United States Office of Air Quality EPA-450 3-80 007a
Environmental Protection Planning and Standards September 1980
Agency Research Triangle Park NC 27711 „ ~
Air
Surface Coating of Draft
Metal Furniture - EIS
Background Information
for Proposed Standards
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EPA-450/3-80-007a
Surface Coating of Metal Furniture
Background Information for
Proposed Standards
Emission Standards and Engineering Division
U S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air, Noise, and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
U.S. Environmental Protection Agency
Region 5, Library (PL-12J)
77 West Jackson Boulevard, 12th Floor
Chicago, II 60604-3590
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This report has been reviewed by the Emission Standards and Engineering Division
of the Office of Air Quality Planning and Standards, EPA, and approved for publication
Mention of trade names or commercial products is not intended to constitute endorsement
or recommendation for use. Copies of this report are available through the Library
Services Office (MD-35), U.S. Environmental Protection Agency, Research Triangle
Park, N.C. 27711, or from National Technical Information Services, 5285 Port Roval
Road, Springfield, Virginia 22161.
Publication No. EPA-450/3-80-007a
U.S. Environmental Protection Agency
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ENVIRONMENTAL PROTECTION AGENCY
Background Information
and Draft
Environmental Impact Statement
for Surface Coating of Metal Furniture
Prepared by:
Don R. Goodwin (Date)
Director, Emission Standards and Engineering Division
U. S. Environmental Protection Agency
Research Triangle Park, NC 27711
1. The proposed standards of performance would limit emissions of
volatile organic compounds from new, modified, and reconstructed
facilities for surface coating of metal furniture. Section 111
of the Clean Air Act (42 U.S.C. 7411), as amended, directs the
Administrator to establish standards of performance for any
category of new stationary source of air pollution which ". . .
causes or contributes significantly to air pollution which may
reasonably be anticipated to endanger public health or welfare."
The proposed standards of performance are expected to affect all
regions of the nation.
2. Copies of this document have been sent to the following Federal
Departments: Labor; Health and Human Services; Defense;
Transportation; Agriculture; Commerce; Interior; and Energy; the
National Science Foundation; and Council on Environmental Quality;
to members of the State and Territorial Air Pollution Program
Administrators (STAPPA) and the Association of Local Air Pollution
Control Officials (ALAPCO); to EPA Regional Administrators; and to
other interested parties.
3. The comment period for review of this document is 60 days and is
expected to begin on or about September 22, 1980.
4. For additional information contact:
Gene W. Smith
Standards Development Branch (MD-13)
U. S. Environmental Protection Agency
Research Triangle Park, NC 27711
telephone: (919) 541-5421.
5. Copies of this document may be obtained from:
U. S. EPA Library (MD-35)
Research Triangle Park, NC 27711
National Technical Information Service
5285 Port Royal Road
Springfield, VA 22161
m
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TABLE OF CONTENTS
Section Page
1.0 Introduction 1-1
1.1 Background and Authority for Standards 1-1
1.2 Selection of Categories of Stationary Sources 1-4
1.3 Procedure for Development of Standards of Performance . . 1-6
1.4 Consideration of Costs 1-8
1.5 Consideration of Environmental Impacts 1-9
1.6 Impact on Existing Sources 1-10
1.7 Revision of Standards of Performance 1-11
1.8 Executive Summary of Regulatory Alternative Impacts . . .1-11
1.9 Environmental Impact 1-12
1.10 Economic Impact 1-12
2.0 The Metal Furniture Industry 2-1
2.1 General Description 2-1
2.2 Processes or Facilities and Their Emissions 2-2
2.2.1 The Basic Process 2-2
2.3 Baseline Emissions 2-11
References for Chapter 2 2-13
3.0 Emission Control Techniques 3-1
3.1 Emission Control Through Coating Formulation Changes. . . 3-2
IV
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Section ^S6-
3.1.1 Powder Coatings 3-2
3.1.2 High Solids Coatings 3-23
3.1.3 Waterborne Coatings 3-35
3.2 Emissions Control with Add-on Control Equipment 3-44
3.2.1 Carbon Adsorption 3-44
3.2.2 Incineration 3-51
3.2.3 Condensation 3-68
3.2.4 Other Add-on Control Equipment and Process
Modification 3-74
3.3 Control Efficiencies for Coating Formulation Changes. . . 3-74
3.3.1 Powder Coatings 3-77
3.3.2 High Solids Coatings 3-77
3.3.3 Waterborne Coatings 3-80
3.4 Control Efficiencies for Add-on Control Equipment .... 3-82
3.4.1 Carbon Adsorption 3-82
3.4.2 Incineration 3-82
3.4.3 Condensers 3-86
References for Chapter 3 3-87
4.0 Modification and Reconstruction 4-1
4.1 40 CFR 60 Provisions for Modification and Reconstruction. 4-1
4.1.1 Definition of Modification 4-1
4.1.2 Definition of Reconstruction 4-2
4.2 Applicability to Surface Coating of Metal Furniture . . . 4-2
4.2.1 Modification Examples 4-3
4.2.2 Examples of Reconstruction 4-6
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Section Pa9e
5.0 Model Plants and Regulatory Alternatives 5-1
5.1 Model Plants 5-1
5.1.1 Spray Coating 5-1
5.1.2 Dip Coating 5-2
5.1.3 Flow Coating 5-14
5.2 Regulatory Alternatives 5-14
5.2.1 Add-on Control Equipment 5-21
5.2.2 Coating Formulation Change 5-33
References for Chapter 5 5-41
6.0 Environmental Impact 6-1
6.1 Air Pollution Impact • 6-1
6.2 Water Pollution Impact 6-7
6.3 Solid Waste Impact 6-12
6.4 Energy Impact- 6-15
6.5 Other Environmental Impacts 6-19
6.6 Other Environmental Concerns 6-19
6.6.1 Irreversible and Irretrievable Commitment of
Resources 6-19
6.6.2 Environmental Impact of Delayed Standards 6-20
References for Chapter 6 6-21
7.0 Economic Impact 7-1
7.1 Industry Profile 7-1
7.1.1 Industry Structure 7-1
7.1.2 Trends in Industry 7-8
7.1.3 Industry Operating Statistics 7-28
VI
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Section
7.1.4 Imports and Exports 7-31
7.1.5 Projections of Affected Facilities 7-31
7.2 Metal Furniture Analysis 7-35
7.2.1 New Facilities 7-35
7.2.2 Modified or Reconstructed Facilities 7-53
7.3 Other Cost Considerations 7-74
7.3.1 Water Treatment 7-74
7.3.2 Solid Waste Disposal 7-74
7.3.3 OSHA Requirements 7-75
7.3.4 Regulatory Agency Manpower Requirements. . . . 7-75
7.4 Economic Impact Assessment 7-75
7.4.1 Introduction and Summary 7-75
7.4.2 Industry Expansion 7-84
7.4.3 Methodology 7-89
7.4.4 Plant-Level Impact Analysis 7-91
7.4.5 Industry Compliance Costs 7-130
7.5 Aggregate Economic Impact Assessment 7-138
7.5.1 Industry Structure and Concentration Effects . 7-139
7.5.2 Employment Effects 7-139
7.5.3 Balance of Trade Effects 7-140
7.5.4 Inflationary Impact 7-140
7.5.5 Energy Impact 7-140
7.5.6 Industry-wide Compliance Costs 7-141
References for Chapter 7 7-149
Vll
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Appendix A ' A-l
Appendix B B~l
Appendix C C-1
Appendix D D-!
Appendix E E-l
vm
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LIST OF FIGURES
Figure f^S6-
2-1 Flow diagram - electrostatic spray coating operation ... 2-7
2-2 Flow diagram - dip coating operations 2-9
2-3 Flow diagram - flow coating operations 2-10
3-1 Electrostatic gun 3-12
3-2 Powder spray booth equipped with powder recovery system. . 3-14
3-3 Flow diagram for a powder coating line 3-18
3-4 Part coating in a fluidized bed of powder 3-20
3-5 Schematic of high solids coating spray equipment 3-29
3-6 Static mixers 3-31
3-7 Typical EDP coating system 3-42
3-8 Carbon adsorption process 3-47
3-9 Incinerator with a distributed burner 3-54
3-10 Incinerator employing mixing plates 3-55
3-11 Incinerator using a discrete burner 3-56
3-12 Bake oven equipped with incinerator and heat recovery. . . 3-59
3-13 Inert gas drying system 3-61
3-14 Schematic of a catalytic afterburner system 3-65
3-15 Bake oven equipped with N2 condenser 3-71
3-16 Effects of temperature and time 3-84
3-17 Typical temperature - performance curve for various
molecular species being oxidized over Pt/A!2Q3 catalyst. . 3-85
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Figure
— Page
5-1 Example automated spray coating lines with manual
touch-up for flat metal furniture surfaces (Models
A and C) .- _
b-3
5-2 Example automated spray coating lines with manual
touch-up for complex metal furniture surfaces
(Models B and D) 5_4
5-3 Example small metal furniture manual spray coatinq
nnes (Models E and F) 5-5
5-4 Example metal furniture dip coating lines for medium
and large plants (Models G and H) . . . . 5_12
5-5 Example small metal furniture dip coating line (Model I) . 5-13
5-6 Example metal furniture flow coating line (Model J) 5-13
5-7 VOC control by incineration 5_34
7-1 Irfn?Sr-1n numbers of establishments and employees in the
Metal Furniture Household Furniture Industry (SIC 2514) . 7-18
7"2 MT?SniJ-nUmrers of establishments and employees in the
Metal Office Furniture Industry (SIC 2522) 7_i8
7-3 Trends in numbers of establishments and employees in the
Public Building and Related Furniture Industry (SIC 2531). 7-19
7-4 Trends in numbers of establishments and employees in the
Metal Partitions and Fixtures Industry (SIC 2542) .... 7-19
7-5 Trends in the value of shipments for the Metal Household
Furniture Industry (SIC 2514) in current and constant
dollars 7-22
7-6 Trends in the value of shipments for the Metal Office
Furniture Industry (SIC 2522) in current and constant
dollars 7-22
7-7 Trends in the value of shipments for the Public Building
and Related Furniture Industry (SIC 2531) in current and
constant dollars 7_23
7-8 Trends in the value of shipments for the Metal Partitions
and Fixtures Industry (SIC 2542) in current and constant
dollars 7-23
7-9 Percent changes from previous year in real gross national
product and constant Metal Household Furniture Industry
shipments (SIC 2514) . 7_26
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Figure Pa9e
7-10 Percent changes from previous year in real gross
national product and constant Metal Office Furniture
Industry shipments (SIC 2522) 7-26
7-11 Percent changes from previous year in real gross
national product and constant Public Building and
Related Furniture Industry shipments 7-27
7-12 Percent changes from previous year in real gross
national product and constant Metal Partitions
and Fixtures Industry shipments (SIC 2542) 7-27
7-13 Spray coating cost effectiveness 7-51
7-14 Dip and flow coating cost effectiveness 7-52
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LIST OF TABLES
Table Page
1-1 Matrix of Environmental and Economic Impacts of the
Proposed Surface Coating of Metal Furniture Emission
Limits 1-13
2-1 Distribution of Establishments by Employment Size 2-3
2-2 Distribution of Establishments by Paint Consumption. . . . 2-4
3-1 Metal Furniture Products Being Powder Coated 3-3
3-2 Other Metal Products Being Powder Coated 3-5
3-3 Powder Coating Resin Groups 3-7
3-4 Advantages of Powder Coating When Compared to Organic
Solvent-Based Coatings 3-8
3-5 Disadvantages of Powder Coatings When Compared to
Organic Solvent-Based Coatings 3-9
3-6 Overall Weight Percent of Powder Utilized 3-16
3-7 Process Operating Parameters for Powder Coating Lines
Using Electrostatic Spray 3-16
3-8 Process Operating Parameters for Powder Coating Lines
Using Fluidized Bed 3-22
3-9 Metal Furniture Products Being Coated With High Solids . . 3-24
3-10 Advantages for High Solids Coatings When Compared to
Organic Solvent-Based Coatings 3-26
3-11 Disadvantages for High Solids Coatings When Compared
to Organic Solvent-Based Coatings 3-27
3-12 Process Operating Parameters for High Solids Coating
Lines 3-33
xn
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Page
Table — *-
3-13 Properties of Waterborne Coatings ............ 3~36
3-14 Solids and Solvent Content of Waterborne Paints ..... 3-37
3-15 Advantages of Waterborne Coating ............. 3-39
3-16 Disadvantages of Waterborne Coating ........... 3-39
3-17 Advantages of Employing Carbon Adsorbers ......... 3-49
3-18 Disadvantages of Employing Carbon Adsorbers ....... 3-49
3-19 Percent of Total VOC Emissions from Various Coating
Steps .......................... 3-50
3-20 Problem Solvents for Carbon Adsorption .......... 3-50
3-21 Process Operating Parameters for Carbon Adsorbers
Employed to Control VOC Emissions ............ 3~b^
3-22 Heat Recovery Equipment and Thermal Energy Recovery . . . 3-58
3-23 Advantages of Employing Thermal Incineration as a
Control Technique .................... 3~b^
3-24 Disadvantages of Employing Thermal Incineration as a
Control Technique
3-25 Process .Operating Parameters for a Thermal Incinerator. . 3-64
3-26 Advantages of Employing Catalytic Incineration as a
Control Technique .................... 3~67
3-27 Disadvantages of Employing Catalytic Incineration as
a Control Technique ................... 3~°'
3-28 Process Operating Parameters for a Catalytic Incinerator. 3-69
3-29 Advantage of Employing Condensation as a Control
Technique ........................ 3~72
3-30 Disadvantages of Employing Condensation as a Control
Technique ........................ 3~72
3-31 Process Operating Parameters for a Shell Tube Condenser . 3-73
3-32 Emission Reduction Via Powder Coatings .......... 3-78
3-33 Control Efficiencies for High Solids Coatings ...... 3-79
xm
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Tab1e Page
3-34 Control Efficiencies for Water-Based Coatings 3-81
3-35 Control Efficiencies for Add-On Air Pollution
Control Equipment .... 3-83
4-1 Potential Modification Examples 4-4
5-1 Model Plant A 5-6
5-2 Model Plant B 5-7
5-3 Model Plant C 5-8
5-4 Model Plant D 5-9
5-5 Model Plant E 5-10
5-6 Model Plant F 5-11
5-7 Model Plant G 5-15
5-8 Model Plant H 5-16
5-9 Model Plant I 5-17
5-10 Model Plant J 5-19
5-11 Regulatory Alternative Summary for Each Model Plant . . . 5-22
5-12 Emission Reduction for Model Plant A - Large Spray
Coating Facility for Flat Metal Furniture Surfaces. . . . 5-23
5-13 Emission Reduction for Model Plant B - Large Spray
Coating Facility for Complex Metal Furniture Surfaces . . 5-24
5-14 Emission Reduction for Model Plant C - Medium Size
Spray Coating Facility for Flat Metal Furniture
Surfaces 5-25
5-15 Emissions Reduction for Model Plant D - Medium Size
Spray Coating Facility for Complex Metal Furniture
Surfaces 5-26
5-16 Emission Reduction for Model Plant E - Small Spray
Coating Facility for Flat Metal Furniture Surfaces. . . . 5-27
5-17 Emission Reduction for Model Plant F - Small Spray
Coating Facility for Complex Metal Furniture Surfaces . . 5-28
5-18 Emission Reduction for Model Plant G - Large Dip
Coating Facility for Metal Furniture 5-29
xiv
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Table
5-19 Emission Reduction for Model Plant H - Medium Size
Dip Coating Facility for Metal Furniture
5-20 Emission Reduction for Model Plant I - Small Dip
Coating Facility for Metal Furniture
5-21 Emission Reduction for Model Plant J - Small Flow
Coating Facility for Metal Furniture
5-22 Process Parameters for Model Plants Applying
Powder Coatings ......................
5-23 Process Parameters for Model Plants Applying
High Solids Coatings ...................
5-24 Process Parameters for Model Plants Applying
Waterborne Coatings ....................
6-1 Emission Estimates for Spray Coating Employing
Regulatory Alternatives .................. b"^
6-2 Emission Estimates for Dip Coating Employing
Regulatory Alternatives .................. b~J
6-3 Emission Estimates for Flow Coating Employing
Regulatory Alternatives .................. b'4
6-4 Quality of Water Discharge ................ 6"8
6-5 Qualitative Analysis for Water Usage at Model Plant A. . . 6-10
6-6 Qualitative Analysis for Pollutant Discharge Rates in
Water Effluents Versus Coating Formulation Changes .... 6-11
6-7 Solid Waste Estimates for Model Plants .......... 6-13
6-8 Energy Consumption Estimates for Model Plants ....... 6-16
6-9 Qualitative Analysis of Energy Consumption on a Coating
Line ........................... 6~17
6-10 Projections of Energy Consumption for Each Regulatory
Alternative ........................ 6"18
7-1 Metal Furniture Manufacturing Industry, 1976-1977 ..... 7-2
7-2 Concentration Ratios in Metal Furniture Manufacturing. . . 7-4
7-3 Percent of Value of Industry Shipment in Metal Furniture
Manufacturing Made by Multi-Unit and Single-Unit
Companies, 1972 ...................... 7~5
xv
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Table • Page
7-4 Distribution of Establishments in the Metal Furniture
Manufacturing Industry by Firm Size, 1972 7-6
7-5 Legal Form of Organization for Metal Furniture
Manufacturers, 1972 7-7
7-6 Geographic Distribution of Metal Furniture
Establishments, 1976 7-9
7-7 Metal Furniture Product Mix, 1963-1967 7-11
7-8 1977 Product Breakdown for Metal Household
Furniture (SIC 2514) 7-12
7-9 1977 Product Breakdown for Metal Office Furniture
(SIC 2522) 7-14
7-10 1977 Product Breakdown for Public Building and
Related Furniture (SIC 2531) 7-16
7-11 Capacity Utilization Rates - Fourth Quarters, 1977
and 1976 7-17
7-12 Number of Establishments and Employees in Metal
Furniture Manufacturing Industry, 1958-1977 7-20
7-13 Industry Shipments for Metal Furniture Manufacturing
in Current and Constant Dollars, 1967-1977 7-24
7-14 Percent Changes from Previous Year in Real Gross National
Product and Constant Metal Furniture Manufacturing
Industry Shipments 7-25
7-15 Labor and Materials Costs in Metal Furniture Manfacturing
Relative to Value of Industry Shipments 7-29
7-16 Metal Furniture Coating Materials Costs Versus Total
Materials Costs and Value of Shipments, 1972 and 1967 . . 7-30
7-17 Profit Before Taxes for Total Assets for Household
Furniture Manufacturers 7-32
7-18 Profit Before Taxes over Total Assets for Metal Office
Furniture Manufacturers and Business and Institutional
Furniture Manufacturers 7-33
7-19 Calculation of Total Affected Facilities, 1980-1985 . . . 7-36
7-20 Control Costs Parameters 7-39
xvn
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Table
7-21 Basis for Control Costs 7-40
7-22 Control Costs for Model Plant A - Large Spray Coating
Facility for Flat Metal Furniture Surfaces 7-41
7-23 Control Costs for Model Plant B - Large Spray Coating
Facility for Complex Metal Furniture Surfaces 7-42
7-24 Control Costs for Model Plant C - Medium Size Spray
Coating Facility for Flat Metal Furniture Surfaces. . . 7-43
7-25 Control Costs for Model Plant D - Medium Size Spray
Coating Facility for Complex Metal Furniture Surfaces . 7-44
7-26 Control Costs for Model Plant E - Small Spray Coating
Facility for Flat Metal Furniture Surfaces 7-45
7-27 Control Costs for Model Plant F - Small Spray Coating
Facility for Complex Metal Furniture Surfaces 7-46
7-28 Control Costs for Model Plant G - Large Dip Coating
Facility for Metal Furniture 7-47
7-29 Control Costs for Model Plant H - Medium Dip Coating
Facility for Metal Furniture 7-48
7-30 Control Costs for Model Plant I - Small Dip Coating
Facility for Metal Furniture 7-49
7-31 Control Costs for Model Plant J - Small Flow Coating
Facility for Metal Furniture 7-50
7-32 Plant A - Incremental Control Costs for Reconstruction
of SIP Level Facilities 7-54
7-33 Plant B - Incremental Control Costs for Reconstruction
of SIP Level Facilities 7-55
7-34 Plant C - Incremental Control Costs for Reconstruction
of SIP Level Facilities 7-56
7-35 Plant D - Incremental Control Costs for Reconstruction
of SIP Level Facilities 7-57
7-36 Plant E - Incremental Control Costs for Reconstruction
of SIP Level Facilities 7-58
7-37 Plant F - Incremental Control Costs for Reconstruction
of SIP Level Facilities 7-59
xvn
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Table • Page
7-38 Plant G - Incremental Control Costs for Reconstruction
of SIP Level Facilities 7-60
7-39 Plant H - Incremental Control Costs for Reconstruction
of SIP level Facilities 7-61
7-40 Plant I - Incremental Control Costs for Reconstruction
of SIP Level Facilities 7-62
7-41 Plant J - Incremental Control Costs for Reconstruction
of SIP Level Facilities 7-63
7-42 Plant A - Incremental Control Costs for Reconstruction
of Uncontrolled Facilities 7-64
7-43 Plant B - Incremental Control Costs for Reconstruction
of Uncontrolled Facilities 7-65
7-44 Plant C - Incremental Control Costs for Reconstruction
of Uncontrolled Facilities 7-66
7-45 Plant D - Incremental Control Costs for Reconstruction
of Uncontrolled Facilities 7-67
7-46 Plant E - Incremental Control Costs for Reconstruction
of Uncontrolled Facilities 7-68
7-47 Plant F - Incremental Control Costs for Reconstruction
of Uncontrolled Facilities 7-69
7-48 Plant G - Incremental Control Costs for Reconstruction
of Uncontrolled Facilities 7-70
7-49 Plant H - Incremental Control Costs for Reconstruction
of Uncontrolled Facilities 7-71
7-50 Plant I - Incremental Control Costs for Reconstruction
of Uncontrolled Facilities 7-72
7-51 Plant J - Incremental Control Costs for Reconstruction
of Uncontrolled Facilities 7-73
7-52 Model Shelving Plants 7-77
7-53 Model Chair Plants 7-77
7-54 Summary of Major Impacts Shelving Plants 7-79
7-55 Summary of Major Impacts Chair Plants 7-80
7-56 Model Shelving and Chair Plants 7-90
xviii
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Table
7-57 Profit Impact Shelving Plants - New Facilities
SIP Baseline
7'93
7-58 Profit Impact Shelving Plants - New Facilities
Uncontrolled Baseline ................... 7-94
7-59 Profit Impact Shelving Plants Modified/Reconstructed
Facilities SIP Baseline .................. 7-95
7-60 Profit Impact Shelving Plants Modified/Reconstructed
Facilities Uncontrolled Baseline ............. 7-96
7-61 Profit Impact Chair Plants - New Facilities
SIP Baseline ....................... 7-97
7-62 Profit Impact Chair Plants - New Facilities
Uncontrolled Baseline ................... 7-99
7-63 Profit Impact Chair Plants - Modified/Reconstructed-
Facilities SIP Baseline .................. 7-101
7-64 Profit Impact Chair Plants - Modified/Reconstructed
Facilities Uncontrolled Baseline ............. 7-103
7-65 Profit Impairment Shelving Plants - New Facilities
SIP and Uncontrolled Baseline ............... 7-108
7-66 Profit Impairment Shelving Plants - Modified/Recon-
structed Facilities SIP and Uncontrolled Baselines .... 7-109
7-67 Profit Impairment Chair Plants - New Facilities
SIP and Uncontrolled Baselines .............. 7-110
7-68 Profit Impairment Chair Plants - Modified/Recon-
structed Facilities SIP and Uncontrolled Baselines .... 7-112
7-69 DCF Analysis for Determining General Criteria for
Major Profit Impairment .................. 7-115
7-70 Estimated Assets for Model Plants ............. 7-119
7-71 Incremental Capital Costs for New Facilities ....... 7-120
7-72 Incremental Capital Costs for Modified/Reconstructed
Facilities ........................ 7-122
7-73 Capital Availability Impact for New Facilities ...... 7-124
7-74 Capital Availability Impact for Modified/Reconstructed
Facilities ........................ 7-126
xix
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Table Page
7-75 Cash Flow to Current Maturities of Long-Term Debt
Analysis 7-128
7-76 Representative Combinations of Regulatory Alternatives
Covering the Ten Types of Model Plants 7-132
7-77 Distribution of Lines in Coating Method Categories
by Size of Plant Involved 7-133
7-78 Surface Area Coated per Year by Projected New and
Replacement Lines 7-135
7-79 Incremental Annualized Control Cost per Thousand
Square Meters Coated New Facilities - SIP Baseline .... 7-136
7-80 Incremental Annualized Control Cost.per Thousand
Square Meters Coated Modified/Reconstructed
Facilities - SIP Baseline 7-137
7-81 Inflation Impact Shelving Plants 7-142
7-82 Inflation Impact Chair Plants 7-143
7-83 Incremental Energy Use per Line per Day-SIP Baseline . . . 7-145
7-84 Incremental Energy Use per Line per Day-Uncontrolled
Baseline 7-146
xx
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1. INTRODUCTION
1.1 BACKGROUND AND AUTHORITY FOR STANDARDS
Before standards of performance are proposed as a Federal regulation,
air pollution control methods available to the affected industry and the
associated costs of installing and maintaining the control equipment are
examined in detail. Various levels of control based on different technolo-
gies and degrees of efficiency are expressed as regulatory alternatives.
Each of these alternatives is studied by EPA as a prospective basis for a
standard. The alternatives are investigated in terms of their impacts on
the economics and well-being of the industry, the impacts on the national
economy, and the impacts on the environment. This document summarizes the
information obtained through these studies so that interested persons will
be privy to the information considered by EPA in the development of the
proposed standard.
Standards of performance for new stationary sources are established
under Section 111 of the Clean Air Act (42 U.S.C. 7411) as amended, herein-
after referred to as the Act. Section 111 directs the Administrator to
establish standards of performance for any category of new stationary
source of air pollution which "... causes, or contributes significantly
to air pollution which may reasonably be anticipated to endanger public
health or welfare."
The Act requires that standards of performance for stationary sources
reflect, "... the degree of emission reduction achievable which (taking
into consideration the cost of achieving such emission reduction, and any
nonair quality health and environmental impact and energy requirements) the
Administrator determines has been adequately demonstrated for that category
of sources." The standards apply only to stationary sources, the construc-
tion or modification of which commences after regulations are proposed by
publication in the Federal Register.
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The 1977 amendments to the Act altered or added numerous provisions
that apply to the process of establishing standards of performance.
1. EPA is required to list the categories of major stationary sources
that have not already been listed and regulated under standards of perfor-
mance. Regulations must be promulgated for these new categories on the
following schedule:
a. 25 percent of the listed categories by August 7, 1980.
b. 75 percent of the listed categories by August 7, 1981.
c. 100 percent of the listed categories by August 7, 1982.
A governor of a State may apply to the Administrator to add a category not
on the list or may apply to the Administrator to have a standard of perfor-
mance revised.
2. EPA is required to review the standards of performance every
4 years and, if appropriate, revise them.
3. EPA is authorized to promulgate a standard based on design, equip-
ment, work practice, or operational procedures when a standard based on
emission levels is not feasible.
4. The term "standards of performance" is redefined, and a new term
"technological system of continuous emission reduction" is defined. The new
definitions clarify that the control system must be continuous and may
include a low- or non-polluting process or operation.
5. The time between the proposal and promulgation of a standard under
section 111 of the Act may be extended to 6 months.
Standards of performance, by themselves, do not guarantee protection
of health or welfare because they are not designed to achieve any specific
air quality levels. Rather, they are designed to reflect the degree of
emission limitation achievable through application of the best adequately
demonstrated technological system of continuous emission reduction, taking
into consideration the cost of achieving such emission reduction, any
nonair-quality health and environmental impacts, and energy requirements.
Congress had several reasons for including these requirements. First,
standards with a degree of uniformity are needed to avoid situations where
some States may attract industries by relaxing standards relative to other
States. Second, stringent standards enhance the potential for long-term
1-2
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growth. Third, stringent standards may help achieve long-term cost savings
by avoiding the need for more expensive retrofitting when pollution ceilings
may be reduced in the future. Fourth, certain types of standards for coal-
burning sources can adversely affect the coal market by driving up the
price of low-sulfur coal or effectively excluding certain coals from the
reserve base because their untreated pollution potentials are high. Con-
gress does not intend that new source performance standards contribute to
these problems. Fifth, the standard-setting process should create incen-
tives for improved technology.
Promulgation of standards of performance does not prevent State or
local agencies from adopting more stringent emission limitations for the
same sources. States are free under Section 116 of the Act to establish
even more stringent emission limits than those established under Section 111
or those necessary to attain or maintain the National Ambient Air Quality
Standards (NAAQS) under Section 110. Thus, new sources may in some cases
be subject to limitations more stringent than standards of performance
under Section 111, and prospective owners and operators of new sources
should be aware of this possibility in planning for such facilities.
A similar situation may arise when a major emitting facility is to be
constructed in a geographic area that falls under the prevention of signi-
ficant deterioration of air quality provisions of Part C of the Act. These
provisions require, among other things, that major emitting facilities to
be constructed in such areas are to be subject to best available control
technology. The term Best Available Control Technology (BACT), as defined
in the Act, means
... an emission limitation based on the maximum degree of
reduction of each pollutant subject to regulation under
this Act emitted from, or which results from, any major
emitting facility, which the permitting authority, on a
case-by-case basis, taking into account energy, environ-
mental, and economic impacts and other costs, determines is
achievable for such facility through application of produc-
tion processes and available methods, systems, and techniques,
including fuel cleaning or treatment or innovative fuel
combustion techniques for control of each such pollutant.
In no event shall application of 'best available control
technology' result in emissions of any pollutants which
will exceed the emissions allowed by any applicable standard
established pursuant to Sections 111 or 112 of this Act.
(Section 169(3))
1-3
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Although standards of performance are normally structured in terms of
numerical emission limits where feasible, alternative approaches are some-
times necessary. In some cases physical measurement of emissions from a
new source may be impractical or exorbitantly expensive. Section lll(h)
provides that ^ >e Administrator may promulgate a design or equipment stan-
dard in those cases where it is not feasible to prescribe or enforce a
standard of performance. For example, emissions of hydrocarbons from
storage vessels for petroleum liquids are greatest during tank filling.
The nature of the emissions, high concentrations for short periods during
filling and low concentrations for longer periods during storage, and the
configuration of storage tanks make direct emission measurement impractical.
Therefore, a more practical approach to standards of performance for storage
vessels has been equipment specification.
In addition, Section Hl(j) authorizes the Administrator to grant
waivers of compliance to permit a source to use innovative continuous
emission control technology. In order to grant the waiver, the Admini-
strator must find: (1) a substantial likelihood that the technology will
produce greater emission reductions than the standards require or an equi-
valent reduction at lower economic energy or environmental cost; (2) the
proposed system has not been adequately demonstrated; (3) the technology
will not cause or contribute to an unreasonable risk to the public health,
welfare, or safety; (4) the governor of the State where the source is
located consents; and (5) the waiver will not prevent the attainment or
maintenance of any ambient standard. A waiver may have conditions attached
to assure the source will not prevent attainment of any NAAQS. Any such
condition will have the force of a performance standard. Finally, waivers
have definite end dates and may be terminated earlier if the conditions are
not met or if the system fails to perform as expected. In such a case, the
source may be given up to 3 years to meet the standards with a mandatory
progress schedule.
1.2 SELECTION OF CATEGORIES OF STATIONARY SOURCES
Section 111 of the Act directs the Adminstrator to list categories of
stationary sources. The Administrator "... shall include a category
1-4
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of sources in such list if in his judgement it causes, or contributes
significantly to, air pollution which may reasonably be anticipated to
endanger public health or welfare." Proposal and promulgation of standards
of performance are to follow.
