v>EPA
           United States
           Environmental Protection
           Agency
           Office of Air Quality
           Planning and Standards
           Research Triangle Park NC 27711
EPA-450/2-78-Cte2
OAQPSNo. 1.2-112
June 1978
           Air
OAQPS Guideline
Series

Control of Volatile
           from Existing
           Stationary Sources
           Volume  VII:  Factory
           Surface  Coating of
           Flat Wood Paneling
   FLAT WOOD
   INTERIOR PANEL
   COATING
   AP-42 Section
   4.2.2.5
   Reference Number
       1

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                                   EPA-450/2-78-032
                                  OAQPS No. 1.2-112
             Control of Volatile
             Organic Emissions
                     from
       Existing Stationary Sources -
Volume VII: Factory Surface Coating of
             Flat Wood Paneling
             Emission Standards and Engineering Division
                Chemical and Petroleum Branch
             U.S. ENVIRONMENTAL PROTECTION AGENCY
                Office of Air and Waste Management
              Office of Air Quality Planning and Standards
             Research Triangle Park, North Carolina 27711

                      June 1978

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                                OAQPS GUIDELINE SERIES
The guideline series of reports is being issued by the Office of Air Quality Planning and Standards
(OAQPS) to provide information to state and local air pollution control agencies; for example, to
provide guidance on the acquisition and  processing of air quality data and on the planning and
analysis requisite for the maintenance of air quality. 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.
                              Publication No. EPA-450/2-78-032
                                    (OAQPS No. 1.2-112)

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                                 PREFACE







     This is one in a series of reports designed to assist State and local



jurisdiction in the development of air pollution control regulations for



surface coating industries.  The series is directed entirely at volatile



organic compounds (VOC) which contribute to the formation of photochemical



oxidants.



     Volume I, "Control Methods for Surface Coating Operations," EPA-450/



2-76-028 (OAQPS No. 1,.2-067), November 1976, provides general information



on the cost and effectiveness of control technology and guidelines for



sampling and analyzing VOC emissions.



     Volume II (EPA-450/2-77-008, May 1977), provides specific information



on five surface coating industries; namely, automobile and light duty



truck, can,coil, fabric, and paper coating operations.  For each industry,



coating systems are reviewed and various VOC control alternatives are



considered with their costs and limitations.  Volume II also provides



guidance on the preparation of air pollution control regulations and test



methodology suitable for their enforcement  (Appendixes A and C of Volume  II),



Volumes III, IV, and V cover magnet wire coating,   large appliance and metal



furniture manufacture.



     It must be cautioned  that the limits provided  in the table are based on



capabilities and characteristics which are general  and therefore presumed



normal to the flat wood industries; the limits may  not be applicable to



every plant within the industry.
                                   m

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     In each case, the recommended limitation is stated in terms of the
total solvent content of all the coatings applied to a specific area of
finished paneling product.  This form is most applicable to situations
where low solvent coatings are employed.  If an operator should choose to
comply by installation of add-on control devices, it may be appropriate
for the agency to set minimal requirements on the hooding or capture and
the efficiency of the control device.
     The table that follows provides emission limitations that represent
the presumptive norm that can be achieved through the application of
reasonably available control technology (RACT).  RACT is defined as the
lowest emission limit that a particular source is capable of meeting by
the application of control technology .that is reasonably available con-
sidering technological and economic feasibility.  It may require technology
that has been applied to similar, but not necessarily identical source
categories.  It is not intended that extensive research and development
be conducted before a given control technology can be applied  to the source.
This does not, however, preclude requiring a short-term evaluation
program to permit the application of a  given technology to a particular
source.  The latter is an appropriate technology-forcing aspect of RACT.
     The recommended emission limits are stated  in terms of kg of VOC per
100 square meters of coated surface  (Ibs per 1000 square feet) to give
operators necessary flexibility in adjusting the VOC content of the various
coatings applied  to a given panel.  Practices vary such that it would
be difficult to set a VOC limit for each type of coating.  By  balancing
the VOC content and properties of the various coats, acceptable VOC

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reductions can be achieved without sacrificing product quality.

