-------
2.2.2 HIGH SOLIDS COATINGS
High solids coatings have shown promise for use on -specific
products other than wood. Although it has been demonstrated that
high solids coatings can fill pores and seal wood, thus offering
considerable encouragement, they do not appear practicable for
current or near future use in the flat wood coating industry.
For additional information on high solids coatings, refer to
Volume I, Section 3.3.2.3
2.3 PROCESS CHANGES
2.3.1 ULTRAVIOLET CURING
Ultraviolet curing is the most widely used process change and,
where applicable, effects almost 100-percent reduction of VOC
emissions. In the flat wood industry, UV systems have been found
to be especially useful on particleboard coating lines and in
specialty coating operations.
Ultraviolet curing is extremely fast: for a typical sealer/
filler, an exposure of approximatley 10 seconds is sufficient.
Thus, a 10 to 20 ft (3 to 6 m) UV oven can replace a 90 to 100
8 9
ft (30 m) thermal oven required for conventional paint.
Ultraviolet-curable coatings are a combination of resin, prepolymers
and monomers, and photosensitizer (which serves as a catalyst).
Polyester, acrylics, methane, and alkyds are common coating mater-
ials. Applied as a liquid, the coating is cross-linked and hardened
on exposure to UV.
Although there have been attempts to develop opaque UV coatings,
such coatings are not available. Thus, in the flat wood industry,
•UV has found use only in the application of clear to semi transparent
filler and topcoat for interior printed paneling and cabinetry
products. Advantages are good machinability, extremely high solids,
2-6
-------
^ ow shrinkage, good adhesion to most substrates, good sanding qualities,
and good chemical resistance.
One of the major disadvantages of UV coating systems is the limited
number of available materials that can be successfully used to overcoat
UV-cured paints. Intercoat adhesion of UV materials to water-borne and
conventional solvent systems remains a problem. Other disadvantages
include the hazards of potential exposure to UV radiation, ozone, and
organic monomers, all of which may pose serious health problems.
2.3.2 ELECTRON BEAM CURING
One commercial facility in the United States uses an E3 curing system.
Opaque coatings can be cured to a depth of approximately 15 mils by
this method; 3 to 5 mils of EB-cured coating produce a smooth, wear resistant
11 12
finish with a performance comparable to many plastic laminates. '
Costs of both the installed system (over $500,000) and the coating
(S22 to $23 per gallon) limit the applicability of EB curing as a
control technique. However, over 99 percent control of VOC can be expected.
Monomers and ozone are possible emissions and some air-borne acrylics
have been experienced.
2.4 CONTROL LEVELS
For purposes of recommending levels of control, flat wood interior
panel products have been divided into three subcategories: 1) printed
interior wall panels made of hardwood plywood (principally lauan) and
oarticleboard ; . 2) natural finish hardwood plywood panels; and 3)
Class I finishes for hardboard paneling. [Class I hardboard panels
(principally exterior siding and tileboard), particleboard used in
furniture, insulation board, and softwood plywood are not considered in
this document. ] Recommended VOC limitations are given in kg/100 ®
2
(lbs/1000 ft ) of surface covered to allow panel coaters maximum flexibility
in adjusting VOC content of the different coatings so as to meet the
emission limitation while maintaining product quality.
2-7
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2.4.1 PRINTED INTERIOR WALL PANELS MADE OF HARDWOOD PLYWOOD AMD PARTICLE-
BOARD
Finishing of panels in this category is characterized by the use
of fillers and basecoats which obscure the grain or natural surface.
Simulated grain patterns or other decorative patterns are then printed
2
on the surface. The recommended VOC limitation of 2.9 kg/100 m
2
6.0 lbs/1000 ft of surface coated permits the use of conventional
organic solvent-borne coatings for topcoats and inks, but will require
use of water-borne coatings for some of the coating types.
The composition of the different coatings used on a given panel
will vary, but the recommended limitation is equivalent to an average
coating with a VQC content of 0.20 kg/1 (1.7 Ibs/gal). Few, if any,
coatings will have this composition. Water-borne coatings will have
less VOC and the solvent-borne coatings more VOC, but the total VOC of
all the coatings used must meet the limitations. In terms of limitations
used in previous documents, the recommended limitation is equivalent to
an average coating with a VOC content of 0.29 kg/1 (2.5 Ibs/gal) less
*
water.
The recommended emission limit will provide an emission reudction of
about 70 percent compared to the use of conventional coatings. This
2
assumes conventional coatings have an emission rate of 18.2 lbs/1000 ft ,
which is derived from the total of 16.1 in Table 2-2 by subtracting
2
1.1 lb/1000 ft for sealer (because this product does not require a
2
sealer) and adding an additional 3.2 lb/1000 ft to allow for coating
the grooves. This modification results in a more representative total
figure for printed hardwood plywood.
2.4.2 NATURAL FINISH HARDWOOD PLYWOOD
Finishes in this cateogry are characterized by use of essentially
transparent coatings frequently supplemented by fillers, toners and other
preliminary coats that complement the natural grain of the wood and
maintains its intrinsic attractiveness.