Since passage of the Clean Air Amendments of 1970, considerable
attention has been given to the development of a system for assigning
priorities to various source categories. The approach specifies areas of
interest by considering the broad strategy of the Agency for implementing
the Clean Air Act. Often, these "areas" are actually pollutants emitted by
stationary sources. Source categories that emit these pollutants are
evaluated and ranked by a process involving such factors as: (1) the level
of emission control (if any) already required by State regulations, (2) esti-
mated levels of control that might be required from standards of performance
for the source category, (3) projections of growth and replacement of
existing facilities for the source category, and (4) the estimated incremental
amount of air pollution that could be prevented in a preselected future
year by standards of performance for the source category. Sources for
which new source performance standards were promulgated or under development
during 1977, or earlier, were selected on these criteria.
The Act amendments of August 1977 establish specific criteria to be
used in determining priorities for all major source categories not yet
listed by EPA. These are: (1) the quantity of air pollutant emissions
that each such category will emit, or will be designed to emit; (2) the
extent to which each such pollutant may reasonably be anticipated to endan-
ger public health or welfare; and (3) the mobility and competitive nature
of each such category of sources and the consequent need for nationally
applicable new source standards of performance.
The Administrator is to promulgate standards for these categories
according to the schedule referred to earlier.
In some cases it may not be feasible immediately to develop a standard
for a source category with a high priority. This might happen when a
program of research is needed to develop control techniques or because
techniques for sampling and measuring emissions may require refinement. In
the developing of standards, differences in the time required to complete
1-5
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the necessary investigation for different source categories must also be
considered. For example, substantially more time may be necessary if
numerous pollutants must be investigated from a single source category.
Further, even late in the development process the schedule for completion
of a standard may change. For example, inablility to obtain emission data
from well-controlled sources in time to pursue the development process in a
systematic fashion may force a change in scheduling. Nevertheless, priority
ranking is, and will continue to be, used to establish the order in which
projects are initiated and resources assigned.
After the source category has been chosen, the types of facilities
within the source category to which the standard will apply must be deter-
mined. A source category may have several facilities that cause air pollu-
tion, and emissions from some of these facilities may vary from insignificant
to very expensive to control. Economic studies of the source category and
of applicable control technology may show that air pollution control is
better served by applying standards to the more severe pollution sources.
For this reason, and because there is no adequately demonstrated system for
controlling emissions from certain facilities, standards often do not apply
to all facilities at a source. For the same reasons, the standards may not
apply to all air pollutants emitted. Thus, although a source category may
be selected to be covered by a standard of performance, not all pollutants
or facilities within that source category may be covered by the standards.
1.3 PROCEDURE FOR DEVELOPMENT OF STANDARDS OF PERFORMANCE
Standards of performance must (1) realistically reflect best demon-
strated control practice; (2) adequately consider the cost, the nonair-
quality health and environmental impacts, and the energy requirements of
such control; (3) be applicable to existing sources that are modified or
reconstructed as well as new installations; and (4) meet these conditions
for all variations of operating conditions being considered anywhere in the
country.
The objective of a program for developing standards is to identify the
best technological system of continuous emission reduction that has been
adequately demonstrated. The standard-setting process involves three
principal phases of activity: (1) information gathering, (2) analysis of
the information, and (3) development of the standard of performance.
1-6
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During the information-gathering phase, industries are queried through
a telephone survey, letters of inquiry, and plant visits by EPA representa-
tives. Information is also gathered from many other sources to provide
reliable data that characterize the pollutant emissions from well-controlled
existing facilities.
In the second phase of a project, the information about the industry
and the pollutants emitted is used in analytical studies. Hypothetical
"model plants" are defined to provide a common basis for analysis. The
model plant definitions, national pollutant emission data, and existing
State regulations governing emissions from the source category are then
used in establishing "regulatory alternatives." These regulatory alterna-
tives are essentially different levels of emission control.
EPA conducts studies to determine the impact of each regulatory alterna-
tive on the economics of the industry and on the national economy, on the
environment, and on energy consumption. From several possibly applicable
alternatives, EPA selects the single most plausible regulatory alternative
as the basis for a standard of performance for the source category under
study.
In the third phase of a project, the selected regulatory alternative
is translated into a standard of performance, which, in turn, is written in
the form of a Federal regulation. The Federal regulation, when applied to
newly constructed plants, will limit emissions to the levels indicated in
the selected regulatory alternative.
As early as is practical in each standard-setting project, EPA represen-
tatives discuss the possibilities of a standard and the form it might take
with members of the National Air Pollution Control Techniques Advisory
Committee. Industry representatives and other interested parties also
participate in these meetings.
The information acquired in the project is summarized in the Background
Information Document (BID). The BID, the standard, and a preamble explaining
the standard are widely circulated to the industry being considered for
control, environmental groups, other government agencies, and offices
within EPA. Through this extensive review process, the points of view of
expert reviewers are taken into consideration as changes are made to the
documentation.
1-7
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A "proposal package" is a-ssembled and sent through the offices of EPA
Assistant Administrators for concurrence before the proposed standard is
officially endorsed by the EPA Administrator. After being approved by the
EPA Administrator, the preamble and the proposed regulation are published
in the Federal Register.
As a part of the Federal Register announcement of the proposed regula-
tion, the public is invited to participate in the standard-setting process.
EPA invites written comments on the proposal and also holds a public hearing
to discuss the proposed standard with interested parties. All public comments
are summarized and incorporated into a second volume of the BID. All
information reviewed and generated in studies in support of the standard of
performance is available to the public in a "docket" on file in Washington,
D. C.
Comments from the public are evaluated, and the standard of performance
may be altered in response to the comments.
The significant comments and EPA's position on the issues raised are
included in the "preamble" of a "promulgation package," which also contains
the draft of the final regulation. The regulation is then subjected to
another round of review and refinement until it is approved by the EPA
Administrator. After the Administrator signs the regulation, it is published
as a "final rule" in the Federal Register.
1.4 CONSIDERATION OF COSTS
Section 317 of the Act requires an economic impact assessment with
respect to any standard of performance established under Section 111 of the
Act. The assessment is required to contain an analysis of: (1) the costs
of compliance with the regulation, including the extent to which the cost
of compliance varies depending on the effective date of the regulation and
the development of less expensive or more efficient methods of compliance;
(2) the potential inflationary or recessionary effects of the regulation;
(3) the effects the regulation might have on small business with respect to
competition; (4) the effects of the regulation on consumer costs; and (5)
the effects of the regulation on energy use. Section 317 also requires that
the economic impact assessment be as extensive as practicable.
1-8
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The economic impact of a proposed standard upon an industry is usually
addressed both in absolute terms and in terms of the control costs that
would be incurred as a result of compliance with typical, existing State
control regulations. An incremental approach is necessary because both new
and existing plants would be required to comply with State regulations in
the absence of a Federal standard of performance. This approach requires a
detailed analysis of the economic impact from the cost differential that
would exist between a proposed standard of performance and the typical
State standard.
Air pollutant emissions may cause water pollution problems, and cap-
tured potential air pollutants may pose a solid waste disposal problem. The
total environmental impact of an emission source must, therefore, be ana-
lyzed and the costs determined whenever possible.
A thorough study of the profitability and price-setting mechanisms of
the industry is essential to the analysis so that an accurate estimate of
potential adverse economic impacts can be made for proposed standards. It
is also essential to know the capital requirements for pollution control
systems already placed on plants so that the additional capital requirements
necessitated by these Federal standards can be placed in proper perspective.
Finally, it is necessary to assess the availability of capital to provide
the additional control equipment needed to meet the standards of performance.
1.5 CONSIDERATION OF ENVIRONMENTAL IMPACTS
Section 102(2)(C) of the National Environmental Policy Act (NEPA) of
1969 requires Federal agencies to prepare detailed environmental impact
statements on proposals for legislation and other major Federal actions
significantly affecting the quality of the human environment. The objective
of NEPA is to build into the decisionmaking process of Federal agencies a
careful consideration of all environmental aspects of proposed actions.
In a number of legal challenges to standards of performance for various
industries, the United States Court of Appeals for the District of Columbia
Circuit has held that environmental impact statements need not be prepared
by the Agency for proposed actions under Section 111 of the Clean Air Act.
Essentially, the Court of Appeals has determined that the best system of
emission reduction requires the Administrator to take into account counter-
1-9
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productive environmental effects of a proposed standard, as well as economic
costs to the industry. On this basis, therefore, the Court established a
narrow exemption from NEPA for EPA determination under Section 111.
In addition to these judicial determinations, the Energy Supply and
Environmental Coordination Act (ESECA) of 1974 (PL-93-319) specifically
exempted proposed actions under the Clean Air Act from NEPA requirements.
According to Section 7(c)(l), "No action taken under the Clean Air Act
shall be deemed a major Federal action significantly affecting the quality
of the human environment within the meaning of the National Environmental
Policy Act of 1969" (15 U.S.C. 793(c)(l)).
Nevertheless, the Agency has concluded that the preparation of environ-
mental impact statements could have beneficial effects on certain regulatory
actions. Consequently, although not legally required to do so by
Section 102(2)(C) of NEPA, EPA has adopted a policy requiring that environ-
mental impact statements be prepared for various regulatory actions, including
standards of performance developed under Section 111 of the Act. This
voluntary preparation of environmental impact statements, however, in no
way legally subjects the Agency to NEPA requirements.
To implement this policy, a separate section in this document is
devoted solely to an analysis of the potential environmental impacts asso-
ciated with the proposed standards. Both adverse and beneficial impacts in
such areas as air and water pollution, increased solid waste disposal, and
increased energy consumption are discussed.
1.6 IMPACT ON EXISTING SOURCES
Section 111 of the Act defines a new source as ". . . any stationary
source, the construction or modification of which is commenced ..." after
the proposed standards are published. An existing source is redefined as a
new source if "modified" or "reconstructed" as defined in amendments to the
general provisions of Subpart A of 40 CFR Part 60, which were promulgated
in the Federal Register on December 16, 1975 (40 FR 58416).
Promulgation of a standard of performance requires States to establish
standards of performance for existing sources in the same industry under
Section 111 (d) of the Act if the standard for new sources limits emissions
of a designated pollutant (i.e., a pollutant for which air quality criteria
1-10
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have not been issued under Section 108 or which has not been listed as a
hazardous pollutant under Section 112). If a State does not act, EPA must
establish such standards. General provisions outlining procedures for
control of existing sources under Section lll(d) were promulgated on
November 17, 1975, as Subpart B of 40 CFR Part 60 (40 FR 53340).
1.7 REVISION OF STANDARDS OF PERFORMANCE
Congress was aware that the level of air pollution control achievable
by any industry may improve with technological advances. Accordingly,
Section 111 of the Act provides that the Administrator "... shall, at
least every 4 years, review and, if appropriate, revise ..." the standards.
Revisions are made to assure that the standards continue to reflect the
best systems that become available in the future. Such revisions will not
be retroactive, but will apply to stationary sources constructed or modified
after the proposal of the revised standards.
1.8 EXECUTIVE SUMMARY OF REGULATORY ALTERNATIVE IMPACTS
Chapter 5 of this BID describes the selected regulatory alternatives.
The bases of selection of these regulatory alternatives are presented in
Chapters 2 through 4 of this document. Chapters 5, 6, and 7 contain infor-
mation pertaining to the environmental and economic impacts for each of the
regulatory alternatives, respectively. The regulatory alternatives selected
for controlling volatile organic compounds (VOCs) from surface coating of
metal furniture are:
Regulatory
alternatives
I
II
III
IV
Typical control option
(a) SIP - 60 percent
solids coating
(b) 60 to 70 percent
solids coating
(c) SIPs and Inciner-
ation
(d) Waterborne coatings
(e) Waterborne (electro-
deposition)
(f) Powder
Additional emission
reduction from
SIPs (percent)
Baseline 0
30
30 to 50
50
85
slOO
Control options
to meet
regulatory
alternative
(a) through (f)
(a) through (f)
(c), (d), (e),
and (f)
(e) and (f)
1-11
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The environmental and economic impacts of each regulatory alternative
are summarized in the next two sections.
1.9 ENVIRONMENTAL IMPACT
V
A summary of the environmental impacts for each regulatory alternative
is contained in Table 1-1. These impacts are detailed in Chapter 6 of this
BID. The most oeneficial regulatory alternative from an environmental
impact standpoint is Number IV.
1.10 ECONOMIC IMPACT
None of the regulatory alternatives cause an irreversible economic
impact upon the metal furniture industry. However, the higher the emission
reduction requirements (Regulatory Alternative III and IV), the more costly
it becomes for the industry to comply.
1-12
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Table 1-1. MATRIX OF ENVIRONMENTAL AND ECONOMIC IMPACTS OF THE
PROPOSED SURFACE COATING OF METAL FURNITURE EMISSION LIMITS
\Impact
Control \
option (regu- \
latory alter- \ Water Solid
native) \ Air pollution waste Energy Noise
Powder,
electrostatic +4** +3** +2* +3** n
spray (Regulatory
Alternative IV)
Infla-
Economic tionary
+1** to +1** to
-2** -2**
Powder,
fluidized bed „„ y* _„»» „„ „, ^
(Regulatory +4+3^+2 032
Alternative IV)
Waterborne,
Electrostatic Spray -*» ,* ,« -»* Q „** *
(Regulatory Alter- J ^ l * u £ 1
native III)
Waterborne, Dip,
and Flow (Regula- ,** ,* 0 ?Jt» .
tory Alternative III) * u
Waterborne,
Electrodeposition .».„ ,„ 3>t* „,
(Regulatory Alter- * l +J +l u
native IV)
High Solids
(Regulatory Alter- +3** -1* -1* +2** 0
natives I or II)
Incinerator plus
High Solids or
Waterborne (Regula- +3** -1* -1* +1* 0
tory Alternatives I,
II, or III)
-1* -1*
-3* -1**
+1* 0
-1* 0
Key.:
+ Beneficial 0 No Impact * Short-term Impact
- Adverse Impact 1 Negligible Impact ** Long-term Impact
2 Small Impact
3 Moderate Impact
4 Large Impact
*** Irreversible Impact
1-13
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2. THE METAL FURNITURE INDUSTRY
2.1 GENERAL DESCRIPTION
The metal furniture industry consists of the following industry
groups and subgroups:
Metal household furniture (SIC 2514)
Dining and breakfast furniture
Kitchen furniture
Porch, lawn, and outdoor furniture
Other metal household furniture
Metal household furniture, nsk (not specified by kind)
Metal office furniture (SIC 2522)
Metal office seating
Desks
Cabinets and cases
Other metal office furniture including tables, standard, etc.
Metal office furniture, nsk (not specified by kind)
Public building and related furniture (SIC 2531)
School furniture, except stone and concrete
Public building and related furniture, except school furniture
Public school furniture, nsk
Metal partitions and fixtures (SIC 2542)
Metal partitions
Metal shelving and lockers
Metal storage racks and accessories
-------
Metal partitions and fixtures (SIC 2542) (continued)
Metal fixtures for stores, banks, offices and miscellaneous
fixtures
Metal partitions, shelving, lockers, fixtures, nsk
The industry includes approximately 1400 establishments employing
approximately 100,000 people. The term "establishment" means a plant,
rather than a company; i.e., a company can consist of more than one
establishment. In this industry, however, few companies actually have
more than one establishment. In 1972, the average number of establishments
per company in SICs 2522, 2531, and 2542 were 1.16, 1.04, and 1.05,
respectively. (No similar data for SIC 2514 are available).
Table 2-1 shows a distribution of establishments according to
employment size classes. The four distributions are remarkably consistent
with each other: all four show definite biases toward small plants.
Fifty percent of the establishments in the metal furniture industry,
viewed as a whole, have less than twenty employees, and eighty percent
have less than 100 employees.
The industry size diversity is also demonstrated by a study of the
p_-l /-
annual paint consumption rates of the plants in existence. This
breakdown is shown in Table 2-2. These data were used to determine size
categories for the model plants presented in Chapter 5 of this document.
2.2 PROCESSES OR FACILITIES AND THEIR EMISSIONS
2.2.1 The Basic Process
The metal furniture coating industry utilizes primarily solvent-
borne coatings being applied by spray, dip, and flow coating processes.
y_ -| c
Dry coating thickness is generally in the area of 1 mil. Coatings
for metal furniture must be resistant to abrasion and maintain a good
appearance. In addition, metal furniture must often be able to withstand
regular cleaning with harsh detergents.
The coatings used in the industry consist primarily of solvent-
borne resins. Other coatings include acrylics, amines, vinyls, and
cellulosics. Some metallic coatings are also used on office furniture.
The solvents used are mixtures of aliphatics, xylene, toluene, and other
aromatics.
2-2
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Table 2-1. DISTRIBUTION OF ESTABLISHMENTS BY EMPLOYMENT SIZE
no
oo
SIC
code
2514
2522
2531
2542
Industry
group
Metal household furniture
Number of establishments
Percent of establishments
Metal office furniture
Number of establishments
Percent of establishments
Public building and
related furniture
Number of establishments
Percent of establishments
Metal partitions and fixtures
Number of establishments
Percent of establishments
Totals for four industry
groups
Number of establishments
Percent of establishments
Cumulative percent of
establishments
Employment size class
Total
391
100
177
100
377
100
449
100
1394
100
100
1-9
128
33
42
24
133
35
167
33
470
34
49
10-19
69
18
25
14
52
14
71
16
218
16
49
20-49
64
16
23
13
92
24
102
23
281
20
69
50-99
42
11
25
14
44
12
49
11
160
11
80
100-249
47
12
38
21
43
11
45
10
173
12
92
250-499
35
9
12
7
12
3
11
2
70
5
Approx.
> 500
6
2
9
5
1
<1
4
1
20
2
100
Source: U. S. Department of Commerce, Bureau of the Census, County Business Patterns 1976, CBP-76-1.
-------
Table 2-2. DISTRIBUTION OF ESTABLISHMENTS BY PAINT CONSUMPTION
ro
SIC
code
2514
2522
2531
2542
Industry
group
Metal Household Furniture
Number of establishments
Percent of establishments
Metal Office Furniture
Number of establishments
Percent of establishments
Metal Office Furniture
Number of establishments
Percent of establishments
Metal Partitions and Fixtures
Number of establishments
Percent of establishments
Totals for Four Industry
Groups
Number of establishments
Percent of establishments
Cumulative percent of
establishments
Annual paint
Total
391
100
177
100
377
100
449
100
1395
100
100
0-
2000
39
10
9
5
30
8
67
15
145
10
10
2001-
7500
90
23
35
20
31
8
45
10
201
14
24
7501-
40000
133
34
53
30
158
42
135
30
479
35
59
consumption (liters)
40001-
115000
51
13
9
5
98
26
67
15
225
16
75
115000-
190000
27
7
44
25
30
8
45
10
146
11
86
>1 90001
51
13
27
15
30
8
90
20
198
14
100
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The metal furniture coating industry solvent emissions are directly
related to the types of coating materials used and the technique with
which they are applied. Typical coatings presently used contain 65
volume percent solvent and 35 percent solids. Other types of
coatings such as waterborne, high solids and powder are beginning to
appear in the industry. These will be further discussed in Chapter 3.
Application, or transfer, efficiencies range from 30 to 95 percent
depending upon the application technique and the configuration of the
item being coated.17'18 Application efficiency does not affect emis-
sions from the curing oven; however, it is a major factor in emissions
from the coating application step. It is important, therefore, to
achieve the highest application efficiency possible. Application
efficiency may be calculated by the following equation:
c _ (AKTKIOOO) T (S/100)
E -
where, E = Application efficiency
A = Area coated (square meters)
T = Dry coating thickness (meters)
S = Solids content of paint (volume percent)
Q = Quantity of paint applied (liters)
2.2.1.1 Spray Coating. Spray coating is the most common application
technique used. Spray coating lines generally consist of six major
steps. These may vary, however, from plant to plant. These steps are
listed below:
1. Three- or five-stage washer
2. Oven
3. Manual touch-up spray
4. Electrostatic spray
5. Manual touch-up spray
6. Oven
Furniture pieces are loaded onto an overhead conveyor moving at speeds
ranging from 2.5 to 7 meters per minute. This conveyor carries the
2-5
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pieces through all steps of the coating process. Figure 2-1 provides a
block diagram of the steps involved in the process.
A five-stage cleaning process contains the following steps:
1. Alkaline cleaner wash
2. Iron phosphate
3. Hot water rinse
4. Chromic wash
5. Cold water rinse
The alkaline cleaning removes oil and grease and the phosphate
treatment improves the adhesion characteristics of the surface. Most
metal furniture coating operations use only three stages eliminating the
chromic wash and cold water rinse.
After washing, the parts pass through a dry-off oven and then into
a touchup booth where manual spray guns apply a reinforcement coating to
the parts prior to topcoat application. This step is generally eliminated
in metal furniture coating operations and a one coat process is used.
The topcoat operation is, naturally, the most important step in the
finishing process. The paint is applied by manual or automatic electro-
static spraying. Application efficiency for electrostatic spraying
varies from 60 to 95 percent depending upon the type of application
equipment and the configuration of the item being painted.18 Applica-
tion efficiency for flat surfaces is generally 85 percent and for
complex shaped objects it is 65 percent. Because of the length of time
that the item is in the spray booth and flash-off area, approximately 70
percent of the solvent evaporates prior to the curing step.19
Color changes present no great problem for electrostatic spraying.
In manual operations, the operator purges the line with solvent, wipes
the gun, and connects the line to the new color coating supply. In some
larger operations different spray guns may be used, each attached to a
different feed line. Automated systems may have several guns which are
programmed for color sequence or there may be a single gun and line
purging may be required as with the manual operation. Some larger
operations perform color mixing compounding with computer programming.
The color ingredients are selected in accordance with programs designed
to meet customer requirements.
2-6
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Load
3-stage
washer
Dry off
oven
ro
Unload
Curing
oven
Flash-off
area
Electrostatic
spray booth
Figure 2-1. Flow diagram - electrostatic spray coating operation.
-------
2-2-l-2 Dip Coating. Dip coating is the second most commonly used
method of paint application. With this method, the wash stage is
similar to that of spray coating.
Dip coating may be done manually or automatically. Items to be
coated are loaded on an overhead conveyor which lowers them into the
paint tank. They are then raised from the tank and suspended in a
flash-off area over a drainboard. The items are then passed into the
oven. Figure 2-2 shows the steps involved in the dip coating process.
Approximately 40 percent of the solvent emissions which occur
during dip coating are released during application and flash-off.19
Application efficiency is approximately 90 percent for dip coating and
there is no appreciable difference resulting from differing object
configurations. Typical dry coating thickness is 2.54 x 10-3 cm (1
mil) and the paint is usually a solvent-based alkyd with 35 volume
percent solids.
Color changes are not easily accomplished with dip coating. If an
operation requires multiple colors, it will generally require several
tanks, each filled with a different color paint.
2.2.1.3 Flow Coating. Flow coating is a method used to a much
lesser extent in the metal furniture coating industry. The wash stage
is the same as with spray and dip coating.
For topcoat application, furniture items are carried by an overhead
conveyor into a flow coating chamber. In the chamber, paint is directed
at the object from many angles through as many as 100 nozzles. These
nozzles effectively form a curtain of paint through which the furniture
items must pass. After application, the coated objects are held over a
drain board in a flash-off area. They then pass into the curing oven.
Figure 2-3 shows the steps involved in the flow coating process.20
Approximately 80 percent of all solvent emissions are released in the
application and flash-off areas. Application efficiency is estimated
at 90 percent for flow coating and there is no significant difference
18
with varying object shapes. Typical dry coating thickness is 2.54 x
10-3 cm (1 mil) and the paint is usually a solvent based alkyd with 35
volume percent solids.
Color changes are not easily accomplished with flow coating. If
multiple colors are needed, several coating chambers are usually needed.
2-8
-------
Load
3-stage
washer
Dry off
oven
ro
Unload
v
Curing
oven
>»
"s
Flash-off
area
**
*•
Dip
tank
€
^»
Figure 2-2. Flow diagram - dip coating operations.
-------
Load
3-stage
washer
Dry off
oven
INi
Unload <-
Curing
oven
Flash-off
area
Flow
Chamber
Figure 2-3. Flow diagram - flow coating operations.
-------
2.3 BASELINE EMISSIONS
For the purpose of this study, the term "baseline emissions" refers
to the level of emission control required of the metal furniture surface
coating industry in the absence of a New Source Performance Standard
(NSPS).
The metal furniture industry is located almost entirely in urban
areas which are nonattainment areas for photochemical oxidants. State
Implementation Plans (SIPs) have been developed to control volatile
organic compound (VOC) emissions from various sources including the
metal furniture industry within these areas. In addition to some
existing facilities, all new, modified and reconstructed metal furniture
coating facilities will be required to comply with these SIP regulations.
The method for control of VOC emissions by the SIPs is based on the
Control Techniques Guideline (CTG) document published by the U. S.
21
Environmental Protection Agency in December 1977. This document
presents an emission limit of 0.35 kg VOC per liter of coating applied
(3.0 Ib/gallon). This level is, therefore, considered to be the base-
line emission rate and is used as the basis for comparison of regulatory
alternatives in Chapter 5.
2-11
-------
REFERENCES FOR CHAPTER 2
1. U. S. Department of Commerce, 1972 Census of Manufacturers, Industry
Series, MC72(2)-25B, January 1975.
2. Oge, M. T. Trip Report. Bunting Company. Philadelphia, Pennsylvania.
Springborn Laboratories, Enfield, Connecticut. Trip Report 86.
March 8, 1976.
3. Oge, M. T. Trip Report. Goodman Brothers Manufacturing Company.
Philadelphia, Pennsylvania. Springborn Laboratories, Enfield,
Connecticut. Trip Report 85. March 8, 1976.
4. Oge, M. T. Trip Report. Steelcase Company. Grand Rapids, Michigan.
Springborn Laboratories, Enfield, Connecticut. Trip Report 72.
February 24, 1976.
5. Fisher, J. R. Trip Report. Virco Manufacturing Corporation. Gardena,
California. Springborn Laboratories, Enfield, Connecticut. Trip
Report 57. February 11, 1976.
6. Oge, M. T. Trip Report. Herman Miller Incorporated. Zeeland,
Michigan. Springborn Laboratories, Enfield, Connecticut. Trip
Report 100. April 2, 1976.
7. Thompson, M. S. Trip Report. U. S. Furniture Industries. Blacksmith
Shop Division. Highpoint, North Carolina. Springborn Laboratories,
Enfield, Connecticut. Trip Report 108. April 6, 1976.
8. Oge, M. T. Trip Report. Angel Steel Company. Plainwell, Michigan.
Springborn Laboratories, Enfield, Connecticut. Trip Report 103,
April 5, 1976.
9. Industrial Surface Coating Questionnaire. OMB No. 158-S75014.
Simmons Company. Atlanta, Georgia. December 4, 1975.
10. Industrial Surface Coating Questionnaire. OMB No. 158-S75014.
Lyon Metal Products, Inc. Aurora, Illinois. February 12, 1976.
11. Industrial Surface Coating Questionnaire. OMB No. 158-S75014.
Shelby Williams Industrial, Inc. Philadelphia, Pennsylvania.
February 26, 1976.
2-13
-------
12. Telecon Survey. TRW, Inc. , Environmental Engineering Division.
Telecon survey of metal furniture coating plants regarding annual
paint consumption. January-February 1979.
13. California Air Resources Board Survey of Metal Furniture Coating
Plans. 1978.
14. Economic Information Systems. Listing of metal furniture coating
establishments.
15. Nunn, A. B. and D. L. Anderson. Trip Report. Steelcase, Inc.
Grand Rapids, Michigan. TRW, Inc. , Durham, North Carolina.
March 27-28, 1979.
16. Nunn, A. B. and D. L. Anderson. Trip Report. Delwood Furniture
Co. Irondale, Alabama. TRW, Inc., Durham, North Carolina.
April 18, 1979.
17. Danielson, John A., Editor. Air Pollution Engineering Manual,
AP-40, 2nd Edition. Air Pollution Control District County of
Los Angeles, EPA, Office of Air and Water Programs, Office of
Air Quality Planning and Standards, Research Triangle Park,
North Carolina. May 1973.
18. Brewer, G. E. F., "Painting Waste Loads Associated with Metal
Finishing", Journal of Coatings Technology, Vol. 49, No. 625,
February 1977.
19. Suther, Burton J. , (Foster D. Snell) and Uday Potasku (JACA
Corporation). Controlling Pollution from the Manufacturing and
Coating of Metal Products—Metal Coating Air Pollution Control,
Volume 1, EPA-625/3-77-009. May 1977.
20. Flow Coating Process of Paint Application. Data Sheet F-24,
George Koch Sons, Inc., Evansville, Indiana.
21. Gallagher, V. N., and J. Pratapas. Control of Volatile Organic
Emissions from Existing Stationary Sources, Volume III: Surface
Coating of Metal Furniture. EPA-450/2-77-032. U. S. Environmental
Protection Agency, Research Triangle Park, North Carolina.
December 1977.
2-14
-------
3. EMISSION CONTROL TECHNIQUES
This chapter establishes control techniques that are available to the
metal furniture industry to control volatile organic compound (VOC) emis-
sions. In addition, it develops control efficiencies for each control
technique. Control techniques which are evaluated include coating formula-
tion changes, "add-on" air pollution control equipment, and process modifi-
cations. Coating formulation changes include powder, high solids, and
waterborne coatings instead of conventional solvent-based coatings. The
basic aim behind coating formulation changes is to reduce or eliminate the
organic solvent concentrations present and to increase the solids content
or the water content of the coating. These changes should in turn reduce
VOC emissions to the atmosphere.
Add-on air pollution control equipment which is considered includes
incinerators, process boilers, carbon adsorbers, condensers and absorbers.
Both types of incinerators are evaluated: thermal and catalytic. Discus-
sions relating to add-on control techniques are only applicable to paint
lines that continue to use conventional organic solvent-based coatings.
Finally, emission reduction performance associated with process
modification is discussed. Improving transfer efficiencies in applying
solvent-borne coatings is emphasized for this control technique.
Each control technique is also evaluated to determine impact upon
reducing or eliminating "fugitive" emissions of VOC. Without this
evaluation, the exact control efficiency of a control technique cannot be
determined.
Control techniques and their associated control efficiencies are
applied in Chapter 5 to the model plants to establish regulatory alterna-
tives. From the regulatory alternatives, the control techniques which will
be recommended for economic analysis in Chapter 7 will be determined.
-------
3.1 EMISSION CONTROL THROUGH COATING FORMULATION CHANGES
Topics regarding formulation changes which are discussed in the
following sections are:
1. Discussion of which surface coating industries (metal furniture
and other related) employ coating formulation changes as an air
pollution control technique.
2. Chemical compositions.
3. Advantages and disadvantages of coating formulations.
4. Coating application techniques.
5. Process descriptions.
6. Process VOC emissions.
7. Operating parameters for new metal furniture lines.
3.1.1 Powder Coatings
A control technique often employed in the metal furniture industry is
powder coating. Powder is applied to outdoor furniture as well as indoor
products such as shelves, beds, and chair frames. Table 3-1 shows the type
of metal furniture products being powder coated, the powder resin type, the
application process, and the coating thickness.
In addition to the metal furniture industry, several other surface
coating industries apply powder coatings to metal substrates. Table 3-2
lists some of these. The process steps for powder coating of metal pro-
ducts shown in Table 3-2 are the same or similar to process steps in the
metal furniture industry. Since the application of powder coatings to
metal substrates is a physical process, most comparisons between surface
coating of metal furniture and surface coating of other metal products are
applicable. Before powder can be applied as a coating, part size, part
mass, part shape, paint thickness, color changing and matching, and
"Faraday Effect" are the most important evaluations to be made.