                       FACTORY FINISHED PANELING
     Product Category                         Recommended Limi tation
                                          kg of VOC per     Ibs of VOC per
                                          100 sq meters of  1,000 sq ft of
                                          coated surface    coated surface
Printed interior wall panels made             2.9                6.0
of hardwood plywood and thin particle-
board
Natural finish hardwood                       5.8               12,0
plywood panels
Class II finishes for hardboard               4,8               10.0
paneling

     For printed interior panels, emission limits are based on partial
use of water-borne and solvent-borne coatings.  Water-borne coatings that
produce products of acceptable quality are not available for all coatings,
particularly clear topcoats and printing inks.  For natural finish
paneling, the limits are based on use of solvent based coatings of lower
solvent content than conventional coatings.  The number of coats and
coverage of coatings vary but (for typical usage) the recommended limitations
are equivalent to usage of coatings which have average VOC contents of
0.20 kg/1 (1.7 Ibs/gal) for printed hardwood paneling,  0.33 kg/1 (3.2 Ibs/gal
for natural finish panelinq, and 0.32 kg/1 (2.7 Ibs/gal) for Class II
finishes for hardboard paneling.
     Interior printed wall paneling is made from tropical hardwood plywood
(and a few domestic hardwoods) and from thin particleboard.  Natural finish
hardwood plywood is made from domestic hardwoods.  Class II finishes  for
hardboard are used for printed wall paneling and panels for other interior
uses.

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     The other significant categories of factory finished flat wood products -
exterior siding,  tileboard, and particleboard used as a furniture component
are not reviewed  in this document nor are emission limitations suqgested.

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                              GLOSSARY
Printed panels means panels whose grain or natural surface is obscured
by fillers and basecoats upon which a simulated grain or decorative
pattern is printed.

Hardwood plywood is plywood whose surface layer is a veneer of hardwood.

Particleboard is a manufactured board made of individual wood particles
which have been coated with a binder and formed into flat sheets by pressure.
Thin particleboard has a thickness of one-fourth inch or less.

Natural finish hardwood plywood panels means panels whose original grain
pattern is enhanced by essentially transparent finishes frequently
supplemented by fillers and toners.

Hardboard is a panel manufactured primarily from inter-felted ligno-
ce'llulosic fibers which are consolidated under heat and pressure in a
hot-press.

Class II hardboard paneling finishes means finishes which meet the
specifications of Voluntary Product Standard PS-59-73 as approved by
the American National Standards Institute.

Lauan is an imported tropical hardwood.

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                 CONVERSION FACTORS FOR METRIC UNITS
                                                                Equivalen
Metric Unit                      Metric Name                   English^ Unit
Kg                            kilogram (103grams)               2.2046 Ib
liter                         liter                             0.0353 ft3
m                             meter                             3.28 ft
m                             cubic meter                      35,31 **

Mg                            megagram (10 grams)              2,204.6 Ib
metric ton                    metric ton (10 grams)            2,204.6 Ib

     In keepinq with U.S. Environmental Protection Agency policy, metric
units are used in this report.  These units may be converted to common
English units by using the above conversion factors.
     Temperature in degrees Celsius (C°) can be converted to temperature
in degrees F4renheit ( F) by the following formula:

         = 1.3 (t° } + 32
     t f - temperature in degrees Farenheit
     t   = temperature in degrees Celsius or degrees Centrigrade

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                        TABLE OF CONTENTS

Section                                                       Page
1.0  SOURCES AND TYPES OF EMISSIONS	1-1
     1.1  General Discussion	1-1
     1.2  Flat Wood Products and Coatings	 1-4
          1.2.1  Flat Woods and Products	1-4
          1.2.2  Flat Wood Coatings	1-5
     1.3  Flat Wood Coating Processes	1-6
          1.3.1  Coating Application Methods	1-6
          1.3.2  Process Description	 1-9
     1.4  Sources and Types of Emissions	1-15
     References for Section 1.0	1-17
2.0  APPLICABLE SYSTEMS OF EMISSION REDUCTION . 	 2-1
     2.1  Add-on Devices.	2-1
          2.1.1  Incineration	  . 2-1
          2.1.2  Adsorption ,	 2-2
     2.2  Materials Changes 	 2-2
          2.2.1  Water-borne Coatings	  . 2-2
          2.2.2  High Solids Coatings ..... 	  .2-6
     2.3  Process Changes	2-6
          2.3.1  Ultraviolet Curing	 2-6
          2.3.2  Electron Beam Curing	2-7
     2.4  Control Levels	2-7
          2.4.1  Printed Interior Wall  Paneling ....... 2-8
          2.4.2  Natural Hardwood Plywood Interior  Paneling  . 2-8
     References for Section 2.0	2-9
3.0  COSTS AND ANALYSES OF CONTROL OPTIONS	3-1
     3.1  Introduction.	3-1
          3.1.1  Purpose	3-1
          3.1.2  Scope.	3-1
          3.1,3  Use of .Model Plants.	3-1
          3.1.4  Bases for Estimates of Capital Costs  .... 3-2
          3.1.5  Bases for Annual i zed Cost  Estimates	3-3

