions Standards Division
(MD-13)
Research Triangle Park, NC
27711
Mr. Jack Edwardson
Dr. Madeleine Strum
U. S. EPA Region III
841 Chestnut Building
Philadelphia, PA 19107
Mr. Ray Chalmers
Ms. Eileen Glen
U. S. Environmental Protection
Agency
AEERL, MD-62B
Research Triangle Park, NC
27711
Mr. Charles Darvin
Mr. Robert McCrillis
U, S. Environmental Protection
Agency
Region I
JFK Federal Building
One Congress Street
Boston, MA 02203
Ms. Janet Beloin
VA Dept. of Air Pollution
Control
7701-03 Timberlake Road
Lynchburg, VA 24502
Mr. Terry Moore
VA State Air Pollution Control
Board
P. O. Box 10089
Richmond, VA 23240
Mr. Robert Mann
Dept. of Natural Resources
Box 7921
Madison, WI 53707
Mr. Robert Park
Mr. Jon Heinrich
A-13
-------
ASSOCIATIONS
American Furniture Manufacturers
Assn.
P. O. Box HP-7
High Point, NC 27261
Mr. Larry Runyan
American Furniture Manufacturers
Association
918 16th Street, NW, Suite 402
Washington, DC 20006
Mr. Joe Gerard
American Lung Association of NC
P. O. Box 27985
916 W. Morgan Street
Raleigh, NC 27611
Mr. Steve Wilcox
Architectural Woodwork Institute
13924 Braddock Road, Suite 100
Centreville, VA 22020
Ms. Judith Durham
Business &• Instit. Furn. Mfg.
Assn.
2680 Horizon Drive, S.E., A-l
G2;and Rapids, MI 49546
Mr. Brad Killer
C&i.adiar. Paint & Coatings Assn.
9900 Cavendish Blvd., Suite 103
Quebec St.Laurent, Quebec,
CANADA K4KZVZ
M<3 Karen Dav- c.
Canadian Kitchen Cabinet Assn
27 Goulburn Avenue
Ottawa, Ontario, CANADA K1N6C7
Mr- Marco Durepcs
Kitchen Cabinet Manufacturers
Assn.
1899 Preston White Drive
Reston, VA 22051-432^
K'". Richard Titus
Manufacturers of Emissions
Controls Assr.
1707 L Street, NW, Suite 570
Washington, IX' 2003-
"''•" - Raymond Connor
National Paint & Coatings Assn.
1500 Rhode Island Avenue, NW
Washington, DC 20005
Mr. Bob Nelson
Mr. Allen Irish
New York ITAC
253 Broadway, Room 302
New York, NY 10007
Mr. Jon Zeltsman
Southern CA Finishing & Fab.
Assn.
2552 Lee Avenue
S. El Monte, CA 91733
Mr. Ed Laird
Western Furnishings Mfg. Assn.
12631 East Imperial Hwy., Suite
106F
Sante Fe Springs, CA 90670
Mr. Jay Walton
-------
OTHER
CDR Associates
100 Arapahoe Avenue
Boulder, CO 80302
Mr. John Lingelbach
Ms. Susan Wildau
ENSR Consulting & Engineering
35 Nagog Park
Acton, MA 01720
Mr. Kevin Jameson
Ms. Vicky Putsche
Environmental Defense Fund
128 East Hargett St.
Raleigh, NC 27601
Mr. Brian Morton
EnvironTech Associates, Inc.
485 Juniper Street
Warminster, PA 18974
Mr. Pete Obst
IRTA
2800 Olympic Blvd. #101
Santa MOnica, CA 90404
Ms. Katy Wolf
Journal of Waterborne Coatings
1 Technology Plaza
Norwalk, CT 06854
Mr. Stewart Ross
Miller, Johnson, Snell, &
Cummiskey
800 Calder Plaza Building
Grand Rapids, Mi 49503
Ms. Sue Perry
Patton, Boggs, & Blow
1660 Lincoln, Suite 1975
Denver, CO 80264
Mr. J.G. Arbuckle
Rettew Associates, Inc.
3020 Columbia Avenue
Lancaster, PA 17603
Mr. Terry Black
Ron Joseph & Associates Inc.
12514 Scully Avenue
Saratoga, CA 95070
Mr. Ron Joseph
Sierra Club
394 E. Blaisedell Dr.
Claremont, CA 91711
Mr. Freeman Allen
Sizemore & Associates
1807 Pembroke Road
Suite* 4
Greensboro, NC 27408
Mi'. Trip Sizemore
Southern California Edison
Customer Technology Application
Ce;nter
6090 N. Irwindale Avenue
Irwindale, CA 91702
Mr. Paul Delaney
Mr. John Hornung
The Furniture Mfg. and
Management Center
NC State University
Campus Box 7906
Raleigh, NC 27695
Ms. Sholeh Azar
West Michigan Environmental
A.ction Council
Grand Valley State University
1 Campus Drive
Allendale, MI 49401
Ms. Janet Vail
A-15
-------
DRAFT
3104/650272
7/11/95
APPENDIX B. MODEL RULE FDR WOOD FURNITURE
FINISHING AND CLEANING OPERATIONS
B.1 INTRODUCTION
This appendix presents a model rule for limiting volatile
organic compound (VOC) emissions from wood furniture
manufacturing facilities located in ozone nonattainment areas or
in the ozone transport region. The model rule is a product of
negotiations with the wood furniture industry, environmental
group representatives, State representatives, and the
U. S. Environmental Protection Agency. The model rule addresses
various factors, including applicability, definitions, emission
standards, work practice standards, compliance and monitoring,
test methods, and recordkeeping and reporting requirements, that
need to be addressed in writing an enforceable rule. The model
rule is for illustrative purposes only; it does not preclude the
use by States of alternative approaches, including more stringent
ones, that are consistent with basic program requirements.
The model rule also provides information on how to
incorporate an emission averaging program to meet the
requirements of the model rule. The model rule does not address
all situations or options for control; it only contains the
presumptive requirements for a State to receive Federal approval
of their rules developed for the wood furniture industry. The
Economic Incentive Program Rules (EIP), promulgated on April 7,
1994 (59 FR 16690), provide more general information on using
innovative strategies to meet Clean Air Act requirements,
including reasonably available control technology (RACT). The
EIP contains a range of options for States to use in
incorporating economic incentives/innovative strategies into
B-l
-------
DRAFT
3104/650272
7/11/95
their State implementation plans (SIP's). A State may use the
BIP rule to develop an alternative trading method for meeting the
wood furniture RACT requirements that are defined by this model
rule.
This document provides guidance on emission averaging as
applied specifically to the wood furniture RACT requirements.
None of the provisions are intended to apply, a priori, to
emission trading programs involving other source categories
covered by SIP's or other Clean Air Act requirements.
Attachment l includes additional information pertaining to
small businesses. Attachment 2 includes information related to
the emission standards presented in Section B.4 and the
monitoring requirements presented in B.6. Attachment 3 includes
an example of a wood furniture manufacturing facility using an
averaging approach to meet RACT requirements.
B.2 APPLICABILITY
(a) Provisions of this rule apply to:
(1) Each wood furniture manufacturing facility located in
marginal, moderate, serious, or severe ozone nonattainment areas,
or in the ozone transport region that has the potential to emit
greater than or equal to 25 tons per year of volatile organic
compounds (VOC); and
(2) Each wooci furniture manufacturing facility located in
an extrerr. 2 ozone nonattainment area that has the potential to
emit greater than or equal to 10 tons per year of volatile
organic compounds,
B.3 DEFINITIONS AND NOMENCLATURE
(a) Provided below 3s a list of definitions for terms as
they are used in this model rule. (State-adopted rules should
include definitions for these terms, as well as any other terms
in their rule whose definition may be ambiguous.)
Adhesive means any chemical substance that is applied for
the purpose of bonding two surfaces together other than by
mechanical means
E-?
-------
DRAFT
3104/650272
7/11/95
ftdm.;ipifitrator means the Administrator of the United States
Environmental Protection Agency or his or her authorized
representative.
Affected source means a wood furniture manufacturing
facility that meets the criteria listed in Section B.2(a).
Aoencv means the regulatory agency responsible for
enforcement of the rule. *
Alternative method means any method of sampling and
analyzing for an air pollutant that is not a reference or
equivalent method but that has been demonstrated to the
Administrator's satisfaction to, in specific cases, produce
results adequate for a determination of compliance.
As applied means the VOC and solids content of the finishing
material that is actually used for coating the substrate. It
includes the contribution of materials used for in-house dilution
of the finishing material.
Basecoat means a coat of colored material, usually opaque,
that is applied before graining inks, glazing coats, or other
opaque finishing materials and is usually topcoated for
protection.
Baseline conditions means the conditions that exist prior to
an affected source implementing controls, such as a control
system.
Capture device means a hood, enclosed room, floor sweep, or
other means of collecting solvent emissions or other pollutants
into a duct so that the pollutant can be directed to a pollution
control device such as an incinerator or carbon adsorber.
Capture efficiency means the fraction of all organic vapors
generated by a process that are directed to a control device.
Certified product data sheet means documentation furnished
by a coating supplier or an outside laboratory that provides the
VOC content, solids content, and density of a finishing material,
strippable booth coating, or solvent, measured using the EPA
Method 24, or an equivalent or alternative method (or formulation
data if the coating meets the criteria specified in § B.7(a)).