Calculations in Appendix B-U
2-8
-------
A recommended VQC limitation of 5.3 kg/100 m2 (12.0 lb/1000 ft2)
of surface coated permits the use of conventional organic coating
solvents for most applications, but with somewhat decreased amounts of
VQC. Water-borne groove coats and some water-based inks are being used
commercially; however, product quality cannot be maintained by use of
the other developmental water-borne coatings. The recommended emission
limit is equivalent to the usage of coatings which average 0.40 kg/1
(3.3 Ibs/gal) of VOC. This is equivalent to the usage of organic
solvent-borne coatings average 55 percent solids*
A typical total emission rate for coating panels with natural finish
2 13
coatings is 24 lbs/1000 ft . Thus, the recommended emission limits
will result in a 50 percent reduction in emissions of VOC for this
category.
2.4.3 CLASS II FINISHES FOR HARDBOARD PANELS
Factory applied finishes for hardboard panels are classified as
Class I and Class II by American National Standards Institute under
Voluntary Product Standard PS 59-73. Class II finish has no heat,
humidity, or steam resistance requirements as it is not meant to be
used' where these conditions are excessive. Combinations of water-borne
and solvent-borne coatings can be used to meet the recommended emission
limit and produce a panel which meets the Class II requirements.
7 2
The recommended emission limit of 4.8 kg/100 m (10 lbs/1000 ft )
is equivalent to the usage of coatings which average 0.34 kg/1 (2.8 Ibs/gal
of VOC. Assuming 40 percent solids, this would be equivalent to 0.43 kg/1
(3.6 Ibs/gal) less water.*
Calculations in Appendix 8-11
2-9
-------
References for Section 2.0
]. Test Report Summaries, Los Angeles County Zone, South Coast
Air Quality Management District (SCAOMD), El Monte, Calif.
2. Gadomski, R.R. et al., Evaluations of Emissions and Control
Technologies in the Graphic Arts Industries, Phase II, Graphic
Arts Technical Institute, Pittsburgh, Pa. 1973
3. U.S. Environmental Protection Agency, Control of Volatile
Organic Emissions from Existing Stationary Sources - Volume I:
Control Methods for Surface Coating Operations, EPA-450/2-76-
028 (OAQPS No. 1.2-067), Research Triangle Park, N.C.,
November 1976
4. Harr, G.R., Hirt Combustion Engineering, Montebello, Calif.
5. William, P., Ashdee Division of George Koch Sons, Inc., Evans-
vine, Ind., September 1977
6. Russel, P., Abitibi Corporation, Cucamonga, Calif.
7. Price., M.D., Reliance Universal, Inc., "The Future of High-
Solids Coatings," Proceedings of the Fourth Water-Borne and
Higher-Solids Coatings Symposium, New Orleans. La., 1977. p. 155
8. Koch, R.L., Ashdee Division of George Koch Sons, Inc., "UV-
Curing of Particleboard," Bulletin, Evansville, Ind.
9. PPG Industries, "A Cure for Energy, Pollution and Plant Space
Woes," PPG Products. Vol. 184, No. 2, Pittsburgh, Pa., 1976
10. Leary, P.E., Reliance Universal,Inc., "Ultraviolet Curable
Coatings for Industrial Finishings," American Paint and
Coatings Journal. Vol. 59, No. 15, 1974, pp. 86, 88, 90, 92
11. Christopherson, B., and Carnagey, D., Brookes-Willamette
Corporation, Bend, Ore.
12. "Space-Age Coating of Particleboard Offers Durable Surface,"
Furniture Methods and Materials, May 1977
13. Letter of comment to EPA from Hardwood Plywood Manufacturers
Association, Arlington, Virginia. May 17, 1978.
2-10
-------
3.0 COSTS AND ANALYSES OF CONTROL OPTIONS
3.1 INTRODUCTION
3.1.1 PURPOSE
The purpose of this section is to present estimated costs and
cost analyses for the control of volatile organic compound (VOC)
emissions from existing flat wood interior panel coating lines.
3.1.2 SCOPE
Estimates of capital and annualized costs are presented for con-
trolling VOC emissions from a model printed interior panels coating
line that includes the application and curing of filler/sealer,
basecoat, ink, and topcoat. Two categories of VOC control tech-
niques, changes in coating material to water-borne and ultraviolet
(UV) coating systems, have been costed. The alternatives considered
include (1) the complete conversion — except ink — to a water-
borne system, and (2) use of UV-curable coatings for the filler and
topcoat, with a water-borne basecoat.
Control devices such as afterburners and adsorbers are not gen-
erally suitable as retrofit emission control systems for existing
interior wall panel coating plants. Cost information for incinera-
tion and adsorption systems will not be discussed herein, but gen-
eral information can be obtained from Volume 1, Section 4.2.2.
Note, however, that add-on devices are viable control techniques
for VOC and are not ruled out on the basis of emission limits or
applicability.
3.1.3 USE OF MODEL PLANTS
For the interior wood panel coating industry, facility size is
normally a function of the number of finishing lines. It is assumed
3-1
-------
that differences in modifications of the various finishing lines
for the same process change are not significant. Therefore, costs
are estimated for typical modifications required to one line, and
several throughputs for the one line are then considered. The
basis for the throughputs is the number of hours of operation, since
the production rate of a given line is essentially constant. Also,
existing plants are assumed to use conventional organic solvent-
based coatings for all applications.