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                  TABLE OF CONTENTS (Concluded)

Section                                                       Page
     3.2  Control of Solvent Emissions	3-4
          3.2.1  Retrofit Costs of Water-Borne Systems. ... 3-4
          3.2.2  Operation of a Water-Borne System	3-5
          3.2.3  Retrofit Costs of Ultraviolet/Water-Borne
                 Systems	  . 3-5
          3.2.4  Operation of an Ultraviolet/Water-Borne
                 System 	  ..... 3-5
          3.2.5  Net Annualized Cost.	3-7
     3.3  Cost-Effectiveness Analysis	  . 3-7
     References for Section 3.0	3-11
4.0  EFFECTS OF ACHIEVING EMISSION LEVELS REPRESENTATIVE OF
     RACT	4-1
     4.1  Water-Borne Systems 	 4-1
     4.2  Ultraviolet-Curable Coatings	 4-2
5.0  MONITORING TECHNIQUES AND ENFORCEMENT ASPECTS	5-1
     References for Section 5.0	5-3
APPENDIX A  DETERMINATION OF VOC IN COATINGS	A-l
APPENDIX B  CALCULATIONS OF EMISSION  RATES AND
            REDUCTIONS	   	B-l
APPENDIX C  EFFECT OF DEPRECIATION AND TAXES	C-l

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                      LIST OF ILLUSTRATIONS
Figure                                                       Page

1-1  Simplified Schematic of Roll  Coaters	1-7
1-2  Pressure Head Curtain Coater	1-8
1-3  Printed Interior Paneling Line (Lauan, Hardboard ,and
     Particleboard)	1-10
1-4  Natural Hardwood Plywood Interior  Paneling Line ....  1-13
3-1  Cost Effectiveness for VOC Control  at Existing Printed
     Panel  Coating Plants	3-10
                         LIST OF TABLES

Table                                                        Page

1-1  Flat Wood Plants	1-2
1-2  Flat Wood Coatings	1-16
2-1  Volatile Organics in Flat Wood Coatings	2-4
2-2  Sample Estimation of VOC Emissions for Interior Printed
     Panels	2-5
3-1  Cost Factors Used for Computing Annualized Costs. .  .   . 3-6
3-2  Net Annual ized Cost Estimates '	3-9
C-l  Computation of Present Value Tax Savings	C-3

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               1.0  SOURCES AND TYPES  OF EMISSIONS

1.1   GENERAL DISCUSSION
     Prefinished flat wood construction products included in  this
document are interior paneling made of wood materials  such as
plywood, particleboard, and hardboard.
     Plywoods are assemblies of layers of veneer or veneer in
combination with a lumber core which are joined together with an
adhesive.  Particleboards are panels manufactured from discrete
pieces or particles of lignocellulosic materials (usually wood)
with added binder.  Particleboards with different properties  are
produced by the addition of other materials and by manufacturing
process variations.  Hardboards are panels manufactured from  wood
(usually) or other vegetable fibers to which other materials  are
added to improve product properties; the panels are then consoli-
                                                               3
dated under heat and pressure to a density of at least 31 Ib/ft .
     Although plants which handle these flat woods are located
throughout the United States, the Pacific Coast and the southern
States have the largest numbers (Table 1-1).  Listings from the
1976 Directory of Panel Plants-U.S.A.1 and from several  wood  pro-
ducts associations, "  along with direct phone contacts, were
used to compile the plant numbers.  Hardwood plywood prefinishers
                           o
and converters of hardboard  are included in the plant numbers.
These numbers are intended to give an indication of the general
regional distribution of plants which handle flat woods and are
not intended to provide exact numbers of coaters or flat wood
plants.
     However, the overall differences between the numbers of plants
shown in Table 1-1 and those given in the 1972 Census of Manu-
         q
facturers  are relatively minor, except for hardwood plywood
                                 1-1