The purpose of the CPDS is to assist the affected source in
B-3
-------
DRAFT
3104/650272
7/11/95
demonstrating compliance with the emission limitations presented
in B.4. Therefore, the VOC content should represent the mavlimim
VOC emission potential of the finishing material, strippable
booth coating, or solvent.
Cleaning operations means operations in which organic
solvent is used to remove coating materials from equipment used
in wood furniture manufacturing operations.
Coating means a protective, decorative, or functional
material applied in a thin layer to a surface. Such materials
include, but are not limited to, paints, topcoats, varnishes,
sealers, stains, washcoats, basecoats, adhesives, inks, and
temporary protective coatings.
Coating solids (or solids! means the part of the coating
that remains after the coating is dried or cured; solids content
is determined using data from EPA Method 24.
Continuous coater means a finishing system that continuously
applies finishing materials onto furniture parts moving along a
conveyor system. Finishing materials that are not transferred to
the part are recycled to the finishing material reservoir
Several types of application methods can be used with a
continuous coater including spraying, curtain coating, roll
coating, dip coating, and Clow coating.
Continuous compliance means that the affected source is
-meeting the emission limitations and oLher requirements of the
rule at all times ami is fulfilling all monitoring and
recordktieping provisions of the rule in order to demonstrate
compliance.
Control device means any equipment that reduces the quantity
of a pollutant that is emitted to the air. The device may
destroy or secure the pollutant for subsequent recovery.
Includes, but is not limited to, incinerators, carbon adsorbers,
and condensers.
Control device efficiency means the ratio of the pollution
released by a control device and the pollution introduced to the
control device, expressed as a fraction
B-4
-------
DRAFT
3104/650272
7/11/95
Control system means the combination of capture and control
devices used to reduce emissions to the atmosphere.
Conventional air spray means a spray coating method in which
the coating is atomized by mixing it with compressed air at an
air pressure greater than 10 pounds per square inch (gauge) at
the point of atomization. Airless and air assisted airless spray
technologies are not conventional air spftray because the coating
is not atomized by mixing it with compressed air.
Day means a period of 24 consecutive hours beginning at
midnight local time, or beginning at a time consistent with a
facility's operating schedule.
Emission means the release or discharge, whether directly or
indirectly, of VOC into the ambient air.
Equipment leak means emissions of volatile organic compounds
from pumps, valves, flanges, or other equipment used to transfer
or apply finishing materials or organic solvents.
Equivalent method means any method of sampling and analyzing
for an air pollutant that has been demonstrated to the
Administrator's satisfaction to have a consistent and
quantitatively known relationship to the reference method under
specific conditions.
Finishing application station means the part of a finishing
operation where the finishing material is applied, e.g., a spray
booth.
Finishing material means a coating other than an adhesive.
For the wood furniture manufacturing industry, such materials
include, but are not limited to, basecoats, stains, washcoats,
sealers, and topcoats.
Finishing operation means those activities in which a
finishing material is applied to a substrate and is subsequently
air-dried, cured in an oven, or cured by radiation.
Incinerator means, for the purposes of this industry, an
enclosed combustion device that thermally oxidizes volatile
organic compounds to CO and C02. This term does not include
devices that burn municipal or hazardous waste material.
B-5
-------
DRAFT
3104/650272
7/11/95
Material safety data sheet (MSDS) means the documentation
required by the Occupational Safety and Health Administration
(OSHA) Hazard Communication Standard (29 CFR 1910) for a solvent,
cleaning material, finishing material, or other material that
identifies select reportable hazardous ingredients of the
material, safety and health considerations, and handling
procedures. '
Nonpermanent final finish means a material such as a wax,
polish, nonoxidizing oil, or similar substance that must be
periodically reapplied to a surface over its lifetime to maintain
or restore the reapplied material's intended effect.
Normally closed container means a container that is closed
unless an operator is actively engaged in activities such as
emptying or filling the container.
Operating parameter value means a minimum or maximum value
established for a control device or process parameter that, if
achieved by itself or in combination with one or more other
operating parameter values, determines that an owner or operator
has complied with an applicable emission limit.
Organic solvent means a liquid containing volatile organic
compounds th?:: is used for dissolving or dispersing constituents
in a coating, adjusting the viscosity of a coating, cleaning, or
washoff. Whe: used in a coating, f.he organic solvent evaporates
during drying and does not: become -a part of the dried film.
Overall control efficiency means the efficiency of a control
system, calculated as the product of the capture and control
device efficiencies, expressed as a percentage.
Ozone nonattainment area means an area that does not attain
the National Ambient Air Quality Standard for ozone, pursuant tc
Section 107 of the Clean Air Act,
Permanent__tot.al enclosure meatu> a permanently installed
enclosure that completely surrounds a source of emissions such
that all emissions are captured and contained for discharge
through a control device. The enclosure must meet the criteria
presented in § E.7(e) (1) >' . } through (iv^ . For additional
information, se^ The MeasurementL. ScLutJ.on: Using a Temporary
B-6
-------
DRAFT
3104/650272
7/11/95
Total Enclosure for Capture Efficiency Testing
(EPA-450/4-91-020). (This document is available from National
Technical Information Services (NTIS), 5825 Port Royal Road,
Springfield, VA, 22161. Telephone 1-800-553-NTIS.
Potential to emit n»ean» the mayitnyim capacity of a stationary
source to emit a pollutant under its physical and operational
design. Any physical or operational limitation on the capacity
of the source to emit a pollutant, including air pollution
control equipment and restrictions on hours of operation or on
the type of material combusted, stored, or processed, shall be
treated as part of the design if the limitation or the effect it
would have on emissions is federally enforceable.
Reference method means any method of sampling and analyzing
for an air pollutant that is published in Appendix A of
40 CFR 60.
Responsible official has the meaning given to it in
40 CFR Part 70, State Operating Permit Programs (Title V
permits).
Sealer means a finishing material used to seal the pores of
a wood substrate before additional coats of finishing material
are applied, washcoats, which are used in some finishing systems
to optimize aesthetics, are not sealers.
Solvent means a liquid used in a coating for dissolving or
dispersing constituents in a coating, adjusting the viscosity of
a coating, cleaning, or washoff. When used in a coating, it
evaporates during drying and does not become a part of the dried
film.
Stain means any color coat having a solids content by weight
of no more than 8.0 percent that is applied in single or multiple
coats directly to the substrate. Includes, but is not limited
to, nongrain raising stains, equalizer stains, sap stains, body
stains, no-wipe stains, penetrating stains, and toners.
Storage containers means vessels or tanks, including mix
equipment, used to hold finishing or cleaning materials.
Strippable booth coating means a coating that: (1) is
applied to a booth wall to provide a protective film to receive
B-7
-------
DRAFT
3104/650272
7/11/95
overspray during finishing operations; (2) that is subsequently
peeled off and disposed; and (3) by achieving (l) and (2),
reduces or eliminates the need to use organic solvents to clean
booth walls.
Substrate^ means the surface onto which coatings are applied
(or into which coatings are impregnated).
Temporary total enclosure means an enclosure that meets the
requirements of § B.7(e) (1) (i) through (iv) and is not permanent,
but constructed only to measure the capture efficiency of
pollutants emitted from a given source. In addition to meeting
the requirements of § B.7(e)(1)(i) through (iv), any exhaust
point from the enclosure shall be at least 4 equivalent duct or
hood diameters from each natural draft opening. For additional
information, see The Measurement Solution; Usinga Temporary
Total Enclosure for Capture Efficiency Testing
(EPA-450/4-91-020).
Thinner means a volatile liquid that is used to dilute
coatings (to reduce viscosity, color strength, and solids, or to
modify drying conditions).
Topcoat means the last film-building finishing material
applied in a finishing system Non-permanent final finishes are
not- topcoats.
Touch-up and repair- mean«j the application of finishing
materials to cover minor finishing imperfections.
Vgd_a 111e organ i c compound (VOC) means any organic compound
that participates in atmospheric photochemical reactions; that
is, any organic compound other than those that the Administrator
designates as having negligible photochemical reactivity. VOC is
measured by a reference method, an equivalent- method, an
alternative method, or by procedures specified under any rule. A
reference method, an equivalent method, or an alternative method,
however, may also measure nonroactive organic compounds. In such
cases, any owner oz operator may exclude the nonreactive organi-
compounds when determining compliant: • with a standard. For a
list cf JGiripounds that the Adr \aistr-3tor hap designated as having
negligih'e photochemical reactivity, refer to 40 CFR 51.00.
-------
DRAFT
3104/650272
7/11/95
Washcoat means a transparent special purpose coating having
a solids content by weight of 12.0 percent or less. Washcoate
are applied over initial stains to protect and control color and
to stiffen the wood fibers in order to aid sanding.
Washoff operations means those operations in which organic
solvent is used to remove coating from a substrate.
Waterborne coating means a coating tthat contains more than
five percent water by weight in its volatile fraction.
Wood furniture facility means all of the pollutant-emitting
activities that belong to the wood furniture industrial grouping,
are located on one or more contiguous or adjacent properties, and
are under the control of the same person (or persons under common
control). The wood furniture industrial grouping includes the
following standard industrial classification (SIC) codes: 2434,
2511, 2512, 2517, 2519, 2521, 2531, 2541, and 2599.
Wood furniture manufacturing operations means the finishing
and cleaning operations conducted at a wood furniture facility.
Wprking day means a day, or any part of a day, in which a
facility is engaged in manufacturing.
(b) The nomenclature used in this rule has the following
meaning:
(1) Ak = the area of each natural draft opening (k) in a
total enclosure, in square meters.