Chemical compositions of powder coatings used in surface coating
industries consist of synthetic resins, pigments, solid additives, and from
0 to 10 percent entrapped volatiles. The film formers are the synthetic
resins (alkyd, vinyl, acrylic, epoxy, urethane, etc.). The surface
coating industry classifies surface coatings by the resin type (e.g., alkyd
paint, vinyl paint, etc.). Pigments consist of both inorganic and organic
3-2
-------
Table 3-1. METAL FURNITURE PRODUCTS BEING POWDER COATED
CO
CO
Product
Indoor metal furniture
Outdoor metal furniture
Outdoor metal furniture
Lawn and patio furniture
(17 and 22 guage mild steel)
Patio and casual furniture
Steel file cabinets and desks
Metal furniture
Metal chairs
Lawn furniture
Hospital bed frames and parts
Chair bases, frames, and
other parts
Application
process9
ES-automatic
ES-automatic
FB
ES
ES
ES.ED
ES-automatic
FB
ES
ES-automatic
ES-automatic
Powder Coating _3
resin type thickness (10 cm)
Epoxy resin
Cellulose
acetate
butyrate (CAB)
CAB
—
Polyester
—
PVC
polyester
(thermoset)
Vinyl and
polyester
Polyester
Epoxy
Epoxy
3.81 - 12.7
17.8 - 20.8
17.8 - 20.3
—
—
—
6.35
2.54
38.1 - 40.6
3.81
6.10
6.10
Reference
1
1
1
2
3
4
5
6
7
8
9-11
(continued)
-------
Table 3-1. (Concluded)
CO
Product
Chair bases and arms
Shop furniture
Tubular metal furniture
Stadium seating
Hospital beds
Indoor and outdoor furniture
Library shelves
Dinette tables
Metal finishing parts
Office furniture
Hospital furnishing parts
Application
process3
FB
ES
ES-manual
ES-manual
ES
ES-automatic
ES-automatic
ES
ES-manual
ES-automatic
FB and ES
Powder Coating3
resin type thickness (10 cm)
Nylon 11
CAB
Epoxy and
thermoplastic
polyester
Polyester
(thermoplastic)
Nylon II
Epoxy and
polyester
Epoxy
Epoxy
Epoxy
Epoxy
Nylon
25.5 - 50.8
8.89 - 10.2
3.81
7.62
—
2.54 - 7.62
5.59
—
6.35 - 10.2
7.62 - 20.3
— — —
Reference
10,11
12
13
14
15
16,17
18
16
19
20
19
ES refers to electrostatic application of powder.
FB refers to fluidized bed application of powder.
ED refers to electrostatic disk application of powder.
-------
Table 3^2. OTHER METAL PRODUCTS BEING POWDER COATED
co
i
01
Metal
product
Bicycle parts
Metal tubing
Trailer hitches
Lawn and garden
equipment
Metal part for
electrical equipment
Metal parts for fan
coils and ice makers
Lawn and garden
tractors
Automobiles
Oil filters
Outside and floor panels
of automobiles
Refrigerator liners,
shelving and kick plates
Components for electrical
equipment
Application
process3
ES-automatic
ES-automatic
ES-automatic
ES-automatic
and manual
—
ES
ES-automatic
ES-automatic
ES-automatic
ES-automatic
ES-automatic
and manual
Powder
type
CAB
Vinyl
Epoxy
Acrylic
Epoxy
Epoxy
Acrylic
Epoxy
Epoxy
Epoxy
Epoxy
Coating o
thickness (10 cm) Reference
7.62 21
5
22
23
16, 24
6.10 - 10.2 25
26
27
2.54 - 5.08 28
on
t.y
30
2.29 31
aES refers to electrostatic application of powder.
-------
compounds which are used for color and opacity. Additives are used to aid
in production and improve application and performance properties of the
32
film former.
There are two general synthetic resin types of powder coatings:
thermoset and thermoplastic types. Thermosetting powders harden during
heating inside a bake oven as a result of cross-linking or polymerizing of
the resin. Thermoplastic powders soften with the application of heat and
resolidify during cooling. Table 3-3 lists the powder coatings grouped
I c OQ
by synthetic resins. ' Thermosetting and thermoplastic coatings are
usually applied by electrostatic spray and fluidized bed, respectively.
Most thermoplastic coatings require a solvent or powder primer before the
coating can be applied. ' The most widely applied thermosets in the
metal furniture industry are epoxies and polyesters. ' These materials
provide a tough, chemical and abrasive resistant coating which achieves
excellent adhesion to almost any metallic substrate. Several of the thermo-
plastics listed in Table 3-3 are being applied successfully to metal furni-
ture products. Most of the thermoplastics are applied in thick films for
wear resistance in areas such as chair legs, bases and arms.
Both powder coating types offer several advantages and disadvantages
(Tables 3-4 and 3-5). when compared to solvent-based coatings. The majority
of advantages apply to outdoor type products where color matching is not as
important. Some of the disadvantages mentioned in Table 3-5 are so critical
that powder coating certain parts may not be possible, e.g., color matching
and Faraday Effect. Color matching presents problems for facilities that
coat parts with different paint types (metal!ics) and then assemble the
34 35
parts into a finished product. ' Lack of proper color match can result
in a large number of rejected parts. The second disadvantage, Faraday
Effect, applies to all types of coatings applied electrostatically. This
phenomenon occurs for parts with recesses which are surrounded by metal.
The electrostatically charged particles travel to the closest ground and as
a result the recesses on the part are not coated. The Faraday Effect
becomes a significant problem if the parts require a reinforcement spray
or a touch-up spraying. This effect can sometimes be overcome by preheating
the part, coating at a reduced voltage, or focusing the spray directly at
•3 I n ic oc
the problem recess area. ' ' '
3-6
-------
Table 3-3. POWDER COATING RESIN GROUPS
Thermosetting
Thermoplastics
Epoxy
Polyester
Acrylic
Polyvinyl chloride or "vinyl"
Polyethylene
Cellulose acetate butyrate (CAB)
Nylon
Polyester
Acrylic
Cellulose acetate propionate (CAP)
Fluoroplastics
3-7
-------
Table 3-4. ADVANTAGES OF POWDER COATINGS WHEN COMPARED TO
ORGANIC SOLVENT-BASED COATINGS
Advantages Reference
1. Provides •• tougher more abrasive resistant
finish. 3, 5, 18, 24, 28, 36, 37
2. Fewer rejects and sags. 5, 14, 26, 28, 38, 39
3. Lower energy consumption. 2, 25, 28, 38, 40-42
4. Production rates can sometimes be
increased. 26, 28, 38, 40
5. Less metal products are damaged during
packing and shipping because coating is
more abrasive resistant. 38, 40
6. Eliminates OSHA requirements for
solvents. 24, 43
7. Usually no final refinishing required. 43
8. Less metallic preparation for parts
to be coated. 10, 14, 18, 36, 40
9. Preferred for wire-type parts. 14, 36, 39
10. Superior for tubular parts. 36
11. No additional solvents for controlling
viscosity or cleaning equipment required
to be purchased or stored at facility. 24, 38
12. Less powder required to cover same
surface area at same coating thickness. 24, 38, 42
13. Good coatings for electrical insulation
and ambient temperature variations. 16
14. Significant reduction of VOC emissions. 44
15. No primer required for thermosets and
some thermoplastics. 14
16. Problems associated with water usage are
reduced or eliminated. —
17. In many applications powder can be reclaimed
and reused, providing a higher powder utili-
zation efficiency than transfer efficiencies
achieved with conventional solvent-based
coatings. 38
3-8
-------
Table 3-5. DISADVANTAGES OF POWDER COATINGS WHEN COMPARED TO
ORGANIC SOLVENT-BASED COATINGS
Disadvantages Reference
1. Color changes require that appli-
cation area and powder recovery
system be thoroughly cleaned. 1, 2, 10, 26, 28, 33, 36, 40, 44
2. Tapped holes in parts require
masking. 26, 36, 45
3. Almost all thermoplastics
presently require a organic
or powder primer. 10, 16
4. Certain shapes cannot be electro-
statically coated because of the
"Faraday Effect." 10, 13, 28, 33, 40, 43, 44
5. Difficult to coat small numbers
of parts. 11, 36
6. Powders are explosive, but minimum
ignition temperature of powders
is higher than for organic
solvents. 10, 36
7. High capital costs for manufac-
turing and application equipment
for powder coatings. 26, 33
8. Electrostatic gun hoses may plug
frequently. 25
9. Difficult to touch-up complex
surfaces. 3, 13, 38
10. Metallic and some other types of
finishes available from organic
solvent-based coatings have not
been duplicated commercially in
available powder coatings. 34, 35
3-9
-------
The application of powder coatings to metal parts eliminates VOC
emissions in the coating storage, application and flash-off areas. Also,
VOC emissions from the bake oven are reduced significantly when compared to
other coatings. The only exceptions are thermoplastic powders which
require that the part be coated with an organic solvent-based primer. For
this type of operation, VOC emissions can result from the primer application
area and preheat oven. Control efficiencies developed for powder coatings
are discussed in Section 3.3.1 of this chapter. The remainder of the
discussion in this section concentrates on powder application techniques.
Powder coatings can be applied to metal parts by one of several
coating techniques which include: (a) spray, (b) fluidized bed, and
(c) electrofluidized bed.11'36'44 Application techniques most common to
the metal furniture industry are electrostatic spray and fluidized bed
coating. Sections 3.1.1.1 and 3.1.1.2 discuss these two coating techniques
in detail.
3.1.1.1 Electrostatic Spraying of Powder Coatings. Electrostatic
spraying of powder is the most widely used application technique for powder
coatings in the metal furniture industry. The basic principal of electro-
static spray is that opposite charges attract and like charges repel.
Therefore, the metal part to be coated is grounded or given a positive
charge, whereas the atomized powder particles (20 to 80 pm) receive a
negative charge at the discharge point of a spraying gun. The electrical
potential that results between the particles and the part causes the par-
ticle to be physically attracted to the part. As a result, the particles
adhere uniformly to the surface of the metal part. As the powder film
forms, the part becomes insulated and the powder charge is dispelled
through the grounded part. A uniform film which is free of voids, is the
final result.37'44'46'47 Thermosets are the preferred powder for electro-
static application because not all of the thermoplastics can be ground to
the required spraying particle size range.
If the powder is a thermoset, the film coating on the part is cured by
baking in an oven at an elevated temperature. However, for thermoplastic
powders, the part must be preheated before the powder is applied electrosta-
tically. Post heating may be necessary even for the thermoplastic powders.
3-10
-------
Usually, finished film thicknesses for electrostatically applied powder
coatings vary from about 0.025 to 0.170 mm (1.0 to 8.0 mils), depending
upon part temperature, powder particle size, electrical potential difference
between part and particles, and spraying duration. It is much more common,
however, to find film coating thicknesses of 0.025 to 0.106 mm (1.0 to 5.0
mils).36'48'49
The most common electrostatic spraying device used in the metal
furniture industry is the manual electrostatic gun. Figure 3-1 shows
schematically an electrostatic gun spraying a grounded part. The basic
components of an electrostatic gun include a basic console, powder spray
gun, spray booth, and powder recovery and recycling system. Each component
is discussed below in detail.7'12'16'25'50"53
• Basic Console
The basic console or cabinet contains the powder supply for the gun
and converts line current to high-voltage direct current. The unit contains
the air supply which is used to atomize the powder particles. Moisture
from the air supply is removed by a drier. The unit is usually equipped
with a reservoir, vibrator, air fluidizer and hose. The control regulates
air volume and pressure, voltage, amperage, vibrator frequency and powder
flow rate.11'37'50'51'53
• Powder Spray Gun
The spray is activated by manually depressing a trigger switch which
initiates powder flow and transfer of voltage. The pattern flow is deter-
mined by a deflector located inside the gun. The electrode on some guns is
cleaned by an airstream. ' This ensures that the gun provides a constant
electrical discharge to the powder particles. Also a powder hose and a
high-voltage cable are connected to the gun.
Automated electrostatic guns are mounted on vertical or horizontal
reciprocators, and operation is controlled by a master switch on the control
panel. The number of guns in an automatic system usually varies from 1 to
12 and is dependent upon part size and complexity, the extent and rate of
travel of the reciprocating guns, and the conveyor speed. Most automated
application lines require that more than one gun be employed because the
operation of several guns at a moderate output rate provides a higher
transfer efficiency than one gun operating at a high output rate.2'35'38'50'52
3-11
-------
Rosin Picks Up Charge Here
GO
I
ro
High Voltage
Semi-Conducting Paint
High-Voltage Lead
\
Resin and Air
Figure 3-1. Electrostatic gun.
-------
• Spray Booth
Powder spray booths are much simpler in design than spray booths
oo
employed for solvent-based coatings. The floors are sloped downward to
improve powder overspray collection and to allow for easier cleanout of the
spray booths. The guns are mounted in the side of the walls of the booth,
but sizes of openings are kept to a minimum to prevent powder loss. Guns
can also be mounted on both sides of a booth to allow both surfaces of a
part to be coated at one time. The interior walls are vertical and free of
any type of projections to minimize hang-up of powder.
The dimensions of the booth are governed by part size, conveyor size,
38
conveyor speed and the number of guns.
• Recovery and Recycle System
Figure 3-2 shows a spray booth with a powder recovery system. Recovery
and recycling of overspray powder is of economic significance when considering
powder coating. Most recovery systems collect powder particles by filtration
systems which are usually preceeded by cyclones. If cyclones are employed,
the largest particles are removed from the spray booth exhaust air as a
result of centrifugal action and collected in a hopper below the cyclone. '
The smaller particles are removed from the exhaust air by filtration.
Collection systems also include bag filters, tube filters, or a continuous
37
moving belt of fabric filter. The application of the belt filtration
system reduces some of the problems associated with color changes because
powder is removed after the belt leaves the spray booths. Cyclones
recover about 75 to 95 weight percent of the powder but the collection
efficiency depends upon the powder particle size.
After the airstream leaves the cyclone, particles of less than 2 urn in
size remain in the airstream. The filtration system removes about 99
weight percent of these particles, whereas, if an "absolute" filter is
employed, a total of 99.97 percent of the powder can be removed from the
airstream. After the airstream has been adequately filtered, it can be
exhausted back into the building.
For coating operations in which only one color is being used, powder
particles recovered from the cyclone and filtration system can be recycled
and about 98 percent of the overspray powder can be utilized. However,
3-13
-------
a. Reservoir and controls
b. Elevator-mounted industrial spray gun
c. High-voltage electrode and deflector plate
d. Part being coated
e. Grounded conveyor
f. Powder tube and high-voltage cable
g. Spray booth
h. Powder recovery unit
i. Exhaust fan
j. Exhaust line for powder recovery
k. Clean air returned to booth
1. Clean air exhausted to atmosphere
Figure 3-2. Powder spray booth equipped with powder recovery system.
3-14
-------
if more than one color is required, only the powder collected by the cyclone
can be reused because powder recycled from the filtration system can cause
color contamination, a problem which can be overcome if a separate filtra-
tion system is employed for each color. For operations in which color
changes are required, powder utilization depends upon a combination of the
efficiency of the powder recovery unit and the initial transfer efficiency
in the spraying booth. The effect of these two variables is shown in Table
3-6.
Powder to be recycled is pneumatically or manually transported to the
powder reservoir. This material is screened to remove oversized particles
that will not carry a charge and is mixed with virgin powder in the
1 _ O ~j "1C -3-1 OQ CT
reservoir. ' »1D»0/»°°»3-L jne voltage for most electrostatic guns can be
varied to 90 KV which provides a method of controlling powder film thickness.
The polarity of the charging electrode in the guns can be varied but most
powder particles are sprayed with a negative charge.
Transfer efficiency for electrostatic spraying of powders varies
depending upon part shape and size. The transfer efficiencies for certain
shapes and sizes are shown below. ' ' However, powder utilization
efficiency is much higher (90 percent or greater) than the transfer
efficiencies shown since oversprayed powder is recycled.
Shape Size Transfer efficiency (percent)
Flat surface Large 65-85
Wire racks and baskets Variable 50-80
Table 3-7 lists the operating parameters of powder coating lines
presently in use. This information may be representative of new coating
lines that would fall under New Source Performance Standard (NSPS) regula-
tions. These coating lines are considered to be both manually or automati-
cally operated and apply only to the spraying of thermoset powders. The
same coating lines may be employed for thermoplastics but either additional
equipment for a primer or preheating of parts might be required. In some
cases, both might be required. The coating line for powder thermosets does
not require spray primer and flash-off areas as are needed for solvent-based
3-15
-------
Table 3-6. OVERALL WEIGHT PERCENT OF POWDER UTILIZED'
Weight fraction
Powder recovery
80
85
90
Weight fraction transfer
50 65 80
82.5 90.1 95.2
85.7 91.8 96.4
89.2 94.6 97.5
'Assuming color changes, with powder in bag filters discarded,
bWeight fraction deposited on the part to be painted.
Table 3-7. PROCESS OPERATING PARAMETERS FOR
POWDER COATING LINES USING ELECTROSTATIC SPRAY
Parameter
Conveyor speed
Spacing between furniture parts
Number of cleaning stages for
parts
Dry-off oven
Application area
Electrical output of guns
Number of guns
Touch-up guns
Polarity of charged particles
Compressed air output
Powder output
Powder overspray reuse
Flash-off
Powder baking
Operating range
—___—————
1.5-14 m/min (5-45 ft/mln)1-4'7'13'15'40
0.31-0.61 m (1-2 ft)3
31, 3, 5,7,16
370-530 K (200-500°F) for 5-15 min
1,4,11
35-100 KV DC''*'
1 121-3,7,11,16,26,35
°-21'26
Positive or negative
1420-7080 m3/sec at 146-488 kg/m
(30-100 psig)35*48'49
0-36 kg (0-80 IbJ/hr/gun1 >35
97 percent
Not required for all thermosets and
some thermoplastics.
436-505 K (325-450°F) for 4-30
^1,2,4,5,7,11-13
^Usually negative.
3-16
-------
coatings (Figure 2-1). The spray booths are also not equipped with water
curtains. A powder recovery system on the spray booth is the only additional
equipment required.
The remainder of this section details process descriptions of a coating
line employing electrostatic spraying of powder and evaluates the process
parameters shown in Table 3-7. The process involves five steps which
include loading of parts on a conveyor, cleaning of parts, drying of parts,
spraying of parts, and curing of the powder coatings on the parts
(Figure 3-3). Each is discussed in detail below.
• Conveyor
All of the coating facilities studied that employ electrostatic spraying
of powder use a conveyor system (mainly overhead) which transports the
parts through a cleaning rinse, dry-off oven, spray booth, bake oven, and
unloading area. Parts are hung on hooks at specified intervals governed by
part size. Conveyors are normally loaded and unloaded by hand, but automatic
systems are available.1-4'7-12'15'17'19'28
0 Cleaning
Usually, the metal parts are cleaned in a 3-stage iron phosphate
rinse. From 1 to 3 stages of the cleaning system may consist of an iron
phosphate rinse. The purpose of this rinse is to remove oil and dirt on
the parts. This phosphatizing of the metal parts is followed by a water
rinse stage. The last stage involves spray coating the parts with a chromic
acid rinse.1-4'16'26
• "Dry-Off" Oven
The wet parts next travel through the "dry-off" oven to vaporize the
liquid on the parts. Before the parts are sprayed with powder, they are
cooled by traveling along on the conveyor in the open plant for 5 to 15
minutes.1"4'7"12
• Powder Spraying
Powder spraying of the parts can begin after parts have cooled, but
this is not a requirement for thermoplastic powders. In some automated
systems, the parts are indexed by an "electric eye" located at the entrance
of the spray booth. The electric eye is part of the automatic control that
starts and stops the powder flow to the electrostatic gun. The remainder
i_4 7-1? 90
of the spraying booth was discussed earlier in this section. ' «-,<-u
3-17
-------
Parts
Stages of cleaning
Dry-Off
Oven
co
CO
Powder Spray
Booth
No Flash-Off Area
Oven
To Assembly
of Parts
Figure 3-3. Flow diagram for a powder coating line.
-------
Some coating lines are equipped with manual spraying in a smaller
touch-up booth.
• Baking
After the parts have been coated, the coating is cured in a bake oven.
The oven itself is usually gas- or oil-fired and consists of more than one
zone. One or more of the zones are used to bring the part to a specified
temperature while the remainder of the zones maintains the part temperature.
Curing time depends upon the mass of these parts, the type of powder, and
the coating thickness. This process on the coating line is the only source
1-3 n 44 4ft 57
of VOCs on a powder coating line employing thermosetting powders. ' ' ' '
The flow diagram in Figure 3-3 shows the equipment that would be
needed for powders that require parts to be prime coated first. Emissions
of VOCs would also result from the primer application, the preheat oven,
and the post heat oven (if required).
In the area of new developments in application techniques, a high
A
speed rotating disk has been used to powder coat office cabinets and desks.
The disk is a spraying device that could replace the electrostatic gun on a
powder coating line. Powder particles are discharged from the disk which
rotates at high centrifugal speeds (30,000 rpm), and the particles are
atomized by a combination of centrifugal and electrostatic forces. The
disk offers higher transfer efficiencies and is considered to be an
improvement over the electrostatic gun. ' '
Section 3.1.1.2 discusses the second application technique (fluidized
bed) employed in the metal furniture industry. This application technique
is used when an extra thick coating is desired.
3.1.1.2 Fluidized Bed Application of Powder Coatings. Figure 3-4 is
a schematic of a metal part to be powder coated in a fluidized bed. The
metal part is cleaned by the same iron phosphate system discussed in
Section 3.1.1.1. For parts to be coated with a thermoplastic powder, an
organic primer (or sometimes a powder) is added to the surface of the part.
Next, the part is preheated above the fusion point of the resin particles
and is dipped manually or automatically into the fluidized bed where the
particles melt onto the part. Loose powder is blown or shaken from the
formed film. For thermoplastics, the coating solidifies as the part cools
3-19
-------
PREHEATED
PART TO BE_
COATED
POROUS
PLATE
t1
mr\ v,
,
•iir»'iui_r\
T
LOW PRESSURE AIR
Figure 3-4. Part coating in a fluidized bed of powder.
3-20
-------
on the conveyor line. However, for some thermoplastics and all thermosets,
post heating is required. The post heating of some thermoplastics is
employed to provide a more uniform film. After the coating has cured and
the part is sufficiently cool, each part is removed manually from the
1,10,14,28,33,36,38,39
conveyor line. ' ' ' '
A particle recovery system much like those employed for electrostatic
spraying systems can also be used to collect resin particles from the top
of the fluidized bed. Resin particles, because of the decreasing particle
size, are elutriated from the fluidized bed. A slightly negative pressure
is maintained across the top of the fluidized bed of resin particles to
collect this elutriated material. The resin particles are collected by
either a cyclone and filtration system, or both. '
The fluidized bed application technique is preferred in the metal
furniture industry for thermoplastics coating operations. Thicker protec-
tive films can result from this application technique. Coating thicknesses
can range from 0.15 to 1.5 mm (6 to 60 mils); they depend upon mass and
temperature of the part and part residence time within the fluidized bed of
resin particles.10'28'36'58 In fact, two different coatings (vinyl and
polyester) have been applied with this application technique to the same
chair parts.
Emissions of VOCs can result from the following processes when
10 29
applying either a thermoset or thermoplastic: '
Coating Process source of VOC emissions
Thermoset Bake oven
Thermoplastic (no primer)3 Bake oven
Thermoplastic (organic primer)3 Primer application area, preheat
oven, and bake oven
Emissions of VOCs from the bake oven only result if post heating is
3required.
Table 3-8 contains process operating parameters for fluidized bed
coating lines presently operating in the metal furniture industry. These
data are representative of the new coating lines that would fall under NSPS
regulations.
3-21
-------
Table 3-8. PROCESS OPERATING PARAMETERS FOR POWDER COATING
LINES USING FLUIDIZED BED
Parameter
Operating range
Conveyor speed
Spacing between furniture parts
Number of cleaning stages
for parts
Dry-off oven
Primer applicationa
Flash-off3
Preheat oven
Particle resin size
Air flow through fluidized
bed
Bake ovenc
Cool down time
2.4-4.9 m/min (8-16 ft/min)11'59
0.31-0.61 m (1-2 ft)3
3-611
370-530 K (290°F-500°F) for 5-15 min.
One coat11
8 min.11
400-615 K f275°F-650°F) for 4-6
min.ll'39*59
200 y and above.60
15:61 m3/hr per m2 of plate (50-200
ftYhr per ft* of plate)"30
440-500 K (340°F-450°F) for 4-30
rnin.11*58
11
5-15 min.
10
Only required for certain thermoplastic powders.
temperature will vary depending upon resin type.
••
"Bake oven required for all thermosets and some thermoplastics where
film uniformity is a problem.
Applies only to thermoplastics that cure as a result of cooling.
3-22
-------
3.1.2 High Solids Coatings
A second coating formulation change currently employed in the metal
furniture industry to reduce VOC emissions is high solids coatings. This
group of coatings is oligomeric and includes such general categories as
radiation curable systems, "high solids coatings" (anything greater than
50 percent by volume solids is being considered) and the already discussed
powder coatings (see Section 3.1.1). The radiation curable systems are not
discussed. These types of coatings are not being used in the metal furniture
industry since there is a potential health hazard associated with the
isocyanate emissions from these coatings, and the difficulties involved
61 62
in curing these coatings. '
Table 3-9 shows the types of metal furniture products being coated
with higher solids coatings. All coatings are being applied by electro-
static guns unless specified otherwise in the table. Other industries
which require surface coating and which are investigating and using high
C O_ "7 C
solids include the automotive, can, coil, and appliance industries.
Surface coating of appliance parts with high solids has been very success-
ful. The metal furniture industry is studying everything from 50 to 100
percent by volume solids.
The chemical composition of high solids coatings consists of
modifications of their solvent-based counterparts. High solids coatings
are categorized into two general groups: two-component/ambient curing and
single-component/heat-converted materials. The general chemical composi-
tion of both groups includes synthetic resins, pigments, additives, and
solvents at a reduced concentration (when compared to solvent-based coatings).
The general properties of pigments and additives have been mentioned in
Section 3.1.1. The synthetic resin types that have been developed for
single-component/heat-converted materials include epoxy, acrylic, polyester
and alkyd. The two-component systems include acrylics, polyesters, epoxys,
en -jr\ -}•} 77—QC
urethanes, and others. ' ' ' The single- and two-component coatings
offer several advantages and disadvantages which are presented in Table
3-10 and 3-11, respectively.
Three spraying techniques can be employed to apply single- and
two-component high solids coatings: (1) air atomization, (2) airless
atomization, and (3) electrostatic methods.44'81'97'101'102
3-23
-------
Table 3-9. METAL FURNITURE PRODUCTS BEING COATED WITH HIGH SOLIDS
Product
Panel and desk
parts
Metal drawers
Metal furniture
parts
Shop furniture
and shelving
Office
furniture
Metal furniture
parts
Metal furniture
parts
Lighting fix-
tures, shelving,
and office
furniture3
Metal furniture
shelving.and
fixtures0
Resin Solids content
type by volume (%)
Acrylic/
polyester 54
Alkyd
Alkyd 55
Alkyd
Acrylic/
polyester
—
56
Alkyd
enamel 66-80
Alkyd-
ami ne 62
Coating
thickness (10~3 cm) Reference
3.05 10
2.54-3.81 63
64
65
65
66
67
68
68
(continued)
-------
Table 3-9. Concluded
Product
Steel office
furniture
Steel .
shelving
Steel .
shelving
Resin
type
Polyester
Alkyd
Polyester
Solids content Coating.,
by volume (%) thickness (10" cm)
60
67
65
Reference
68
68
68
aThe low range of solids coating applied by disc and the high range of solids coating applied by
high speed disc.
Coating applied by disk.
cCoating applied by high speed bell or disk.
Coating applied by high speed disk.
-------
Table 3-10. ADVANTAGES FOR HIGH SOLIDS COATINGS WHEN
COMPARED TO CONVENTIONAL ORGANIC SOLVENT-BASED COATINGS
Advantage Reference
1. Reduction of VOC emissions. 44, 86-109
2. Reduced shipping costs, inventory,
and handling of drums containing
the coatings. 44, 87, 88, 94, 95
3. Potential for reduction of energy 44, 69, 79, 81, 87-92,
usage to cure coatings. 94, 100
4. Reduced air flow rates through
spray booths and bake ovens. 81, 89, 105
5. Less coating is applied to obtain
same dry film thickness. 67, 70, 80, 87, 90, 104
6. Two-component systems can cure
under ambient conditions. 77
7. Higher production rates can be
achieved. 69
8. Color matching comparable to
solvent-based paints. 69
9. Utilization of paint heaters, high
speed disks and bells can result in
the application of coatings that
contain more solids. 93-97, 101-103, 110
3-26
-------
Table 3-11. DISADVANTAGES FOR HIGH SOLIDS COATINGS WHEN
COMPARED TO ORGANIC SOLVENT-BASED COATINGS
Disadvantage Reference
1. Higher viscosity in application area. 44, 88, 97
2. Reduced shelf-life for two-component ..
coating.
3. Less latitude with in-plant formula ..
modifications.
4. Short pot lives for some two-component ft,
coating systems.
5. Elaborate feeding equipment required
for two-component coating systems. 81
6. Premature loss of solvent caused by
preheating. 97
7. Possible requirement of careful
metal preparation. 10, 67, 69, 90
8. Decrease in quality of mechanical
properties of a coating as the
molecular weight of the resin
decreases. 93
9. More difficult spray booth cleaning
due to tackiness of some high solids
coatings. 10, 67, 80
10. "Faraday effect" is a problem for
certain shapes. 33, 34
11. Metallic finishes from organic solvent-
based coatings have not been matched with
other high solids coatings.
3-27
-------
Air atomization uses its own air supply which may be heated, filtered,
humidified, or a combination thereof. Airless atomization is accomplished
by forcing the coating through spray nozzles under a pressure of 6.9 to
13.8 MPa (1,000 to 2,000 psig). Both the air and airless spraying techniques
exhibit poor transfer efficiencies. ' As a result, these spraying
techniques are not common for applying high solids coatings in the metal
furniture industry. These two spraying techniques are mainly employed for
touch-up work for parts that exhibit the Faraday Effect. Therefore, the
spraying technique this section concentrates on is spraying by electrostatic
methods.
The three basic types of electrostatic spraying techniques that have
been successful in applying high solids coatings at acceptable transfer
efficiencies (greater than 50 percent) are listed below and shown
schematically in Figure 3-5:81»93,94,101,102
Type of Spray Equipment Mechanical Energy for Atomization
Air atomization - electrostatic guns Compressed air
Airless or hydraulic atomization -
electrostatic guns Hydraulic
Electrostatic atomizing -
electrostatic disks and bells Centrifugal and electrostatic
For electrostatic guns using air and airless atomization, the coating is
atomized by compressed air or mechanical forces and charged electrostatically.
In the disk or bell systems, a combination of mechanical force (centrifugal)
and electrostatic means are used to atomize, charge, and deposit the coating.
Transfer efficiencies achieved by applying high solids (60 to 70 percent by
volume solids) with the disks and bells range from 80 to 90 percent regardless
of part shape. These systems are schematically shown in Figure 3-5. '
Each electrostatic system is equipped with coating handling equipment.
The air and airless electrostatic guns are supplied from a pressure fed
device with a fluid regulator or metering valve, and an air driven piston
pump with a fluid regulator, respectively. Two-component coating systems
present additional equipment problems associated with the varying pot lives
of the coatings. The pot lives of certain two-component coatings and mixing
requirements of equipment located before the electrostatic spraying device
01
are listed below:
3-28
-------
Coating
Coating
(a) Electrostatic Gun
Paint
Spraying
Direction
Rotating Disk
(b) High Speed Disk
Paint
^- Spraying
Direction
High
Voltage
Drain
(c) Mini-Bel
Figure 3-5. Schematic of high solids coatings spraying equipment,
-------
Pot Life
One to five minutes
Five minutes to eight hours
spray device
Eight hours
supply tanks
Mixing Equipment
External mix at the site of
atomization
Static mixers located close to the
Static mixers or premixers in fluid
Figure 3-6 shows how electrostatic equipment is fed with static mixers
depending upon pot lives that are associated with two-component coatings.
All of the feeding systems in Figure 3-6 are automatically controlled to
maintain a close relationship (± 5 percent) between the coating and the
catalyst. This is done to avoid the coatings' curing in the spraying
device, or at some other earlier stage of processing before the baking
ovens. Paint heaters constitute additional equipment which may be neces-
sary for electrostatic guns. Some single- and two-component coatings
must be heated to a flowable viscosity. Paint heaters, however, are not
always necessary for disk or bell systems. These systems seem to be parti-
cularly well suited to the application of high solids coatings. ' '
The remainder of this section discusses the process description of a
representative high solids coating line, and describes the various sources
(including fugitive) of VOC emissions. The process description of a coating
line is very similar to that of an organic solvent-based coating line. The
line consists of a conveyor and cleaning, dry-off, application, flash-off,
and baking areas. The conveyor, cleaning, and dry-off areas are basically
the same as the powder coating lines and are not discussed in this section.