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           Table  1-1.  FLAT WOOD PLANTS'
             (Fabricates/Converts/Coats)
State
Connecticut
Maine
New Hampshire
Vermont
New Jersey
New York
Pennsylvania
Florida
Georgia
Maryland
North Carolina
South Carolina
Virginia
West Virginia
Alabama
Kentucky
Mississippi
Tennessee
Arkansas
Louisiana
Okl ahoma
Texas
Illinois
Indiana
Michigan
Ohio
Wisconsin
Iowa
Minnesota
Missouri
Arizona
Colorado
Idaho
New Mexico
Montana
California
Oregon
Washington
Hardwood
Plywood
1
2
2
4
4
4
2
7
10
0
28
16
18
1
9
5
7
14
3
4
0
6
4
9
9
2
19
0
2
2
0
0
3
0
0
24
16
10
Softwood
Plywood
0
0
1
0
0
0
0
1
6
1
5
3
3
0
6
0
6
0
n
12
i
n
i
0
i
0
0
0
0
0
0
1
5
0
7
25
98
35
Particle-
board
0
0
0
0
0
0
2
1
3
0
6
2
5
1
4
2
4
1
5
4
1
6
0
1
1
0
1
0
2
0
1
0
1
1
1
<9
14
1
Hard-
board
0
0
0
0
4
1
1
2
4
0
4
2
3
0
0
0
3
2
2
2
1
3
1
1
1
0
3
0
2
1
0
0
1
0
1
7
12
3
Source:  References 2-8 and direct contacts.
                               1-2

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plants, for which the census data show significantly larger
numbers in Indiana and North Carolina and smaller numbers  in  the
Pacific States.
     Statistical  information concerning the flat woods  industry
as a whole can be obtained under the following Standard Industrial
Classifications  (SIC):
     2431  - Mi 11 work, doors, moulding
            24314 - Wood doors
     2435 - Hardwood veneer and plywood
     2436 - Softwood veneer and plywood
     2492 - Particleboard
     2499 - Wood, not elsewhere classified
            24996 - Hardboard
     No more than one quarter of the flat wood manufacturers
discussed herein are estimated to coat in their plants.  In some
of the plants that do coat, only a small percentage of the total
production capacity is coated.  In addition to manufacturing
plants, there are intermediate plants, which obtain unfinished
products and prefinish or finish them according to their customers'
specifications or product requirements.
     Based on membership information from the several wood product
associations (which are not all inclusive), approximately 40
percent of the hardwood plywood handling plants coat,  '  10 per-
cent of the softwood  plywood plants coat,  and under 15 percent
of the particleboard  plants coat.  The American Board Products
Association estimates that 70 percent or more of the hardboard
manufactured is factory coated in some fashion.
     It appears that  there will be an increase in the factory
surface coating of flat wood products due to the increased use
of prefinished wood  in the building  trade (including recreational
                                1-3

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 vehicles)  for  paneling,  flooring, cabinetry, moulding, and exterior
 siding  (only paneling  is covered  in this report).  Reasons given
 for  this  increase  are:
     • Cost savings
     • Uniform  and  better quality  finish
     • Longer life  finish
     Control of emissions of  volatile organic solvents from the
 factory coating of flat  wood products  by add-on  devices  is not
 being practiced to any great extent.   Many coaters are using
 solvents  which were previously  assumed to be of  low  photochemical
                                                 *
 reactivity and were therefore considered exempt.   Others have
 been converting to water-borne  coatings where  possible.  Coatings
 manufacturers  and  certain  wood  coaters are continuing efforts to
 develop useful  water-borne coatings with reduced quantities of
 volatile  organics.

 1.2   FLAT WOOD PRODUCTS  AND  COATINGS
 1.2.1  FLAT WOODS  AND PRODUCTS
     Flat  woods discussed herein include  products from hardwood
 plywood,  particleboard (products  not used  in cabinetry and
 furniture), and hardboard.  Product categories considered are:
     • Printed  interior paneling
     • Natural  hardwood plywood  interior  panels
     Printed interior panel ings  are  produced  from plywoods with
 hardwood  surfaces  (primarily lauan) and  from various wood com-
position  panels, including hardboard and  particleboard.   Finishing
 techniques are used primarily to  cover the original  surfaces;
 * The only VOC recommended as exempt are:  methane,  ethane,  1,1,1-
   trichloroethane (methyl  chloroform), and trichlorotrifluoro-
   ethane (Freon 113).10
                                 1-4

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they also function to produce various decorative surfaces,  which
include wood patterns, simulations of other natural  materials,
and original decorative effects.
     Natural hardwood plywood interior panels are prefinished to
enhance and protect their natural  appearance.  Almost all  the
finishes applied are essentially clear.   Possible exceptions
include coatings for the grooves that may be cut into the panel
and  stains  or toners used to complement the natural wood grain.