For both control systems analyzed, water-borne and UV coatings,
three throughputs were considered: coating of 1,000,000, 1,920,000,
2
and 4,000,000 standard panels per year. A standard panel is 32 ft
(2.97 m ). Prior studies had used 1,920,000 panels per year for a
2
one shift operation as a basis for evaluation. This rate of pro-
duction was used as a midpoint in the present analysis; those who
do not coat daily are represented by the lower production value, and
the higher value represents two full shifts of operation per day.
Model plant control cost estimates will differ from actual costs.
This is especially true for the coating of interior wall panels be-
cause different substrates are used, different finishes are applied
(due to process and customer requirements), and there are plant-to-
plant process differences, such as existing line equipment and line
speed. Model plant estimates are, however, the most convenient
means of comparing the relative costs of alternative control measures.
3.1.4 BASES FOR ESTIMATES OF CAPITAL COSTS
Capital cost represents the total investment required for the
purchase and installation of each control option. Costs due to pro-
duction losses during installation and startup, retraining of per-
sonnel, and other items affecting production are not included.
Major equipment purchases are not normally necessary to convert
from conventional to water-borne coatings. However, costs can be
3-2
-------
incurred (1) to shield or substitute corrosion resistant material
for those components that come into contact with and can be affected
by the coating, and (2) to provide a higher oven temperature or to
increase oven length. For facilities that do not utilize forced
airflow over the coatings, additional heating capacity and blowers
may be required. In most facilities, forced airflow exists to min-
imize organic solvent concentrations in the work area and to main-
tain the organic content in oven exhaust at low levels. For such
coaters, a net reduction in energy requirements may result.
Use of UV systems is limited to the application of filler and
topcoat to the wood. Ultraviolet curing systems require a signif-
icant capital investment. If conversion to water-borne coatings is
also desired, further expenditure is necessary.
3.1.5 BASES FOR ANNUALIZED COST ESTIMATES
Annualized cost estimates consist of the differences in expend-
itures between controlled and uncontrolled processes for direct op-
erating costs and annualized capital charges. A summary of factors
used in computing the annualized costs appears in Table 3-1.
Direct operating costs include expenditures for the following
i terns:
• Labor
• Materials (including solvent)
• Utilities
• Disposal of wastes
Annualized capital charges include the following expenses:
• Depreciation and interest
• Taxes, insurance, and administration
The depreciation and interest is computed by multiplying the capital
cost by a capital recovery factor, which is dependent on the life of
3-3
-------
the equipment at an appropriate interest rate. The taxes, insur-
ance, and administration are determined by multiplying the capital
cost by a factor of 4 percent.
3.2 CONTROL OF SOLVENT EMISSIONS
Developing estimates for the control of VOC emissions from the
coating of flat woods is not a straightforward task. In addition
to a wide diversity in the types and needs of existing facilities,
the procedures used to establish similar control systems are also
varied. This results in a lack of models that exemplify what might
be called a "standard" system. Also, facilities tend to make use of
equipment they already have and are often able to improvise. More-
over, it was found that there were significant plant-to-plant differ-
ences in applying the same emission control techniques, and that not
every plant controlled emissions from the same coating function.
Therefore, the following presentation is based on the experiences
of those who have installed various segments of a control system.
Using these data, costs for installation of complete systems are
estimated.
3.2.1 RETROFIT COSTS OF WATER-BORNE SYSTEMS
The coaters who provided data indicated that the total cost for
conversion system procurement and installation ranged from $40,000
to $55,000. Costs were accumulated on the basis of the processes em-
ployed in a water-borne system (filler/sealer, basecoat, and topcoat).
For each process, equipment modifications cost $5,000 to $7,000, in-
stallation and startup expenses ranged from $7,000 to $10,000, and
system engineering and design work was between $1,000 and $2,000.
Thus the cost of an individual process was between $13,000 and $19,000.
3-4
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3.2.2 OPERATION OF A WATER-BORNE SYSTEM
Operation of a water-borne system should result in-little change
in labor and energy costs. Labor requirements are identical with
those necessary for a solvent-based system. Energy needs should
grow as a result of increased temperature and airflow requirements
in the ovens. However, this increase will be compensated for by a
decrease in the blower requirements needed to maintain safe working
areas and to insure that organic concentrations in exhaust do not
exceed approved limits.
The major element affecting cost in the changeover to a water-
borne system is the cost differential of materials, especially the
cost of paint. Estimates of paint costs, assuming a facility with
a complete coating system and based on factors shown in Table 2-2,
are given in Table 3-1.
3.2.3 RETROFIT COSTS OF ULTRAVIOLET/WATER-BORNE SYSTEMS
Since UV systems cannot be used to apply a basecoat, a water-
borne process must be used. From the previous discussion, this
cost can be estimated at $15,000.