The application, flash-off, and baking areas are discussed below:
t Application Area
This area includes the spray booth, electrostatic spraying device,
possibly a paint heater, and paint mixing equipment. Of these, only the
spray booth has not previously been discussed.
Spray booths on high solids coating lines are downdraft or sidedraft
design and can be smaller in size when compared to conventional solvent-
based spray booths because less makeup air is required to handle VOC
3-30
-------
Ratio pump or
other feed source
Short Pot Life Systems
Rotating head
dual-disk atomizer
External
mix manual
spray gun
Ratio pump or
other feed source
External mix
Electrostatic
airspray gun
with static
mi xer
Medium or Long Pot Life Systems
Rotating head
disk atomizer
Ratio ump or
other feed source
Ratio pump or
other feed source
Figure 3-6. Static mixers.
3-31
-------
emissions. '' Most spray booth dimensions are based on the largest
part to be coated.
For electrostatic systems, the spray booth is equipped with hand held
and automatically operated guns, disks or bells. The number of electrostatic
guns reported to be in use (mounted on vertical or horizontal reciprocators)
range from one to twelve. For spray booths using a disk, the booths are
designed in a circular shape. Also, coating lines equipped with disks or
bells usually require two of each of these atomizing devices.
Due to the difficulty of controlling film thickness with high solids
paints, automatic electrostatic spraying systems are usually employed;
69 94 112
manual equipment is used for touch-up only. ' '
• Flash-Off Area
A flash-off area is required to allow a prescribed amount of solvent to
evaporate before the coated part enters the bake oven. This prevents bubbling,
44
uneven coating thickness, etc.
Enclosed flash-off areas used with high solids coatings, when compared
to conventional solvent based coatings, require less residence time for the
89
coated part and allow reduced air flows. However, most flash-off areas
in the metal furniture industry are not enclosed.
• Baking Oven
Two-component systems require little or no baking to cure the resins.
However, single-component coatings require baking at 425 to 450 K (300° to
350°F) which aids in the crosslinking of reactive groups, like hydroxyls or
carboxyls, with ami no compounds.
The process operating parameters are summarized in Table 3-12. This
information is considered to be representative of a new coating line using
high solids coatings.
Emissions of VOCs from high solids coating lines result from the
application, flash-off and baking oven. For plants in which the flash-off
area is not enclosed, VOC emissions that result from this area are con-
sidered to be fugitive. The other part of the plant that might be a source
of fugitive VOCs is the coatings storage area. Section 3.3.2 discusses
control efficiencies of high solids coating systems compared to conventional
organic solvent-based coatings.
3-32
-------
Table 3-12. PROCESS OPERATING PARAMETERS FOR
HIGH SOLIDS COATING LINES
Parameter
Operating range
Conveyor speed
Parts spacing
Number of cleaning stages for
parts
Dry-off oven
Application area
Electrostatic gun systems
Number of guns
Touch-up guns
High solids output
Compressed air
Electrostatic disk systems
Number of disks
Rotation speed
High solids output
Disk diameters
Air requirements
Electrostatic bell systems
Number of bells
Rotation speed
High solids output
Air requirements
Coating thickness
Electrical output
1-4 10
1 H'1U
1.5-14 m/min (5-45 ft/min).
0.31-0.61 m (1-2 ft)3
3_510,64,67,69
370-530 K (200-500°F) for 5-15 min.
1_1264'67
0_264,67
200-1500 1/min (0.05-0.4 gal/min)113'114
1420-7080 m3/sec at 150-490 kg/m3
(30-100 psig)37'50'51
,108
.70
1800-20,000 RPM'
0-1000 1/min (0-0.3 gal/min)115'116
200-500 mm (8-20 inches)115'116
0.009 m3/sec (18 CFM) at 190 kg/m3
(40 pslg)115'116
2-694
900-30,000 RPM70'94'117
0-400 1/min (0-0.1 gal/min)117
0.005 m3/sec (10 CFM) at 290 kg/m3
(60 psig)117
(0.5-2.0 mil)70'112
0-140 KV118
(Continued)
3-33
-------
Table 3-12. Concluded.
Parameter Operating range
Bake oven
High solids baking
Single-component 410-470 K C275-4000F>63'64'7Q'81
97,102
Two-component 340-360 K (150-180°F) for 10 nrin.19
3-34
-------
3.1.3 Waterborne Coatings
One of the control techniques presently employed in the metal furniture
industry is the use of waterborne coatings. These coatings can be applied
by conventional or electrostatic spray, conventional or electrophoretic
dip, or flow coating lines to a wide variety of parts. Waterborne coatings
are being successfully applied in the automobile, coil, appliance, metal
can, and electronics industries as well as in the metal furniture
11Q-104
industry.liy '^
The term waterborne refers to any coating which uses water as the
primary carrier combined with organic solvent and is differentiated from
pure organic solvent-borne paints. There are basically three types of
waterborne coatings: latex or emulsion paints, partially solubilized
125
dispersions, and water-soluble coatings. Table 3-13 lists the proper-
ties of these three types of paints. Most current interest is centered
around the partially solubilized dispersions and emulsions. Emulsions are
of particular interest because they can build relatively thick films without
1 ?fi 1?7
blistering and they contain no noxious amine solubilizers. '
Most of the solubilized waterborne paints are based on alkyd or polyester
resins. Table 3-14 shows the solids and water content of several types of
waterborne paints.
A common method of solubilizing is to incorporate carboxyl-containing
materials such as maleic anhydride and acrylic acid into the polymer. The
acids are then "solubilized" with low molecular weight amines such as
triethylamine. After application, the coatings are baked and the water,
128
solvent, and amine evaporate leaving a pigment film on the object.
The use of waterborne coatings can reduce the explosion problem
associated with organic solvent-based paints. Some organic solvents are
used, but the amount used is greatly reduced. Waterborne coatings have the
additional value of reducing the amount of air flow needed from the
application areas and curing ovens and can reduce energy consumption.
In organic solvent-based paints, relatively few monomers can be used
because of solubility and viscosity. Molecular weights are especially
restricted. In waterborne coatings, the selection of useable monomers is
much wider. In addition, waterborne paints can contain a higher solids
3-35
-------
Table 3-13. PROPERTIES OF WATERBORNE COATINGS
Properties
Latex or
emulsion
paints
Partially
sol utilized
dispersions
Water-soluble
coatings
Molecular weight
Viscosity
Viscosity
control
Solids content
Gloss
Chemi cal
resistance
Exterior
durability
Impact
resistance
Stain
resistance
Color reten-
tion on oven
bake
Reducer
Wash-up
Up to 1 million 50,000 to 200,000 20,000 to 50,000
Low - not de-
pendent on mole-
cular weight
Require thick-
ness
High
Low
Excellent
Excellent
Excellent
Excellent
Excellent
Water
Difficult
Somewhat depen-
dent on molecu-
lar weight
Thickened by
addition of
co-solvent
Medium
Medium
Good to
excellent
Excellent
Excellent
Good
Good to
excellent
Water
Moderately
difficult
Very dependent on
molecular weight
Governed by mole-
cular weight and
solvent control
Low
High
Fair to good
Very good
Good to excellent
Fair to good
Fair to good
Water or solvent/
water mix
Easy
3-36
-------
Table 3-14. SOLIDS AND SOLVENT
CONTENT OF WATERBORNE PAINTS
Waterborne
paint system
High solids polyester
Coil -coating polyester
High solids alkyd
Short oil alkyd
Water reducible polyester
Water reducible alkyd
High solids water reducible
Solids content
volume percent
80
51
80
34
48
29
80
Water to
solvent ratio
80/20
51/49
80/20
34/66
82/18
67/33
90/10
conversion varnish
3-37
-------
content than organic solvent-based coatings without an increase in
42
viscosity.
An additional advantage of waterborne systems is ease of cleanup.
Waterborne paint systems can usually be cleaned with water whereas organic
solvent-based systems require solvents for cleaning. Organic solvent may
be needed for cleanup of waterborne systems if the paint has dried.
A problem associated with waterborne systems is the propensity to rust
and corrode. Coating lines, including ovens, must therefore be protected
by the use of stainless steel or some other appropriate material.
Another disadvantage is the requirement for more pretreatment. Most
organic solvent-based systems can tolerate small amounts of grease or oil
on the surface to be coated because they have the ability to "self clean"
the part. This is not true for most waterborne systems in that the surface
129
must be totally oil free or the paint will not adhere properly. This
can increase pretreatment costs. On the other hand, drying is not always
needed prior to coating; therefore this step may be eliminated and
pretreatment costs decreased.
Ambient humidity levels can cause problems for waterborne systems. On
days of high humidity the drying process may be slowed, requiring proper
air conditioning to overcome the problem. In addition, a longer flash-off
time is usually needed for waterborne systems thereby increasing space
requirements.
Color availability has been suggested as a problem with waterborne
coatings. One furniture manufacturer reports, however, that any color can
be obtained and that the quality of the finish is as good or better than
122
that of organic solvent-based systems.
Summaries of the advantages and disadvantages of waterborne paints are
presented in Table 3-15 and 3-16. The use of these coatings in the metal
furniture industry is limited at present; however, it is expected to
130
increase.
3.1.3.1 Waterborne Spray. Spraying of waterborne paints has been
used little in the past although it is a growing technology. At present,
waterborne paints are being applied electrostatically on commercial equip-
ment,131"133 farm machinery,134'135 automobiles,136 fabricated metal
3-38
-------
Table 3-15. ADVANTAGES OF WATERBORNE COATINGS
1. Reduction of fire or explosion potential and toxicity in
both the storage and application areas.
2. Greater variety of available monomers.
3. Higher solids content possible at same viscosity.
4. Lower raw material cost (e.g., water vs. solvent).
5. Ease of clean-up.
6. Good selection of colors.
7. Good quality finish.
8. Can be formulated for metal!ics.
9. Rapid color changes possible.
Table 3-16. DISADVANTAGES OF WATERBORNE COATINGS
1. Protection of equipment against rust needed.
2. More pretreatment may be required than for organic
solvent-based paint.
3. Longer flash-off may be required.
4. Humidity control equipment may be necessary.
5. Possible emission of amines to the atmosphere.
6. "Faraday effect" is a problem for certain shapes.
7. Metallic finishes from organic solvent-based coatings have
not been matched with other waterborne coatings.
3-39
-------
products,137"139 and appliances',140 as well as on metal furniture.122'141'142
Since waterborne paints are readily atomized, they can be applied by
140 143
air, airless, or by electrostatic spray using guns, disks, or bells. '
These can be operated manually or automatically. Waterborne and organic
solvent-borne pai.its are generally of similar viscosity; therefore, there
are few if any differences between spray systems for the two coating types.
Waterborne paints are more corrosive however, and require the use of
stainless steel or plastic pipes and pumps, and stainless steel or aluminum
spray nozzles.
The only significant problem associated with electrostatic spraying of
waterborne paints is a safety hazard resulting from the high conductivity
of the paint itself. As the paint is charged at the gun, the charge travels
back through the supply line to the paint reservoir. The system, therefore,
must be insulated or isolated. This presents no problem for small operations;
however, for large facilities using separate paint supply rooms, it presents
a significant problem. There is a possible method for overcoming this
disadvantage. It involves the use of a small paint reservoir at the spray
booth which, through the use of a level sensor, is automatically filled as
needed from the main paint supply line. The supply line is equipped with a
spray nozzle similar to that of a garden hose and the line is grounded.
The small paint reservoir is charged to approximately 90 kV and is isolated.
As the supply line fills the reservoir, the electrostatic charge atomizes
the paint, thus producing an air gap between the reservoir and the nozzle.
This gap isolates the supply line and paint supply room from the electro-
static charge at the booth. Color changes with this type of system can be
accomplished through the use of multiple reservoirs at the spray booth.
These buckets are small and could be changed within a matter of seconds.
The system appears to be technically feasible although it has not been
applied to an actual coating line. The technology was developed by the
Applied Technology Division of TRW, Inc., while designing a charged droplet
scrubber. The system has been successfully tested for that operation.
The basic spray painting process using waterborne paint differs very
little from a process using organic solvent-borne coating. Emissions
come from the spray booth, flash-off area, and curing oven. The magnitude
3-40
-------
of the emissions is dependent upon the organic solvent content of the paint
and the efficiency with which it is applied. Transfer efficiency for
conventional spraying ranges from 30 to 60 percent depending upon a number
of variables including part complexity. Electrostatic spraying by guns,
disks, and bells can increase to levels ranging from 60 to 95 percent. '
3.1.3.2 Waterborne Dip Coating. Dip coating is one of the most
145
common techniques for the application of waterborne paints. This method
is presently being used in the automobile and bicycle industries as well as
in the metal furniture industry. The dip coating process is
essentially the same for waterborne as with organic solvent-borne coatings.
The dip tank must be constructed of stainless steel or some other corrosion
resistant material and the flash-off period may have to be longer for the
reasons previously explained. These are the only significant differences
between the two systems.
The factors affecting emissions from a dip coating line are the same
as for spray coating. The transfer efficiency for dip coating of waterborne
paint is estimated at 90 percent which is the same as for organic
solvent-borne paint.
3,1.3.3 Electrodeposition of Waterbornes. Electrodeposition (EDP) of
waterborne paint is one of the most promising emission control techniques
available. It has proved successful when applied to automobiles, lawnmowers,
metal furniture, and miscellaneous other metal parts and products.
Electrodeposition is capable of applying a 0.25 urn (1 mil) coating in a
single application which makes it very attractive to the metal furniture
industry. Autophoretic coating which is similar to EDP is not used in the
metal furniture industry because this technique is presently limited to
150
black paint only.
Electrodeposition involves lowering parts to be coated into a tank of
low solids waterborne coating solution. The tank or the periphery of the
tank are negatively charged while the parts are grounded. The negatively
charged polymer is attracted to the metal surface and is deposited uniformly.
152
Systems of opposite polarity can also be used. Figure 3-7 represents a
typical EDP line using ultrafiltration.
3-41
-------
CO
I
-P*
ro
Deionized Water
S IS —
v^Conveyor ^x" >^gJ^.-j
Electrodeposition
Dip Tank
Paint Supply
Rinse Tank #2 Rinse Tank #3
Paint Return
Ultrafiltration
Ultrafiltrate
Holding Tank
Drain
Figure 3-7. Typical EDP coating system.
-------
Electrodeposition lines require a deionized water rinse stage at the
end of the pretreatment cycle which is not found in other systems; however,
a dry-off oven, though often used, is not required. The rinsed parts are
lowered into the EDP tank containing waterborne paint consisting of a 7 to
1 ^"3
10 percent dispersion of a colloidal polymer. To avoid striping, the DC
current is not applied until the parts are totally submerged. Dwell time
in the tank is typically 1.5 to 2 minutes.153'154 The thickness of the
coating can be controlled by selecting the appropriate dwell time and
electrical potential. The voltage ranges from 50 to 400 volts and the
amperaqe ranges from 50 to 4,000 amps. Average conditions involve a voltage
125 152
of 200 to 250 volts and an amperage of 300 to 450 amps.
After the current is turned off, the parts are lifted from the bath,
drained, rinsed in deionized water to remove "dragout," and then baked.
Solids from the dragout are carried by the rinse water and collected by
ultrafiltration. The rinse water is passed through an ultrafilter which
allows no particles larger than 200 angstroms to pass. Only water, some
electrolyte, and organic solvent permeate the filter and are reused in the
41
rinse. Resin and pigment materials are returned directly to the EDP tank.
This process is reported to reduce paint consumption by up to 30 percent. '
The quality of the finish is affected by voltage, amperage, tempera-
119
ture, dwell time, pH, and paint solids content. Excessively high voltage
causes holes in the coating due to gassing. Too high a temperature is
detrimental due to possible paint flocculation at temperatures approaching
305 K (90°F). At high pH levels, there is a reduction in deposition; if
the pH drops below the isoelectric point, the entire tank of paint can
coagulate.
As the paint solids are attracted to the grounded metal part, they
tend to "wring" the water out of the coating leaving the coating which is
approximately 90 percent solids with the remaining 10 percent consisting
primarily of water. Approximately 2.5 percent of the coating on the sub-
-i pc
strate is volatile organic solvent. If the solids content in the EDP
tank is too high, the voltage cannot "wring" the moisture from the deposited
film; if the paint is too low in solids, the film can be too thin.
3-43
-------
Furniture parts painted With EDP are normally baked for 15 to 30
minutes at 410 to 480 K (275° to 400°F).
The EDP process has three potential sources of VOC emissions: solvent
evaporation during curing, evaporation from the surface of the EDP tanks,
and evaporation from the cascading rinse water. Emissions from the tank
surface and the rinse water are very minor. This is due to a large extent
to the ultrafiltration process. Emissions from the curing oven are low due
to the small quantity of solvent on the wet substrate.
3.1.3.4 Waterborne Flow Coating. Waterborne flow coating is
essentially no different from flow coating with organic solvent-based
paint. This process has seen use in several industries including those
producing major appliances, trailers, and metal furniture.158'159 As with
other types of waterborne applications, certain precautions have to be
taken to prevent rusting of the flow coating chamber and nozzles.
Sources of emissions from this system are the flow coating chamber,
flash-off area, and curing oven. Emissions from the flash-off and curing
steps are similar to other waterborne processes. Emissions from the flow
coating chamber are dependent upon the transfer efficiency which is achieved.
This is estimated to be approximately 90 percent.
3.2 EMISSIONS CONTROL WITH ADD-ON CONTROL EQUIPMENT
Each of the following sections describes add-on air pollution control
equipment for VOC emissions as follows:
• Processes which employ add-on control equipment in the metal
furniture industry
• Principle behind add-on control devices
• Variables of performance
• Process descriptions
t Advantages and disadvantages
• Process VOC controls
• Operating parameters for new add-on control devices.
3.2.1 Carbon Adsorption
Carbon adsorption as a control technique has been commercially used
for several years. Although carbon adsorbers are not being employed in the
metal furniture industry, nor any other metal coating industry to date,
3-44
-------
several other facilities within the surface coating industry have used
carbon adsorption to control VOC emissions. These industries include those
which surface coat paper, and rubber products.I60~163 it is felt that
carbon adsorbers have the potential to be incorporated in the metal
furniture industry.
In general terms, the principle behind adsorption as it applies to the
metal furniture industry includes the following. The "activated" carbon
constitutes the adsorbent, and the organic solvent that is removed from an
airstream is referred to as the adsorbate. For the metal furniture industry,
there is a mixture of organic solvents or adsorbates. These include a
complex combination of aliphatics, aromatics, esters, ketones, alcohols,
etc. ' ' Adsorption of the adsorbates occurs at the surface of the
adsorbent. The effectiveness of the adsorbent depends on its surface area,
porosity and existence of capillaries. In the metal furniture industry,
for each adsorbate removed, the type of adsorption is "physical." Physical
adsorption means that the adsorbates are collected by and removed from the
adsorbent without a chemical change. All adsorption processes are exother-
mic, and for surface coating operations, the temperature change in a carbon
bed would be about 10 K.34'164'165
There are several variables which affect the performance of carbon
adsorbers and most are related mathematically to the adsorptive capacity of
the carbon. This term, adsorptive capacity, defines the weights of adsor-
bates that can be retained on a given weight of carbon and is expressed
below:166
Adsorptive Capacity = T 1ogV(Co/Ci)
where, adsorptive capacity = 9 of adsorbate
v ^ J g of adsorbent
Vm = liquid molar volume of adsorbate at normal boiling point
T = absolute temperature
Co = concentration of adsorbate at saturation
Ci = initial adsorbate concentration into adsorber
The liquid molar volume of an individual adsorbate is related to the
individual molecular weight and density of the solvent at its boiling
3-45
-------
point. The greater the Vm of the adsorbates, the higher the molecular
weights and boiling points. In other words, carbon generally has a greater
adsorptive capacity for higher boiling solvents. The removal of solvents
by physical adsorption is practical for adsorbates with molecular weights
32
over 45. The actual quantity of adsorbates removed increases as their
concentration increases and the adsorbent temperature decreases.
Generally, physical adsorption of a group of adsorbates in the metal
furniture industry results in both low and high boilers at first being
adsorbed across the bed uniformly. However, as more high boilers increase
on the adsorbent, the more volatile portion of the adsorbates are vaporized.
At this point, the bed has reached the breakthrough point. This process
continues until the exit airstream contains the highest boiling component
which means the adsorbent is saturated. In practice, it is best to operate
the carbon bed until the breakthrough point has been reached and then the
32
bed is regenerated.
Figure 3-8 shows a typical carbon adsorption process and is repre-
sentative of a unit that could be installed at a metal furniture facility.
Usually, the equipment consists of a filter and cooler, blower, two carbon
beds, condenser, and decanter. The blower maintains a constant flow of
organic vapor-laden air to the unit. As the airstream travels through the
carbon adsorber, it is first filtered to remove particulate matter and
cooled to no greater than 311 K (100°F). The adsorbates in the airstream
are adsorbed onto the activated carbon in one of the two carbon beds.
Usually, two carbon beds are adequate for continuous operation; one unit
adsorbs gaseous organics, while the other is desorbed with steam or hot
air. However, three or more carbon beds may handle more effectively the
heterogeneous mixture of adsorbates resulting from the surface coating of
metal furniture. For the three bed case, two beds in series operate while
the third is regenerated. This permits the activated carbon bed to remain
in service after breakthrough since the second bed in series removes the
low boiling solvents emitted from the first bed. When the first bed becomes
saturated, it is removed from service and regenerated. The second bed then
becomes the first bed and the newly regenerated bed is the new second bed
in series.34'164'166'167
3-46
-------
Stripped
Air
Vapor-
laden
Air-
stream.
CO
I
I
Filter
Cooler Blower
Adsorber No. 1
y
Adsorber No. 2
Low-pressure
Steam
•>
Condenser
Jte covered
"Solvent
Water
Decanter
Figure 3-8. Carbon adsorption process.
-------
During the desorption process, organics are removed from the carbon
bed by blowing steam, hot air or inert gas across the bed. The removed
organic vapors and steam (the preferred carrier gas) are liquified from the
airstream in a condenser. The collected solvents and water are then
separated in a decanter. To separate the recovered mixture into reusable
solvents would require fractional distillation. ' An alternative to
this approach is to incinerate the organics in order to recover heat to
produce steam for other processes at the plant. ' '
Tables 3-17 and 3-18 list advantages and disadvantages for employing
carbon adsorbers on coating lines in the metal furniture industry. The
advantages and disadvantages discussed relate only to carbon adsorbers that
have the potential to be employed on coating lines that apply conventional
solvent-based paints to metal parts. The remainder of this section concen-
trates upon the emissions from a coating line and determines what processes
on the coating line can be controlled by carbon adsorbers.
Theoretically, carbon adsorbers could be employed to control VOC from
the application, flash-off and bake oven areas. The applicability of doing
this is discussed in detail for each process area that emits VOCs.
Carbon adsorbers could be used to control VOCs from all of the
different types of application techniques (including touch-up) such as
spray, flow, dip, and roller coating. The percent of VOC emitted from the
44
application areas is shown in Table 3-19. The table indicates that
carbon adsorbers are best employed for coating methods using spray and
flow. All of the coating methods could feasibly be controlled by this
method if the flash-off area were enclosed and flash-off air were vented
along with the air from the application area to the carbon adsorber.
Generally, most of the emitted solvents from the application and flash-off
areas used in the metal furniture industry fall into a molar volume range
(80 to 190 cmVmole) that is generally acceptable for adsorption. Table
3-20 lists some of the solvents that present problems for carbon adsorbers.
Of the solvents listed, nonane (a component of most grades of mineral
spirits) is commonly used in the metal furniture industry. Mineral spirits
are used in substantial proportions in many alkyd and acrylic enamels but
might not be effectively desorbed with either super heated steam or hot
3-48
-------
Table 3-17. ADVANTAGES FOR EMPLOYING CARBON ADSORBERS
Advantage Reference
1. Proven technology for controlling
solvent emissions in other non-related
industries. Ill, 168, 169
2. If treating a homogeneous phase, reduced
costs because of solvent recovered. Ill, 168
Table 3-18. DISADVANTAGES OF EMPLOYING CARBON ADSORBERS
Disadvantage Reference
1. Carbon beds that treat exhaust concentrations
of 100-200 ppm of solvent require large
amounts of steam during regeneration (30 kg/
kg of solvent). 44, 164, 168
2. Materials of construction must be
corrosive resistant. 44, 164, 168
3. The Mass Transfer Zone (MTZ) will increase
as air velocities increase. 44, 164
4. Increased non-production related operating
costs of a facility. 168
5. Adsorbers have to handle a mixture of
solvents. 44
6. Effluents from bake ovens must be cooled
to less than 310 K (lOQOF). 44
7. Water vapor (spray booths) from the
application area would compete for
adsorptive sites. 44
8. High boiler solvents emitted from the bake
oven would be difficult to desorb. Ill, 170
9. Polymerized products and plasticizers from
the bake oven could foul a carbon bed. 44
10. Carbon bed fires can occur. Ill
11. Any particulate can coat a carbon bed and
render it ineffective. 44
3-49
-------
Table 3-19. PERCENT OF TOTAL VOC EMISSIONS
42
FROM VARIOUS COATING STEPS
Coating Method3
Spray Coat
Flow Coat
Dip Coat
Roller Coat
Coating Step
Application Flash-Off
30-50
30-50
5-10
0- 5
10-30
20-40
10-30
10-20
Bake Oven
20-40
10-30
50-70
60-80
aCoating only with organic solvent-based coatings.
Table 3-20. PROBLEM SOLVENTS FOR CARBON ADSORPTION169
Sol vent
Dodecane
Undecane
2-ethylhexyl acetate
Decane
Butyl carbitol
Nonane
2,6-dimethyl 4-heptanone
Di ethyl cyclohexane
Butyl cyclohexane
1 -methyl pentyl acetate
Di ethyl cyclopentane
Nitroethane
Propanone
Dichloromethane
Ethanol
Nitromethane
Methanol
Boiling
Vmcm3/mol
274
251
238
229
213
207
207
207
207
194
192
75
74
65
61
53
42
Point
K
489
468
472
447
504
423
446
—
447
—
425
389
329
313
351
374
339
(°F)
(421)
(383)
(390)
(345)
(448)
(302)
(345)
—
(345)
—
(307)
(239)
(133)
(104)
(173)
(214)
(149)
3-50
-------
129
air. The major disadvantages that might prevent this control technique
from being employed on this part of the coating line are 1, 3, 5, and 7
(Table 3-18).
Controlling VOCs from the flash-off area offers three alternatives all
of which require enclosing the flash-off area: (a) control combined air
flow from the flash-off and application areas (already discussed); (b)
control individual air flow from flash-off; and (c) control combined air
flow from the flash-off and baking oven areas. A fourth alternative,
representative of the industry, is to allow this area to remain as a fugi-
tive source of VOCs. For carbon adsorbers, the handling of emissions
from the flash-off area depends in part on a detailed analysis of Table
3-19.
The last area emitting VOCs that could be controlled by a carbon
adsorber is the baking oven. However, Disadvantages 2, 5, 6, 8, and 9
shown in Table 3-18 may prevent utilization of this control technique for
most metal furniture bake oven VOC emissions. Section 3.4.1 discusses the
control efficiencies of using carbon adsorbers when employed to control VOC
emissions from the various process areas. Table 3-21 contains information
considered to be representative for new metal furniture coating lines
employing carbon adsorbers.
3.2.2 Incineration
Incineration of gaseous organics has been widely used in several
industrial surface coating industries including the metal furniture
124
industry. Other industries which have successfully employed incinera-
tion as a control technique for VOC emissions include automobile, paper,
Ifi3 17?~-lftfi
can fabric, and coil coating industries. ' Data from these indus-
tries indicate that incineration could also be considered a possible control
technique for the metal furniture industry.
There are two different types of incineration processes: thermal or
direct flame, and catalytic. Before these two incineration methods are
described, a brief explanation of the principle of this control technique
for VOCs is provided here as it relates to the metal furniture industry.
In general terms, the gaseous solvents emitted from a coating line are
combustible materials which can under proper conditions be converted to
3-51
-------
Table 3-21. PROCESS OPERATING PARAMETERS FOR
CARBON ADSORBERS EMPLOYED TO CONTROL VOC EMISSIONS
Parameter
Operating range
Application area
Air flow through adsorber
Carbon in bed
Blower
Number of carbon beds
Saturation point
Percent by volume of
solvent in coating
Steam usage
Carbon bed replacement
4.7-21 SCMS (10,000-45,000 SCFM)159'160'161
5,000-12,000 kg (11,000-27,000 lb)159'160'162
2_3159,161
60-90 min.
161
50_78159,160,161
30 kg/kg of solvent (30 Ib/lb of solvent)163
0.5-2 yr.Ul.162.163
3-52
-------
carbon dioxide and water vapor. However, no combustion process is TOO
percent efficient and some carbon monoxide is formed. During the incinera-
tion of these materials, proper control of time, temperature, and turbu-
lence determines how efficient the incinerator is in controlling VOC emis-
sions. The remainder of this section concentrates on the two types of
incineration.
3.2.2.1 Thermal or Direct Flame Incinerator. A thermal incinerator
consists essentially of a fuel feed system and burners, a combustion zone,
and a means of exhausting the products of combustion. The auxiliary fuel
is usually natural gas, although propane and butane and some fuel oils are
employed. The purpose of the burners is to combust the auxiliary fuel so
that the temperature inside the combustion chamber is high enough to ensure
incineration of the gaseous vapors emitted from the coating line. This
zone of the thermal incinerator must also provide good mixing. There are
four types of gas burners which are used to burn the auxiliary fuel; nozzle-
mixing, premixing, multiport, and mixing plates. The gas burners are
arranged either in distributive or discrete patterns. Nozzle-mixing and
premixing burners are arranged in distributive patterns for which firing is
done tangentially (Figure 3-9). Air for combustion of the gaseous fuel is
taken from the waste stream or outside air. The contaminated air stream is
32 44
introduced tangentially or along the major axis of the incinerator. '
Multiport burners are installed across a section of the incinerator
and use only the air from the waste stream for combustion. This type of
incineration cannot handle all of the VOC contaminated airstream. Thus the
portion of the waste stream that is bypassed mixes with the burner flames
32 44
in a restricted and baffled area. '
Mixing plate burners (discrete pattern) are placed across the inlet of
the incinerator and the flames are mixed directly with the VOC contaminated
exhaust stream. This mixing provides high velocities which improves turbu-
lence of the waste stream. Figure 3-10 shows an example of a burner employing
mixing plates.32'44 Figure 3-11 shows a burner that employs fuel oil as
the auxiliary fuel. This type of incinerator uses a discrete pattern.
To increase mixing in all of the above mentioned burning techniques,
baffles or turning vanes are placed in front of the air inlet zone. Also,
3-53
-------
Exhaust
A
Vapor-Laden
Airstream
Natural Gas
Figure 3-9. Incinerator with a distributed burner
3-54
-------
co
en
cn
Natural Gas
D Adjustable-1
Gap
D
D
D
D
\
Vapor-Laden
Airstream
Baffles
M
Exhaust
^•"T-VT" / / /////////
Figure 3-10. Incinerator employing mixing plates
-------
co
Vapor-Laden
Airstream
Fuel
Exhaust
Combustion
Air
Figure 3-11. Incinerator using a discrete burner.
-------
tangential air inlet is part of the design of the burner. The mixing in
this part of the incinerator is very critical to efficient burning of the
44
gaseous solvent.
The next part of the incinerator is the combustion zone. After the
temperature of the vapor-laden airstream is raised, the combustion zone
must maintain this temperature and provide the required residence time for
the organic solvents to be converted to carbon dioxide and water vapor. A
range of 922 to 1,089 K (1,200° to 1,500°F) for 0.3 to 0.5 seconds is quite
efficient in converting most gaseous solvents to carbon dioxide and water
vapor. Insufficient combustion chamber volume has been the most significant
design flaw in the failure of some incinerators. The size of the combus-
tion chamber is determined by the volumetric flow rate of the vapor-laden
gas stream, and combustion products at the design temperature and retention
44
time.