1.2.2  FLAT WOOD COATINGS
     All coatings which can be applied to a flat wood substrate
can be factory applied.  These include but are not limited to
filler, sealer, groove coat, primer, stain, basecoat, inks, and
topcoat.  Fillers are used to fill pores, voids, and cracks in
the wood to provide a smooth surface; they can also accentuate
the grain of natural hardwood veneers.  Sealers seal off sub-
stances in the wood which may affect subsequent finishes as well
as protect the wood from moisture.  Groove coats cover grooves
cut into the panel to assure that the grooves are compatible with
the final surface color.  Primers are used to protect the wood
from moisture and to provide a good surface for further coating
applications.  Stains are nonprotective, coloring the wood sur-
face without obscuring the grain.  Basecoats are the primary
coating/coloring of panels and normally should completely hide
substrate characteristics.  Inks are used to put a decorative
design on printed panels; they can also produce special appear-
ances on natural hardwood plywoods.  Topcoats provide protection,
durability, and the required sheen or gloss to the product.
     Each type of substrate coated and product category handled
usually requires a different coating formulation for each
                                1-5

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appropriate coating application.  Moreover, not all  factory
wood products with the same substrate and prefinished for the
same end use have the same series of coatings applied.

1.3  FLAT WOOD COATING PROCESSES
1.3.1  COATING APPLICATION METHODS
     Different forms of roll  coating are the favored procedures
for applying coatings to flat woods.  Roll  coating is a process
in which coating is applied to the wood by cylindrical  rollers
(Figure 1-1).  If the applicator rotates in the same direction
as the panel movement, the coater is called a direct roll coater.
Most coatings (primer, sealer, basecoat, topcoat, and other
coatings used for surface coverage) can be applied with a direct
roll coater.  When the applicator roll is followed by a wiper
roll that rotates against the direction of the panel movement,
the process is called reverse roll coating.  Reverse^ roV[ coaters
are generally used to apply filler, which is forced into the
voids and cracks in the panels by the reverse roller.  Precision
coating and printing are also forms of roll coating.  The appli-
cator roll shown in Figure 1-1 is used to place the ink or coating
onto a second roll (engraved for printing) on which the coating
thickness is monitored; the coating is then passed to a final
roller which coats the wood.
     Several types of curtain coaters are also used.  In this
method, the panel passes through a free-falling film of coating.
In a pressure head curtain coater (Figure 1-2), coating material
is metered into a pressure head, then forced through a calibrated
slit between two knives.  The rate of panel movement and the
controlled uniform flow of the film determines the coating thick-
ness.  The physical properties of the material, temperature, slit
width, coating flow rate, and panel speed are important variables.
                                1-6

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               COATING
      APPLICATOR
                                       PANEL
               A.  DIRECT ROLL COATER
                    APPLICATOR
           COATING—I
DOCTOR BLADE
                                         EVERSE ROLLER

                                           PANEL
               B.  REVERSE ROLL COATER
              (ARROWS SHOW DIRECTION OF
              ROLLER AND PANEL MOVEMENT)
Figure 1-1.   Simplified Schematic of Roll  Coaters
                      1-7

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   COATER  HEAD
PRODUCT
                          COATING
                          TROUGH
                        1
                           COATING
                          RESERVOIR
                                          PUMP
Figure 1-2.   Pressure Head Curtain  Coater
                1-f

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 All  excess  coating  is caught  in a  trough and recirculated.
 Additional  coating  methods  include various spraying techniques
 and  brush coating.

 1 .3.2   PROCESS  DESCRIPTION
     The flow diagrams  that accompany  the following process
 descriptions are  general, showing  some  but not all typical
 production  line variations.   Product categories  included are
 printed interior  paneling and natural  hardwood plywood  interior
 paneling.

 1.3.2.1 Printed  Interior Paneling (Lauan, Hardboard, and
         Particleboard)
     Printed interior paneling products are the  result  of
 applying a  decorative finish  to the surface of lauan, hardboard,
 or particleboard.   Substrates are  often presanded  by  the flat
 wood manufacturer prior to  delivery to  the intermediate coating
 plant  or in-house coating line.  The basic series  of  coatings
 applied consists  of filler, basecoat,  inks, and  topcoat
 (Figure 1-3).
     The first  step in  finishing hardboard consists of  tempering
 the board with  a  mixture of oil and resin to give  it  added
 strength and stability.   This is followed by brush dusting  to
 remove any  foreign matter from the surface of the  board.   For
 particleboard,  on the other hand,  the  first step in the finishing
 process is  sanding (refer to  Figure 1-3).
     Groove cutting is  usually done prior to filling.   Groove  -
•color  can  be applied in different  ways  and at different points
 in the coating  procedure; in  Figure 1-3,  it is shown  preceding
 the application of filler.  Groove coats are usually  pigmented,
 low resin  solids  that are reduced  with  water prior to use.
                                 1-9