(2) C = the VOC content of a coating (c) , in kilograms of
VOC per kilogram of coating solids (kg VOC/kg solids), as
applied. Also given in pounds of VOC per pound of coating solids
(Ib VOC/lb solids), as applied.
(3) Caj - the concentration of VOC in gas stream (j)
exiting the emission control device, in parts per million by
volume.
(4) Cbi « the concentration of VOC in gas stream (i)
entering the emission control device, in parts per million by
volume.
(5) Cd^ « the concentration of VOC in gas stream (i)
entering the emission control device from the affected emission
point(s), in parts per million by volume.
B-9
-------
DRAFT
3104/650272
7/11/95
(6) Cfk - the concentration of VOC in each uncontrolled gas
stream (k) emitted directly to the atmosphere from the affected
emission point (s) , in parts per million by volume.
(7) E « the emission limit achieved by the affected
emission point (s), in kg VOC/kg solids.
(8) P m the control device efficiency, expressed as a
fraction. •
(9) FV = the average inward face velocity across all
natural draft openings in a total enclosure, in meters per hour.
(10) N - the capture efficiency, expressed as a fraction.
(11) Qaj - the volumetric flow rate of gas stream (j)
exiting the emission control device, in dry standard cubic meters
per hour.
(12) Qi.)i = the volumetric flow rate of gas stream (i)
entering the emission control device, in dry standard cubic
meters per hour.
(13) Qd^ * the volumetric flow rate of gas stream (i)
entering the emission control device from the affected emission
point (s), in dry standard cubic meters per hour.
(14) Qf)c = the volumetric flow rate of each uncontrolled
gas strearr. (k) emitted directly to the atmosphere from the
affected err.lssicn point (s), in dry standard cubic meters per
hour ,
(15) Q,-n j_ - the volumetric flow rate of gas stream (i)
entering th« total enclosure through a forced makeup air duct, in
standard cubic meters per hour (wet basis)
(l£j QOU*- i * tne volumetric flow rate of gas stream (j)
exiting the total enclosure through an exhaust duct or hood, in
standard cubic meters per hour (wet basis) .
(17) R = the overall efficiency of the control system,
expressed as a percentage ,
B.4 EMISSION STANDARDS
(a) Each owner or operator of an affected source subject t
this rule shall limit VCC emissions from finishing operations by
11' Using topcoat a with a VOC content no greater than
0.8 kg VC'V'kc solids '0.8 Ib VGC/lb r,olic-= as applied; or
B--10
-------
DRAFT
3104/650272
7/11/95
(2) Using a finishing system of sealers with a VOC content
no greater than 1.9 kg VOC/kg solids (1.9 Ib VOC/lb solids), as
applied, and topcoats with a VOC content no greater than 1.8 kg
VOC/kg solids (1.6 Ib VOC/lb solids), as applied; or
(3) For affected sources using acid- cured alkyd amino vinyl
sealers or acid -cured alkyd amino conversion varnish topcoats,
using sealers and topcoats based on the following criteria:
(i) If the affected source is using acid- cured alkyd amino
vinyl sealers and acid- cured alkyd amino conversion varnish
topcoats, the sealer shall contain no more than 2.3 kg VOC/kg
solids (2.3 Ib VOC/lb solids), as applied, and the topcoat shall
contain no more than 2.0 kg VOC/kg solids (2.0 Ib VOC/lb solids),
as applied; or
(ii) If the affected source is using a sealer other than an
acid- cured alkyd amino vinyl sealer and acid- cured alkyd amino
conversion varnish topcoats, the sealer shall contain no more
than 1.9 kg VOC/kg solids (1.9 Ib VOC/lb solids), as applied, and
the topcoat shall contain no more than 2.0 kg VOC/kg solids
(2.0 Ib VOC/lb solids), as applied; or
(iai) if the affected source is using an acid- cured alkyd
amino vinyl sealer and a topcoat other than an acid- cured alkyd
amino conversion varnish topcoat, the sealer shall contain no
more than 2.3 kg VOC/kg solids (2.3 Ib VOC/lb solids), as
applied, and the topcoat shall contain no more than 1.8 kg VOC/kg
solids (1.8 Ib VOC/lb solids), as applied; or
(4) Meeting the provisions established in B.10 for sources
using an averaging approach and demonstrating that actual
emissions from the affected source are less than or equal to the
lower of the actual versus allowable emissions using one of the
following inequalities:
0.9 (0.8 (rq + rc2 «• . . .)) itER^,) (rq) + ER,^ (re,) + . . .) (i)
0.9 {[1.8 (TCj + TCj + ...)) + (1.9 (SEj + SEj +..)) +
[9.0 (WCj + WCj + ...)] + [1.2 (BCj + BCj +...)] +
[0.791 (ST, + ST2 + . . .)]} £ [ERTC, (TC,) + ERTC2 (TCj) + ...] +
B-ll
-------
DRAFT
3104/650272
7/11/95
[ERSE1
t^BCl ore tho- 0.6 kg VOC'/ka solidf:, as applied
(0.'« «.b VOC/lb sclids) .
B-12
-------
DRAFT
3104/650272
7/11/95
B.5 WORK PRACTICE STANDARDS
(a) Work practice implementation p3.au.
(1) Each owner or operator of an affected source subject to
this rule shall prepare and maintain a written work practice
implementation plan that defines work practices for each wood
furniture manufacturing operation and addresses each of the
topics specified in paragraphs (b) through (j) of this section.
The plan shall be developed no more than 60 days after the
compliance date. The owner or operator of the affected source
shall comply with each provision of the work practice
implementation plan. The written work practice implementation
plan shall be available for inspection by the Agency, upon
request. If the Agency determines that the work practice
implementation plan does not adequately address each of the
topics specified in paragraphs (b) through (j) of this section,
the Agency may require the affected source to modify the plan.
(b) Operator training course. Each owner or operator of an
affected source shall train all new and existing personnel,
including contract personnel, who are involved in finishing,
cleaning, or washoff operations or implementation of the
requirements of this rule. All new personnel, those hired after
the effective date of the rule, shall be trained upon hiring.
All existing personnel, those hired before the effective date of
the rule, shall be trained within 6 months of the effective date
of the rule. All personnel shall be given refresher training
annually. The affected source shall maintain a copy of the
training program with the work practice implementation plan. The
training program shall include, at a minimum, the following:
(l) A list of all current personnel by name and job
description that are required to be trained;
(2) An outline of the subjects to be covered in the initial
and refresher training for each position, or group of personnel;
(3) Lesson plans for courses to be given at the initial and
the annual refresher training that include, at a minimum,
appropriate application techniques, appropriate cleaning and
washoff procedures, appropriate equipment setup and adjustment to
B-13
-------
DRAFT
3104/650272
7/11/95
minimize finishing material usage and overspray, and appropriate
management of cleanup wastes; and
(4) A description of the methods to be used at the
completion of initial or refresher training to demonstrate and
document successful completion and a record of the date each
employee is trained.
(c) Leak inspect;?.on and maintenance* plan. Each owner or
operator of an affected source shall prepare and maintain with
the work practice implementation plan a written leak inspection
and maintenance plan that specifies:
(1) A minimum visual inspection frequency of once per month
for all equipment used to transfer or apply finishing materials
or organic solvents;
(2) An inspection schedule;
(3) Methods for documenting the date and results of each
inspection and any repairs that were made;
(4) The timeframe between identifying a leak and making the
repair, which adheres to the following schedule:
(a) A first attempt at repair (e.g., tightening of packing
glands) shall be made no later than 5 working days after the leak
is detected; and
(ii] Final repairs shall be made within 15 working days,
unless the leaking equipment is to be replaced by a new purchase
in which case repairs shall be completed within 3 months.
(d) Cleaning and washoff solvent accounting system. Each
owner or operator of an affected source shall develop an organic
so].vent accounting form to record;
(I) The quantity and type cf organic solvent used each
month for washoff and cleaning;
(2) The number of pieces //ashed off, and the reason for the
washoff; and
(3) The net quantity of cper.t organic solvent generated
from each ?-.;tivit> . The net quantity of spent solvent is
equivalent Lo th~ octal Amount of organic solvent that is
generated .rom ti:-: activity minus arty organic solvent that is
-------
DRAFT
3104/650272
7/11/95
reused onsite for operations other than cleaning or washoff and
any organic solvent that was sent offsite for disposal.
(e) Spray booth cleaning. Each owner or operator of an
affected source shall not use compounds containing more than
8.0 percent by weight of VOC for cleaning spray booth components
other than conveyors, continuous coaters and their enclosures,
and/or metal filters, unless the spray booth is being
refurbished. If the spray booth is being refurbished, that is,
the spray booth coating or other material used to cover the booth
is being replaced, the affected source shall use no more than
1.0 gallon of organic solvent to prepare the booth prior to
applying the booth coating.
(f) Storage requirements. Bach owner or operator of an
affected source shall use normally closed containers for storing
finishing, cleaning, and washoff materials.
(g) Application equipment requirements. Each owner or
operator of an affected source shall not use conventional air
spray guns for applying finishing materials except under the
following circumstances:
(1) To apply finishing materials that have a VOC content no
greater than 1.0 kg VOC/kg solids (1.0 Ib VOC/lb solids), as
applied;
(2) For touch-up and repair under the following
circumstances:
(i) The finishing materials are applied after completion of
the finishing operation; or
(ii) The finishing materials are applied after the stain
and before any other type of finishing material is applied, and
the finishing materials are applied from a container that has a
volume of no more than 2.0 gallons.