Additional equipment that can be installed along with thermal
incinerators consists of heat recovery equipment. This equipment has been
employed only with incinerators that control VOC emissions from bake oven
areas. Heat recovery equipment reduces the amount of fuels required by the
incinerator and, in some cases, by the bake ovens. The type of heat recovery
equipment varies depending on the desired amount of fuel savings. The
various heat recovery equipment and approximate thermal energy that can be
recovered are shown in Table 3-22.
Figure 3-12 shows an incinerator equipped with a single pass fume
preheater. Required equipment includes a preheat recuperator, piping, and
a pump for the working fluid. Heat recovered by-this system can be used in
the metal dry-off ovens and makeup air for the oven. ' '
A second heat recovery system which is more efficient than the single
pass is a multiple chamber preheat and recovery system. This type of heat
recovery system has been installed on a coil coating line. The equipment
includes an incinerator equipped with an odd number of preheat and recovery
chambers which contain stoneware material. In operation, the bake oven
exhaust is preheated in one chamber before passing through the incinerator,
and heat is recovered from the incinerator exhaust stream. Each chamber
can serve to preheat or recover heat in this system. All of the recovered
3-57
-------
Table 3-22. HEAT RECOVERY EQUIPMENT AND THERMAL ENERGY RECOVERY
Heat recovery Percent of thermal energy
equipment recovered from incinerator Reference
Single-pass fume preheater 40-69 44, 177, 189, 194
Multi-pass preheat and recovery 70-90 44, 177
Regenerative heat exchanger 75-90 44
Inert Gas drying system 90 191
3-58
-------
CO
I
en
Di lution Air —£*
Work In >
Fuel
Bake Oven
To Exhaust
->-Work Out
Figure 3-12. Bake oven equipped with incinerator and heat recovery.
-------
energy is maintained with the process. Another example (regenerative heat
exchange) of this type of heat recovery equipment uses both refractory and.
44 177
rotary plates instead of stoneware. '
A proposed inert gas drying system would reduce fuel consumption in
the incinerator and bake oven. In this system, the incinerator handles
only an inert gas with solvent vapors exhausted from a bake oven. The
incinerator only required auxiliary fuel for a pilot burner and just enough
combustion air (stoichiometrically balanced ) to burn the solvents in the
inert gas stream. This produces an exhaust gas from the incinerator which
contains very little oxygen. Heat from the incinerator exhaust gas is
recovered and heat demand in the bake oven is satisfied by recycling the
cooled incinerator exhaust stream through the bake oven. Heat captured in
the heat recovery system can be used in the metal preparation area. The
inert gas drying system can reduce the size of the bake oven (reduced lower
explosive limit [LEL] concerns) and the incinerator. The proposed system
191
and incinerator are shown in Figure 3-13.
Tables 3-23 and 3-24 provide advantages and disadvantages of employing
incineration as a control technique for processes on a metal furniture
coating line.
Thermal incinerators could be employed on all three process areas that
emit VOCs on a coating line. However, as mentioned in Table 3-24,
Disadvantage 3 would be a significant problem for controlling VOCs from a
spray booth because of air flow requirements based on the threshold limit
value (TLV) which by definition demands more air than lower explosive limit
values used by ovens. For TLVs, about 60 times more air is necessary above
the amount that is required for evaporation. Thus, it is not practical to
recommend thermal incinerators for the spray booth or an enclosed flash-off
area (which would require TLV design basis). '
Thermal incinerators have only been employed successfully on bake
ovens. With heat recovery equipment to reduce fuel consumption, thermal
incinerators have proven to be an acceptable control technique for this
process area. Also, from Table 3-19, it appears for the dip and roller
application methods that the majority of VOCs would be controlled by this
method. Finally, if the flash-off area was enclosed and designed to
3-60
-------
GO
cr>
Dilution
Work In
Pilot
Burner
LT
Incinerator
Bake Oven
n.
Pilot
Burner
•>-To Vent
Heat
Recovery
System
• Air
a MI
xer
Work Out
Figure 3-13. Inert gas drying system.
-------
Table 3-23. ADVANTAGES OF EMPLOYING THERMAL INCINERATION AS A
CONTROL TECHNIQUE
Advantage Reference
1. Has small space requirement, low-maintenance 167
operation.
2. Can provide waste boiler heat for other plant 167
operations.
3. With heat recovery equipment, can provide
energy to other process areas. 44, 177, 189-194
Table 3-24. DISADVANTAGES OF EMPLOYING THERMAL INCINERATION AS A
CONTROL TECHNIQUE
Disadvantage Reference
1. High operating costs in areas of large air
requirements with low VOC concentrations
(0.1 to 10 percent LEL). 167
2. Cannot be used on some types of halogenated
solvents because of toxic combustible
products. 167
3. Large air flows (e.g., from spray booth)
reduce the efficiency of an incinerator. 44, 162
4. Problem of auto-ignition for single-pass
heat recovery systems, because of
condensation. 177
5. Warping of materials of construction for
some incinerators. 174, 181
3-62
-------
handle air flows in the 25 percent LEL range, it might be practical to
combine this flow with bake oven exhaust to further reduce VOC emissions
from the coating line.
Table 3-25 contains the process operating parameters for thermal
incinerators that have been employed on surface coating lines other than
the metal furniture industry. This information is considered to be
representative of a metal furniture bake oven employing thermal incinera-
tion to control VOC emissions.
3.2.2.2 Catalytic Incineration. The catalytic incinerator differs
from the direct-fired unit in that the catalyst enables combustion of the
solvent at a lower temperature. The catalyst promotes combustion by
increasing the rate of oxidation reactions without itself changing chemi-
cally. Oxidation of the solvents occurs at the surface of the catalyst
(Figure 3-14).34,44,168
A catalytic incinerator contains a preheat section, a chamber which
contains the catalyst, temperature indicator and controllers, safety equip-
ment and optional heat recovery equipment. The preheat section is used to
raise the temperature of the incoming gas stream to 590 to 750 K (600° to
900°F). The preheat section is basically a discrete burner followed by a
mixing zone. The increase of gas temperature obtained in the preheat
section is sufficient for the solvent vapors to be catalytically burned as
the gas stream leaves the incinerator at an elevated temperature of 700 to
860 K (800° to 1,100°F). Heat recovery equipment at the exit of a catalytic
incinerator is optional. This type of equipment has already been discussed
in Section 3.2.2.1.
The catalyst itself is usually of the platinum family of metals supported
on metal or matrix elements made of ceramic honeycombs or rods, or aluminum
pellets. Criteria for catalyst supports are (a) high geometric surface
area, (b) low pressure drop, (c) uniform gas flow across the surface of the
catalyst, and (d) structural integrity and durability. The performance of
the catalyst is dependent upon the temperature of the incoming gas and
residence time between the solvent vapors and catalyst. In addition, the
efficiency of the catalyst is also a function of organic compositions and
concentration being oxidized. ''
3-63
-------
Table 3-25. PROCESS OPERATING PARAMETERS
FOR A THERMAL INCINERATOR
Parameter
Range
Volumetric Flow Rate
Oven Exhaust Temperature
Oven Exhaust Residence Time
Inside Incinerator
Incinerator Operating
Temperature
Normal Operating Temperature
Single Pass Fume Preheater
Exhaust
2.4 to 24 SCMS (5000 to 50 000 SCFM)172'
176, 180, 187, 190
330 to 420 K (140»to 300°F)185' 187' 190'
191
0.3 to 0.5 sec.
42
920 to 1250 K (1200°to 1800°F)162' 17°5
172-175, 181, 187, 189, 190
1030 K(1400°F)
620 to 730 K (650° to 850°F) 187' 19°
3-64
-------
PREHEAT
BURNER
CATALYST
ELEMENT
cn
FUEL
STREAM —
300-480 K
(70-400 F)
590-750 K
(600-900 F)
700-860 K
(800-1100 F)
CLEAN GAS
•TO STACK
COMBUSTION/MIXING
CHAMBER
OPTIONAL HEAT RECOVERY
(REGENERATIVE OR
RECYCLE SYSTEM)
Figure 3-14. Schematic of catalytic afterburner system.
-------
Tables 3-26 and 3-27 list advantages and disadvantages of employing
catalytic incinerators on coating lines for the metal furniture industry.
This information relates to coating lines that employ solvent based coatings
(e.g., the model plants) in the application area.
Disadvantages 2 and 4 shown in Table 3-27 would present a problem for
a catalytic incinerator employed in the application area of a coating line.
Application areas (e.g., spray booths) would probably have to be equipped
with water curtains and maybe even filtration pads to collect particulates
emitted from applying the coating. The particulate contains pigments and
additives. Inorganic pigments contain heavy metals that can poison the
catalyst. The known heavy metal poisons contained in inorganic pigments are
zinc, lead, arsenic, bismuth, tin, and cadmium. Organic pigments, addi-
tives (e.g., plasticizers, paint driers, etc.) and other metallic oxides
coat and deactivate (disadvantage 3) certain catalyst sites. The catalyst
poisoning and deactivating coupled with high air flow requirements and low
vapor concentrations in the application oven exhaust reduces the effective-
ness of this control technique. Therefore, catalytic incineration is not
recommended to control VOC emissions from the application area, or combined
32 44
application and flash-off areas. '
Catalytic incinerators could probably operate more effectively in
controlling VOC emissions from the bake oven. This is the process in which
the catalytic units have been employed to control VOCs in other surface
104.-107
coating industries mainly due to the fact that the incinerator can
handle lower air flows and, in turn, higher solvent vapor concentrations.
Catalyst coating still might occur for certain solvent based coatings
because of additives and plastic resins. Therefore, some gas conditioning
may be required for bake oven gaseous exhaust.
It might also be applicable to combine the flash-off area exhaust air
with the bake oven exhaust. This would require enclosing the flash-off
area with design flow rates of 25 percent LEL or less. The disadvantages
of such a recommendation are:
• The exhaust air from the flash-off area would lower the temperature
of bake oven gaseous exhaust which, in turn, increases the fuel
usage in the preheat section of the catalytic unit.
3-66
-------
Table 3-26. ADVANTAGES OF EMPLOYING CATALYTIC
INCINERATION AS A CONTROL TECHNIQUE
Advantage Reference
1.
2.
Requires less auxiliary fuel to operate than
a thermal incinerator.
Smaller combustion chambers are employed
42
42
than with a thermal incinerator.
Table 3-27. DISADVANTAGES OF EMPLOYING CATALYTIC
INCINERATION AS A CONTROL TECHNIQUE
Disadvantage Reference
1. Platinum family metals are very expensive. 32
2. Catalysts can be poisoned by heavy metals 32, 42, 193
present in the off-gas stream.
3. Deactivation of the catalyst can result from 32, 42,
coating of catalyst sites and excessive use 166, 193
at temperatures above 863 K (1100°F).
4. Gas conditioning, filtration of inlet gas 42
stream to incinerator, might be necessary.
3-67
-------
• Access to the flash-off area by plant personnel would require
that protective respiratory devices be worn.
Table 3-28 contains process operating parameters for a catalytic
incinerator employed to control VOCs from bake ovens. This information is
based on data collected for catalytic units installed on bake ovens in
other surface coating industries. However, these parameters are considered
representative for the metal furniture industry.
3.2.3 Condensation
Vapor condensers have been employed principally in the refinery and
petrochemical, and the chemical industries. They have found use in
controlling odors from certain other industries (e.g., rendering cookers,
coal-tar-dipping, etc.). Condensers have also been used as an integral
part of other air pollution control systems (e.g., carbon adsorbers). '
Condensers have not been used in the metal furniture nor any other surface
coating industry to control VOC emissions. However, since the exhaust from
metal furniture coating lines contains VOCs, this control technique may be
employed under proper process conditions, alone or in conjunction with
another control technique.
The principle behind condensation of vapors is operation of the condenser
at an increased pressure or to extract heat from the vapor-laden exhaust
stream. In practice, air pollution control condensers operate through
removal of heat from the exhaust stream. With this type of unit, condensa-
tion occurs through two distinct physical mechanisms: (a) dropwise mechanism,
and (b) filmwise mechanism. Only steam condenses in a truly dropwise
manner. Dropwise condensation yields higher heat transfer coefficients
than film condensation. Chemical promoters can be added to the condensing
surface of certain metals to prevent the condensate from forming a film.
It would be difficult to predict the physical mechanisms by which condensates
would form from exhaust streams associated with the metal furniture or any
other surface coating industry.
Two types of condensers that can be employed are contact and surface
condensers. Contact condensers require that the coolant physically mix
with the vapor-laden gas stream. For the most part, only surface con-
densers are recommended for this control technique.
3-68
-------
Table 3-28. PROCESS OPERATING PARAMETERS
FOR A CATALYTIC INCINERATOR
Parameter " Range
Volumetric Flow Rate 1.9 to 17 SCMS (4000 to
36 000 SCFM)182' 184' 185
Oven Exhaust Temperature 370 to 420 K (200° to 300°F)184' 185
d?
Preheated Temperature 590 to 750 K (600-900°F)^
Operating Temperature of 700 to 860 K (8000-1100°F)42' 183' 185
Catalyst
Catalyst Replacement 0.2-3 years 182' 183
3-69
-------
Most surface condensers are the tube and shell type. Water or air
flows inside the tubes and vapors condense on the shell side. Usually, if
water is used as a coolant, chilling is required. Surface condensers
recover 10 to 20 times less condensate than contact condensers. Other
equipment that might be necessary is subcooling associated devices which
prevent the condensate from vaporizing after it has been discharged from
the condenser. This depends upon whether the surface contactor is a
horizontal or vertical condenser.
Figure 3-15 depicts a tube and shell system which uses an inert or air
gas stream and a precooler to lower the bake oven exhaust gas temperature.
The inert or air stream contains the vaporized solvent from the bake oven
which is removed in a two-stage condenser. After the inert or airstream
leaves the second condenser, it is preheated by energy recovered by the
precooler to satisfy the heating requirements of the bake oven. The inert
gas stream can be liquid nitrogen or any inert gas at ambient temperature.
An inert gas system would reduce the size of the bake oven and associated
fuel requirements. If liquid nitrogen is used, it aids in removing the
qaseous solvent by condensation. This type of system, therefore, would be
-I QC I Q~7
a combined surface and contact condenser. '
Tables 3-29 and 3-30 contain advantages and disadvantages for employing
condensation as a control technique. Because of the disadvantages 1 through
3 shown in Table 3-30, employing condensation to control VOC emissions from
the application area is not recommended.
This control technique can only be considered for the flash-off or
bake oven areas or both. Combining the flash-off exhaust with the bake
oven exhaust stream would be beneficial since the oven's exhaust tempera-
ture would be lowered. This would reduce some of the cooling requirements
of the condenser. However, this might require that the flash-off area be
designed at flow rates of 25 percent LEL.
Table 3-31 contains process operating parameters for a condenser
employed to control VOCs from the flash-off and bake oven areas. Very
little actual data are available for controlling VOCs with the control
technique for surface coating processes. Even though it is a proven tech-
nology, it has not been demonstrated successfully on any surface coating
line in the metal furniture industry.
3-70
-------
co
Recycled N_ ^-
Work In
H,,0 Condenser
Bleed-Off
Stream
-K
Heater
Bake Oven
Recovered
Solvent
Recycled
N0 Stream
/ c.
c
Recovered
Solvent
Storage
Work Out
Figure 3-15. Bake oven equipped with N9 condenser.
-------
Table 3-29. ADVANTAGES OF EMPLOYING
CONDENSATION AS A CONTROL TECHNIQUE
Advantage Reference
1. Proven technology in other nonrelated industries. 109,166
2. Recovered heterogeneous mixtures of organic 42
solvents could be burned in a process boiler.
3. Heat exchangers and low temperature cooling 194
coils can reduce cooling requirements (some-
times up to 75%).
4. May perform best as an integral part of other 109
air pollution control equipment.
Table 3-30. DISADVANTAGES OF EMPLOYING
CONDENSATION AS A CONTROL TECHNIQUE
Disadvantage Reference
1. At a solvent concentration in the 100 to 32
200 ppm range, refrigeration costs would
be very expensive.
2. Since most application areas for conventional 166
solvent based paints are equipped with water
curtains, the condensation of water and
solvent would occur. A decanter would be
required to separate the collected water
and solvents.
3. Large air volumes or particulate matter can 109
reduce condensation efficiencies by as much
as 50%.
4. Cooling requirements are more demanding 194, 195
for bake oven exhaust streams.
3-72
-------
Table 3-31. PROCESS OPERATING PARAMETERS FOR A SHELL TUBE CONDENSER
Parameters Range
Volumetric flow rate 0.14 to 4.7 SCMS (300 to 10,000 SCFM)196
Oven exhaust temperature 3?° to 420 K (200° to 300°F) 186>187
Preheated temperatures of air 370 K (200°F)196'197
or inert gas to bake oven
Solvent concentration 1500 ppma
Pressure 1.0 (105)Pa (1 atm)196
aModel plant concentration.
3-73
-------
3.2.4 Other Add-on Control Equipment and Process Modification
This section discusses other add-on equipment for controlling VOC
emissions, and process modification of existing conventional solvent based
coatings to reduce VOC emissions. Other add-on control devices evaluated
were process boilers, and absorption systems. Both of these add-on control
devices were rejected because of technical problems associated with each
control system. Therefore, these control techniques will not be considered
in Chapter 5 (Model Plants and Regulatory Alternatives).
Process modification, which would improve coating transfer efficien-
cies of existing lines applying conventional solvent based coatings, was
also rejected as a control technique. It was rejected because there are no
possible process modifications which would reduce emissions below the level
103
specified by the existing State Implementation Plans (SIP).
3.3 CONTROL EFFICIENCIES FOR COATING FORMULATION CHANGES
This section establishes control efficiencies of coating formulation
changes such as powder, high solids, and waterborne formulations. The
bases and assumptions for the control efficiencies are established in the
following discussions. The control efficiencies presented in this section
are utilized in Chapter 5 to determine emission reduction for the model
plants in selecting regulatory alternatives.
It is assumed that all of the organic solvent in any paint is emitted
and is proportional to a ratio of percent solvent per unit of dry solids
applied. This is not a linear function but instead an exponential
relationship. As solids content decreases in the coating, the organic
solvent content increases exponentially. This ratio can be expressed
mathematically as shown below:
Relative Solvent Emissions = RSE
Percent Solvent
RSE =
Percent Solids
where percent solvent = 100 - percent solids
DCC _ 100 - Percent Solids
Kbt Percent Solids(3-2)
3^74
-------
Equation 3-2 can also be employed to determine RSE values for waterborne by
adjusting the equation for the amount of solvent presented in the volatile
portion of the coating:
0<;r _ 100 ~ Percent Solids Pu
K5t ~ Percent Solids *"v (3-3)
where FV = organic fraction of the volatile.
Finally, the calculated RSE for different coating formulations can be
adjusted for different transfer efficiencies (TE) that result from applica-
tion techniques and coating types.
_ 100 - Percent Solids FV
Percent Solids x TE (3-4)
Equation 3-4 was employed to calculated RSE values for all coating
44 77 ft? ftfi 9^
formulations on a volume or weight basis. ' ' ' '
To obtain emission reduction by volume or weight basis when comparing
two different coatings, the following example can be employed:
Example Calculation
Determine the emission reduction (volume and weight basis) when
switching from a 35 percent by volume solids coating to a 70 percent by
volume solids coating. Transfer efficiencies are 85 and 80 percent,
respectively. Solvent density for both paints is 0.88 kg/liter.
(a) Using Equation 3-4 to determine emission reduction by volume.
(RSE)35 = ^5~ 0785" = 2'18
.'., Emission reduction by volume is
(RSE),, - (RSE)7n
Percent Emission Reduction = - ?^cc\ - ~ (100) (3-5)
= 75 percent
3-75
-------
(b) Determine emission reduction by weight:
Equation 3-4 can be rewritten to consider percent solvent as
shown below:
R<-r _ Percent Solvent FV
* 1 - Percent Solvent x TE
By multiplying both sides of the above equation by a solvent density
(ps), emission reduction by weight for two coatings can be obtained. The
solvent density of 0.88 kg/liter is based on reference 106.
o (RSE) = Percent Solvent x £V 0.65 1_ n ftft
ps ^KbtJ65 1 - Percent Solvent x TE ps ~ 1 - 0.65 * 0.85 °'88
Ps (RSE)65 =1.92 kg/liter
(ps RSE)3Q = ^ -1- 0.88 = 0.47 kg/liter
.'., Emission reduction by weight is:
1 92 - 0 47
Percent Emission Reduction = , 9? = 76 percent
The above calculations were verified by employing a material balance
on each model. The material balance calculation presented below was used
to verify Equation 3-4 calculations.
Example Calculation (Model Plant A, Chapter 5)
Total solids on coated parts = 101,600 liters
(35% by volume solids coating; 85% transfer efficiency; 0.88 solvent density)
Total solids applied = 10Q'|i|0 = 119,500 liters
Total coating applied = 119>500 = 119>500 = 341,000 liters
% solids 0.35
Total emitted solvent = (341,000)(0.65)(0.88) = 195,000 kg
3-76
-------
(70% by volume solids coating; 80% transfer efficiency; 0.88 solvent density)
Total solids applied = "^o'sQ0 = 127,000 liters
Total coating applied = 1Q7^00 = 181,400 liters
Total emitted solvent = (181,400)(0. 30)(0.88) = 48,000 kg
.'., Percent emission reduction by weight = -—/-iQ5Vin3>) = ^ Percer|t
3.3.1 Powder Coatings
After using Equations 3-4 and 3-5 for 100 percent solids coatings, the
control efficiencies are 100 percent. This emission reduction can only be
employed for the application and flash-off areas of a coating line, and for
the spraying of thermoset powders. Therefore, transfer efficiencies for
this type of coating were not considered because overspray in the metal
furniture industry is not emitted through a bake oven. Other control
efficiencies shown apply to thermoplastic powder not requiring a primer.
The values are applicable when the thermoplastic is sprayed or applied via
a fluidized bed. Control efficiency values shown in Table 3-32 are based
upon percent by weight change in the applied solids coating. This change
is a result of VOC emissions mainly from thermoset coatings. The VOC
44 57
emissions are due to polymerization byproducts. '
Emission reduction from coating lines employing a thermoplastic that
required a low solids primer will not be provided. This is because emis-
sions from this type of coating would be comparable to model plants applying
35 percent by volume solids coating by the dip methods. Therefore, control
efficiencies for these lines would be above the level established by the
State Implementation Plans (SIPs).10
3.3.2 High Solids Coatings
The control efficiencies (by volume and weight) shown in Table 3-33
are based on the approach shown in the example calculation provided in
Section 3.3. The emission reductions represent a comparison with the 35
percent by volume solids coating associated with the model plants presented
in Chapter 5. All three electrostatic spraying techniques were evaluated:
gun, disk, and bell. ' The following assumptions were employed in
determining the control efficiencies:
3-77
-------
Table 3-32. EMISSION REDUCTION VIA POWDER COATINGS
Coating Emission References
reduction (%)
Thermosetting powders3
Epoxy
Acrylics
Polyester (urethane)
Thermoplastic powders
Polyester (others)
Acrylics
PVC and cellulose acetate
Butyrate
97-99
99
96-98
99
99
90-95
48,
48,
48,
48,
48,
48,
57
57
57
57
57
57
aVOC emissions from bake oven only.
bVOC emissions from application and cool down areas.
3-78
-------
Table 3-33. CONTROL EFFICIENCIES FOR HIGH SOLIDS COATINGS
High solids coatings Emission reduction '
by weight or volume (%)
60% by Volume solids
Flat surface 62
Complex surface 61
65% by Volume coatings
Flat surface 69
Complex surface 69
70% by Volume coatings
Flat surface 75
Complex surface 75
80% by Volume coatings
Flat surface 85
Complex surface 85
aApproach the same as reported in References 44, 85, 86 and 90.
Some round-off error (approximately 2 percent) may exist for
the calculations (e.g., 60% solids).
3-79
-------
A. In converting from a volume to weight basis, the solvent density
employed was 0.88 kg per liter (7.3 Ib per gal). This value is consistent
with the density employed in reference 106 which is the basis for the 0.36
kg of VOC per liter of coating (minus water) limitation that has been
adopted by most states in their State Implementation Plans. The emission
limitation of 0.36 kg of VOC per liter of coating (minus water) is the
regulation being employed for new coating lines in the absence of a New
Source Performance Standard.
B. The transfer efficiencies employed in the calculations for flat
and complex surfaces are 80 and 60 percent, respectively. These values are
considered to be conservative, but data presented in references 89 and 106
are inconsistent. The transfer efficiencies employed, however, are con-
sidered to be representative at high solids (greater than 60 percent by
volume) coatings because mechanical energies associated in applying the
coatings are higher.
C. The control efficiencies presented in Table 3-33 are considered to
be applicable for both single and dual component high solids coatings.
D. Only electrostatic spraying techniques are considered to be
applicable.
3.3.3 Waterborne Coatings
Control efficiencies (by volume and weight) shown in Table 3-34 for
the spray, dip, flow, and electrodeposition coating of waterborne paints
are also based on the example calculations shown in Section 3.3. These
control efficiencies are also based on a comparison with solvent emissions
from systems applying solvent based paint containing 35 percent by volume
solids. The water-to-solvent ratio of the volatile portion of the paint
considered ranged from 67/33 to 82/18.^ Assumptions employed in determining
the control efficiencies are presented below:
(a) All waterborne spraying was assumed to be accomplished by
electrostatic techniques.
(b) Transfer efficiencies for electrostatic spraying used in the
calculations are based on data reported in reference 106.
(c) Transfer efficiency used for dip and flow coating is 90
percent.
3-80
-------
Table 3-34. CONTROL EFFICIENCIES FOR WATER-BASED COATINGS
Application Control efficiency
technique % by weight or volume Ref.
82/18 Waterborne - Electrostatic
spraying3»b
Flat surface 80-82 42, 54, 118
Complex surface 80-82 123, 143
67/33 Waterborne - Electrostatic
sprayingb.c
Flat surface 67 42, 54, 123, 143
Complex surface 67
82/18 Waterborne - Dip and flow coating9 82 42, 118, 123, 143
67/33 Waterborne - Dip and flow coating0 67 42, 118, 123, 143
82/18 Waterborne - Electrodeposition 95 123, 152, 154, 155
For a 35 percent by volume solids with 82 to 18 hLO solvent ratio.
Control efficiencies for any electrostatic spraying technique.
c
For a 35 percent by volume solids with 67 to 33 H20 to solvent ratio.
Regardless of chemical composition of coating - 20 percent solids.
3-81
-------
3.4 CONTROL EFFICIENCIES FOR ADD-ON CONTROL EQUIPMENT
Control efficiencies of VOCs for add-on air pollution control
equipment are presented in Table 3-35, and these data will be used in
Chapter 5 to select regulatory alternatives. Add-on control equipment
evaluated for emission reduction were carbon adsorbers, thermal and cata-
lytic incinerators, and condensers. The bases and assumptions for the
control efficiencies are presented in the following sections.
3.4.1 Carbon Adsorption
The control efficiencies (weight basis) presented in Table 3-35 are
based on data collected by Springborn Laboratories. This information
includes control efficiencies received from plant trips. ' None
of the control efficiency data for VOCs are for coating lines in the metal
furniture industry. The control efficiencies are for spray booths equipped
with carbon adsorbers in such industries as surface coating of paper and
asbestos fibers. The only source test data were for a can coating line
equipped with a carbon adsorber. All process emissions of VOCs on the
coating line were vented to this ,control device. The following assumptions
were employed in utilizing the above data:
A. The control efficiencies reported in Table 3-35 were considered to
be representative of metal furniture coating lines since surface coating
lines in other industries are comparable or exactly the same.
B. Control efficiencies would only be applicable for coating lines
spraying conventional solvent based coatings.
3.4.2 Incinerators
The control efficiencies for incinerators are based on stack test data
reported in references 42, 185 and 196, and data obtained during plant
trips taken by Springborn Laboratories.13'171"175'181'182'184'185 Only one
plant trip, taken by Springborn Laboratories was to a metal furniture
facility using an incinerator. Also, control efficiency data are only
applicable for incinerators controlling VOC emissions from bake ovens.
Figures 3-16 and 3-17 show effects of temperature on percent VOC destruc-
tion for a thermal and catalytic incinerator, respectively. Assumptions
employed in selecting control efficiencies for incineration are presented
below:
3-82
-------
Table 3-35. CONTROL EFFICIENCIES FOR ADD-ON
AIR POLLUTION CONTROL EQUIPMENT
Add-on control
device
Process being
controlled
Control efficiency
for control device
(% by wt)
Ref.
Carbon adsorber
Carbon adsorber
Thermal incinerator
Spray booth
Entire coating line
Bake oven
90
80
96
111,160,163
162
44,183,187
198
Catalytic incinerator Bake oven
Shell-tube condenser Bake oven and flash-off
90
44,183,187
JSee Section 3.4.3 for explanation of control efficiency.
3-83
-------
TOO
80
c
O)
ID 60
Q.
O
3
S-
•4->
en
Ol
Q
O
O
40
20
0 BUD
1UUU TTDtT
Increasing Temperature. K
Figure 3-16. Effects of temperature and time.
(Redrawn from Reference 42)
3-84
-------
100
so
c
QJ
O
0>
Q.
to
s_
C
o
40
20
200
400 600 800
Temperature, K
1000
Figure 3-17. Typical temperature - performance curve for
various molecular species being oxidized over Pt/Al203
catalyst. (Redrawn from Reference 42).
3-35
-------
A. The control efficiencies for both the thermal and catalytic
incinerator are mainly based on operating temperatures of 1,033 K (1,400°F)
and 703 K (800°F), respectively. These operating temperatures are consis-
tent with temperature data presented in trip reports written by Springborn
Laboratories and information obtained from a literature
. 13,44,171-175,181-189
search. '
B. Reported control efficiencies and operating temperatures reported
for incinerators being employed on bake ovens in other surface coating
industries are considered to be applicable.
3.4.3 Condensers
No control efficiency for condensers is shown in Table 3-35 because no
stack test data are available for this control technique. Vendor and
literature information indicate the control efficiencies range from about
90 to 95 percent by weight.167'195'196 A more conservative 90 percent by
weight control efficiency is used to control VOC emissions from flash-off
areas or bake oven areas or both.
3-86
-------
REFERENCES FOR CHAPTER 3
1. Bardin, P. C., Field Editor, High-Production EPS System at Bunting.
Industrial Finishing. 48 (3). March 1972.
2. Hood, Jack. Powder Application at Flanders Industries, Inc. The
Association for Finishing Processes of SME, Dearborn, Michigan.
FC 76-434, 1976.
3. Burnham, Lowell. Power Application to Complex Shapes and Masses at
Homecrest. The Association for Finishing Processes of SME, Dearborn,
Michigan. FC 76-436, 1976.
4. Schrantz, Joe, Executive Editor. How Oxford Pendaflex Gets that
Quality Finish. Industrial Finishing. 52 (7): 18-22. July 1976.
5. Schrantz, Joe, Executive Editor. High-Production System Powder
Coats Structural Steel Tubing. Industrial Finishing. 5_2 (4): 52-60.
April 1977.
6. Poll, Gerald H., Editor. Super-Durable Exterior Powder Coatings.
Products Finishing. 39: 62-67. March 1975.
7. Schrantz, Joe, Editor. Automatic Powder Systems Coat Lawn Furniture.
Industrial Finishing. 51 (4): 32-38. April 1975.
8. Oge, M. T. Trip Report - Goodman Brothers Manufacturing Co.,
Philadelphia, Pennsylvania. Springborn Laboratories, Enfield,
Connecticut. Trip Report 85. March 8, 1976.
9. Oge, M. T. Trip Report - Steelcase Co., Grand Rapids, Michigan.
Springborn Laboratories, Enfield, Connecticut. Trip Report 72.
February 24, 1976.
10. Nunn, A. B. and D. L. Anderson. Trip Report - Steelcase, Inc.,
Grand Rapids, Michigan. TRW, Inc., Durham, North Carolina.