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1-10

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     Filler is normally applied by reverse roll  coating.   Fillers
must dry fast, be easily sanded, seal  the board  (especially if
no separate sealer is applied), and not shrink with age.   Several
different fillers, each with various advantages  and disadvantages,
are available:  (1) polyester filler,  which is ultraviolet-cured,
(2) water-based filler, (3) lacquer-based filler, (4)  polyurethane
filler, and (5) alkyd urea-based filler.  Water-based fillers are
in common use on printed paneling lines.  Filler is of course
not applied to prefilled particleboard and to boards that can
successfully remain nonfilled.  It can be applied more than once
to assure complete coverage of particularly porous substrates,
and is followed by application of a separate sealing compound
when necessary.  The sealer may be water- or solvent-based, and
is usually applied by airless spray or direct roll coating,
respectively.  Both filling and sealing operations are followed
by ovens (steam heated, convection, infrared, or ultraviolet,
as applicable) and by sanders.  In hardboard finishing, the next
step may consist of a spray booth where specialty coatings for
textured board are applied.
     For printed paneling, the purpose of the basecoat is to
provide a smooth surface of the appropriate color on which to
print the wood grain or other pattern.   Basecoats must therefore
be fast drying and provide good coverage.  Those used in printed
paneling usually fall into the following categories:  lacquer,
synthetic, vinyl, modified alkyd urea, catalyzed vinyl, and
water-based (which are now used at some lauan finishing plants).
Basecoats are usually applied by direct roll coaters.
     Inks are applied by an offset gravure printing^operajnon
sirnijar_tpLJ>irec_t_roll_cjQajtirLg-.  Several colors may be applied
in order to reproduce the appearance of wood, marble, leather,
textured cloth, and so on.  The final  effect depends on surface
                                 1-11

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smoothness,  color of the basecoat and inks,  strength  and  transfer
properties of the inks,  and other variables.   Most lauan  printing
inks are pigments dispersed in  alkyd resin,  with  some nitrocel-
lulose added for better  wipe and profitability.  Water-based  inks
have a good future for clarity, cost and ecological  reasons.
     After printing, the board  goes through  one or two direct
roll coaters for application of the clear,  protective topcoat.
These are wet-on-wet applications, usually  employing  three-roll
precision roll  coaters.   Some topcoats are  now synthetic,
prepared from solvent soluble alkyd or polyester  resins,  urea
formaldehyde cross linkings, resins, and solvents.  Such  synthetic
topcoats are catalyzed and sent through a hot air oven for curing;
other topcoats are cured in infrared or ultraviolet ovens.  The
panels are cooled prior to stacking, inspection,  and  shipping.

1.3.2.2  Natural Hardwood Plywood Interior  Paneling
     Hardwood plywood has a face ply of hardwood  veneer.   The
woods used are classified as porous or open  grain species and
nonporous or smooth species.  Natural hardwood plywood panels
use transparent or clear finishes that enhance the real wood
surface, which is usually modified in color and appearance by
stains, toners, fillers, sealers, glazes, and topcoats.  Satis-
factory finishes require a number of operations,  which are shown
in flow chart form in Figure 1-4.
     The first step in finishing a hardwood panel is to fill  the
open knots with a putty material.  The second step is to  cut a
groove and paint it with an opaque finish.   The panel is  then
sanded prior to application of a stain, which gives the surface
a uniform color without raising the grain of the wood fiber.
The.stain is normally applied by a direct roll coater with a
grooved or wire-wrapped doctor roll to increase the application
                                1-12