(3) If spray is automated, that is, the spray gun is aimed
and triggered automatically, not manually;
(4) If emissions from the finishing application station are
directed to a control device;
(5) The conventional air gun is used to apply finishing
materials and the cumulative total usage of that finishing
B-15
-------
DRAFT
3104/650272
7/11/95
material is no more than 5.0 percent of the total gallons of
finishing material used during that semiannual reporting period;
or
(6) The conventional air gun is used to apply stain on a
part for which it is technically or economically infeasible to
use any other spray application technology. The affected source
shall demonstrate technical or economic infeasibility by
submitting to the Agency a videotape, a technical report, or
other documentation that supports the affected source's claim of
technical or economic infeasibility. The following criteria
shall be used, either independently or in combination, to support
the affected source's claim of technical or economic
infeasibility:
(i) The production speed is too high or the part shape is
too complex for one operator to coat the part and the application
station is not large enough to accommodate an additional
operator; or
(ii) The excessively large vertical spray area of the part
makes it difficult to avoid sagging or runs in the stain.
(h! Linecleaning. Each owner or operator of an affected
source shall pump or drain all organic solvent used for line
cleaning into a normally closed container.
(i; Gur_ cleanir.?. Each owner or operator of an affected
source snail collect all organic solvent used to clean spray guns
irt.o a normally closed container
(j) Washsff operations. Each owner or operator of an
affected source shall control emissions from washoff operations
by:
(15 Using norrrally closed canks for washoff; and
(25 Minimizing dripping by tilting or rotating the part to
drain as much organic solvent as possible.
B.6 COMPLIANCE PROCEDURES AND MONITORING REQUIREMENTS
(a) The owner or operator of au affected source subject to
the emission standards in § E.4 of Ltiis rule shall demonstrate
compliance with those provision? fry using arv of the following
methods •.
ii-lC
-------
DRAFT
3104/650272
7/11/95
(1) To support that each sealer, topcoat, and strippable
booth coating meets the requirements of § B.4(a)(l), (2), or (3)
or B.4(b) of this rule, maintain certified product data sheets
for each of these finishing materials. If solvent or other VOC
is added to the finishing material before application, the
affected source shall maintain documentation showing the VOC
content of the finishing material as applied, in kg VOC/kg
solids.
(2) To comply through the use of a control system as
discussed in B.4(a)(5):
(i) Determine the overall control efficiency needed to
demonstrate compliance using Equation 3;
R - [(C - E)/C](100) (3)
(ii) Document that the value of C in Equation 3 is obtained
from the VOC and solids content of the as-applied finishing
material;
(Hi) Calculate the overall efficiency of the control
device, using the procedures in § B.7(d) or (e), and demonstrate
that the value of R calculated by Equation 6 is equal to or
greater than the value of R calculated by Equation 3.
(b) Initial compliance.
(l) Owners or operators of an affected source subject to
the provisions of § B.4(a)(l), (2), or (3) or B.4(b) that are
complying through the procedures established in § B.6(a)(1) shall
submit an initial compliance status report, as required by
B.9(b), stating that compliant sealers and/or topcoats and
strippable booth coatings are being used by the affected source.
(2) Owners or operators of an affected source subject to
the provisions of B.4(a}(l), (2), or (3) that are complying
through the procedures established in B.6(a)(1) and are applying
sealers and/or topcoats using continuous coaters shall
demonstrate initial compliance by:
(i) Submitting an initial compliance status report stating
that compliant sealers and/or topcoats, as determined by the VOC
B-17
-------
DRAFT
3104/650272
7/11/95
content of the finishing material in the reservoir and the VOC
content as calculated from records, are being used; or
(ii) Submitting an initial compliance status report stating
that compliant sealers and/or topcoats, as determined by the VOC
content of the finishing material in the reservoir, are being
used and the viscosity of the finishing material in the reservoir
is being monitored. The affected source shall also provide data
that demonstrates the correlation between the viscosity of the
finishing material and the VOC content of the finishing material
in the reservoir.
(3) Owners or operators of an affected source using a
control system (capture device/control device) to comply with the
requirements of this rule, as allowed by SS B.4(a)(5) and
B.6(a)(2) shall demonstrate initial compliance by:
(i) Submitting a monitoring plan that identifies the
operating parameter to be monitored for the capture device and
discusses why the parameter is appropriate for demonstrating
ongoing compliance;
(il) Conducting an initial performance test using the
procedures and test methods listed in § B.7(c) and (d) or (e);
(iii) Calculating the overall control efficiency (R) using
Equation 6; and
(iv Determining those operating conditions critical to
determining compliance and establishing operating parameters that
will en^r;re compliance wj th tbe standard.
(A) Fcr compliance with a thermal incinerator, minimum
combustion temperature shall be the operating parameter.
(E) For compliance with a catalytic incinerator equipped
with a fixed catalyst bed, the minimum gas temperature both
upstream and downstream of the catalyst bed shall be the
operating parameter.
(C For compliance with i catalytic incinerator equipped
with a ::iuidized catalyst beu f.he minimum gas temperature
upstrea:.. cf the catalyst bed ^nd the pressure drop across the
catalyst be~ shaix be the opc-"'-v::'nq parameters.
-------
DRAFT
3104/650272
7/11/95
(D) For compliance with a carbon adsorber, the operating
parameters shall be either the total regeneration mass stream
flow for each regeneration cycle and the carbon bed temperature
after each regeneration, or the concentration level of organic
compounds exiting the adsorber, unless the owner or operator
requests and receives approval from the Administrator to
establish other operating parameters. •
(E) For compliance with a control device not listed in this
section, the operating parameter shall be established using the
procedures identified in section B.6(c)(3)(vi).
(v) Owners or operators complying with paragraph (b)(3) of
this section shall calculate the site-specific operating
parameter value as the arithmetic average of the maximum or
minimum operating parameter values, as appropriate, that
demonstrate compliance with the standards, during the three test
runs required by § B.7(c)(1).
(4) Owners or operators of an affected source subject to
the work practice standards in section B.5 shall submit an
initial compliance status report, as required by B.9(b), stating
that the work practice implementation plan has been developed and
procedures have been established for implementing the provisions
of the plan.
(c) Continuous compliance demonstrations.
(l) Owners or operators of an affected source subject to
the provisions of § B.4 that are complying through the procedures
«
established in § B.6(a)(l) shall demonstrate continuous
compliance by using compliant materials, maintaining records that
demonstrate the materials are compliant, and submitting a
compliance certification with the semiannual report required by
§ B.9(c) .
U) The compliance certification shall state that compliant
sealers and/or topcoats and strippable booth coatings have been
used each day in the semiannual reporting period, or should
otherwise identify the days of noncompliance and the reasons for
noncompliance. An affected source is in violation of the
standard whenever a noncompliant material, as determined by
B-19
-------
DRAFT
3104/650272
7/11/95
records or by a sample of the finishing material, is used. Use
of a noncompliant material is a separate violation for each day
the noncompliant material is used.
(ii) The compliance certification shall be signed by a
responsible official of the company that owns or operates the
affected source.
(2) Owners or operators of an affected source subject to
the provisions of B.4 that are complying through the procedures
established in B.6(a)(l) and are applying sealers and/or topcoats
using continuous coaters shall demonstrate continuous compliance
by following the procedures in (i) or (ii) of this paragraph.
(i) Using compliant materials, as determined by the VOC
content of the finishing material in the reservoir and the VOC
content as calculated from records, and submitting a compliance
certification with the semiannual report required by B.9(c).
(A) The compliance certification shall state that compliant
sealers and/or topcoats have been used each day in the semiannual
reporting period, or should otherwise identify the days of
noncompliance and the reasons for noncompliance An affected
source is in violation of the standard whenever a noncompliant
material, as determined by records or by a sample of the
finishing material, is used Use of a noncompliant material is a
separate violation for each day the noncompliant material is
used.
(£.: The compliance certification shall be signed by a
responsible official of the company that owns or operates the
affected source.
(ij; Using compliant material:-;, as determined by the VOC
content of the finishing material in the reservoir, maintaining
a viscosity cf the finishing material in the reservoir that is no
less than the viscosity or the initial finishing material by
monitoring the viscosity with a viscosity meter or by testing the
viscosity of the initial finishing material and retesting the
material in the reservoir each Lirae solvent is added, maintainir. ;
records: cf solvent additions, and subserving a compliance
certification with ;:he semiauAual report required by B.9(ci -
3 • 2'.'
-------
DRAFT
3104/650272
7/11/95
(A) The compliance certification shall state that compliant
sealers and/or topcoats, as determined by the VOC content of the
finishing material in the reservoir, have been used each day in
the semiannual reporting period. Additionally, the certification
shall state that the viscosity of the finishing material in the
reservoir has not been less than the viscosity of the initial
finishing material, that is, the material that is initially mixed
and placed in the reservoir, for any day in the semi annual
reporting period.
(B) The compliance certification shall be signed by a
responsible official of the company that owns or operates the
affected source.
(C) An affected source is in violation of the standard
when a sample of the as-applied finishing material exceeds the
applicable limit established in B.4(a)(l), (2), or (3), as
determined using EPA Method 24, or an alternative or equivalent
method, or the viscosity of the finishing material in the
reservoir is less than the viscosity of the initial finishing
material.
(3) Owners or operators of an affected source subject to.
the provisions of B.4 that are complying through the use of a
control system (capture/control device) shall demonstrate
continuous compliance by installing, calibrating, maintaining,
and operating the appropriate monitoring equipment according to
manufacturers specifications.