For the filler/sealer and topcoat processes, equipment expenses
should run between $45,000 and $55,000 per process, including the
purchase of an oven and other items. Installation and startup costs
vary from $10,000 to $15,000, and engineering and design costs $3,000
to $5,000 per process. Summing up these estimates yields a price tag
of $130,000 to $165,000 for retrofitting a UV/water-borne system.4"7
3.2.4 OPERATION OF AN ULTRAVIOLET/WATER-BORNE SYSTEM
Labor costs should not change due to conversion to a UV/water-
borne system, but energy costs will decrease. The power requirements
3-5
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Table 3-1. COST FACTORS USED FOR COMPUTING ANNUALIZED COSTS
I. Direct Operating Costs
1. Materials3'5
Cost per 1,000 ft2
Organic
Filler
Sealer
Basecoat
Ink
Topcoat
Total
Lamps0
2. Utilities
$ 6
0
4
1
3
$15
.00
.90
.00
.30
.20
.40
($ 6.
( 1.
( 4.
( I.
( 3.
($16.
50)
00)
30)
40)
40)
60)
( 100 m2) Covered
Water
$ 6
1
3
1
4
$16
.40
.05
.60
.35
.55
.95
($ 6
( 1
( 3
( 1
( 4
($18
.90)
.10)
.90)
.45)
.90)
.25)
Ultraviolet
$ 9
3
1
3
$17
.00
-
.60
.35
.30
.25
($ 9.70)
( - )
( 3.90)
( 1.45)
'( 3.55)
($18.60)
$150 each
Electricity (net savings)d $0.50 kW at 130 kW/hr
II. Annualized Capital Charges
1. Depreciation and interest expense 13% of capital cost
2. Taxes, insurance, and administration 42 of capital cost
a
Refer to Table 2-2 for coverage factors.
Paint costs per gallon:
Paint Costs Per Gallon
Filler
Sealer
Basecoat
Ink
Topcoat
Organic
$ 3.50
3.00
5.00
12.50
4.50
Water
$ 4.00
3.00
5.50
13.50
7.00
Ultraviolet
$ 8.00
-
-
-
10.00
From Reference 3.
From Reference 2.
3-6
-------
for UV lamps are 10 kilowatts per 50-inch lamp, so for two 12-1 amp
systems replacing infrared ovens, a reduction of 130 kilowatts per
2
shift hour will be realized. Reduced blower needs will also add
a minimal amount to the energy savings.
As with the water-borne system previously discussed, material
costs, such as paint expenses and lamp replacement, will have a
major impact. Paint costs are listed in Table 3-1. A sealer is
not required with the UV filler and the basecoat is water-borne.
Therefore, the increased cost for coatings that are UV-cured is ap-
proximately $1.80 per 1,000 ft2 ($1.95 per 100 m2). Ultraviolet
lamps have a normal burn life of 2,000 to 8,000 hours, depending on
their use. Therefore, they should be replaced every 1 to 4 years.
•3
At a cost of $150 per lamp, a complete set of 24 costs $3,600.
3.2.5 NET ANNUALIZED COST
Net annualized cost estimates for water-borne and UV/water-borne
systems are given in Table 3-2. This table compares the net annual
cost of the two methods for three different throughput levels. In
gathering the cost data, a range was noted for almost all expenses,
so an effort was made to use the values that are most likely to re-
flect the expected costs. The footnotes provide explanatory infor-
mation as to how this table was compiled.
3.3 COST-EFFECTIVENESS ANALYSIS
The cost-effectiveness analysis was conducted by first describing
the incremental annual costs required for existing facilities to in-
stitute a program of effective VOC control. These costs were then
compared with the expected VOC reductions in order to determine
cost-effectiveness over the useful life of the system.
3-7
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The analyses were based on the following principles:
• The discount rate (cost of capital) was taken to be
10 percent.
• The useful life of each system was taken at 15 years,
with no salvage value.
• A capital recovery factor was used to allocate the
cost of equipment and interest over its useful life.
• Insurance, taxes, and administrative expenses were
taken as a standard percentage of capital expenditures.
The results of the cost-effective analysis are listed in Table
3-2, and are graphically presented in Figure 3-1. These results
clearly show that the water-borne method is more cost-effective, and
illustrate the impact of throughput on each method. Throughput has
a much smaller effect on the water-borne method than it does on its
UV/water-borne counterpart. While the total variation in the former
case is just 3 cents per kilogram of hydrocarbon controlled, the
difference is 9 cents in the latter case. The use of lower VOC con-
tent water-borne coatings (10 to 15 percent of the volatile portion)
would further reduce emissions and improve cost-effectiveness.