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amount of this thin coating,  which is then dried in a  high
velocity or infrared oven.
     A thin wash coat, known  as a "toner"  if it is colored with
dyes or transparent pigments, is then direct roll  coated over
the stain.  The toner seals the stain, improves the clarity and
lightness of the finish, and  performs various other preparatory
functions.
     Next, the plywood is filled, usually  by a reverse roll  coater
followed by a series of pads  or brushes to glaze the surface of
the wood.  The sealed, filled panels are then dried and polished
in a brush unit.
     The primer sealer is the next coating applied, normally by
direct roll coating.  The sealer floods the complete panel,
including the grooves, in order to protect the wood from moisture,
provide a smooth base for the topcoat, and give gloss  to the
grooves.  Following application, the sealer is dried,  sanded,
and buffed.
     At this point, the surface of the pane] is embossed and
valley printed to give a distressed or antique_appjeanance.  One
or more print steps may then  be used to upgrade the veneer
surface or provide special  effects.  This  glaze is then dried and
a sealer applied with a direct roll coater to smooth the surface
in preparation for topcoating.
     One or more topcoats are used to provide durability, pro-
tection, and gloss.  Direct roll coating is the usual  application
method, but curtain coating may also be employed.   The set topcoat
is cured at 200 to 230°F (93  to 110°C).  The panels are then
cooled, buffed, and stacked for shipment.
                                1-14

-------
1.4  SOURCES AND TYPES OF EMISSIONS
     Emissions of volatile organic solvents at flat wood coating
plants occur primarily at the coating lines.   Solvents used in
organic-based coatings are normally multicomponent mixtures
that may include methyl  ethyl ketone, methyl  isobutyl  ketone,
toluene, xylene, butyl acetates, propanol,  ethanol, butanol,
VM&P naptha, methanol, amyl acetate, mineral  spirits,  SoCal I
and II, glycols, and glycol ethers.  Organic solvents  most often
used in water-borne coatings are glycol, glycol-ethers such as
butyl cellosolve, propanol, and butanol.  Ranges of nonvolatile
materials and volatile organics present in  the different types
of conventional and water-borne coatings supplied to the flat
wood coating industry are shown in Table 1-2.  Information from
PPG Industries and Reliance Universal indicates that there are
no volatile organic compounds (VOC) in the newer water-borne
fillers.  Vaporization of organics at coaters and paint mixing
and storage areas occurs at ambient temperature and pressure.
Emissions from ovens are at ambient pressure and at temperatures
determined by the substrate and the coatings used.
     The primary fuel  used in flat wood coating is natural gas;
liquified petroleum gas is the primary backup fuel during curtail-
ments of natural gas supplies or where natural gas is  not available.
Some coating plants employ infrared and/or ultraviolet cure ovens,
which are electrically heated.  This type of oven can  normally
eliminate onsite combustion emissions, such as carbon monoxide,
unburned fuel, and nitrogen oxides.
                                1-15

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-------
 References  for  Section  1,0
 1.   "Directory  of  Panel  Plants-U.S.A.,"  Forest  Industries, March
     1976,  pp. 122-125

 2.   National  Particleboard  Association,  Directory  of  Particleboard
     and  Medium  Density  Fiberboard  Manufacturers, Silver  Spring,
     Md.,  December  1975

 3.   American  Plywood Association,  "Plywood  Paneling and  Siding
     Manufacturers," Tacoma, Wash., no  date

 4.   Acoustical  and Board Products  Association,  "Insulation Board
     and  Hardboard  Plants in the  United States," Park  Ridge,  111.,
     March 1976

 5.   Hardwood  Plywood Manufacturers Association, Where to Buy
     Hardwood  Plywood and Veneer, Arlington,  Va., August  1976

 6.   Wood and  Wood  Products/Reference  Data  Buying Guide,  March  1977,
     pp.  9 and 10

 7.   Hardwood  Plywood Manufacturers Association, Directory of Hard-
     wood Plywood Prefinish  Industry,  Arlington, Va.,  May 1977

 8.   American  Board Products Association, "Latest ABPA Listings  of
     Hardboard Panel  Converters,"  Park Ridge, 111., April 1978

 9.   1972 Census of Manufacturers,  United States Bureau of Census,
     Vol.  II,  Industry  Statistics,  Part I.  SIC 20-26,  2431, 2435,
     2436, 2492, 24996

10.   U.S.  Environmental  Protection  Agency,  "Recommended Policy  on
     Control  of  Volatile Organic  Compounds," Federal  Register,
     Vol.  42,  No. 131,  3T314-3T316, July  1977
                                1-17

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         2.0  APPLICABLE SYSTEMS OF EMISSION REDUCTION

    Potential  emission reduction systems are categorized as add-on
devices, materials changes, and process changes.   Add-on devices
include incineration and adsorption systems, coupled with their
attendant systems to capture the volatile organic compounds (VOC)
being released at the affected facilities.   Materials change
refers to modifying a coating formulation so that the quantity
of organic solvents per unit of solids is substantially reduced.
Process modifications may be required, but are not the primary
consideration  involved in the change.   Process changes include
ultraviolet (UV) and electron beam (EB) systems,  for which the
physics of curing requires that specialized coating materials
be used.  Coating materials have been  developed to take advantage
of these curing processes.