(i) Where a capture/control device is used, a device to
monitor the site-specific operating parameter established in
accordance with B.6(b)(2)(i) is required.
(ii) Where an incinerator is used, a temperature monitoring
device equipped with a continuous recorder is required.
(A) Where a thermal incinerator is used, a temperature
monitoring device shall be installed in the firebox or in the
ductwork immediately downstream of the firebox in a position
before any substantial heat exchange occurs.
(B) Where a catalytic incinerator equipped with a fixed
catalyst bed is used, temperature monitoring devices shall be
B-21
-------
DRAFT
3104/650272
7/11/95
installed in the gas stream immediately before and after the
catalyst bed.
(C) Where a catalytic incinerator equipped with a fluidized
catalyst bed is used, a temperature monitoring device shall be
installed in the gas stream immediately before the bed. In
addition, a pressure monitoring device shall be installed to
determine the pressure drop across the catalyst bed. The
pressure drop shall be measured monthly at a constant flow rate.
(Hi) Where a carbon adsorber is used:
(A) An integrating regeneration stream flow monitoring
device having an accuracy of ± 10 percent, capable of recording
the total regeneration stream mass flow for each regeneration
cycle; and a carbon bed temperature monitoring device having an
accuracy of ±1 percent of the temperature being monitored
expressed in degrees Celsius or ±0.5 C, whichever is greater,
capable of recording the carbon bed temperature after each
regeneration and within 15 minutes of completing any cooling
cycle;
(B) An organic monitoring device, equipped with a
continuous recorder, to indicate the concentration level of
organic compounds exiting the carbon adsorber; or
(C) Any other monitoring device that has been approved by
the Administrator as allowed under E.6(b) (3) (iv) (D) ,
(iv Owners cr operators cf ;*n affected source shall not
operate the capture or control device at a daily average value
greater than or less than (as appropriate) the operating
parameter value. The daily average value shall be calculated as
the average of all values for a monitored parameter recorded
during the operating day.
(v, Owners or operators of an affected source that are
complying through the use of a catalytic incinerator equipped
with a fluidized catalyst bsd shall maintain a constant pressure
drop, measured monthly, across the catalyst bed,
(vi, An ownsr cr operator ut. inq a control device not listen
in this section shall, submit to the: Administrator a description
of the 'ievice,. test cata ve -ify 1113 i:he performance of the device
-------
DRAFT
3104/650272
7/11/95
and appropriate operating parameter values that will be monitored
to demonstrate continuous compliance with the standard.
Compliance using this device is subject to the Administrator's
approval.
(4) Owners or operators of an affected source subject to
the work practice standards in § B.5 shall demonstrate continuous
compliance by following the work practice implementation plan and
submitting a compliance certification with the semiannual report
required by § B.9(c).
(1) The compliance certification shall state that the work
practice implementation plan is being followed, or should
otherwise identify the periods of noncompliance with the work
practice standards. Each failure to implement an obligation
under the plan during any particular day is a separate violation.
(ii) The compliance certification shall be signed by a
responsible official of the company that owns or operates the
affected source.
B.7 PERFORMANCE TEST METHODS
(a) The EPA Method 24 (40 CFR 60) shall be used to
determine the VOC content and the solids content by weight of the
as supplied finishing materials. The owner or operator of the
affected source may request approval from the Administrator to
use an alternative or equivalent method for determining the VOC
content of the finishing material. If it is demonstrated to the
satisfaction of the Administrator that a finishing material does
not release VOC reaction byproducts during the cure (that is, no
VOC is produced by the reaction), for example, all VOC is
solvent, then batch formulation information shall be accepted.
In the event of any inconsistency between an EPA Method 24 test
and a facility's formulation data, that is, if the EPA Method 24
value is higher, the EPA Method 24 test shall govern. Sampling
procedures shall follow the guidelines presented in 'Standard
Procedures for Collection of Coating and Ink Samples for VOC
Content Analysis by Reference Method 24 and Reference
Method 24A," EPA-340/1-91-010.
B-23
-------
DRAFT
3104/650272
7/11/95
(b) Owners or operators demonstrating compliance with the
provisions of this rule via a control system shall determine the
overall control efficiency of the control system (R) as the
product of the capture and control device efficiencies, using the
test methods cited in § B.7(c) and the procedures in § B.7 (d) or
(e).
(c) Owners or operators using a control system shall
demonstrate initial compliance using the procedures in paragraphs
(c)(1) through (c) (6) of this section.
(1) The EPA Method 18, 25, or 25A (40 CFR 60) shall be used
to determine the VOC concentration of gaseous air streams. The
test shall consist of three separate runs, each lasting a minimum
of 30 minutes.
(2) The EPA Method 1 or 1A (40 CFR 60) shall be used for
sample and velocity traverses.
(3) The EPA Method 2, 2A, 2C, or 2D (40 CFR 60) shall be
used to measure velocity and volumetric flow rates.
(4) The EPA Method 3 (40 CFR 60) shall be used to analyze
the exhaust gases.
(5) The EPA Method 4 (40 CFR 60) shall be used to measure
the moisture in the stack gas.
(6) The EPA Methods 2, 2A, ?.C, 2D, 3, and 4 shall be
performed as applicable, at leas*- twice during each test period.
(d) Owners cr operat-.ors using a control system to
demonstrate compliance wit'" thie rule shall use the following
procedures:
(1) Construct the overall VOC control system so that
volumetric flow rates; and VOC concentrations can be determined by
the tesu methods specified in § B.7(c)(l) through (6);
(2^ Measure the capture efficiency from the affected
emission point(s) by capturing, venting, and measuring all VOC
emissions froiv. the affected emission point (s) To measure the
capture efficiency o? a capture device located in an area with
nonaffeared VOC emission point(s) the affected emission point(s
shall be iso'.-^sd from, al; othe*- -/OC sources by one of the
followin methods;
-------
DRAFT
3104/650272
7/11/95
(i) Build a temporary total enclosure (see § B.3) around
the affected emission point (s);
(ii) Shut down all nonaffected VOC emission point (s) and
continue to exhaust fugitive emissions from the affected emission
point (s) through any building ventilation system and other room
exhausts such as drying ovens. All exhaust air must be vented
through stacks suitable for testing; or •
(Hi) Use another methodology approved by the Agency
provided it complies with the EPA criteria for acceptance under
Part 63, Appendix A, Method 301.
(3) Operate the control system with all affected emission
point (s) connected and operating at maximum production rate;
(4) Determine the efficiency (F) of the control device
using Equation 4;
n
.E Obi °bi ~ £ Qaj Caj
in
£
(4)
n
(5) Determine the efficiency (N) of the capture system
using Equation 5;
n
.E Qdi Cdi
n P
E Qdi cdi * E c
>f k Cf k
N = - l - - - (5)
(6) Compliance is demonstrated if the value of (R) in
Equation 6 is greater than or equal to the value of R calculated
by Equation 3 in accordance with § B.6(a) (2) (i) .
R « (F x N) (100) (6)
(e) An alternative to the compliance method presented in
§ B.7(d) is the installation of a permanent total enclosure. A
B-25
-------
DRAFT
3104/650272
7/11/95
permanent total enclosure presents prima facia evidence that all
VOC emissions from the affected emission point (s) are directed to
the control device. Bach affected source that complies using a
permanent total enclosure shall:
(l) Demonstrate that the total enclosure meets the
following requirements:
(i) The total area of all natural draft openings shall not
exceed 5 percent of the total surface area of the total
enclosure's walls, floor, and ceiling;
(i.i) All sources of emissions within the enclosure shall be
a minimum of four equivalent diameters away from each natural
draft opening;
(iii) Average inward face velocity (FV) across all natural
draft openings shall be a minimum of 3,600 meters per hour
(200 ft/min) as determined by the following procedures:
(A) All forced makeup air ducts and all exhaust ducts are
constructed so that the volumetric flow rate in each can be
accurately determined by the test methods and procedures
specified in § E.7(c) (2) and (3) Volumetric flow rates shall be
calculated without the adjustment normally made for moisture
content ; and
(B; Determine FV by the following equation:
n P
~
FV - = _____ = _ (7)
q
L Ak
k=i
(iv] All access doors and windows whose areas are not
included as natural draft openings and are not included in the
calculation cf FV shall be closed during routine operation of the
process ,
(2; Determine the control device efficiency using
Equation ±, and the >.;esf. methods and procedures specified in
§ B . 7 ( c ; (I } through ( 6 }
R- 26
-------
DRAFT
3104/650272
7/11/95
(3) If the permanent enclosure is demonstrated to be total,
the value of N in Equation 5 is equal to 1.
(4) For owners or operators using a control system to
comply with the provisions of this rule, compliance is
demonstrated if:
(i) The installation of a permanent total enclosure is
demonstrated (N-l); and *
(ii) The value of (R) calculated by Equation 6 in
accordance with B.7(d) is greater than or equal to the value of R
calculated by Equation 3 in accordance with § B.6(a)(2).
B.8 RECORDKEEPING REQUIREMENTS
(a) The owner or operator of an affected source subject to
the emission limits in § B.4 of this rule shall maintain records
of the following:
(l) A certified product data sheet for each finishing
material and strippable booth coating subject to the emission
limits in B.4;
(2) The VOC content, kg VOC/kg solids (Ib VOC Ib/solids),
as applied, of each finishing material and strippable booth
coating subject to the emission limits in B.4, and copies of data
sheets documenting how the as applied values were determined.