3-8
-------
Table 3-2. NET ANNUAL1ZEO COST ESTIMATES
i
ID
Shifts
Panels
Feet^/Year
Installed capital costa
Direct operating cost
Pdintb
Lamps
Utilities'1
Capital charges
Net annual ized cost
Controlled emissions (kg)
Controlled emissions (Ib)
Cost-effectiveness ($/kg)
Cost-effectiveness ($/lb)
Less
1,0
32,0
Water-Borne
$ 52,000
48,000
8,840
$156,000
196,000
432,000
0.286
0.130
Than 1
30,000
00,000
Ultraviolet/
Water-Borne
$155,000
57,600
1,800
(6,500)
26,350
$ 79,200
222,100
489,600
0.357
0.162
1.92
61,4'
Water-Borne
$ 52,000
92,200
8,840
$101,000
376,000
829,000
0.269
0.122
1
>0,000
10,000
Ultraviolet/
Water-Borne
$155,000
110,600
1,800
(12,480)
26,350
$124,600
426,000
940,000
0.292
0.132
4.0C
128, Of
Water-Borne
$ 52,000
192,000
8,840
$ 200,800
783,800
1,728,000
0.256
0.116
2
10,000
)0,000
"ultraviolet/
Water-Borne
$ 155.000
230,400
3,600
(26,000)
26,350
$ 234,400
888,100
1,958,000
0.264
0.120
Installed capital cost for water-borne method
Installation and startup costs
Increase in oven capacity
Pumps ($1,000 per process)
Engineering and development cost
Blowers (4 per process at $500 each)
Total
.
$ 30,000?
10,000.
3,000^
3,000.
6.000
$ 52,000
Installed capital cost for ultraviolet/water-borne
method 4
Installation and startup costs (filler and topcoat) $ 24,000.,
Ovens (2 at $45,000)
Add-on equipment (for filler and topcoat)
Engineering and development cost
Water-borne for basecoat
Total
'Water-borne $1.50/1,000 ft2 x throughput
.2
-7
90,
16,000"*
9,000.est.
JJjjOOO
$155,000
Ultraviolet/water-borne $1.80/1,000 ft x throughput
c$150 per lamp. Useful life assumed to be 2 years for one shift or less, and 1 year for two shifts.
$0.50 per KW x 130 KW per hour x annual hours of operation.
-------
0.40
0.30
o
UJ
O
ce
o
o
an
UJ
Q.
0.20
0.10
\
JV/water costings
~~"—-— _
"
Water-borne
coatings
30
60
90
120
150
ID6 FT2 PER YEAR OF PANELING FINISHED
Figure 3-1. Cost Effectiveness for VOC Control at Existing
Printed Panel Coating Plants
3-10
-------
References for Section 3.0
1. U. S. Environmental Protection Agency, Control of Volatile
Organic Emissions from Existing Stationary Sources - Volume I:
Control Methods for Surface Coating Operations, EPA-450/2-76-Q28
(OAQPS No. 1.2-067), November 1976
2. Springborn Laboratories, Inc. (formerly Debell and Richardson),
"Air Pollution Control Engineering and Cost Study of Surface
Coating Industries," First Interim Report, Appendix, Basis for
Coatings, Case B-2, Prepared for U.S. Environmental Protection
Agency, 1976
3. Martin, M., PPG Industries, Inc., Plainfield, 111.
4. Springborn Laboratories, Inc. (formerly Debell and Richardson),
Report of trips made to plants during December 1975 through
March 1976
5. Christopherson, B., Brooks-Willamette Corporation, Bend, Ore., 1977.
6. Nickolson, T., Ashdee-George Koch, Inc., Evansville, Ind., 1977.
7. Estipia, J., General Wood Corporation, Buena Park, Calif., 1977.
3-11
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APPENDIX C
EFFECT OF DEPRECIATION AND TAXES
Tax incentives and depreciation may have a significant impact
for many companies contemplating a vapor recovery investment. In
this connection, the Internal Revenue Code includes special provis-
ions for firms, and especially small businesses purchasing and in-
stalling certified pollution control facilities. In addition to
all interest payments being deductible expenses for tax purposes,
Section 169 of the Internal Revenue Code permits rapid write-off of
such certified investments. Under this regulation a business may
choose to depreciate its newly acquired equipment over a 60-month
period instead of over its useful life. Employing the straight •
line depreciation method, 20 percent of the cost of this investment
would be deductible annually for 5 years.
Sections 46 and 50 of the code deal with the subject of invest-
ment tax credits. All businesses may credit 10 percent of the cost
of equipment with a depreciable life of at least 7 years to their
actual tax liability. Lesser percentages may be credited for equip-
ment depreciated over a minimum of 3 years to a maximum of 6 years;
for a life of 3 or 4 years, the investment tax credit is 3.33 per-
cent; for 5 or 6 years, the credit is 6.67 percent. The purpose of
this regulation is to provide businesses with added incentives to
purchase equipment.
Finally, Section 179 of the code furnishes small business with
an additional opportunity to reduce their taxes. It permits an ad-
ded first year bonus depreciation allowance equal to 20 percent of
the purchase price of the equipment up to a maximum of $2,000. If
this bonus depreciation is taken by the taxpayer, he must make an
appropriate reduction in the basis of the equipment.
Accordingly, a small business may be able to deduct its interest
expense plus up to 30 percent of the purchase and installation price
C-l
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4.2 ULTRAVIOLET - CURABLE COATINGS
The advantages of ultraviolet-curable coatings include reduced power
requirements, very little emission of VOC, and the essentially 100
percent usable coating (since all components of the caating normally
react and become part of the coating). As a result, blower requirements
are negligible, space savings are effected by reduced storage and oven
space needs, and very little waste is produced for disposal. Moreover,
cure times can be measured in seconds and a superior product results.