2.1  ADD-ON DEVICES

2.1.1  INCINERATION

    Afterburners have been used successfully for many operations
with emissions similar to those from flat wood coating.  The
minimum control efficiency of an afterburner should be in excess
of 90 percent of the vapors captured.   Nineteen test reports of
direct flame afterburners showed an average reduction efficiency
of 95-percent across the afterburner,  and eight tests of catalytic
                                            1 2
afterburners averaged 89-percent efficiency.     Overall plant
control would be less because not all  organic emissions are
captured.  Refer to Volume I, Section 3.2.2 for further discussion
of incinerators.3
    Of the more than 150 flat wood handling plants contacted,
only two, both in southern California, have afterburners as add-
on controls.  Representatives of two equipment manufacturers who
                                2-1

-------
 were  contacted  had  no  knowledge of afterburners  being  installed as
                                               4  5
 add-ons  at other  flat  wood coating operations.  '   Nevertheless, the
 use of afterburners  is a viable option for  reducing VOC emissions
 where other  control  techniques are not applicable due  to product
 requirements.

 2.1.2 ADSORPTION
    No adsorption system was  found to be  used  in the flat wood  indus-
 try.  Multicomponent solvents and the use of different coating  formu-
 lations  for  the several steps along  the coating  line are not  conducive
 to the general  use  of  adsorption to  control flat wood  coating emis-
 sions.   Specific  applications may be found, however, e.g.,  in redwood
 surface  treatment,  where over 90 percent  of the  coating is  volatile
 and can  be recycled.   In this treatment,  a  solution of pentachloro-
 phenol in mineral spirits  is  applied to redwood  or cedar sidings for
 protection against  mildew  and water  staining.  This volatile  solvent
 is recoverable  and  reusable with minimal  processing.   Further details
                                                          3
 on carbon adsorption are given in Volume  I, Section 3.2.1.

 2.2   MATERIALS  CHANGES

 2.2.1 WATER-BORNE  COATINGS
    The  use  of  water-borne coatings  is continually increasing in
 the surface  coating of flat woods, primarily for the reduction  of
 VOC emissions.  This material change can  also  result in reduced
 fire  hazard, some reduction in fire  insurance, improved working
 conditions,  and reduced air pollution.
    Paint manufacturers have  developed and  are continuing to
 develop  water-borne coating formulations  to replace conventional
.organic  solvent-borne  coatings for many factory  flat wood appli-
 cations.   In water-borne coatings, the organic content of the
 volatile portion  of the coating  is normally 20 volume  percent
                                  2-2

-------
or less.  Typically, the use of an applicable water-borne coating
in place of a conventional organic solvent-borne coating can
reduce volatile organic emissions by at least 70 percent.
     Values of volatile organics in water-borne and conventional
coatings for factory application to flat woods are given in Table
2-1.  From the range of VOC values provided by various paint manu-
facturers for their water-borne coatings, a fixed value was esti-
mated for each paint category.  The paint manufacturers contacted
indicated that coatings with these estimated VOC contents are avail-
able, but not all paint manufacturers supply all of the listed
coatings.  Table 2-2 presents estimated VOC emissions for coating
printed panels for interior use, assuming that the coatings listed
in Table 2-1 are employed.  For this example, complete conversion
to available water-borne coatings would reduce VOC emissions by
84 percent.
     Printed paneling for interior walls can be made of hardboard,
particleboard and other composition boards, and lauan-faced ply-
woods.  Also, the coating lines can differ substantially even when
the same substrate is used.  Thus, many lines can either apply  fewer
coatings or additional print inks and groove coats.
     Thejnajoruse gfjjjater^borne^ flat wood coatings j[s_j ri_t:Jie  f i 1 -
ler and basecoat ap£]J^djyL4ir.linJ^                     Limited use
has been made of water-borne materials for inks, groove coats,  and
topcoats for printed paneling, and for inks and groove coats for
natural hardwood panels.
     Problems with water-borne coatings include grain raising,  wood
swelling, poor finish quality, difficulties in curing topcoats, and
possible care required to prevent freezing.  Volume  I, Section  3.3.1
may be  consulted for additional information concerning water-borne
coatings.
                                  2-3

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 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

-------
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

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               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

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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

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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

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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

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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

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                                                                   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.

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     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

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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

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     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

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          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

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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

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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

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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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