(b) The owner or operator of an affected source following
the compliance procedures of B.6(c)(2) shall maintain the records
required by B.8(a) and records of the following:
(1) Solvent and finishing material additions to the
continuous coater reservoir; and
(2) Viscosity measurements.
(c) The owner or operator of an affected source following
the compliance method of § B.6(a)(2) shall maintain the following
.records:
(1) Copies of the calculations to support the equivalency
of using a control system, as well as the data that are necessary
to support the calculation of E in Equation 3 and the calculation
of R in Equation 6;
(2) Records of the daily average value of each continuously
monitored parameter for each operating day. If all recorded
B-27
-------
DRAFT
3104/650272
7/11/95
values for a monitored parameter are within the range established
during the initial performance test, the owner or operator may
record that all values were within the range rather than
calculating and recording an average for that day; and
(3) Records of the pressure drop across the catalyst bed
for facilities complying with the emission limitations using a
catalytic incinerator with a fluidized catalyst bed.
(d) The owner or operator of an affected source subject to
the work practice standards in S B.5 of this rule shall maintain
onsite the work practice implementation plan and all records
associated with fulfilling the requirements of that plan,
including, but not limited to:
(1) Records demonstrating that the operator training
program is in place;
(2) Records maintained in accordance with the inspection
and maintenance plan;
(3) Records associated with the cleaning solvent accounting
system;
(4) Records associated with the limitation on the use of
conventional air spray guns showing total finishing material
usage and the percentage of finishing materials applied with
conventional air spray guns for each semiannual reporting period;
(5) Records showing the VOC content of compounds used for
cleaning booth components, except for solvent used to clean
conveyors, continuous coaters and their enclosures, and/or metal
filters; ar.d
(6) Copies of logs arid other documentation developed to
demonstrate that the other provisions cf the work practice
implementation plan are followed.
(e) In addition to tho records required by paragraph (a) of
this section, the owner or operator of an affected source that
complies via the provisions of § B.£(a)(l) or § B.5 shall
maintain a copy of the compliance certifications submitted in
accorcoi-ce with {•; B. :>•(<„) for each sorraannual period following tIn-
compliance dat--.
6-28
-------
DRAFT
3104/650272
7/11/95
(£) The owner or operator of an affected source shall
maintain a copy of all other information submitted with the
initial status report required by S B.9(b) and the semiannual
reports required by § B.9(c).
(g) The owner or operator of an affected source shall
maintain all records for a minimum of 5 years.
(h) Failure to maintain the records required by (a) through
(g) of this section shall constitute a violation of the rule for
each day records are not maintained.
B.9 REPORTING REQUIREMENTS
(a) The owner or operator of an affected source using a
control system to fulfill the requirements of this rule axe
subject to the following reporting requirements:
(Note: Regulatory agencies may want to adopt the reporting
requirements contained in S 63.7 through § 63.10 of the General
Provisions to part 63 [HACT standards]. These requirements
specify time frames for reporting performance test results,
monitoring parameter values, and excess emissions reports.)
(b) The owner or operator of an affected source subject to
this rule shall submit an initial compliance report no later than
60 days after the compliance date. The report shall include the
items required by § B.6(b) of this rule.
(c) The owner or operator of an affected source subject to
this rule and demonstrating compliance in accordance with
§ B.6(a)(1) or (2) shall submit a semiannual report covering the
previous 6 months of wood furniture manufacturing operations
according to the following schedule:
(i) The first report shall be submitted 30 calendar days
after the end of the first 6-month period following the
compliance date.
Ui) Subsequent reports shall be submitted within
30 calendar days after the end of each 6-month period following
the first report.
(Hi) Each semiannual report shall include the information
required by § B.6(c), a statement of whether the affected source
was in compliance or noncompliance, and, if the affected source
B-29
-------
DRAFT
3104/650272
7/11/95
was in noncompliance, the measures taken to bring the affected
source into compliance.
B.10 SPECIAL PROVISIONS FOR SOURCES USING AN AVERAGING APPROACH
The owner or operator of an affected source complying with
the emission limitations established in B.4 through the
procedures established in B.4(a)(4) shall also meet the
provisions established in (a) through (i) of this section.
(Attachment 3 includes an example of a facility that is planning
to use an averaging approach to meet the requirements of the
model rule. The example addresses each of the provisions
discussed below.)
(a) Program goals and rationale. The owner or operator of
the affected source shall provide a summary of the reasons why
the affected source would like to comply with the emission
limitations through the procedures established in B.4(a)(4) and a
summary of how averaging can be used to meet the emission
limitations. The affected source shall also document that the
additional environmental benefit requirement is being met through
the use of the inequalities in B.4(a)(4). These inequalities
ensure that the affected source is achieving an additional
10 percent reduction in emissions when compared to affected
sources vising a compliant coatings approach to meet the
requirements of the rule.
(b) Program scope. The owner or operator of the affected
source shall describe the types of finishing materials that will
be included in the effected source's averaging program. Stains,
basecoats, washcoats, sealers, and topcoats may all be used in
the averaging program. The affected source may choose other
finishing materials for its averaging program, provided the
program complies with the State's case-by-case basis for VOC
averaging in the SIP. Fini&hing materials that are applied using
continuous coaters may only be us<. d in an averaging program if
the affec'ced source can determine the- amount of finishing
material usea each day
^•' P-^Sgrar-. baseline The baseline- for. each finishing
material Included in the averaging program shall be the lower of
-------
DRAFT
3104/650272
7/11/95
the actual or allowable emission rate as of the effective date of
the State's RACT rule. In no case shall the facility baseline
emission rate be higher than what was presumed in the
1990 emissions inventory for the facility unless the State has
accounted for the increase in emissions as growth.
(d) Quant i f icat ion procedures. The owner or operator of
the affected source shall specify methods and procedures for
quantifying emissions. Quantification procedures for VOC content
are included in B.7. The owner or operator shall specify methods
to be used for determining the usage of each finishing material.
The quantification methods used shall be accurate enough to
ensure that the affected source's actual emissions are less than
the allowable emissions, as calculated using Inequality 1 or 2 in
B.4(a)(4), on a daily basis to a level of certainty comparable to
that for traditional control strategies applicable to surface
coating sources.
(e) Monitoring. recordkeeping. and reporting. The owner or
operator of an affected source shall provide a summary of the
monitoring, recordkeeping, and reporting procedures that will be
used to demonstrate daily compliance with the inequalities
presented in B.4(a}(4). The monitoring, recordkeeping, and
reporting procedures shall be structured in such a way that
inspectors and facility owners can determine an affected source's
compliance status for any day. Furthermore, the procedures must
include methods for determining required data when monitoring,
recordkeeping, and reporting violations result in missing,
inadequate, or erroneous monitoring and recordkeeping. These
procedures must ensure that sources have sufficiently strong
incentive to properly perform monitoring and recordkeeping.
(f) SIP creditability and audit/reconciliation procedures.
[The State must specify values for rule compliance and program
uncertainty factors based on program elements such as the
quantification and enforcement procedures and on the predictive
quality of the information used by the State to develop the
projections of emission reductions. The State must include a
justification for the values assigned to these factors. If a
B-31
-------
DRAFT
3104/650272
7/11/95
direct determination of emissions is available, then rule
compliance and uncertainty factors can be presumed to be 1.
The State must also specify the auditing methods that will
be used to demonstrate successful operation of the averaging
program.]
(g) Implementation schedule. The owner or operator of an
affected source shall submit an averaging, proposal for State and
EPA approval any time after [State needs to insert the date that
EPA approves this averaging framework. This must ensure that all
sources are in compliance with the State's rule by the effective
date. Submittal of the averaging proposal does not provide an
exemption from the model rule. The source must submit the
averaging proposal by a date that allows sufficient time for EPA
approval.]
(h) Administrative procedures. [The State needs to provide
this information, which should include the requirements for who
may submit an averaging proposal, who the proposal should be
submitted to, and when the proposal may be submitted.
Administrative procedures must recognize that EPA must approve
proposals before an averaging program may be used to meet the
rale . ]
(i) Enforcement mechanisms. [The State needs to
incorporate provisions that provide adequate enforcement measures
Jior nonccr.pl iance with any source requirements, including
monitoring, recordkeepino, and reporting. Each program must
include provisions ensuring that Stace/local and Federal
statutory maximum penalties preserve the deterrent, effect of
programs that do not allow averaging. Enforcement provisions
should preserve the criminal sanctions (for knowing violations)
authorized in the Clean Air Act for violations of State
Implements Lien Plar: requirements,
Corr.pliance with monitoring, reoordkeeping, and reporting
requirements is critical to i:he integrity and success of the
averaging program Therefore, thesf penalty provisions must
include enforcement provisions that -'tstaVish ?» regulatory
E-32
-------
DRAFT
3104/650272
7/11/95
structure that clearly and effectively deters inadequate or
improper monitoring, recordkeeping, and reporting.
The example permit located at (insert location of sample
permit that includes averaging) demonstrates how these provisions
will be applied by the (insert name of permitting authority).)