Since little or no curing takes place after the panel leaves the
oven, proper cure times must be carefully established. Safety
precautions must be taken to minimize exposure to UV radiation and to
avoid contact with the coating as some of the raw materials can cause
chemical burns.
4-2
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5.0 MONITORING TECHNIQUES AND ENFORCEMENT ASPECTS
As indicated previously, add-on control devices are not gener-
ally applied to the factory prefinishing of flat woods. However,
they may be used to meet VOC emission control requirements. Thus,
regulations must not only specify that a given percentage of nonmeth-
ane VOC be either converted to carbon dioxide and water or be ad-
sorbed, but must also require that approved capture systems be used
in conjunction with the add-on devices. Since suitable techniques
for testing capture systems are dependent on the facility, it is
recommended that each facility be individually reviewed to assure
that a satisfactory capture system is installed. Volume I, Section
5.0 of this series should be consulted for approaches to the deter-
mination of total nonmethane hydrocarbons.
For facilities that control emissions by using coatings contain-
ing lower overall VOC, emission measurements to determine compliance
may be difficult. Whether or not direct emission measurements can be
correlated with the rate of finishing interior panels must be deter-
mined on an individual basis.
For most plants, emission estimates require knowing the VOC
content of each coating, the quantity of each coating used per thou-
sand square feet of each product finished, and any additional
quantities of VOC used.
Density and volatile content of coatings can be determined by
using ASTM D 1475-60, ASTM D 1644-59, and ASTM D 2369-73. Applica-
bility, and procedures for using these methods to determine the
volatile content of paint, varnish, lacquer, and related products
are given in Volume II, Appendix A.2 These methods are not
applicable to coatings that require UV or EB curing. If an analysis
of these special coatings is required, alternative methods must be
developed. Procedures for calculating thequantity of VOC per
volume of paint, given the composition and density of the coating,
are presented in Appendix A.
5-1
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If the pounds of VOC per gallon of coating and the spread rate
of the coating (in square feet per gallon) are known, pounds of VOC
2
per 1,000 ft for each coating can be computed as shown in Appendix
2
B. The sum of the pounds of VOC per 1,000 ft for each coating ap-
plied to a specific product would give the final pounds of VOC per
2
1,000 ft . An alternative procedure would be to obtain, for each
relevant facility, data on the quantity and VOC content of each type
of coating used, the quantity of solvents used as diluent, and the
amount of finished paneling produced during a specified period of
time. These data permit computation of the average pounds of VOC
2
per 1,000 ft of product finished.
With the recommended system of emission limitations, enforce-
ment becomes relatively difficult. For some regulating agencies,
limitations in pounds of VOC per unit volume of coating may be more
suitable. Field personnel can then collect samples, have them anal-
yzed, and make determinations more rapidly.
Overall average values of VOC content for the recommended
limits are estimated to be 0.20 kg/1 (1.7 Ib/gal) for printed hard-
wood panels, 0.40 kg/1 (3.3 Ib/gal) for natural finish panels, and
0.34 kg/1 (2.8 Ib/gal} for Class II hardboard panel finishes. Since
each coating type differs in both composition and spread rate, these
values cannot be applied indiscriminately to all coatings.
5-2
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References for Section 5.0
1. U.S. Environmental Protection Agency, Control of Volatile Organ-
ic Emissions From Existing Stationary Sources - Volume1: Con-
trolMethods for Surface Coating Operations, EPA-450/2-76-028
(OAQPS No. 1.2-067), November 1976
2. U.S. Environmental Protection Agency, Control of Volatile Organ-
ic Emissions From Existing Stationary Sources - Volume II: Sur-
face Coating of Cans. Coils, Paper,Fabrics, Automobiles,and
Light Trucks, EPA-450/2-77-008 (OAQPS No. 1.2-073), May 1977
5-3
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APPENDIX A
DETERMINATION OF VOC IN COATINGS
Data Required:
Coating density D( Ib/gal )
Paint composition non-V, V, VOC, H
where:
V = volatile*, including water
VOC * volatile organic compounds * 7.36 Ib/gal (Vol II, p. D-2)
H20 * water * 8.34 Ib/gal
For Conventional Paint
(data in weight I): VOC « [•=jflr| (0) Ib/gal
(data in volume %): VOC « pTO~) (7-36)
ForWater-Borne Paint
(data in weight 5)
fsvocl
X of total coating; VOC - LToTj (D) Ib/gal
X of volatiles: VOC » pyj^l [fj|] ^ lb/9al
(data in volume $)
% of total coating: VOC * fijflj (7.36) Ib/gal
5 of volatiles: VOC - py^] [ygj] (7.36) Ib/gal
For VOC (Ib/gal less water)
VOC * ^—
100
Conversion
Ib/gal times 0.12 * kg/liter
A-l
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APPENDIX B
CALCULATIONS OF EMISSION RATES AND REDUCTIONS
I. Weight of VOC Per 1,000 Square Feet of Finished Product*
1- In the determination of potential volatile organic compound
(VOC) emissions from an interior wall paneling finishing plant,
two important factors must be known:
(1) Ib VOC/gal -- This factor is known by the formulator of the
industrial finish (the amount of solvent added can be ob-
tained from the finisher, or samples of the coating can be
tested).