March 27-28, 1979.
11. Besselsen, John. Painting with Powder. The Association for Finishing
Processes of SME, Dearborn, Michigan, FC 76-431, 1976.
12. Thompson, M. S. Trip Report - U. S. Furniture Industries, Highpoint,
North Carolina. Springborn Laboratories, Enfield, Connecticut.
Trip Report No. 108. April 6, 1976.
13. Fisher, J. R. Trip Report - Visco Manufacturing Corp., Gardena,
California. Springborn Laboratories, Enfield, Connecticut, Trip
Report No. 57. February 11, 1976.
3-87
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14 Powder Coating Seating Scores at Iowa State's New Stadium. Powder
Finishing World. 2 (3): 50-52. Third Quarter 1975.
15. Hospital Bed Protected by Nylon 11 Powder Coating. Powder Finishing
World. 2 (2): 78. Second Quarter 1975.
16. Obrzut, J. J. Powder Coating: A Finisher's Finish. Iron Age.
November 16, 1972.
17. Oge, M. T. Trip Report - Bunting Co., Philadelphia, Pennsylvania.
Springborn Laboratories, Enfield, Connecticut. Trip Report No. 86.
March 8, 1976.
18. Poll, Gerald H., Jr. Powder Coating Over One Million Square Feet
Per Month. Products Finishing. 38: 58-65. December 1975.
19 Oge M T Trip Report - Herman Miller, Inc., Zelland, Michigan.
Springborn Laboratories, Enfield, Connecticut. Trip Report No. 100.
April 2, 1976.
20 Powder Systems Cuts Finishing Costs at Westinghouse. Powder
Finishing World. 2 (3): 20-21. Third Quarter 1975.
21 Inversion Powder Coatings Bicycles in 20 Colors. Industrial
Finishing. 50 (9): 58-63. September 1974.
22 Robinson, Thomas, G., Associate Editor. Powder Coating Trailer
Hitches. Products Finishing. 38: 76-81. June 1974.
23 Stacy, B. J. and Akin R. H. Powder Coatings at Gravely. Presented
at the Association of Finishing Processes of SME, Dearborn, Michigan.
FC 76-450, 1976.
24 Mazin, J. Technical Developments in 1976. Metal Finishing.
75 (2): 74-75. February 1977.
25 Meyer C. H. Epoxy Powder Coating at McQuay-Perfec, Inc. The
Association for Finishing Processes of SME, Dearborn, Michigan.
FC 76-441, 1976.
26. Poll, Gerald, H., Jr., Editor. High-Production Acrylic Powder
Coating. Production Finishing. 38 (12): 46-52. September 1974.
27. Cole, Edward N. Coatings and Automobile Industries Have Common
Interest. American Paint and Coatings Journal. 58 (51): 58-63.
June 3, 1974.
28 Schrantz, Joe, Editor. Automatic Powder Systems Coat Lawn Furniture.
Industrial Finishing. 51 (4): 32-38. April 1975.
29. Automotive Powder: Under the Hood. Products Finishing. 40: 56-57.
November 1976.
3-88
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30. Cole, Gordon E., Jr. Outlook for Powder in '76: Up 20 Percent.
Powder Finishing World. 2 (4):6. Fourth Quarter 1975.
31. St. John, W. Allis-Chalmer's Thin-Film Powder Coating. Products
Finishing. 38:3-8. March 1973.
32. Hughes, T. W., . A. Horn, C. W. Sandy, and R. W. Serth. Source
Assessment: Prioritization of Air Pollution from Industrial Surface
Coating Operations. Monsanto Research Corporation, Dayton, Ohio.
Office of Research and Development, U. S. EPA, Washington, D.C.
EPA-650/2-75-019a. February 1975.
33. Cole, G. E. The Powder Coatings Market. GCA Chemical Corporation.
(Presented at NPCA Chemical Coatings Conference, Powder Coatings
Session. Cincinnati, Ohio. April 22, 1976).
34. Ramig, Alexander, Dr. of Glidden Coatings and Resins Division.
Rebuttal Presentation before NAPCTAC concerning Industrial Surface
Coating of Metal Furniture. February 27, 1980.
35. Lissy, Gus of Nordson Company. Rebuttal Presentation before NAPCTAC
concerning Industrial Surface Coating of Metal Furniture.
February 27, 1980.
36. Cehanowicz, L., Editor. The Switch On for Powder Coating. Plastics
Engineering. 31 (9): 28-30. September 1975.
37. Gabris, Tibor. Trip Report - Interrad Corporation, Stanford,
Connecticut. Springborn Laboratories, Enfield, Connecticut.
August 27, 1975.
38. Levinson,.S. B. Powder Coating. Journal of Paint Technology.
44 (570): 38-52. July 1972.
39. Pegg, F. E. Applying Plastic Coatings with the Fluidized Bed Process:
Part 1 - Coating Materials. Plastic Design and Processing.
10 (9): 38-41. 1970.
40. Halappen, H. S. and G. H. Poll. Powder Coating '76: State of the
Art. The Association for Finishing Processes of SME, Dearborn,
Michigan. FC 76-430. 1976.
41. Garrder, D. S. Energy Consumption of Six Different Coatings.
Products Finishing. 40:46-49. March 1976.
42. Goodell, P. H. Economic Justification of Powder Coating. The
Association for Finishing Process of SME, Dearborn, Michigan.
FC 76-459. 1976.
43. Feith, D. When To Powder? When To Paint? The Association for
Finishing Process of SME, Dearborn, Michigan. FC 76-457. 1976.
3-89
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44. Suther, B. J., (Foster D. Snell) and Uday Potasku (JACA Corporation)
Controlling Pollution from the Manufacturing and Coating of Metal
Products—Metal Coating Air Pollution Control, Volume 1.
EPA-625/3-77-009. May 1977.
45. Axtell, D. Automated Powder Coating System Problems, Solutions,
Assets. The Association for Finishing Process of SME, Dearborn,
Michigan. FC 76-435. 1976.
46. The Ransburg Automatic Process - The Worlds Standard for Electrostatic
Printing Efficiency. Ransburg Electrostatic Equipment, Indianapolis,
Indiana. Equipment Bulletin.
47. Ransburg Manual Electrostatic Equipment. Ransburg Electrostatic
Equipment, Indianapolis, Indiana. Equipment Bulletin HG-76-10M.
48. Cole, G. E., Jr. (GCA Chemical Corporation) and D. Scarborough.
Volatile Organic and Safety Considerations for Automotive Powder
Finishes. SAE, Dearborn, Michigan.
49. Letter and attachments from Farrell, R. F., Glidden Powder Coatings,
to Cole, G. C., GCA Associates. April 3, 1978. Response to initial
draft of Surface Coating of Metal Furniture prepared by Springborn
Laboratories.
50. Gabris, Tibor. Trip Report - Interred Corporation, Stanford,
Connecticut. Springborn Laboratories, Enfield, Connecticut.
August 27, 1975.
51. Ransburg Electrostatic Powder Coating. Ransburg Electrostatic
Equipment, Indianapolis, Indiana. Bulletin Number P-101.
52. Melchore, J. Trip Poport - Nordson Corporate'"0 Amherst, Ohio.
Springborn Laboratories, Enfield, Connecticut. Trip Report No. 88.
March 11, 1976.
53. Gabris, Tibor. Trip Report - W. R. Grace & Co., Lexington,
Massachusetts. Springborn Laboratories, Enfield, Connecticut.
September 18, 1975.
54. Ransburg Electrostatic Swirl-Air. Ransburg Electrostatic Equipment,
Indianapolis, Indiana. Equipment Bulletin.
55. Memo from Holley, W. H., Springborn Laboratories, Inc., Enfield,
Connecticut, to Robert Diehl, Springborn Laboratories. November 1, 1977.
Covering the problem of powder fines.
56 Brewer, George E. F. Painting Waste Loads Associated with Metal
Finishing. Journal of Coating Technology: 48-51. February 1977.
3-90
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57 Telecon. Holley, William H., Springborn Laboratories, Inc., Enfield,
Connecticut, with Jim Pfeifer, Pratt and Lambert, Buffalo, New York
and Tim Birdsall, Warren, Indiana. October 18, 1977. Emissions of
volatile organics from cured powder coatings.
58. How Nylon Powder Coatings Help. Products Finsihing. 38: 80-81.
April 1974.
59. Besselsen, J. Paint Finishing 1977. The Association for Finishing
Processes of SME, Dearborn, Michigan. FC 77-692. 1977.
60. Hall, A. Maybe It's Not Goodbye Paint, But It's Certainly Hello
Powder Coating. Modern Plastics. 49 (5): 48-51. May 1972.
61. Curtis, L. G. Higher Solids Coatings for Metals and Plastics. High
Solids Coatings. 2 (4): 4-10. October 1977.
62. Nickerson, R. S. The State-of-the-Art in UV Coating Technology.
Industrial Finishing. 50 (2): 10-13. February 1974.
63. Oge, M. T. Trip Report - Simmons Co., Munster, Indiana. Springborn
Laboratories, Enfield, Connecticut. Trip Report No. 41.
January 28, 1976.
64. Oge, M. T. Trip Report - Lyon Metals Products, Inc., Aurora, Illinois.
Springborn Laboratories, Enfield, Connecticut. Trip Report No. 91.
March 12, 1976.
65. Telecon. Holley, W. H., Springborn Laboratories, Enfield, Connecticut,
with L. LeBras, PPG, Pittsburgh, Pennsylvania. August 24, 1977.
Use of high solids paints in the metal furniture industry.
66. Letter from Scharfenberger, J., Ransburg Electrostatic Equipment,
Indianapolis, Indiana, to W. Holley, Springborn Laboratories, Enfield,
Connecticut. September 16, 1977. Covering high solids coating
uses.
67. Sremba, J. The Real World of High Solids. High Solids Coatings.
3 (3): 17-20.
68. Fugita, E. M. and L. G. Shepard. Consideration of Model Rule for
the Control of Volatile Organic Compound Emissions from Metal Furniture
and Fixture Coating Operations. State of California Air Resources
Board. September 27, 1978.
69. Jeff, W. High Solids Coatings for General Industrial. High Solids
Coatings. 3 (2): 17-20. June 1978.
70. Murphy, E. M. High Solids Coatings - Experience. High Solids
Coatings. 3 (4): 5-11. December 1978.
3-91
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71. More Solids, Less Solvent. Products Finishing. 42: 46-48.
July 1978.
72. Consdorf, A. P., Editor. Which Way Will You Go On Finishing?
Appliance Manufacturer. April 1977. pg. 43-49.
73. Price, M. B. High Solids Coatings Where Can They Be Used? Reliance
Universal, Anc. (Preprint, NPCA Chemicals Coatings Conference,
Cincinnati, Ohio. April 22, 1976).
74. Telecon. Holley W. H., Springborn Laboratories, Enfield, Connecticut
with R. Craig, Rohn and Haas, Philadelphia, Pennsylvania. Status of
high solids acrylic coatings and waterborne coatings.
75. Telecon. Holley, W. H., Springborn Laboratories, Enfield, Connecticut
with G. Wilhelm, Ashland Chemical, Columbus, Ohio. August 24, 1977.
Status of high solids coatings, particularly alkyds for metal furniture.
76. Tweet, D. High Solids Coatings Market Trends for 1977. High Solids.
1: 12. October 1976.
77. Lovald, R. A. and D. D. Taft. High Solids Epoxy Coatings. High
Solids Coatings. 1: 3:10. October 1976.
78. Young, R. G. and W. R. Howe11, Jr. Epoxies Offer Fulfillment of
High Performance Needs. Modern Paint and Coatings. 52 (3): 43-47.
March 1975.
79. Lunde, D. Acrylic Oligomers: One Approach to High Solids. High
Solids Coatings. 1 (3): 5-9. July 1976.
80. Question Corner. High Solids Coatings. 2 (3): 4. July 1977.
81. DeVittorio, J. M. Application Equipment for High Solids and Plural
Component Coatings. High Solids Coatings. 1 (2): 7-12. April 1976.
82. Lunde, D. I. Acrylic Resins Defy Conventional Relationships in New
Technology Coatings. Modern Paint and Coatings. 53 (3): 51-53.
March 1976.
83. Baker, R. D. and J. J. Bracco. Two-Component Urethanes: Higher
Solids Systems at Lower Cure Temperature. Modern Paint and Coatings.
53 (3): 43-47. March 1976.
84. Telecon. Holley, W. H., Springborn Laboratories, Enfield, Connecticut
with J. J. Bracco, Mobay, Pittsburgh, Pennsylvania. August 23, 1977.
Status of high solids coatings in the metal furniture industry.
85. Telecon. Holley, W. H., Springborn Laboratories, Inc. Enfield,
Connecticut, with J. A. Scharfenberger, Ransbury Corporation,
Indianapolis, Indiana. August 29, 1977. High solids application
equipment.
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86. Mercuno, A., and S. N. Lewis. High Solids Coatings for Low Emission
Industrial Finishing. Journal of Paint Technology. 47 (607)- 37-44
August 1975. —
87. Letter from LeBras, L. R., PPG Industries, Pittsburgh, Pennsylvania,
to W. H. Holley, Jr., Springborn Laboratories, Enfield, Connecticut.
September 16, 1977. High solids industrial coatings.
88. Lunde, D. I. Aqueous and High Solids Acrylic Industrial Coatings.
High Solids Coatings. 1 (2): 13-15. April 1976.
89. Wilhelm, G. H. Conservation Through High Solids Coating Systems
High Solids Coatings. 2 (4): 11-14. October 1977.
90. Question Corner. High Solids Coatings. 1 (1): 3-4. January 1976.
91. High Solids Paint: A Cost Comparison. High Solids Coatinq
1 (1): 4-5. January 1976.
92. Garrder, D. S. Energy Consumption of Six Different Coatings.
Products Finishing. 40: 46-49. March 1976.
93. Golownia, R. F. High Solids Coatings for Applicances. High Solids
Coatings. 3 (2): 2-14. June 1978.
94. Nunn, A. B. and D. L. Anderson. Trip Report - Ransburg Electrostatic
Equipment, Indianapolis, Indiana. TRW, Inc., Durham, North Carolina
April 24-25, 1979.
95. Pontius, J. D. High Solids Are Here Today. High Solids Coatings
3 (3): 13-16. September 1978.
96. Bernard, D. A. Will High Solids Work? High Solids Coatinqs
3 (4): 12-15. December 1978.
97. Scharfenberger, J. A. New High Solids Coating Equipment Offers
Energy/Ecology Advantages. Modern Plastics. 53 (2): 52-53.
February 1976.
98. LeBras, L. R. Prospects for Low Emissions Liquid Industrial Coatings -
High Solids. PPG Industries, Pittsburgh, Pennsylvania, (presented
at Fourth Water-Borne and Higher Solids Coatings Symposium, New Orleans
Louisiana, February 14, 1977). '
99. High Solids Coatings Based on Acrylates. High Solids Coatinqs
2 (4): 15-16. October 1977.
100. Powers, H. R. Economic and Energy Savings Through Coatings. The
Association for Finishing Process of SME, Dearborn, Michigan
FC 76-217. 1976.
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101. Scharfenberger, J. A. Application Equipment for High Solids Coatings.
Ransburg Corporation, Indianapolis, Indiana. October 15, 1975.
102. DeVittorio, J. M. Application Equipment for High Solids and Plural
Component Coatings. Ransburg Corporation, Indianapolis, Indiana.
November 7, 1975.
103. Caffee, D. F. Electrostatic Spraying from Its Origin to Today.
Ransburg Electrostatic Equipment. September 5, 1978.
104. Brenner, D. L. and J. D. Pontius. High Solids Coatings Are Ready.
Management. January 1978.
105. High Solids, A Rosy Outlook. Industrial Finishing. 54 (7).
July 1978.
106. Walberg, A. C. Electrostatic Application of High Solids Coatings.
High Solids Coatings. 3: 5-14. March 1978.
107. Ellis, William H., Z. Saary, and D. G. Lesnini. Insulation of
Exempt Replacements for Aromatic Solvents. Journal of Paint
Technology. 41 (531): 249-258. April 1969.
108. Gallagher, V. N., and J. Pratapas. Control of Volatile Organic
Emissions from Existing Stationary Sources Volume III: Surface
Coating of Metal Furniture. EPA-450/2-77-032. U. S. Environmental
Protection Agency, Research Triangle Park, North Carolina.
December 1977.
109. Larson, E. C., and H. E. Sipple. Los Angeles Rule 66 and Exempt
Solvents. Journal of Paint Technology. 39 (508): 258-264. May 1967.
110. The Ransburg Automatic Process. Technical Bulletin.
111. Danielson, J. A., Editor. Air Pollution Engineering Manual. AP-40,
Second Edition, Air Pollution Control District of Los Angeles, EPA,
Office of Air and Water Programs Office of Air Quality Planning and
Standards, Research Triangle Park, North Carolina. May 1973.
112. Telcon. Holley, W. H., Springborn Laboratories, Enfield, Connecticut
with L. LeBras, PPG, Pittsburgh, Pennsylvania. August 25, 1977.
Questions on high solids finishings.
113. Unpublished data. Received from E. W. Pete Drum, Ransburg
Electrostatic Equipment, Indianapolis, Indiana.
114. Product Profile R-F-H Hand Gun. Ransburg Electrostatic Equipment,
Indianapolis, Indiana. Technical Bulletin.
115. Product Profile Ransburg Turbodisk. Ransburg Electrostatic Equipment,
Indianapolis, Indiana. Technical Bulletin.
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116. Product Profile 17384 Tilted Disk Rotator. Ransburg Electrostatic
Equipment, Indianapolis, Indiana. Technical Bulletin.
117. Product Profile Turbobell. Ransburg Electrostatic Equipment,
Indianapolis, Indiana. Technical Bulletin.
118. Product Profile 18100, 17264 Power Supply System. Ransburg
Electrostatic Equipment, Indianapolis, Indiana. Technical Bulletin.
119. Loop, F. M. Automotive Electrocoat. PPG Industries, Inc.
(Presented at NPCA, Chemical Coatings Conference. Cincinnati, Ohio.
April 22, 1976).
120. Coutts, G. Our Experience with Water-Reducible Paint. The Association
for Finishing Process of SME, Dearborn, Michigan. FC 74-647. 1974.
121. LeBras, L. R. Prospects for Low Emission Liquid Industrial Coatings -
Water-Borne. PPG Industries, Inc., Pittsburgh, Pennsylvania.
(Presented at Fourth Water-Borne and Higher Solids Coatings Symposium,
New Orleans, Louisiana. February 14, 1977).
122. Nunn, A. B. and D. L. Anderson. Trip Report - Delwood Furniture
Co., Irondale, Alabama. TRW, Durham, North Carolina. April 18, 1979.
123. Vierling, E. J. Conversion to Water-Reducible Paint. Control Data
Corporation. (Presented at NPCA, Chemical Coatings Conference.
Cincinnati, Ohio. April 23, 1976).
124. Strand, R. L. Water-Borne Coatings in Metal Packaging. American
Can Company. (Presented at NPCA, Chemical Coatings Conference.
Cincinnati, Ohio. April 23, 1976).
125. Fugita, E. M. and L. G. Shepard. Consideration of Model Rule for
the Control of Volatile Organic Compound Emissions from Metal
Furniture and Fixture Coating Operations. State of California Air
Resources Board. June 29, 1978.
126. Telecon. Holley, W. H., Springborn Laboratories, Enfield, Connecticut
with Kurnik, Walt, Ashland Chemical. August 24, 1977. Status of
waterborne coatings, particularly alkyds, in the metal furniture
industry.
127. Telecon. Holley, W. H., Springborn Laboratories, Enfield, Connecticut
with Dunham, John, Hanna Chemical Coatings, Columbus, Ohio.
August 25, 1977. Status of waterborne and high solids coatings in
the metal furniture industry.
128. Rifi, M. R. The Use of Neutralizing Agents and Cosolvents in
Water-Borne Coatings. Union Carbide Corporation. (Presented at
NPCA, Chemical Coatings Conference. Cincinnati, Ohio April 23, 1976).
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129. Kuehner, N. A. Pretreatment for Water-Borne Coatings. Metal Finishing.
75 (4): 33-36. April 1977.
130. Prane, J. W. Water-Borne Coating Usage -- Current and Future.
(Presented at NPCA, Chemical Coatings Conference, Cincinnati, Ohio.
April 23, 1976).
131. Heffron, W. H. Conversion to Water-Borne Coatings at Pitney Bowes.
Pitney Bowes. (Presented at NPCA, Chemical Coatings Conference.
Cincinnati, Ohio. April 23, 1976).
132. Kloppenburg, W. B. Trip Report — ESF (Electro Coating Finishers),
Arden Hills, Minnesota. Springborn Laboratories, Enfield, Connecticut.
Trip Report No. 135.
133. Kloppenburg, W. B. Trip Report — Singer Co., Auburn, New York.
Springborn Laboratories, Enfield, Connecticut. Trip Report No. 144.
July 21, 1976.
134. Thompson, M. S. Trip Report - Allis Chalmers Corp., LaPorte, Indiana.
Springborn Laboratories, Enfield, Connecticut. Trip Report No. 18.
January 8, 1976.
135. Thompson, M. S. Trip Report - J. I. Case Division of Tenneco,
Racine, Wisconsin. Springborn Laboratories, Enfield, Connecticut.
Trip Report No. 98. April 2, 1976.
136. Gabris, T. Trip Report - Ford Motor Co., Canada. Springborn
Laboratories, Enfield, Connecticut. Trip Report No. 56.
February 10, 1976.
137. Water-Borne Coating Applied by Automatic, Electrostatic, Heated,
Airless Spray System. Industrial Finishing. 53 (8): 22-26.
August 1977.
138. Electric Wheel Converts to Water-Borne Alkyd Enamel. Industrial
Finishing. 52 (12): 50-52. December 1976.
139. Kloppenburg, W. B. Trip Report - Peachtree Door, St. Josephs,
Missouri. Springborn Laboratories, Enfield, Connecticut. Trip
Report No. 87. March 11, 1976.
140. Heuertz, M., Editor. Electrostatic Disks Apply Water-Borne Acrylic
Coating. Industrial Finishing. 52 (4): 22-26. April 1976.
141. Schrantz, J., Editor. Water-Borne Coating Applied Electrostatically.
Industrial Fnishing. 52 (8): 24-28. August 1978.
142. Robison, G. T., Associate Editor. Water-Borne Coatings Decorate
Lee/Rowan Products. Products Finishing. 42: 72-76. October 1978.
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143. The Latest In Water-Borne Coatings Technology. Industrial Finishing
51 (9): 48-53. September 1975.
144. TRW CDS Corrosion Studies by CDS Product Operations. U.S. Environmental
Protection Agency. Industrial Environmental Research Laboratory,
Office of Research and Development, Research Triangle Park
North Carolina. Publication No. EPA-600/7-79-017. January 1979.
145. Telecon. Hoi ley, W. H., Springborn Laboratories, Enfield, Connecticut
with Kirkpatrick, Bob, Lilly Industrial Coatings, Indianapolis
Indiana. August 26, 1977. Use of waterborne and high solids coatings
in the metal furniture industry.
146. Gabris, T. Trip Report - Chrysler Corporation, Detroit, Michigan
Springborn Laboratories, Enfield, Connecticut. Trip Report No 8
December 30, 1975. ' '
147. Gabris, T. Trip Report - Chrysler Corporation, Belvidere, Illinois
Springborn Laboratories, Enfield, Connecticut. Trip Report No 14
January 5, 1976.
148. Gabris, T. Trip Report - General Motor Corporation, South Gate
California. Springborn Laboratories, Enfield, Connecticut. Trip
Report No. 102. April 5, 1976.
149. Oge, M. T. Trip Report - Schwinn Bicycle Co., Chicago, Illinois
Springborn Laboratories, Enfield, Connecticut. Trip Report No 97
April 2, 1976. '
150. Telecon. Gabris, T., Springborn Laboratories, Enfield, Connecticut
with Henning, Fred, Amcherm Products. November 15, 1977. Waterborne
coatings usage.
151. Gabris, T. Trip Report - General Motors Corporation, Detroit,
Michigan. Springborn Laboratories, Enfield, Connecticut Trip
Report No. 9. December 30, 1975.
152. Levinson, S. D. Electrocoat, Powder Coat, and Radiate - Which and
Why? Journal of Paint Technology. 44 (569): 41-49. June 1972.
153. One-Coat Finish for Supermarket Shelving by Electrocoat. Product
Bulletin F-46. George Koch Sons, Inc. Evansville, Indiana.
154. Electrocoating Twins Offer Two Colors. Product Bulletin F-38
George Koch Sons, Inc. Evansville, Indiana.
155. Oge, M. T. Trip Report - Angel Steel Co., Plainwell, Michigan
Springborn Laboratories, Enfield, Connecticut. Trip Report No 103
April 5, 1976. '
156. Schrantz, J. , Associate Editor. How Ultra-Filtration Benefits
Equipto. Industrial Finishing. 48 (9): 28-32. September 1972.
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157. Schrantz, J., Associated Editor. UF Benefits Conveyorized, Batch-Type
EDP Systems. Industrial Finishing. 48 (11): 26-29. November 1972.
158. Switching to a Water-Borne Flow Coat System. Finishing Highlights.
p. 16-19. March/April 1976.
159. Flow Coating Water Base Paint. Data Sheet F-52. George Koch Sons,
Inc. Evansville, Indiana.
160. Oge, M. T. Trip Report - Fasson Co., Painesville, Ohio. Springborn
Laboratories, Enfield Connecticut. Trip Report No. 141. July 14, 1976.
161. Oge, M. T. Trip Report - Scott Graphics, South Hadley, Massachusetts.
Springborn Laboratories, Enfield, Connecticut. Trip Report No. 139.
July 19, 1976.
162. Gabris, T. Trip Report - American Can Co., Lemonyne, Pennsylvania.
Springborn Laboratories, Enfield, Connecticut. Trip Report No. 89.
March 11, 1976.
163. McCarthy, R. A. Trip Report - Raybestos-Manhattan, Inc., Mannheim,
Pennsylvania. Springborn Laboratories, Enfield, Connecticut. Trip
Report No. 77. February 27, 1976.
164. Mattai, M. M. Process for Solvent Pollution Control. Chemical
Engineering Process. 66 (12): 74-79. December 1970.
165. Control of Gaseous Emissions. Training Course 415. Office of Air
and Waste Management Air Pollution Training Institute. Research
Triangle Park, North Carolina. May 1975.
166. Grant, R. M., M. Manes, and S. B. Smith. Adsorption of Normal
Paraffins and Sulfur Compounds on Actuated Carbon. AIChE Journal.
8 (3): 403. 1962.
167. Oge, M. T. Trip Report - Brown-Bridge Mills, Troy, Ohio. Springborn
Laboratories, Enfield, Connecticut. Trip Report No. 140.
July 20, 1976.
168. Lund, H. F., Editor. Industrial Pollution Control Handbook.
New York. McGrawHill. 1971.
169. Perry, J. H., Editor. Chemical Engineer's Handbook. Fourth Edition,
New York. McGrawHill. 1963.
170. Cavanaugh, E. C., G. M. Clancy, and R. G. Wetherold. Evaluation of
a Carbon Adsorption/Incineration Control System for Auto Assembly
Plants. Radian Corporation, Austin, Texas. EPA Contract No.
68-02-1319, Task 46. May 1978.
171. Stern, A. C. Air Pollution. Academic Press, New York. Vol. II,
Second Edition. Chapter 16. 1968.
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172. Gabns, T. Trip Report - Litho-Strip Co., South Kilburn, Illinois.
Springborn Laboratories, Enfield, Connecticut. Trip Report No 35
January 22, 1976.
173. Gabris, T. Trip Report - Ford Motor Co., Milpitas, California.
Springborn Laboratories, Enfield, Connecticut. Trip Report No 120
April 8, 1976.
174. Gabris, T. Trip Report - Roll Coater, Inc., Kingsbury, Indiana.
Springborn Laboratories, Enfield, Connecticut. Trip Report No 76
February 26, 1976.
175. Gabris, T. Trip Report - National Gas Corporation Danbury, Connecticut.
Springborn Laboratories, Enfield, Connecticut. Trip Report No 128
April 27, 1976.
176. Gabris, T. Trip Report - American Can Co., Plant No. 025, Erickson
New Jersey. Springborn Laboratories, Enfield, Connecticut. Trip
Report No. 6. December 29, 1975.
177. Mueller, J. H. Coil Coating Fume Control with a Feedback Energy
Recovery System. (Reprint of a paper presented at 1977 Annual
Meeting of the National Coil Coaters Association. May 9, 1977).
178. Oge, M. T. Trip Report - Hazen Paper Company, Holyoke, Massachusetts
Springborn Laboratories, Enfield, Connecticut. Trip Report No 134
May 19, 1976.
179. Fisher, R. J. Trip Report - California Finished Metals, Inc.
Cucamonga, California. Springborn Laboratories, Enfield, Connecticut
Trip Report No. 27. January 14, 1976.
180. Gabris, T. Trip Report - American Can Co., Hillside, New Jersey
Springborn Laboratories, Enfield, Connecticut. Trip Report No 5
December 19, 1975. ' '
181. Gabris, T. Trip Report - Armco Steel Corp., Middletown, Ohio
Springborn Laboratories, Enfield, Connecticut. Trip Report No 16
January 5, 1976. "
182. Gabris, T. Trip Report - Ford Motor Co., Milpitas, California.
Springborn Laboratories, Enfield, Connecticut. Trip Report No 112
April 7, 1976. "
183. Fisher, J. R. Trip Report - Supracote Svc., Cueamonga, California
Springborn Laboratories, Enfield, Connecticut. Trip Report No 31
January 16, 1976. "
184. Kloppenburg, W. B. and W. R. Diehl. Trip Report - General Electric
Co., Schenectady, New York. Springborn Laboratories Enfield
Connecticut. Trip Report No. 106. April 6, 1976.
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185. Gabris, T. Trip Report - Continental Can Co., Inc., Portage, Indiana.
Springborn Laboratories, Enfield, Connecticut. Trip Report No. 80.
March 3, 1976.
186. McCarthy, R. A. Trip Report - DuPont Corporation, Fairfield,
Connecticut. Springborn Laboratories, Enfield, Connecticut. Trip
Report No. 130. April 30, 1976.
187. Godonski, G. Raymond, Anthony, V. Gimbrone, William J. Green
(Graphics Arts Technical Foundation), Robert J. Reita, Paul R. Eisanan
(Carnegie-Mellon University), and John T. Dale (EPA). An Evaluation
of Emissions and Control Technologies for the Metal Decorating
Process. J. of APCA. 24 (6): 579-585. June 1974.
188. Kloppenburg, W. B. Trip Report - Chicago Magnet Wire, Elks Grove,
Illinois. Springborn Laboratories, Enfield, Connecticut. Trip
Report No. 124. April 9, 1976.
189. Heat Recovery Combined with Oven Exhaust Incineration. Industrial
Finishing. 52 (6): 26-27. June 1976.
190. Benfarado, D. M. Air Pollution Control by Direct Flame Incineration
in the Paint Industry. Journal of Paint Technology. 39 (508): 265.
May 1967.
191. Hemsath, K. H., A. C. Thekdi, and F. J. Vereecke. Pollution Control
with Energy Recovery in Coating Industry. (Presented at 67th Annual
Meeting of the Air Pollution Control Association, Denver, Colorado.
June 9-13, 1974).
192. Digiacomo, J. D. and H. T. Lindland. An Economical Design for a
Solvent Fume Incinerator. (Presented at 67th Annual Meeting of the
Air Pollution Control Association, Denver, Colorado. June 9-13,
1974).
193. Young, R. A., Editor. Heat Recovery: Pays for Air Incineration and
Process Drying. Pollution Engineering. 7 (9): 60-61. September 1975.
194. Beltram, M. R. Heat Recovery and Smoke Abatement Can Be Profitable.
American Dyestuff Reporter. August 1975. p. 22-23.
195. Thermal Versus Catalytic Incineration. Products Finishing.
38: 83-85. November 1975.
196. Kon-den-Solver, a subsidiary of Allied Air Products Co. Technical
Bulletin KDS-100-179.