B-33
-------
Attachment 1
Attachment 1 to EPA's Model Rule for
Wood Furniture Manufacturing Facilities
The model rule reflects, to the extent possible, concepts
laid out in tentative agreements by the regulatory negotiation
committee and the "Harrisburg Work Group, • a small working group
of committee members. Some of the items regarding small business
which, by their nature, do not fit into draft model rule format
are briefly described here:
A. Reportj.T^q and Recordkeepingr Associated with Federally
Enforggafrl ft VOC Ljn\jtg which are Below the RACT Appliqab.jj) ifr-Y
Threshold
Facilities emitting 75 percent or less of the "RACT
applicability threshold"1 should maintain records of emissions
based on purchases2 adjusted by inventory and submit annual
reports. Sources with annual emissions of 75 percent to
100 percent of the RACT threshold should keep records either
based on purchases adjusted by inventory or based on usage, with
quarterly reporting. A source whose emissions cross from below
the 75 percent level to above should notify the permitting agency
and submit quarterly reports for the remainder of that year and
the next year. If such a source emits at the 75 percent or less
level throughout that next year, it can return to annual
reporting the third year.
B. Clarification Regarding New Source Review (NSR) for Major
Sources
In response to a request to clarify issues dealing with New
Source Review that may affect small businesses:
1. If an area source3 or "synthetic minor" source4
modifies its facility but plans to remain below the RACT
applicability threshold, does it, as a result of facility
modifications with a potential increase in VOC emissions, have to
undergo NSR?
1 The RACT applicability threshold for this model rule is
10 tons for wood furniture facility located in an extreme ozone
nonattainment area, and 25 tons per year for a wood furniture
facility located in a marginal, moderate, serious or severe ozone
nonattainment area or the ozone transport region.
2 VOC data on coatings must use EPA Method 24 as the basis.
3 An area source is one whose emissions are not sufficient
to make the facility a major source.
A synthetic minor source is a source which has obtained a
Federally enforceable permit limitation to limit its potential to
emit such it is no longer a major source.
-------
Under current regulations, the source would not have to
undergo NSR if it requests and is given a Federally enforceable
limit that ensures that it remains below the threshold limit for
major sources and the threshold does not subsequently change. It
may not be necessary to receive a new limit if the old federally
enforceable limit (1) contains conditions that still apply and
(2) ensures that the source remains a minor source even after the
modification has occurred. For reference, see 40 CFR 52.21(r)(4)
and 52.21 (b)(7) which pertain to the "Prevention of Significant
Deterioration," and 40 CFR 51.165 (a)(5)(ii) and
51.165(a)(1)(xiv) which pertain to nonattainment NSR.
2. If an area source or synthetic minor source increases
its actual or potential emissions above the applicability
threshold and eliminates its Federally enforceable emission
limit, but does not modify its plant, does it, as a result of its
increase in VOC emissions, have to undergo NSR?
Under current "source obligation provisions" in the NSR
rules removing a federal limitation is considered a modification.
Therefore, if removing an existing limitation causes a source to
have a potential to emit that is higher than the major source
threshold for the locality, the source is subject to NSR. For
reference, see 40 CFR 52.2l{r)(4) and 52.21 (b)(7) which pertain
to the Prevention of Significant Deterioration, and 40 CFR
51.165(a)(5)(ii) and 51.165(a)(1)(xiv) which pertain to
nonattainmert NSR.
C. Sen era 1_ Pe rmit s
It was recommended that the CTG explain and encourage the
use of general permits5. In addition, the CTG should recommend
that £:rall businesses, where appropriate, establish a Federally
enforceable permit limitation such that their potential to emit
is below the RACT applicability threshold.
D - 1 r,format^or. __Cutreach for small business
Ic was recommended that an Information Outreach Program be
developed tc serve as a resource for small wood furniture
manufacturers and enabling or guidance document be prepared that
will set forth guidance on aspects of the CTG. It should also
detail the process of obtaining a Federally enforceable permit
limitation that restricts a facility's potential emissions to
below the RACT applicability threshold. This in being worked on
5 A ger.eral permit is defined under 40 CFF 70 as a permit
that lueets tr.e requirements of Section 70.6 (d). It is issued by
the permitf ..-.g authority to cov< r numerous similar sources. The
permitting authority grants thfc- Conditions and terms of the
general per-;.it to sources which qualify for ir •
-------
by the North Carolina Small Business Ombudsman with the EPA's
Federal Small Business Assistance Program.
E. Extension of Compliance Date for RACT
It was understood by the committee that the compliance date
for facilities to comply with RACT would be May of 1995. The
committee recommended that a source emitting less than 50 tons of
VOC's annually be allowed an additional period of time to either
(1) establish a federally enforceable emission limit or, (2) if
it is above the RACT applicability threshold, to research
technologies, train employees, and develop recordkeeping
capabilities. This period of time recommended is up until
November 1996.
-------
Attachment 2
Attachment 2 to EPA's Model Rule for
Wood Furniture Manufacturing Facilities
A. The units of "kilograms VOC per kilogram coating solid
(pounds VOC per pound coating solid)," which are the units of the
emission limitations in Section B.4, will be unfamiliar to most.
Two notes are provided to help relate these units to a basis
which may be more familiar. The following two notes pertain to
Sections B.4.(a)(1) and B.4.(a)(2) of the preliminary draft model
rule: •
1. Section B.4(a)(1) provides an avenue for compliance that
requires the facility to use a topcoat with a VOC content of no
greater than 0.8 pounds VOC per pound of coating solids. A
20 percent nitrocellulose lacquer (conventional) topcoat has a
VOC content of approximately 4.0 pounds VOC per pound of solids.
Therefore, a topcoat with a VOC content of 0.8 pound VOC per
pound of coating solids represents approximately 80 percent
reduction in VOC from a 20 weight percent solids nitrocellulose
lacquer topcoat.
2. Section B.4(a)(2) provides an avenue for compliance that
requires the facility to change both its topcoats and sealers.
Use of sealers with a VOC content of no greater than 1.9 pounds
VOC per pound coating solids represents approximately a
53 percent in VOC from a 20 percent nitrocellulose lacquer
sealer, and use of a topcoat with a VOC content of no greater
than 1.8 pounds VOC per pound solids represents approximately a
55 percent reduction in VOC emissions from a 20 weight percent
solids nitrocellulose lacquer topcoat.
B. This model rule also allows some monitoring requirements
for control devices that may not be appropriate for other source
categories. These include monitoring requirements for catalytic
incinerators equipped with a fluidized catalyst bed, which are
presented in B.6(b)(3)(iv)(C), and for carbon adsorbers, which
are presented in B.6(b)(3)(iv)(D). These monitoring requirements
have been negotiated with the wood furniture industry, and the
EPA feels that they are appropriate for this industry. However,
these monitoring requirements should not be adopted by another
source category without a complete evaluation as to whether they
are appropriate and reasonable for that source category.
-------
Attachment 3
Example of Permit Conditions Related to Averaging
for a Wood Furniture Manufacturing Facility
I. Introduction
On June 16, 1994, representatives of the Environmental
Protection Agency visited a wood furniture manufacturing facility
located in Pennsylvania. The facility is located in a
nonattainment area and is subject to a source-specific RACT
determination. The source-specific RACT determination allows the
facility to meet the required emission limitations by averaging
its emissions across wood furniture finishing lines on a
production-weighted daily basis. The facility also intends to
use averaging to meet the emission limitations in B.4 of this
model rule.
The purpose of the visit was to examine the monitoring and
recordkeeping practices currently being used at the facility.
This example provides guidance for developing source-specific
monitoring and recordkeeping requirements for other wood
furniture manufacturing facilities. Bach State must submit an
actual permit that applies to a source located within a
nonattainment area within its borders if the State wishes to use
the two-step approach as described in the EIP to allow averaging.
The following discussion addresses each of the provisions that
were presented in section B.10 of the attached model rule as they
relate to the example facility, including program goals and
rationale, the program scope, the program baseline,
quantification procedures, and monitoring, recordkeeping, and
reporting procedures. Each of these provisions must be addressed
by sources that wish to use an averaging approach to meet the
emission limitations presented in B.4. In addition, the example
addresses information that needs to be provided by the State in
which the facility is located.
II. Permit Conditions for Averaging
A. Program Goals and Rationale
Plant description. The facility manufactures custom office
furniture. The furniture is typically finished and then
assembled. Parts are finished on one of two lines, a hanging
line, where the finishes are spray applied, and a flat line that
uses both curtain and roll coaters. Some pieces, such as
conference room table tops, are finished using spray application
technology in a booth. Both fully pigmented finishes and wood
tone finishes are used.
Program goals. One of the goals of the averaging program is
to allow the facility to use finishing materials that do not meet
the emission limitations presented in B.4(a)(l) and (2). This
facility wishes to have this flexibility so that it can continue
to meet the demands of the marketplace. The plant will use
finishing materials with lower VOC contents to offset the
-------
emissions resulting from the use of noncompliant finishing
materials on a weighted use basis.
The facility is currently using a number of different types
of lower-VOC finishing materials, including waterborne and higher
solids materials. Many of these materials have a VOC content
lower than the emission limitations presented in B.4(a) (1) and
(2) . The facility also uses some waterborne basecoats. Where
feasible, the facility continues to explore and use lower VOC
finishing materials to produce the finishes they desire.
Because of the custom nature of their work, the facility
also chooses to use finishing materials that do not meet the
emission limitations presented in B.4. The desire to use
noncompliant coatings is due partly to the need to match the
color of previously purchased furniture.
The facility explored the use of abatement equipment. They
found, however, that for their facility it is more cost effective
to use averaging to offset the emissions of the higher VOC
finishing materials. The facility would like to continue to
offset the excess emissions from these higher VOC finishing
materials by using materials that have a lower VOC content than
the emission limitations in the model rule. The facility would
also like to get credit for using waterborne basecoats. The
model rule does not require the use of basecoats, stains, or
washcoats with lower VOC contents. Averaging would allow the
facility to get credit for using these types of finishing
materials with a lower VOC content.