2
(2) Spread rate in ft /gallon -- This factor is known and/or
can be calculated as it relates to each product finished
by the hardwood plywood manufacturer.
2
The appropriate formula for determining Ib VOC/1,000 ft of a
coating type is:
Ib VOC/1,000 ft2 = Ib VOC/gal x 1,000
Spread rate in ft /gal
Example:
Ib VOC/gal of a coating = 4.20
2
Typical spread rate = 1,800 ft
Ib VOC/1,000 ft2 = 4.20 Ib/gal x 1.000
1,800 ft2/gal
Ib VOC/1,000 ft2 = 2.33
Note: A listing of coating types applied and their respective
spread rates per gallon should be available from the hard-
wood plywood factory finisher. Spread rates can also be
estimated by the formula given in Part B.
The Ib VOC/1,000 ft of each coating type?applied can be
added together to obtain Ib VOC/1,000 ft of finished product.
Source: W.J. Groah, Hardwood Plywood Manufacturers Association,
Arlington, Va.
B-l
-------
2. The formula for approximating coating type spread rate is:
Theoretical ]»604 x E x Percent volume
spread rate . solids per gal
ft'Vqal ^m thickness in mils
Where 1,604 = a constant based on the application of 1 gallon
(0.1337 ft3) material of 100 percent solids
applied 1 mil (0.001 in) thick.
E = percent efficiency for application of finish.
For roller coating applications (predominant
in the interior panel finishing industry), E
can be taken as 0.95 (i.e., 95 percent of
material used is applied to the product).
Film thickness is measurable using various techniques.
II. Equivalency of Emission Rates per Area Coated vs. VOC Per Volume
of Coating
1. Printed Hardwood Plywood Panels
Table 2.2 is assumed to apply to this category. A coverage rate
of 3.5 gal/I,000 ft is appropriate.
2
Emission limitation equivalency = 6.0 lbs/1,000 ft0
gal/T,OUO fr
1.7 Ibs/gal (0.20 kg/1)
Assuming a typical coating has a solids content of 40 percent,
and solvent density is 7.36 Ibs/gal, the average coating com-
position would be: 40 percent solids, 23 percent organic solvent
1.7 , and 33 percent water.
(7736)
Emission limit equivalence on a water-free basis = 1.7 Ibs/gal
1 - 0.33
2.5 Ibs/gal less water
(0.29 kg/1)
2. Natural Finish Hardwood Plywood Panels
2
A coverage rate of 3.6 gal/I,000 ft is assumed.
B-2
-------
Emission limitation equivalency =
12.0 lbs/1,000 ftl 3 -
3.6 gal/1,005 ft* J'J
If no water-borne coatings are used, this limitation would require
the average coating to contain 45 percent solvent (3.3/ 7.36), and
55 percent solids. The water-free emission limit would be the same,
3.3 Ibs/gal less water (0,40 kg/1 less water).
Class II Finishes for Hardboard Panels.
2
A coverage rate of 3.5 gal/1,000ft is assumed.
Emission limitation equivalency =
10.0 lbs/1,000 ft? , D 1he/nal /n ,, ^/-n
i g ,-,=.1 /T nnrt f+2 = 2.8 ibs/gal (0.34 kg/1)
Assuming a typical coatina has a solids content of 40 percent, the
average coating composition would be; 40 percent solids, 38 percent
organic solvent(2,8/7,36} and 22 percent water.
Emission limit equivalency on a water-free basis -
2.8 Ibs/gal = 3.6 Ibs/gal less water (0.43 kg/1)
1 - 0.22
III. Emission Reductions Achievable by the Recommended Limitation
Compared to the use of conventional organic solvent-borne coatings with
no emission controls, achievement of the recommended limits will result
in reduced emissions in each category in the following ratios:
Printed Hardwood: 70 percent reduction
Natural Hardwood: 50 percent reduction
Class II Hardboard: 50 percent reduction
The relative production of the three categories on a nationwide basis is
estimated to be as follows:
Printed Hardwood: 55 percent of total
Natural Hardwood: 15 percent of total
Class II Hardboara: 30 percent of total
If the recommended levels are adopted it is estimated that the emission
reduction of each category as a percent of the total for the three
5-3
-------
categories is as follows;
Printed Hardwood: 38 percent of total
Natural Hardwood: 7 percent of total
Class II Hardboard: 15 percent of total
Total reduction 60 percent
Production of the three categories is estimated to be 35 percent of the
total of all factory finished flat wood products. The overall emission
reduction will be about 50 percent of the total emissions from all
flat wood products.
B-4
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APPENDIX C
EFFECT OF DEPRECIATION AND TAXES
Tax incentives and depreciation may have a significant impact
for many companies contemplating a vapor recovery investment. In
this connection, the Internal Revenue Code includes special provis-
ions for firms, and especially small businesses purchasing and in-
stalling certified pollution control facilities. In addition to
all interest payments being deductible expenses for tax purposes,
Section 169 of the Internal Revenue Code permits rapid write-off of
such certified investments. Under this regulation a business may
choose to depreciate its newly acquired equipment over a 60-month
period instead of over its useful life. Employing the straight •
line depreciation method, 20 percent of the cost of this investment
would be deductible annually for 5 years.