197. Berry, J. C. Chemical Application Section, EPA, Research Triangle
Park, North Carolina. Memo to Robert Walsh, Chemical Petroleum
Branch, EPA, Research Triangle Park, North Carolina. January 15, 1979.
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198. Hurst, T. and R. F. Jongleux. Stack Emission Sampling at Ford Motor
Co., Pico Riveria, California. TRW (Rough Draft), Durham, North
Carolina. EPA Research Triangle Park, North Carolina.
February 13, 1979.
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4. MODIFICATION AND RECONSTRUCTION
After the new source performance standards have been promulgated in
accordance with Section 111 of the Clean Air Act, as amended, all "affected
facilities" will include those constructed, modified, or reconstructed
after the date of proposal. These new source performance standards are
also to apply to an "existing facility" as defined in 40 CFR 60.2. An
existing facility would become an affected facility if determined to be
modified or reconstructed. This chapter provides potential examples of
modified and reconstructed affected facilities and details the required
conditions under which an existing facility becomes subject to the stan-
dards of performance. However, the enforcement division of the appropriate
EPA regional office will make the final determination as to whether a
source is modified or reconstructed and, as a result, becomes an affected
facility. The remainder of the sections in this chapter defines and
provides potential examples of modification and reconstruction.
4.1 40 CFR 60 PROVISIONS FOR MODIFICATION AND RECONSTRUCTION
4.1.1 Definition of Modification
It is important that these provisions be understood before considering
potential examples of modifications.
Section 60.14 defines modification as follows:
except as provided under paragraphs (e) and (f) of this
section, any physical or operational changes to an existing
facility which result in an increase in emission rate to the
atmosphere of any pollutant or precursor to pollutant to which a
standard applies shall be a modification. Upon modification, an
existing facility shall become an affected facility for each
pollutant to which a standard applies and for which there is an
increase in the emission rate.
Paragraph (e) lists certain physical or operational changes which are
not considered as modifications, regardless of any changes in the emission
rate. These changes are shown below:
4-1
-------
(1) Routine maintenance, repair, and replacement.
(2) An increase in the production rate not requiring a capital
expenditure as defined in Section 60.2.
(3) An increase in the hours of operation.
(4) Use of an alternative fuel or raw material if, prior to the
standard, the existing facility was designed to accommodate that
alternate fuel or raw material.
(5) The addition or use of any system or device whose primary
function is the reduction of air pollutants, except when an emission
control system is removed or replaced by a system considered to be less
efficient.
(6) The relocation or change in ownership of an existing facility.
Paragraph (b) specifies that an increase in emissions is defined in
kilograms per hour and delineates the methods for determining the increase,
including the use of emission factors, material balances, continuous
monitoring systems, and manual emission tests. Paragraph (c) affirms
that the addition of an affected facility to a stationary source does
not make any other facility within that source subject to standards of
performance. Paragraph (f) simply provides for superseding any conflicting
provisions.
4.1.2 Definition of Reconstruction
Section 60.15 regarding reconstruction states:
If an owner or operator of an existing facility proposes
to replace components, and the fixed capital cost of the new
components exceeds 50 percent of the fixed capital cost which
would be required to construct a comparable, entirely new
facility, he shall notify the Administrator of the proposed
replacements. The notice must be postmarked 60 days (or as
soon as practicable) before construction of the replacements
is commenced.
The purpose of the reconstruction portion of the regulation is to
prevent an owner or operator from continuously replacing an operating
process except for support structures, frames, housing, etc., in an
attempt to avoid falling under new source performance standards.
4.2 APPLICABILITY TO SURFACE COATING OF METAL FURNITURE
The purpose of this section is to outline some of the most probable
types of "modifications" to existing plants and to describe the applica-
bility of "reconstruction" to this industry. The modification and
4-2
-------
reconstruction samples provided in this section are only to be examples
of changes that would require an existing facility to comply with the
standard. The final determination will be made by the appropriate EPA
regional office on a case-by-case basis.
The examples apply to process areas of a metal furniture coating
line that emit volatile organic compounds (VOCs) which are precursors to
air pollution. This would include the coating application, flash-off
and bake oven areas, and exempts metal part precleaning and preheating
areas. The amount of VOCs emitted from the application, flash-off, and
bake oven areas varies depending on the method of coating application.
Paint can be applied by spray, dip, flow, and roller coating methods.
The following two sections define modification and reconstruction
examples for the metal furniture coating lines.
4.2.1 Modification Examples
Examples of increasing VOC emissions as a result of raw material,
coating application, and process changes are provided. Each change is
discussed and the ones that are considered to be potential modifications
are identified. The examples to be evaluated are shown in Table 4-1
along with a determination as to whether or not the example is a
modification. Each is discussed in the following paragraphs.
The modification examples 1 through 3, as shown in Table 4-1, would
cause an increase in VOC emissions. Despite the fact that VOC emissions
would increase, examples 1 and 2 are not considered to be a modification
because of 40 CFR Part 60.14(e)(4). This is because a change in raw
materials, regardless of emission rate, does not constitute a process
modification if the existing process was designed to handle the new raw
materials. The only exception to this might be operators or owners of
coating lines who switch from applying powder to organic solvent-based
coatings. Such a switch might result in a redesign of the application,
flash-off and bake oven areas for some affected facilities. Even though
this type of switch is highly unlikely, it could occur as a result of
changing the color of the coating applied to a particular part at the
request of the customer. This would happen if the required color was
not commercially available in the powder coating. However, because of
4-3
-------
Table 4-1. POTENTIAL MODIFICATION EXAMPLES
Potential modification
example
Determination of
modification
(1) Switching from a higher to a
lower solids coating.
(2) Adding solvent thinners to
coatings.
Is not a modification based on the
above definition in accordance with
40 CFR Part 60.14(e)(4).
Same as (1) above.
(3) Increasing coating thickness. A potential modification.
(4) Changing part size or
complexity.
(5) Addition of extra applica-
tion equipment.
(6) Temporary substitution of
process equipment.
(7) Relocation of a coating line
from another plant site.
Is not a modification based on the
above definition in accordance with
40 CFR Part 60.14(e)(l) and 40 CFR
Part 60.14(e)(4).
A potential modification.
Is not a modification based on the
above definition in accordance with
40 CFR Part 60.14(e)(l).
Is not a modification based on the
above definition in accordance with
40 CFR Part 60.14 (e)(6).
4-4
-------
the cost of such a switch, the change might be termed a reconstruction
instead of a modification.
Increased coating thicknesses, other factors being constant, would
result in increased VOC emissions. Such a change could occur from a
desire to increase durability and resistance for outdoor exposure. This
is a potential modification if the spray booth is enlarged or extra
spray guns are added or both on the coating line. However, operating
changes such as higher air flow rate to a spray gun, decreased conveyor
speed, etc., are not modifications because the existing coating line
would be designed to handle these operational changes.
Changing part size or complexity could feasibly increase VOC
emissions from the existing facility. An increase in part size,
maintaining a constant conveyor speed, would be a source of increased
solvent emissions. Changing the design of a metal part on a production
line is common engineering practice. If the design change resulted in a
more difficult metal part to coat, VOC emissions would increase. The
increased emission rate of VOCs would be due to higher paint consumption,
poorer paint transfer efficiency or both. Each of the above part changes
would not, however, be considered a modification because of 40 CFR Part
60.14(e)(l) and 40 CFR 60 (e)(4).
The addition of extra application equipment (increased VOC emissions)
to an existing coating line in order to increase production and the
improvement of product quality by the application of coating for touch-
up purposes, are examples of process modifications, provided the same
coating is employed. This could also involve reconstruction which is
discussed in the next sections.
Substitution of application equipment on a temporary basis at
existing sources for specific coating jobs might increase VOC emissions.
For example, existing line components such as spray booths and flow
chambers may be interchanged to handle certain customer demands. These
changes would not be considered a modification if such changes are made
routinely with existing equipment prior to the development of a new
source performance standard. This complies with 40 CFR Part 60.14(e)(l).
The last potential modification example to be discussed is the
relocation of any VOC-emitting part of a coating line from one state to
4-5
-------
another state. Emissions of VOC would increase at the new location but
in accordance with 40 CFR Part 60.14(e)(6), this would not be a modification,
4.2.2 Examples of Reconstruction
This provision of the regulation is relatively straightforward in
that, regardless or the VOC emission rate, an existing facility may become
an affected facility because of the "50 percent of the fixed capital
cost" in the above definition. Potential examples on a coating line
that would be affected are shown below:
(1) Replacing or enlarging of the coating application area. This
would include the part touch-up area.
(2) Replacing or enlarging of the bake oven.
(3) Replacing or enlarging of the area (flash-off) between the
application and bake oven where the coated parts travel on a conveyor
line.
The examples shown above are not restricted by any type of time
schedule under present regulations. 'In other words, once an existing
facility starts to replace or enlarge an existing line and exceeds 50
percent fixed capital costs requirement of a new comparable line, the
existing line may become an affected facility depending upon the
Administrator's decision.
4-6
-------
5. MODEL PLANTS AND CONTROL OPTIONS
This chapter defines model plants which represent the metal furniture
surface coating industry and the alternative means by which volatile organic
compound (VOC) emissions can be regulated.
5.1 MODEL PLANTS
Model surface coating plants were developed which represent the various
processes used in the industry and the various sizes of plants found in
existence. The models were developed ^ +he basis of plant operation and
economic data collected from a variety of sources including trip reports,
1~15
industry surveys, computer listings, and published literature.
Based on the industry size fragmentation described in Chapter 2, it
was tentatively decided that three model plants would be needed for each of
the three coating techniques. Annual paint consumption was selected as the
basis for determining the size categories, due to the fact that this type
of data was much more readily available than was information pertaining to
the total surface area coated per year. The three size categories which
were selected are as follows:
Annual Paint Consumption
Size Category liters (gallons)
Large 400,000 (106,000)
Medium 75,000 ( 20,000)
Small 4,000 ( 1,050)
The medium size plant is approximately equal to the average plant size
found in the industry.
5.1.1 Spray Coating
Spray coating is the most common application technique used in the
metal furniture industry. Transfer efficiency for electrostatic spraying
-------
ranges from 50 to 95 percent depending upon the type of application equip-
1 c_] q
ment and the configuration of the item being painted. Transfer effi-
ciency for flat surfaces is generally 85 percent and for complex shaped
objects, it is 65 percent. This difference in efficiency has a substantial
affect on emission rates; therefore, two model plants were developed for
each size category. Emission estimates were calculated by material balance
based upon a dry coating thickness of 2.54 x 103 cm (1 mil), a solvent
based alkyd paint with 35 percent by volume solids, and the indicated
application efficiency. The amount of organic solvent emitted in the
application, flash-off, and curing areas was estimated at 40 percent
20
(including overspray), 30 percent, and 30 percent, respectively. The
operating schedule for all plants is assumed to be 8 hours per day, 5 days
per week, 50 weeks per year. Other operating data such as conveyor speed,
number of daily color changes, and energy consumption were estimated on the
basis of survey data. Application exhaust flow rates were calculated on the
assumption that a 100 ppm organic solvent concentration would be maintained
in the spray booths. Oven exhaust flow rates were calculated on the basis of
maintaining an organic solvent concentration of 15 percent of the lower
explosive limit (LEL) in the curing ovens. In addition a flow rate of approxi-
mately 15 meters per minute (50 ft/min) was assumed across all oven openings.
Figures 5-1, 5-2, and 5-3 depict the model spray coating lines. Tables
5-1 through 5-6 show material and energy balances and operational descrip-
tions of the spray coating model plants.
5.1.2 Dip Coating
Dip coating is the second most commonly used method of paint applica-
tion in the metal furniture industry. Transfer efficiency for this method
is approximately 90 percent and there is no appreciable difference resulting
from differing object configurations. Diagrams of the dip coating models
are shown in Figures 5-4 and 5-5.
Emissions for the model plants were calculated by material balance
assuming a dry coating thickness of 2.54 x 103 cm (1 mil), a 90 percent
transfer efficiency, ' and the use of an alkyd paint containing 35
volume percent solids. Energy consumption and other operating data were
5-2
-------
Load
en
GO
1. Conveyor
2. Three-stage washer
3. Dry off oven
4. Electrostatic disc spray booth
5. Manual touch-up spray booth
6. Flash-off
7. Bake oven
Figure 5-1. Example automated spray coating lines with manual touch-up
for flat metal furniture surfaces (Models A and C).
-------
Load
01
1.
2.
3.
4.
5.
6.
7.
Conveyor
Three-stage washer
Dry off oven
Electrostatic bell spray booth
Manual touch-up spray booth
Flash-off
Bake oven
Figure 5-2. Example automated spray coating lines with manual touch-up
for complex metal furniture surfaces (Models B and D).
-------
Load
cn
i
on
1. Conveyor
2. Three-stage washer
3. Dry off oven
4. Manual spray booth
5. Flash-off
6. Bake oven
Unload
Figure 5-3. Example small metal furniture manual spray coating line (Models E and F)
-------
Table 5-1. MODEL PLANT A
Application method/efficiency: Electrostatic spray/85 percent
Surface type: Flat
2
Approximate surface area per Item: 1.0 m
Total area coated per year: 4,000,000 m
Operating schedule: 8 hours/day S days/Meek 50 weeks/year
Conveyor speed: 4.2 Meters/win.
Number of lines: 6 (3 spray booths per line)
Number of color changes per day: 5
Number of plant employees: 620
Number of coating line employees: 45
MATERIAL BALANCE:
Items coated:
Coating used (liters):8
Material loss during application and
flash off
Solids (liters):
Solvents (Hters):b
Total coating applied to Items (liters):
Net dry solids on Items (liters):
Solvent emissions during curing (kilograms):
Total emissions (kilograms):
Application exhaust flow rate (meters /sec):
Application exhaust concentration (ppm) :
Oven exhaust flow rate (meters /sec):
Oven exhaust concentration (ppm):
ENERGY CONSUMPTION:
Application - Electric (joules):
- Gas (joules):
Cure - Electric (joules):
- Gas (joules):
*35 percent solids
bOverspray Is also Included In this estimate.
Per Line
666,667
56,924
2,989
25.900
48.386
16.934
9.768
32.560
19
100
0.95
1,500
150 X 1010
0
3 X 1010
590 X 1010
Total
4,000.000
341.543
17.931
155.402
290.312
101.600
58.608
195.362
114
100
5.7
1.500
900 X 1010
0
18 X 1010
3538 X 1010
5-6
-------
Table 5-2. MODEL PLANT B
Application Method/efficiency: Electrostatic spray/65 percent
Surface type: Coaplex
Approximate surface area per Item: 0.33 m
Total area coated per year: 4,000,000 m
Operating schedule: 8 hours/day 5 days/week 50 weeks/year
Conveyor speed: 4.6 meters/mln
Number of lines: 10 (3 spray booths per line)
Number of color changes per day: 12
Number of plant employees: 620
Number of coating line employees: 75
MATERIAL BALANCE:
Items coated:
Coating used (liters):8
Material loss during application and
flash off
Solids (liters):
Solvents (liters): b
Total coating applied to Items (liters):
Net dry solids on Items (liters):
Solvent emissions during curing (kilograms):
Total emissions (kilograms):
Application exhaust flow rate (meters /sec) :
Application exhaust concentration (ppm):
Oven exhaust flow rate (meters /sec) :
Ov*n exhaust concentration (ppm):
ENERGY CONSUMPTION:
Application - Electric (joules):
- Gas (joules):
Cure - Electric (joules):
- Gas (joules):
Per Line
1.200,000
44,660
5,471
20,320
29,029
10,160
7,664
25,545
19
100
0.95
1.500
150 X 1010
0
3 X 1010
590 X 1010
Total
12,000,000
446,593
54 ,708
203,200
290,285
101,600
76,636
255 ,452
190
100
9.5
1,500
1500 X 1010
0
30 X 1010
5896 X 1010
*35 percent solids
bOverspray 1s also Included 1n this estimate.
5-7
-------
Table 5-3. MODEL PLANT C
Application method/efficiency: Electrostatic spray 85 percent
Surface type: Flat
Approximate surface area per Item: 1.0 m
Total area coated per year: 780,000 meters2
Operating schedule: 8 hours/day 5 days/week 50 weeks/year
Conveyor speed: 2.5 meters/mln.
Number of lines: 2 (3 spray booths per line)
Number of color changes per day: 5
Number of plant employees: 140
Number of coating line employees: 11
MATERIAL BALANCE:
I tens coated:
Coating used (liters)1
Material loss during application and
flash off
Solids (liters):
Solvents (liters):
Total coating applied to Items (liters):
Net dry solids on Items (liters):0
Solvent emissions during curing (kilograms):
Total emissions (kilograms):
Application exhaust flow rate (meters /sec):
Application exhaust concentration (ppm):
Oven exhaust flow rate (meters /sec):
Oven exhaust concentration (ppm):
ENERGY CONSUMPTION:
Application - Electric (joules):
- Gas (joules):
Cure - Electric (joules):
- Gas (joules):
Per Line
390,000
33,298
1.748
15,150
28,303
9,906
5,714
19.046
19
100
0.95
1,500
55 X 1010
0
3 X 1010
435 X 1010
Total
780,000
66.596
3,496
30,300
56,606
19,812
11.428
38,092
38
100
1.9
1,500
110 X 1010
0
6 X 1010
870 X 1010
*35 percent solids
bOverspray Is also Included 1n this estimate
5-8
-------
Table 5-4. MODEL PLANT D
Application «ethod/eff1dency: Electrostatic spray/65 percent
Surface type: Conplex
ApproxlMBte surface area per Item: 0.33 meters
Total area coated per year: 780,000 meters
Operating schedule: 8 hours/day 5 days/week 50 weeks/year
Conveyor speed: 2.4 meters/m1n.
Number of lines: 2 (3 spray booths per Hne)
Number of color changes per day: 5
Number of plant employees: 140
Number of coating line employees: 11
MATERIAL BALANCE:
Items coated
Coating used (liters):8
Material loss during application and
flash off
Solids (liters):
Solvents (liters):b
Total coating applied to Items (liters):
Net dry solids on Items (liters):
Solvent emissions during curing (kilograms):
Total emissions (kilograms):
Application exhaust flow rate (meters /sec):
Application exhaust concentration (ppm):
Oven exhaust flow rate (meters /sec):
Oven exhaust concentration (ppm):
ENERGY CONSUMPTION:
Application - Electric (joules):
- Gas (joules):
Cure - Electric (joules):
- Gas (joules):
Per Line
1,181,800
43,543
5,334
19,812
28,303
9,906
7,472
24,907
19
100
0.95
1,500
55 X 10
0
3 X 10
435 X 10
10
Total
2,363,636
87,086
10,668
39,624
56,606
19,812
14,944
49,814
38
100
1.9
1,500
110 X 10
0
6 X 10
870 X 10
10
*35 percent solids
bOverspray 1s also Included 1n this estimate.
5-9
-------
Table 5-5. MODEL PLANT E
an,, per Item: 1..
coated per year: 45.000 meters2 Nurt>er of plant e*>loyees: U
sc^Je slurs/day 5 days/*** SO weeks/year Nu*er of coating line employees:
MATERIAL BALANCE: ~—
~ ' <9,QUU
Items coated: . 3 M2
Coating used (liters):
Material loss during application and
flash off 202
Solids (liters): ;48
Solvents (liters)-. '
Total coating applied to 1tew (liters): •
1.143
Solvent emissions during curing (kilograms):
Net dry solids on Items (liters): g5g
2.197
Total emissions (kilograms):
Application exhaust flow rate (meters /sec): ^
Application exhaust concentration (ppm):
Oven exhaust flow rate (meters /sec): ^
Oven exhaust concentration (ppm):
ENERGY CONSUMPTION:
-------
Table 5-6. MODEL PLANT F
Application »ethod/eff1c1ency: Electrostatic spray/65 percent Conveyor speed: 2.5 meters/m1n.
Surface type: Complex Number of lines: 1 (1 spray booth)
Approximate surface area per Item: 0.33 meters ' Number of color changes per day: 5
Total area coated per year: 45.000 meters Number of plant employees: 18
Operating schedule: 8 hours/day 5 days/week 50 weeks/year Number of coating line employees: 3
MATERIAL BALANCE: Total
Items coated: 136,360
Coating used (liters):' 5,024
Material loss during application and
flash off
Solids (liters): 615
Solvents (Hters):b 2,286
Total coating applied to Items (liters): 3,266
Net dry solids on Hems (liters): 1,143
Solvent emissions during curing (kilograms): 862
Total emissions (kilograms): 2,874
Application exhaust flow rate (meters3/sec): 19
Application exhaust concentration (ppm): 100
Oven exhaust flow rate (meters /sec): 0.95
Oven exhaust concentration (ppm): 1,500
ENERGY CONSUMPTION:
Application - Electric (joules): 45 x 1010
- Gas (joules): 0
Cure - Electric (joules): 2 X 1010
- Gas (joules): 366 x 1010
*35 percent solids
bOverspray 1s also Included 1n this estimate.
5-11
-------
en
i
Load
1. Conveyor
2. Three stage washer
3. Dry off oven
4. 53 m3 Dip tank
5. Flash-off
6. Bake oven
©
Unload
Figure 5-4. Example metal furniture dip coating lines for medium and large
plants (Models G and H).
-------
Load
en
CO
Conveyor
Three stage washer
Dry off oven
19 m3 dip tank
Flash-off
Bake oven
Figure 5-5. Example small metal furniture dip coating line (Model I)
-------
estimated from the survey data. Application area and oven exhaust flow
rates were calculated in the same manner described in the previous section.
Material and energy balances and operational data are listed in Tables
5-7, 5-8, and 5-9 for the three dip coating model plants.
5.1.3 Flow Coating
Flow coating is the least used application method in the metal furniture
industry. This method is used primarily by small plants; therefore, only
one model plant was developed.
Transfer efficiency for flow coating is estimated at 90 percent with
no difference for varying part complexity.16'17 Emissions for the model
plant were calculated by material balance using the same assumption dis-
cussed for dip coating. Energy consumption and other operating data were
estimated from the survey information. Application area and exhaust flow
rates were calculated by the methods previously delineated.
Figure 5-6 depicts the model flow coating plant. Material and energy
balances and operational data are listed in Table 5-10 for this model.
5.2 REGULATORY ALTERNATIVES
The purpose of this section is to define different regulatory alterna-
tives based upon their effectiveness for reducing VOC emissions. The
regulatory alternatives are established from the control technologies
described in Chapter 3. Four regulatory alternatives are considered in
developing the control options:
I. No additional emission reduction above the baseline case.
II. 30 percent VOC emission reduction above the baseline case.
III. 50 percent VOC emission reduction above the baseline case.
IV. 85 percent VOC emission reduction above the baseline case.
The baseline case is the emission limitation required by existing
regulations in the absence of an NSPS. This emission limitation is recom-
mended in the Control Techniques Guideline (CTG) document for this industry.
Many states have already adopted or are in the process of adopting this
emission limitation into their State Implementation Plans (SIPs). For the
purpose of this study it is assumed that the SIPs are based on the emission
limitation of 0.36 kg of VOC per liter of coating (minus water).
5-14
-------
Table 5-7. MODEL PLANT G
Application Method/efficiency: Dip coating/90 percent
Surface type: Complex
Approximate surface area per Item: 0.33 meters2
Total area coated per year: 4,000,000 meters
Operating schedule: 8 hours/day 5 days/week 50 weeks/year
MATERIAL BALANCE
Items coated:
Coating used (liters)b:
Material loss during application and
flash off
Solids (liters):
Solvents (liters):
Total coating applied to items (liters):
Net dry solids on Items (liters):
Solvent emissions during curing (kilograms):
Total emissions (kilograms):
Application exhaust flow rate (meters3/sec):
Application exhaust concentration (ppm):
Oven exhaust flow rate (meters3/sec):
Oven exhaust concentration (ppm):
ENERGY CONSUMPTION
Application - Electric (joules):
- Gas (joules):
Cure - Electric (joules):
- Gas (joules):
Conveyor speed: 4.6 meters/min.
Number of lines: 10 (1-53 m3 tank per line)
Number of color changes per day: Oa
Number of plant employees: 620
Number of coating line employees: 60
Per line
1,200,000
32,254
1,129
8,386
29,029
10,160
11,070
18,449
2.5
100
0.95
1,500
7 x 10
0
3 x 10
590 x 10
10
Total
12,000.000
322,540
11,289
83,860
290,^90
101,600
110,700
184,490
25
100
9.5
1,500
70 x 10
0
30 x 10
5.900 x 10
10
'Different color paints 1n the different tanks.
35 percent solids.
5-15
-------
Table 5-8. MODEL PLANT H
Application Kthod/efflclency: Dip coating/90 percent
Surface type: Conplex
eters
.2
Approximate surface area per Item: 0.33
Total area coated per year: 780.000 meters'
Oiwntlng schedule: 8 hours/day 5 days/week 50 weeks/year
Conveyor speed: 2.5 «eters/m1n.
Number of lines: 2 (1-53 m3 tank per line)
Number of color changes per day: Oa
Number of plant employees: 140
Number of coating line employees: 11
MATERIAL BALANCE
Items coated:
Coated used (11ters)b:
Material loss during application and
flash off
Solids (liters):
Solvents (liters):
Total coating applied to Items (liters):
Net dry solids on Items (liters):
Solvent emissions during curing (kilograms):
Total emissions (kilograms):
Application exhaust flow rate (meters /sec):
Application exhaust concentration (ppm):
Oven exhaust flow rate (meters 3/sec):
Oven exhaust concentration (ppm):
ENERGY CONSUMPTION
Application - Electric (joules):
- Gas (joules):
Cure - Electric (joules):
- Gas (joules):
Per line
1,181,818
31.448
1.100
8.177
28.303
9.906
10.793
17.988
2.5
100
0.95
1.500
1 A
7 x 1010
0
in
3 x 1010
1 A
435 x 1010
Total
2.363.636
62.896
2.200
16.354
56.606
19.812
21.586
35.976
5
100
1.
1.500
14 x
0
3 x
870 x
,9
in
1010
10
101U
in
iolu
'Different color In each tank.
b35 percent solIds.
5-16
-------
Table 5-9. MODEL PLANT I
Application «ethod/eff1ciency: Dip coating/90 percent Conveyor speed: 2.5 meters/min.
Surface type: C«*>lex Number of lines: 1 (1-19 m tank)
Approximate surface area per Item: 0.33 meters2 Number of color changes per day: 0
Total area coated per year: 45,000 meters2 Number of plant employees: 18
Operating schedule: 8 hours/day 5 days/week 50 weeks/year Number of coating line employees: 3
MATERIAL BALANCE
Items coated: 136,360
Coating used (liters):3 3'629
Material loss during application and
flash off
Solids (liters): 127
Solvents (liters): 944
Total coating applied to items intersj: 3,266
Net dry solids on Items (liters): L143
Solvent emissions during curing (kilograms): 1.245
Total emissions (kilograms): 2-076
Application exhaust flow rate (meters /sec): 0-3
Application exhaust concentration (ppm): 100
Oven exhaust flow rate (meters 3/sec): °-95
Oven exhaust concentration (ppm): 1>500
ENERGY CONSUMPTION
Application - Electric (joules): 2 x 10
- Gas (joules): °
Cure - Electric (joules): 2 * 1°
- Gas (joules): 366 x 10
a35 percent solids.
5-17
-------
Load v
tn
oo
Unload
1. Conveyor
2. Three stage washer
3. Dry off oven
4. Flow coat chamber
5. Flash-off
6. Dake oven
Figure 5-6. Example metal furniture flow coating line (Model J).
-------
Table 5-10. MODEL PLANT J
Application Mthod/efflclency: Flow coating/90 percent
Surface type: Complex
Approximate surface area per Item: 0.33 meters
o
Total area coated per year: 45,000 meters
Operating schedule: 8 hours/day 5 days/week 50 weeks/year
MATERIAL BALANCE
Items coated:
Coating used (liters)9:
Material loss during application and
flash off
Solids (liters):
Solvents (liters):
Total coating applied to Items (liters):
Net dry solids on items (liters);
Solvent emissions during curing (kilograms):
Total emissions (kilograms):
Application exhaust flow rate (meters /sec):
Application exhaust concentration (ppm):
Oven exhaust flow rate (meters /sec):
Oven exhaust concentration (ppm):
ENERGY CONSUMPTION
Application - Electric (joules):
- Gas (joules):
Cure - Electric (joules):
- Gas (joules):
Conveyor speed: 2.5 Meters/min.
Number of lines: 1 (1 flow-coat booth)
Number of color changes per day: 0
Number of plant employees: 18
Number of coating line employees: 3
Total
136,360
3,629
127
1,877
3,266
1,413
415
2,076
0.4
100
0.95
1,500
3 x 10
0
2 x 10
366 x 10
10
*35 percent solids.
5-19
-------
Listed below are the selected control options (from control techniques
in Chapter 3) for each emission reduction level:
a No NSPS above recommended baseline case.
• 30 percent VOC emission reduction
1. Electrostatic spraying of powder coatings.
2. Applying powder coatings by a fluidized bed.
3. Electrostatic spraying of high solids coatings (60-80 percent).
4. Electrostatic spraying of waterborne coatings (82/18 and
67/33).
5. Thermal incinerator on bake oven plus electrostatic spraying
of high solids coatings (60-80 percent).
6. Dip coating with waterborne coatings (82/18 and 67/33).
7. Flow coating with a waterborne coating (82/18).
8. Thermal incinerator on bake oven plus dip coating with
waterborne coating (82/18 and 67/33).
9. Electrodeposition with a 82/18 waterborne coating.
• 50 percent VOC emission reduction.
1. Electrostatic spraying of powder coatings.
2. Applying powder coatings by a fluidized bed.
3. Electrostatic spraying with a waterborne coating (82/18).
4. Dip coating with a waterborne coating (82/18).
5. Thermal incinerator on bake oven plus dip coating with a
waterborne coating (82/18).
6. Electrodeposition with a 82/18 waterborne coating.
7. Flow coating with a 82/18 waterborne coating.
• 85 percent VOC emission reduction.
1. Electrostatic spray of powder coatings.
2. Applying powder coatings by a fluidized bed.
3. Electrodeposition with a 82/18 waterborne coating.
Some possible control techniques are not presented (e.g., carbon adsorption)
and the reasons for this are discussed later in Section 5.2.1. The above
list of control options is large and was reduced to a more manageable size
through consideration of a cost effectiveness screening study. The analyses
indicated the number of control options required for spray, dip, and flow
coating lines varies as follows:
5-20
-------
Use frequency of control
techniques to meet
Coating line Control alternative control options
Spray 30 percent 4
Spray 50 percent 2
Spray 85 percent 1
Dip 30 percent 4
Dip 50 percent 4
Dip 85 percent 2
Flow 30-85 percent 1
The main parameter was cost changes to comply with any proposed NSPS above
the baseline case associated with the control options. As a result, the
above number of required control techniques are representative of all of
the possible control options from a cost change standpoint. This is also
true regardless of the three regulatory alternatives selected at VOC emis-
sion reduction levels.
The selected control options are shown in Table 5-11. Two general
types of control options are presented in Table 5-11: (a) add-on control
equipment, and (b) coating formulation changes. Emission reductions of VOC
are shown in Tables 5-12 through 5-21 for each model plant. Each control
option is discussed in Sections 5.2.1 and 5.2.2. For reasons which will be
discussed later, not all control techniques evaluated in Chapter 3 can be
applied to each model plant.
5.2.1 Add-on Control Equipment
Add-on control equipment which can be used for metal furniture coating
operations are thermal and catalytic incinerators, carbon adsorbers, and
condensers. A combination of the above can also be used, but this was not
considered in developing control options. The reason for not considering
combinations is presented in the following sections.
5.2.1.1 Incineration. Incineration can be used to control emissions
for curing only and has been used to a limited extent in the metal
furniture industry. Based on information provided in Chapter 3, incinera-
tion of emissions from the application area is not considered technologi-
cally feasible due to the high flow rate and low solvent concentration of
the exhaust gas.