Averaging provides the flexibility the facility needs to
meet their product demands, without violating the RACT emission
limitations. The facility feels that this flexibility will also
be needed tc meet the requirements that will be established by
the Stares in response to this model, rule. The facility does net-
believe they will need to use averaging every day to meet the
emission limitations. They would like the option of using
compliant coatings :ome days and an averaging program other days
The facility's experience with averaging to meet the current
State and Federal requirements has been positive. Averaging has
encouraged them to be innovative in their efforts to develop and
use lower-VOC finishing materials.
Additional environmental benefit. By using the inequalities
presented in B.4(a>(4) of the model rule as the basis for the
averaging program, the facility will meet the requirement for
additional environmental benefit. This equation ensures that the
facility will reduce emissions an additional 10 percent over
facilities using a compliant coatings approach to meet the
emission lirrdtati jn
2
-------
-------
B. Program Scope
This averaging program applies to this facility and may be
used by this facility to comply with the model rule on a daily
basis. The finishing materials used in the averaging program
will vary from day to day for this facility.
C. Program Baseline
The baseline for this facility is the lower of the actual or
allowable emissions that occurred before the application of their
source-specific RACT requirements.
D. Quantification Procedures
There are two components required to quantify the VOC
emissions at the facility; the amount of each finishing material
used, including catalysts and thinners, and the VOC content of
each finishing material used.
Finishing material usage is determined by measuring the
amount of finishing material that the operator begins with and
the amount of finishing material that is left after the operation
is complete. The amount of finishing material the operator
starts with may be measured using manufacturer supplied units,
such as five gallon containers, volumetric measuring devices,
such as a cup, or by taking a beginning height measurement in a
mixing pot. After the finishing operation is complete, the
operator measures the remaining material with a yardstick to the
nearest 0.5 inch. The height measurements have been calibrated
to determine the volume for every mixing container the company
uses. A copy of the calibration tables is attached.
Each employee is given training on how to obtain an accurate
measurement. For example, the specifications for the use of the
yardstick include putting the yardstick on the bottom of the
container, holding the yardstick against a side, and withdrawing
the yardstick to read the height (similar to reading a dipstick
in a car).
The VOC content of the finishing material is calculated
using the as supplied VOC content and the contribution of
thinner. Finishing materials are sampled and tested using EPA
Method 24 to verify the VOC content calculated from formulation
data.
The facility will use one of the following two inequalities
to calculate actual and allowable emissions.
-------
0.9 (0.8
TC2
•(i)
0.9 {[1.8 (TCj + TCj + ...)] + [1.9 (SEj + SEj + ..)] +
[9.0 (WCj + WC2 + ...)] + [1.2 (BCj + BC^ + ...)] +
[0.791 (STj + ST2 + . . .)]} * [ERTC1 (TCj) + ER-j^ (TCj) + .
[ERSE1 (SE^ + ERSE2 (SEj) + ...] + [ERWC1 (WCj) + ERWC2
+ •••] + [ERsn ^l^ t ERST2 (^
.] +
where:
TCj
SE
BC
ERTCi
ERSEi
ERBCi
*WCi
ER
STi
kilograms of solids of topcoat "i" used;
kilograms of solids of sealer "i" used;
kilograms of solids of basecoat "i" used;
kilograms of solids of washcoat "i" used;
liters of stain "i" used;
VOC content of topcoat "i" in kg VOC/kg solids, as
applied;
VOC content of sealer "i" in kg VOC/kg solids, as
applied;
VOC content of basecoat "i" in kg VOC/kg solids, as
applied;
VOC content of washcoat "i" in kg VOC/kg solids, as
applied; and
VOC content of stain "i" in kg VOC/1, as applied.
Inequality 1 would apply when the facility wished to comply
with B.4(a)(1) by averaging topcoats with a VOC content of less
than 0.8 kg VOC/kg solids with those that have a VOC content of
more than 0,8 kg VOC/kg solids.
Inequality 2 would apply to other averaging scenarios. The
facility could use this equation to average among their stains,
sealers, and topcoats or among their sealers and topcoats only.
Because the facility's source-specific requirements are
different than the requirements associated with this model rule,
the facility was not able to provide an actual calculation using
these averaging equations. However, the facility was able to
provide information on finishing materials they use. Following
is a summary of the coating characteristics and the EPA's
suggestion as to how the coatings could be used in the averaging
calculation.
Finishing Material
Sealer
Topcoat l
Topcoat 2
VOC
(ka VOC/ka solids)
2.0
0.9
1.9
Usage
fka solids)
123
258
123
Usage
(liters)
380
380
380
-------
For a facility using these finishing materials in these
amounts, the allowable and actual emissions can be calculated
using Inequality 2. Using this equation the facility's allowable
and actual emissions can be calculated as follows:
0.911.8(381) + 1.9(123)1 - 828 kg VOC - allowable emissions
0.9(258) + 1.9(123) + 2.0(123) - 712 kg VOC - actual emissions
This calculation shows that the facility is in compliance;
the actual emissions are about 15 percent less than the allowable
even though one of the finishing materials, topcoat 2, would not
comply if the facility were limited to a compliant coatings
approach.
E. Monitoring, Recordkeeping, and Reporting
The State would need to incorporate monitoring,
recordkeeping, and reporting requirements consistent with the
criteria in B.10(e) in the permit. The example facility is
currently monitoring finishing material and solvent usage closely
and keeping extensive records on their usage. Finishing material
usage is recorded by the operator on a data sheet each time a
finishing material is used. Any solvent or catalyst that is
added to the finishing material is also recorded. The form used
to record finishing material usage is checked and approved by the
supervisor. A copy of the finishing material usage form is
attached.
Data from the finishing material usage form are input into a
spreadsheet to calculate the VOC content of the finishing
material as applied. The VOC content of each finishing material,
as applied, and the total usage for each finishing material is
then input into another spreadsheet to calculate the total VOC
emissions for the day. The spreadsheet also calculates the
allowable emissions for the day so the facility can determine
compliance for the day. Copies of these spreadsheets are also
attached.
The facility was asked how they would determine compliance
in the event of lost data. Although the facility has never
encountered this problem, they said the data could be
reconstructed using production records and/or finishing material
inventory, presuming worse cast, that is, assuming values for the
unknown variables that would yield the highest weighted emission
rate average.
F. State Implementation Plan Creditability and Audit/
Reconciliation Procedures
This information would normally be provided by the State.
The State must add language that requires the source to submit
the data needed for the audit process. The source needs to
-------
specify a schedule for this data submittal that allows the State
to meet its specified audit frequency.
G. Implementation Schedule
This information would normally be provided by the State.
This must ensure that all sources are in compliance with the
State's rule by the effective date. Submittal of the averaging
proposal does not provide an exemption from the model rule. The
source must submit the averaging proposal* by a date that allows
sufficient time for EPA approval.
K. Administrative Procedures
This information would normally be provided by the State.
This must specify how data is to be submitted to the State by the
source and when such data is to be submitted.
I. Enforcement Mechanisms
Enforcement mechanisms consistent with the requirements of
B.lO(i) would need to be provided. This information would
normally be provided by the State. States need to specify any
special requirements that apply to the permitted source for
enforcement and compliance purposes such as definitions of what
constitutes violations of the various compliance provisions,
including the applicable emission limitations, as well as the
penalty structure for addressing violations.
-------
TECHNICAL REPORT DATA
(Please read Instructions on reverse before completing)
1. REPORT NO. 2.
EPA-453/D-95-002
4. TITLE AND SUBTITLE
Control of Volatile Organic Compound Emissions from Wood
furniture Manufacturing Operations-Draft
7. AUTHORCS)
9. PERFORMING ORGANIZATION NAME AND ADDRESS
U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Emission Standards Division
Research Triangle Park, NC 2771 1
12. SPONSORING AGENCY NAME AND ADDRESS
Director
Office of Air Quality Planning and Standards
Office of Air and Radiation
U.S. Environmental Protection Agency
Research Triangle Park, NC 27711
3. RECIPIENTS ACCESSION NO.
5. REPORT DATE
1994
«. PERFORMING ORGANIZATION CODE
t. PERFORMING ORGANIZATION REPORT NO.
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
13. TYPE OF REPORT AND PERIOD COVERED
Draft
14. SPONSORING AGENCY CODE
EPA/200/04
15. SUPPLEMENTARY NOTES
EPA Work Assignment Manager: Paul Almodovar, (919) 541-0283
16. ABSTRACT
This draft Control Techniques Guideline (CTG) provides the necessary guidance for development
of regulations to limit emissions of volatile organic compounds (VOC's) from wood furniture finishing
and cleaning operations. This guidance includes emission limits for specific wood furniture finishing
steps and work practices to reduce waste and evaporation through pollution prevention methods; these
represent reasonably available control technology for wood furniture finishing and cleaning operations.
This document is intended to provide State and local air pollution authorities with an information base
for proceeding with their own analyses of RACT to meet statutory requirements.
17. KEY WORDS AND DOCUMENT ANALYSIS
i. DESCRIPTORS
Air Pollution, volatile organic compound(s),
Wood furniture manufacturing
Emission limits
Control techniques guideline
11. DISTRIBUTION STATEMENT
Release Unlimited
k. IDENTIFIERS/OPEN ENDED TERMS
Air Pollution control
19. SECURITY CLASS
------- |