Sections 46 and 50 of the code deal with the subject of invest-
ment tax credits. All businesses may credit 10 percent of the cost
of equipment with a depreciable life of at least 7 years to their
actual tax liability. Lesser percentages may be credited for equip-
ment depreciated over a minimum of 3 years to a maximum of 6 years;
for a life of 3 or 4 years, the investment tax credit is 3.33 per-
cent; for 5 or 6 years, the credit is 6.67 percent. The purpose of
this regulation is to provide businesses with added incentives to
purchase equipment.
Finally, Section 179 of the code furnishes small business with
an additional opportunity to reduce their taxes. It permits an ad-
ded first year bonus depreciation allowance equal to 20 percent of
the purchase price of the equipment up to a maximum of $2,000. If
this bonus depreciation is taken by the taxpayer, he must make an
appropriate reduction in the basis of the equipment.
Accordingly, a small business may be able to deduct its interest
expense plus up to 30 percent of the purchase and installation price
C-l
-------
of certified pollution control equipment during the first year.
Other businesses will be able to deduct up to 25 percent plus interest
charges during the first year.
Let us examine the effect of these regulations on a particular
pollution control expenditure. Suppose a facility was required to
spend $10,000 for its equipment and installation, and $1,000 per
year for operations and maintenance. What is the aftertax cost of
this expenditure for both a regular business and a qualifying small
business? Let us assume the marginal tax is 48 percent for a regular
business and 22 percent for a small business and that the cost of
capital is 10 percent. The appropriate calculations are shown in
Table C-l.
Tax deductible expenses include depreciation, operations and
maintenance costs, and property taxes. For a qualifying small bus-
iness, there is also bonus first year depreciation. The total tax
related savings is calculated by taking the sum of the present value
of all deductible expenses, multiplying this figure by the marginal
tax rate, and adding the investment tax credit. This figure is then
subtracted from the before tax present value cost to determine the
"true" expense. Interest payments have not been included in this
example.
Property taxes are assumed to be paid at the end of each year,
while operating and maintenance expenditures are assumed to be con-
tinuous throughout the year. Accordingly, the latter are attributed
to the yearly midpoint for computing present values.
For a regular business, total present value expenses would be
$10,000 + $1,536* + $6,443,** yielding $17,979. With a tax savings
of $8,075, the true cost is $9,904. For a small business, the tax
savings would be $4,096, generating a true cost of $13,883.
* Property taxes
** Operating and maintenance costs
C-2
-------
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This sizable difference is caused by a disparity in marginal
tax rates for the two businesses. A business earning more than
$50,000 net annually has a 48 percent tax rate, while the small bus-
iness has a 22 percent rate. This 26 percent variation has
considerable impact.
C-4
-------
TECHNICAL REPORT DATA
(Please read Inicrucrions on the reverse before completing,1
• PE°ORTNO.
EPA-450/2-78-032
4 TITLE AND SbBT'TLE
Control Of Volatile Organ i
Stationary Sources - Volum
of Flat Wood Paneling
7. AUTHOR(S)
Roy R. Sakaida
9. PERFORMING ORGANIZATION NAME Af>
Pacific Environmental Serv
1930 14th Street
Santa Monica, California 9
12. SPONSORING AGENCY NAME AND ADC
U.S. Environmental Protect
Office of Air and Waste Ma
Office of Air Quality Plan
Research Triangle Park, No
2. |3. RECIPIENT'S ACCESSION'NO.
15. REPORT DATE
c Emissions from Existing ^une ^78
e V: Factory Surface Coating 6. PERFORMING ORGANIZATION CODE
3. PERFORMING ORGANIZATION R£?OR~ NO.
OAQPS No. 1-2. 112
4D ADDRESS 10. PROGRAM ELEMENT NO.
ices, Inc.
11. CONTRACT; GRANT NO.
0404
JRESS 13. TYPE OF REPORT AND PERIOD COVERED
ion Agency
naqement 1*- SPONSORING AGENCY CODE
nina and Standards
rthJCarolina 27711
15. SUPPLEMENTARY NOTES
16. ABSTRACT
This document provides guidance for development of regulations to limit
emissions of volatile organic compounds from the factory surface coating of flat
wood panels. This guidance includes emission limits for three categories of
panels which represents Reasonably Available Control Technology (RACT) for
these _operations. The industry is described, methods for reducing organic
emissions are reviewed, and monitoring and enforcement aspects are discussed.
17.
a. DESCRIPTORS
Air Pollution
Flat Wood Panel Finishing
Emission Limits
Regulatory Guidance
13. DISTRIBUTION STATEMENT
Unlimited
KEY WORDS AND DOCUMENT ANALYSIS
b. IDENTIFIERS/OPEN ENDED TERMS C. COSATI Field/Group
Air Pollution Control
Stationary Sources
Organic Vapors
19. SECURITY CLASS I This Report! 21. NO. OF PAGES
Unclassified 63
20. SECURITY CLASS / This page J 22. PRICE
Unclassified
EPA Form 2220-1 (9-73)
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