5-21
-------
Table 5-11. CONTROL OPTION SUMMARY FOR EACH MODEL PLANT
Control option
Model plants
D
I
Powder coating X X X X
Electrodeposition
Waterborne X X X X
70 percent high solids X X X X
Incineration X X X X
65 percent high solids X X X X
X
X
X
X
X
X
X
X
X
X
X
X
X X
5-22
-------
Table 5-12. EMISSION REDUCTION FOR MODEL PLANT A - LARGE SPRAY COATING FACILITY
FOR FLAT METAL FURNITURE SURFACES
in
i
ro
Plant
A
A
A
A
A
A
Regulatory
alternative
IV
III
II
II
I
I
Control
technique
Powder
Waterborne (35i
by volume solids
82/18 H20 to
solvent'
70% by volume
high solids
Thermal incinerator
65% by volume
high solids
Base case
Emission
reduction
by
weight (X)
98
80
75
96
69
61
Process being
controlled
on coating line
Entire line6
Entire line
Entire line
Bake oven
Entire line
Entire line
Em1ss1onb
estimate
for coating
line (kg/yr)
3,680
38,000
48,300
52 ,600
60,700
75,100
Emission
reduction
by weight0
over the
base case (%)
95
50
35
30
19
--
Emission
reduction by .
weight over the
uncontrolled plant (X)
98
80
75
72
69
61
'Emission reduction for the individual control technique, but not the entire coating line.
Overall emission estimate for the entire coating line.
°Base case = 0.35 kg VOC/liter of coating applied.
Uncontrolled • 35 percent solids paint.
e"Entire line" only refers to the processes on the coating line that might emit VOCs. Therefore, this includes application,
flash-off and curing oven areas.
-------
Table 5'13-EMISSION
Regulatory
Plant alternative
B iv
B III
B II
B II
01
8 B '
B I
Control
technique
Powder
Materbome (35X
volume sol Ids,
82/18 H,0 to
solvent)
70X by volume
high solids
Thermal Incinerator
65X by volume
high solids
Base case
Emission
reduction
by
weight (X)
99
80
75
96
68
61
Process being
controlled
on coating Hne
Entire line6
Entire Hne
Entire line
Bake oven
Entire Hne
Entire Hne
Emission..
estimate"
for coating
line (kg/yr)
3,680
51,000
64,200
69,800
80,600
99,700
Emission
reduction
by weight
over the
base case (X)
96
50
36
50
19
~
Emission
reduction by rf
weight over the
uncontrolled plant (X)
99
80
75
72
68
61
"Emission reduction for the Individual control technique, but not the entire coating line
Overall emission estimate for the entire coating Hne.
cB«se case » 0.36 kg VOC/Hter of coating applied.
Uncontrolled • 35 percent solids paint.
"fla'sh-off'a'n'd
th1s 1nclude$ «PP"«t1on.
-------
Table 5-14. EMISSION REDUCTION FOR MODEL PLANT C - MEDIUM SIZE SPRAY COATING
FACILITY FOR FLAT METAL FURNITURE SURFACES
Ol
I
ro
en
Plant
C
C
C
C
C
C
Regulatory
alternative
IV
III
II
II
I
I
'Emission reduction
bOverall
Control
technique
Powder
Waterborne (35*
by volume solids,
82/18 H20 to
solvent)
70% by volume
high solids
Thermal Incinerator
65% by volume
high solids
Base case
Emission
reduction
by
weight (%)
98
80
75
96
69
62
for the Individual control technique,
emission estimate for the entire
C8ase case « 0.35 kg
VOC/Hter of coating
coating Hne.
applied.
Process being
controlled
on coating Hne
Entire line6
Entire line
Entire line
Bake oven
Entire Hne
Entire line
Emission.
estimate
for coating
line (kg/yr)
715
7,300
9,350
10,200
11,800
14,500
Emission
reduction
by weight
over the
base case (X)
95
50
36
30
19
--
Emission
reduction by
weight over thed
'uncontrolled plant (?)
98
80
75
72
69
62
but not the entire coating line.
Uncontrolled - 35 percent solids paint.
"Entire line" only refers to the processe
flash-off and curing oven areas.
s on the coating
line that might
emit VOCs. Therel
Fore, thl, includ
es application,
-------
ro
01
Table 5-15. EMISSION REDUCTION FOR MODEL PLANT D - MEDIUM SIZE SPRAY COATING
FACILITY FOR COMPLEX METAL FURNITURE SURFACES
Plant
0
D
D
D
0
D
Regulatory
alternative
IV
III
II
II
I
I
Control
technique
Powder
Waterborne (35%
by volume solids,
82/18 H20 to
solvent}
70% by volume
high sol Ids
Thermal Incinerator
65% by volume
high solids
Base case
Emission
reduction
by
weight (%)
99
80
75
96
69
61
Process being
controlled
on coating line
Entire I1nee
Entire line
Entire line
Bake oven
Entire Hne
Entire line
Em1ss1onb
estimate
for coating
Hne (kg/yr)
715
9,700
12 400
13,600
15 600
19/00
Emission
reduction
by weight
over the c
base case (%)
96
50
36
30
20
»
—
Emission
reduction by
weight over thed
uncontrolled plant (%)
99
80
75
72
69
61
Emission reduction for the Individual control technique, but not the entire coating Hne.
Overall emission estimate for the entire coating Hne.
°Base case =• 0.36 kg VOC/Hter of coating applied.
Uncontrolled = 35 percent solids paint.
**e!! on1? refers to the
flash-off and curing oven areas.
«• the coating Hne that might emit VOCs. Therefore, this Includes application,
-------
Table 5-16. EMISSION REDUCTION FOR MODEL PLANT E - SMALL SPRAY COATING
FACILITY FOR FLAT METAL FURNITURE SURFACES
ro
-vl
Plant
E
E
E
E
E
Regulatory
alternative
IV
III
II
I
I
Control
technique
Powder
Waterborne
70% by volume
high solids
65% by volume
high solids
Base case
Emission
reduction
by
weight (%)
98
80
76
69
62
Process being
controlled
on coating line
Entire I1nee
Entire line
Entire line
Entire line
Entire line
Em1ss1onh
estimate"
for coating
line (kg/yr)
41
420
539
678
838
Emission
reduction Emission
by weight reduction by .
over the weight over the
base case (X) uncontrolled plant (%)
95 98
50 80
36 76
19 69
"Emission reduction for the Individual control technique, but not the entire coating line.
Overall emission estimate for the entire coating Hne.
cBase case = 0.36 kg VOC/llter of coating applied.
Uncontrolled = 35 percent solids paint.
e"Ent1re line" only refers to the processes on the coating line that might emit VOCs. Therefore, this Includes application,
flash-off and curing oven areas.
-------
Table 5-17. EMISSION REDUCTION FOR MODEL PLANT F - SMALL SPRAY COATING
FACILITY FOR COMPLEX METAL FURNITURE SURFACES
en
i
ro
00
Plant
F
F
F
F
F
Regulatory
alternative
IV
III
II
I
I
Control
technique
Powder
Waterborne
70% by volume
high solids
65% by volume
high solids
Base case
Emission
reduction
by
weight (*)
99
80
75
69
61
Process being
controlled
on coating line
Entire line*
Entire Hne
Entire line
Entire Hne
Entire line
Em1ss1onh
estimate
for coating
Hne (kg/yr)
39
560
780
905
1 ,120
Emission
reduction
by weight
over the
base case (%)
97
50
36
19
--
Emission
reduction by .
weight over thi
uncontrolled plant (%)
99
80
75
69
61
V
Emission reduction for the Individual control technique, but not the entire coating Hne.
Overall emission estimate for the entire coating line.
C8ase case • 0.36 kg VOC/llter of coating applied.
Uncontrolled * 35 percent solids paint.
e"Entire Hne" only refers to the processes on the coating Hne that might emit VOCs. Therefore, this Includes application,
flash-off and curing oven areas.
-------
cn
i
no
Table 5-18. EMISSION REDUCTION FOR MODEL PLANT G - LARGE DIP COATING
FACILITY FOR METAL FURNITURE
Emission Emission,
. . , 4 , reduction' Process being estimate"
Regulatory Control by controlled for coating
Plant alternative technique weight (X) on coating line line (kg/yr)
G IV
G IV
G III
G III
G II9
Powder-fluldlzed 96 Entire line6'*1 8 370
DGQ
Electrodeposition 95 Entire line 9 300
of waterborne •
Thermal Incinerator 96 Bake oven 31 700
Haterborne 82 Entire line 34.100
Base case 60 Entire line 74.800
Emission
reduction Emission
by weight reduction by
over the6 weight over the"
base case (X) uncontrolled plant (X)
89 96
88 95
58 83
54 82
60
"Emission reduction for the Individual control technique, but not the entire coating line.
Overall emission
^ase case - 0.36
dUncontrolled « 35
"m.bSff'E cur
estimate for the entire coating line.
kg VOC/Hter of coating applied.
percent solids paint.
ers to the processes on the coating line that might emit VOCs Therefor*
Ing oven areas. ' =•»•=.
this Includes application.
Assuming a thermosettlng powder or thermoplastic powder that does not require a primer.
stasc case - regulatory alternative II i*ciu$o of Increased transfer efficiency.
-------
en
i
CO
o
Table 5-19. EMISSION REDUCTION FOR MODEL PLANT H - MEDIUM SIZE DIP COATING
FACILITY FOR METAL FURNITURE
Plant
H
H
H
H
H
Regulatory
alternative
IV
IV
III
III
II
Control
technique
Powder-fluidized
bed
Electrodeposltion
waterborne
Thermal Incinerator
Waterborne
Base case
Emission
reduction
by
weight (%)
96
95
96
82
60
Process being
controlled
on coating line
Entire linee>f
Entire line
Bake oven
Entire line
Entire line
Em1ss1onb
estimate
for coating
line (kg/yr)
1.550
1 ,800
6,120
6,640
14.500
Emission
reduction
by weight
over the
base case (%)
89
87
58
54
Emission
reduction by j
weight over thr
uncontrolled plant (%)
96
95
83
82
60
aEmission reduction for the individual control technique, but not the entire coating line.
bOverall emission estimate for the entire coating line.
cBase case - 0.36 kg VOC/liter of coating applied.
Uncontrolled - 35 percent solids paint.
e"Ent1re line" only refers to the processes on the coating line that might emit VOCs.- Therefore, this Includes application,
flash-off and curing oven areas.
fAssuming a thermosetting or a thermoplastic powder that does not require a primer.
9Base case - regulatory alternative II because of Increased transfer efficiency.
-------
DIP COATING
cn
CO
Plant
I
I
I
I
Regulatory Control
alternative technique
IV Powder-fluldlzed
bed
IV Electrodeposltlon
waterborne
I" Haterborne
II Base case
Emission ,
reduction"
by
weight (X)
96
95
82
60
Process being
controlled
on coating line
Entire I1nee'f
Entire line
Entire line
Entire line
Em1ss1onK
estimate0
for coating
line (kg/yr)
89
104
383
838
Emission
reduction
by weight
over thec
base case (X)
89
88
54
Emission
reduction by .
weight over the"
uncontrolled plant (X)
96
95
82
60
Overall emission estimate for the entire coating line.
cBase case - 0.36 kg VOC/llter of coating applied.
Uncontrolled » 35 percent solids paint.
"'
'"""" " ""
ff
Assuming a thermosettlng powder or a thermoplastic powder that does not require a primer.
9Base case - regulatory alternative II because of Increased transfer efficiency.
Therefore' th1s
Plication.
-------
Table 5-21. EMISSION REDUCTION FOR MODEL PLANT J - SMALL FLOW COATING
FACILITY FOR METAL FURNITURE
Regulatory
Plant alternative
J III
J IIf
Control
technique
Water-borne
Base case
Emission
reduction
by
weight (*)
82
60
Process being
controlled
on coating line
Entire line6
Entire line
Emission^
estimate
for coating
line (kg/yr)
383
838
Emission
reduction
by weight
over the
base case (%)
54
—
Emission
reduction by ,j
weight over the
uncontrolled plant
82
60
(*)
en
i
CO
ro
'Emission reduction for the individual control technique, but not the entire coating line.
bOverall emission estimate for the entire coating line.
cBase case « 0.36 kg VOC/liter of coating applied.
dUncontrolled = 35 percent solids paint.
-Entire line" only refers to the processes on the coating line that might emit VOCs. Therefore, this Includes application,
flash-off and curing oven areas.
fBase case - regulatory alternative II because of increased transfer efficiency.
-------
Thermal incineration is applied only to model plants A, B, C, D, G,
and H. The emission estimates are based on the addition of the incinerator
to the curing oven of a coating line using a CTG level coating material
(60 percent by volume solids or waterborne). Catalytic incineration was
not considered for two reasons; (a) it has lower control efficiencies than
thermal incineration, and (b) precleaning equipment might be necessary to
protect the catalyst. The smaller plants (models E, F, I, and J) are not
considered due to their low emission rates and the high cost of this control
technique. Incineration is most effective for dip coating lines due to the fact
that more solvent (50 to 70 percent) is evaporated in the baking oven with this
process. Spray and flow coating operations emit less during curing. Figure 5-7
shows a block diagram of a process controlled by incineration.
5.2.1.2 Carbon Adsorption. Carbon adsorption can be applied only to
the application and flash-off areas of a coating line. Carbon adsorption
is not presently ustu in the metal furniture industry; however, it is
conceivable that some companies may choose to use it. The emission reduc-
tion achievable is similar to that of incineration; however, the costs are
extremely high. Because of the expense and the technological problems
discussed in Chapter 3, this control technique was not employed as a control
option .
5.2.1.3 Condenser. Condensers can possibly be applied to control
VOC's from the flash-off and bake oven gaseous exhausts. However, this
control technique was not employed as a control option since it is not a
proven technology.
5.2.2 Coating Formulation Change
Coating formulation changes evaluated for control options are powder,
high solids, and waterborne coatings.
5.2.2.1 Powder Coating. Control of VOC emissions by coating with
powder is evaluated for two application techniques: (a) electrostatic spray
and (b) fluidized bed. Electrostatic spray application of thermoset powders
is evaluated for all spray coating model plants. This option offers the
greatest emission reduction potential when compared with other control
techniques. Changes that would occur in model plants A through F as a
5-33
-------
voc
Parts
Incinerator
/ \
Spray Booth
VOC
1
1
i
Flash-off
Area
1 VOC
1
1
Curing
Oven
y
Coated Parts
Figure 5-7. VOC control by incineration.
5-34
-------
result of switching from conventional organic solvent to powder coatings
are shown in Table 5-22.
Also, application of thermoplastic or thermoset powder with a fluidized
bed is evaluated for all dip coating model plants. It is assumed that no
primer is added to the parts before they are coated with a thermoplastic
powder. Changes that would occur on the dip coating lines are also shown
in Table 5-22.
Powder coating is not considered as a control alternative for flow
coating because no appropriate application method is known to be available.
5.2.2.2 High Solids Coatings. Control of VOC emissions by the use of
high solids coatings is considered for electrostatic spray model plants
only. Problems with dip and flow coating are encountered due to the visco-
sity of high solids paints.
Two different levels of high solids coatings are considered (65 and 70
percent). Coating formulations in this range are used to a limited extent
in the metal furniture industry, however, it is a proven technology.
Transfer efficiencies for high solids paints were assumed to be
slightly less than those for conventional solvent-borne paints. The
transfer efficiencies used in calculating emission reduction potential
are 80 percent for flat surfaces and 60 percent for complex surfaces.
Table 5-23 shows coating line changes that result in switching from
organic solvent-borne coatings to high solids coatings.
5.2.2.3 Waterborne Coatings. Waterborne coatings can be used as
control options for all types of application techniques. A volatile formu-
lation of 82 percent water and 18 percent solvent is used to calculate
emissions from this alternative. For electrostatic spray operations,
application efficiencies of 80 percent for flat surfaces and 60 percent for
complex surfaces are used.
Two control options are developed for waterborne dip coating. Standard
dip coating of waterborne paint involves an application efficiency of 90
percent and an emission reduction of 82 percent. Electrodeposition of
waterbornes, however, yields a much higher application efficiency and an
overall emission reduction of 95 percent.
5-35
-------
OJ
en
Table 5-22. PROCESS PARAMETERS FOR MODEL PLANTS
APPLYING POWDER COATINGS
Model
plant
Spraying
A
B
C
0
E
F
Dipping
G
H
I
Coating* used,
103 liters (103 gallons)
283
283
55
55
3.2
3.2
644
119
6.9
(75)
(75)
(15)
(15)
(0.85)
(0.85)
(170)
(31)
(1.8)
Application
exhaust flow rate
m3/sec (ft3/m1n)
1.7
2.3
0.3
0.45
0.02
0.03
(3600)
(4900)
(640)
(950)
(42)
(59)
--
—
--
Ovenc
exhaust flow rate
m3/sec (ft3/m1n)
2.85
4.75
0.95
0.60
0.48
0.48
(6 000)
(10 000)
(2 000)
(1 260)
(1 000}
(1 000)
• -
.-
..
Operating energy consumption"
total electric
1010 Joules OO'MI)
672
1 450
110
110
4
4
130
22
5
(2.42)
(4.03)
(0.31)
(0.31)
(0.09)
(0.09)
(0.36)
(0.06)
(0.01)
total gas,
1010 Joules (10* BTU/hr)
1 770
2 950
435
435
183
183
2 950
435
183
(16
(28
( 4
( 4
( 1
( 1
(28
( 4
( 1
800)
000)
120)
120)
730)
730)
000)
120)
730)
a-ssurning coating thicknesses for spraying and dipping to be 6.35 and 15.24 (10 ) cm, respectively.
bAir flow rates (entire line) based upon a LEL of 30 g/m3 (0.03 OZ/ft ).
22
cAssumed about half the flow rate (entire line) required for model plants.
Energy consumption data based on Table 7-20.
eFor model plants A through D the assumed powder utilization was 90 percent due to the required color change. For model plants E and f
powder utilization was 95 percent.
f?o«'der utilizations for model plants G, H, and I are 95 percent and 97.5 percent, respectively.
-------
Table 5-23. PROCESS PARAMETERS FOR MODEL PLANTS APPLYING HIGH SOLIDS COATINGS
cn
i
co
Model
plant
A
A
B
B
C
C
0
0
E
E
F
F
1 bv volume
solid'.
65
70
65
70
65
70
65
70
65
70
65
70
Coating8
103 liters (10
197
183
262
243
38.2
35.4
50.8
47.1
2.2
2.0
2.9
2.7
used,
gallons)
(52)
(4fl)
(69)
(64)
(10.1)
( 9.35)
(13.4)
(12.4)
( 0.58)
( 0.53)
( 0.77)
( 0.71)
Application
exhaust flow rate
m3/sec (ft3/m1n)
35
23.5
59
47.5
12
9.5
12
9.5
5.9
4.75
5.9
4.75
(74,200)
(60,400)
(125,000)
(100,700)
(25,440)
(20,140)
(25,440)
(20,140)
(12,500)
(10,230)
(12,500)
(10,070)
Ovenb
exhaust flow rate
m3/sec (ft3/nin)
1.9
1.3
3.2
2.1
0.6
0.4
0.4
0.3
0.3
0.2
0.3
0.2
(4,020)
(2,750)
(6,780)
(4,450)
(1,270)
(850)
. (850)
(640)
(640)
(420)
(640)
(420)
Operating energy consumption0
total electric
1010 Joules (106kwh)
872
>I72
!,•' 50
1/50
10
;io
no
no
34
34
34
34
(2.42)
(2.42)
(4.03)
(4 03)
(0.31)
(0.31)
(0.31)
(0.31)
(0.09)
(0.09)
(0.09)
(0.09)
total
1010 Joules
?, 370 '
2,370
3,950
3,950
583
583
583
583
245'
245
245
245
gas.
(106 BTU/hr)
(22,500)
(22,500)
(37,400)
(37.400)
(5,530)
(5,530)
(5,530)
(5,530)
(2,320)
(2,320)
(2,320)
(2,320)
a A coating thickness of 2.54 (10 ) cm was employed.
Flow rates through spray booths and ovens were reduced based on percent solvent savings from the model plant parameters.
Some regulations, however, may require ninimum flow rates for all spray booths.
""Energy consumption data based upon Table 7-20.
-------
Waterborne paint can be applied by flow coaters with an application
efficiency of 90 percent. This yields an emission reduction of 82 percent.
Table 5-24 shows coating line changes that result in switching from organic
solvent-borne coatings to waterborne coatings.
5-38
-------
Table 5-24. PROCESS PARAMETERS FOR MODEL PLANTS APPLYING WATERBORNE COATINGS
tn
oo
'•lodel
plant
Spraying
A
8
C
D
E
F
Oippinq
ay require mninium flow rates for all spray booths.
cClectrodeposition-type processes.
-------
REFERENCES FOR CHAPTER 5
1. Oge, M. T. Trip Report. Bunting Company. Philadelphia, Pennsylvania.
Spn'ngborn Laboratories, Enfield Connecticut. Trip Report 86
March 8, 1976.
2. Oge, M. T. Trip Report. Goodman Brothers Manufacturing Company'.
Philadelphia, Pennsylvania. Springborn Laboratories, Enfield
Connecticut. Trip Report 85. March 8, 1976.
3. Oge, M. T. Trip Report. Steelcase Company. Grand Rapids, Michigan.
Springborn Laboratories, Enfield, Connecticut. Trip Report 72
February 24, 1976.
4. Fisher, J. R. Trip Report. Virco Manufacturing Corporation. Gardena,
California. Springborn Laboratories, Enfield, Connecticut. Trip
Report 57. February 11, 1976.
5. Oge, M. T. Trip Report. Herman Miller Incorporated. Zeeland, Michigan.
Springborn Laboratories, Enfield, Connecticut. . Trip Report 100
April 2, 1976.
6. Thompson, M. S. Trip Report. U.S. Furniture Industries. Blacksmith
Shop Division. Highpoint, North Carolina. Springborn Laboratories,
Enfield, Connecticut. Trip Report 108. April 6, 1976.
7. Oge, M. T. Trip Report. Angel Steel Company. Plainwell, Michigan.
Springborn Laboratories, Enfield, Connecticut. Trip Report 103
April 5, 1976.
8. Industrial Surface Coating Questionnaire. OMB No. 158-S75014. Simmons
Company. Atlanta, Georgia. December 4, 1975.
9. Industrial Surface Coating Questionnaire. OMB No. 158-S75014. Lyon
Metal Products, Inc. Aurora, Illinois. February 12, 1976.
10. Industrial Surface Coating Questionnaire. OMB No. 158-S75014. Shelby
Williams Industrial, Inc. Philadelphia, Pennsylvania. February 26,
1976.
11. Telecon Survey. TRW Inc., Environmental Engineering Division. Telecon
survey of metal furniture coating plants regarding annual paint consump-
tion. January-February 1979.
12. California Air Resources Board Survey of Metal Furniture Coatina
Plants. 1978.
13. Economic Information Systems. Listing of metal furniture coating
establishments.
5-41
\
-------
14. Nunn, A. B. and D. L. Anderson. Trip Report. Steelcase, Inc. Grand
Rapids, Michigan. TRW, Inc., Durham, North Carolina. March 27-28,
1979.
15. Nunn, A. B. and D. L. Anderson. Trip Report. Delwood Furniture Co.
Irondale, Alabama. TRW, Inc., Durham, North Carolina. April 18, 1979.
16. Brewer, George E. F. Painting Waste Loads Associated with Metal
Finishing. Journal of Coatings Technology. 49 (625). February 1977.
17. Danielson, J. A., Editor. Air Pollution Engineering Manual. AP-40,
Second Edition, Air Pollution Control District of Los Angeles, EPA,
Office of Air and Water Programs. Office of Air Quality Planning and
Standards. Research Triangle Park, North Carolina. May 1973.
18. Bernard, D. A. Will High Solids Work? High Solids Coatings. 3 (4):
12-15. December 1978.
19. Walberg, A. C. Electrostatic Painting Efficiency. A. C. Walberg and
Company. Downers Grove, Illinois.
20. Suther, B. J., (Foster D. Snell) and U. Potasku (JACA Corporation).
Controlling Pollution from the Manufacturing and Coating of Metal
Products. Metal Coating Air Pollution Control. Volume 1.
EPA-625/3-77-009. May 1977.
21. Cole, G. W. (GCA Corporation), and D. Scarborough (Nordson Corporation).
Volatile Organic Emissions and Safety Considerations for Automotive
Powder Finishes. SAE. Dearborn, Michigan.
22. Goodell, P. H. Economic Justification of Powder Coating. The Associa-
tion for Finishing Process of SME. Dearborn, Michigan. FC 76-459.
23. Lunde, D. I. Aqueous and High Solids Acrylic Industrial Coatings.
High Solids Coatings. 1(2):13-15. April 1976.
5-42
-------
6. ENVIRONMENTAL IMPACT
This chapter discusses the environmental impacts associated with each
control option developed in Chapter 5. The environmental analyses include
impacts from air and water pollution, solid waste, and energy consumption.
Each is addressed in separate sections of this chapter.
For each specific analysis, both primary and secondary impacts are
identified and discussed. Primary impacts are those directly associated
with the application of a control option. Examples of primary impacts
caused by employing one of the control options (such as a thermal incinera-
tor) are decreased air emissions and increased energy utilization. An
example of a secondary impact is the carbon dioxide generated while burning
the volatile organic compounds (VOC) emitted from a bake oven.
6.1 AIR POLLUTION IMPACT
The air pollution impact is evaluated for coating lines applying
paints by spray, dip, and flow coating methods. Emission reduction of VOC
industry-wide for each application technique were determined and are shown
in Tables 6-1, 6-2, and 6-3. The methodology for developing the emission
estimates shown in the tables is presented in the following paragraphs.
Uncontrolled emission estimates are based on paint consumption of
about 113.6 x 106 liters (30.0 x 106 gallons) in 1975. Of this consump-
tion, 65 percent by volume is solvent. This represents about 68 percent of
the total solvent used in this industry during 1975. Therefore, the total
uncontrolled emission estimate for the metal furniture industry is calcu-
lated in the following manner.1'2
Amount of solvent in paint = 113.6 x 106 (.65) = 73.8 (106) liters
using a solvent density of 0.88 kg/1 (Reference 3)
-------
Table 6-1. EMISSION ESTIMATES FOR SPRAY COATING EMPLOYING CONTROL OPTIONS
VOC Emissions, Metric Tons per Yeara
Year
1975
1976
1977
1978
1979
1980°
1981
1982
1983
1984
1985
1986
Uncontrolled
emissions
81,300
84,200
87,100
90,200
93,400
96,700
100,000
104,000
108,000
112,000
116,000
120,000
SIP
regulations
81,300
84,200
87,100
90,200
93,400
90,900
88,300
86,100
83,800
81,600
79,300
77,000
High
solids
(65%)
81,300
84,200
87,100
90,200
93,400
90,100
86,800
83,700
80,600
77,600
74,500
71,400
Thermal b
incinerator
81,300
84,200
87,100
90,200
93,400
89,800
86,200
82,800
79,500
76,100
72,700
69, 300
High
solids
(70%)
81,300
84,200
87,100
90,200
93,400
89,500
85,700
82,000
78,300
74,600
70,900
67, 200
Waterborne
81,300
84,200
87,100
90,200
93,400
89,100
84,700
80,500
76,300
72,100
67,900
63,700
Powder
81,300
84,200
87,100
90,200
93,400
87,300
81,300
75,200
69,200
63,100
57,000
51, 000
a
'Columns 3 through 9 are emission estimates for the control options presented in Chapter 5.
On curing oven only.
cEmission controls begin in 1980.
-------
Ol
I
GO
Table 6-2. EMISSION ESTIMATES FOR DIP COATING EMPLOYING CONTROL OPTIONS
VOC Emissions, Metric Tons per Year3
Year
1975
1976
1977
1978
1979
1980d
1981
1982
1983
1984
1985
1986
Uncontrolled
emissions
8,600
8,900
9,220
9,540
9,880
10,200
10,600
11,000
11,400
11,900
12,300
12,700
SIP .
regulations
8,600
8,900
9,220
9,540
9,880
9,600
9,350
9,110
8,860
8,650
8,400
8,160
Waterborne
8,600
8,900
9,220
9,540
9,880
9,400
8,920
8,450
7,980
7,530
7,060
6,590
Thermal
incinerator
8,600
8,900
9,220
9,540
9,880
9,390
8,900
8,420
7,940
7,480
7,000
6,520
El ectrodeposi ti on
8,600
8,900
9,220
9,540
9,880
9,270
8,660
8,050
7,440
6,840
6,230
5,620
Powder
8 600
8,900
9,220
9,540
9 880
9,260
8,620
7,990
7,360
6,730
6,100
5,470
Columns 3 through 8 are emission estimates for the control options presented in Chapter 5.
Must be a waterborne coating that would at least provide a 61 percent by weight emission
reduction.
On curing oven only.
Emission controls begin in 1980.
-------
Table 6-3. EMISSION ESTIMATES FOR FLOW COATING EMPLOYING CONTROL OPTIONS
VOC Emissions, Metric Tons per Year3
01
Year
1975
1976
1977
1978
1979
1980
1981
1982
1983
1984
1985
1986
Uncontrolled emissions
5,640
5,840
6,050
6,260
6,480
6,710
6,970
7,230
7,500
7,780
8,080
8,390
SIP regulations
5,640
5,840
6,050
6,260
6,480
6,310
6,160
6,000
5,850
5,700
5, 560
5,420
Waterborne
5,640
5,840
6,050
6,260
6,480
6,170
5,860
5,550
5,240
4,930
4,630
4,330
^Columns 3 and 4 are emission estimates for the control options presented in Chapter 5.
""Emission controls begin in 1980.
-------
Amount of solvent consumed in kg = 73-8 (1Q6) (0-88)
0.68
Amount of solvent consumed in metric tons (MT) = 95,500 (for 1975)
The uncontrolled emission estimates developed in 1975 are proportioned
into the three different application techniques (spray, dip, and flow)
based on survey data. The
projected from Equation 6-1.
based on survey data. The uncontrolled emissions shown in the tables are
UE = Eig?5 (1 + G)Yr F (6-1)
where, UE = uncontrolled emissions, MT.
E19?5= 95 500, MT.
G = New coating line growth rate, per year 0.0353 (1975-1980)
and 0.0379 (1981-1985).
F = Fraction of industry employing a certain application
technique.
Yr = Years since 1975.
The growth rate in Equation 6-1 is based on economic data presented in
Chapter 7 and is weighted based on emission estimates per Standard Industrial
Classification (SIC) code obtained from emission inventory data.
The controlled emission estimates are based on three separate pro-
jections that considered State Implementation Plans (SIP) and New Source
Performance Standards (NSPS) based on the control options. The first
projection, (AE)new, represents emission estimates after air pollution
controls are required on new coating lines because of SIP or NSPS regula-
tions. The next projection, (AE)m&r, is for affected, modified, and recon-
structed coating lines which have been assumed to have a 15-year life. The
last projections, (AE) is for facilities remaining uncontrolled after
SIP and NSPS regulations. These terms are combined into Equation 6-2.
E = (AE) + (AE)m&r + (AE)yr (6-2)
where, E = controlled emissions, MT.
(AE)new =
E1979 = emissions for which the SIP and NSPS regulations go into effect,
MT.
CE = control efficiency of selected control techniques from Chapter 5,
or SIP requirement.
6-5
-------
(AE)m&r = (n) MR E1979 (
n = 1+ years after 1979.
MR = rate per year of modified and reconstructed coating lines, 0.067
(see Chapter 7)
(AE)yr = UE - (AE)m&r
For the above calculations it was assumed that emission controls would
take effect in 1980.
The primary impacts of the control options from Chapter 5 are summarized
below.
• All of the control options will reduce VOC emissions below 1975
levels before the last projected year of 1986 (see Tables 6-1 to 6-3).
This assumes that NSPS regulations will be required by 1980.
Secondary impacts associated with each control option is discussed
below.
• Carbon dioxide is produced as a combustion product from coating
lines employing thermal incineration as a control technique. Even though
carbon dioxide is not considered a pollutant, it is being studied to deter-
mine if increased emissions of carbon dioxide from combusting fossil fuels,
forest fires, etc., could cause a "green house" effect. Thermal incineration
is a source of increased emissions of carbon dioxide because of the organic
solvents and fossil fuels burned by the incinerators. No emission estimate
is presented for carbon dioxide because chemical composition of the solvent
used in the metal furniture industry varies from plant to plant.
• The utilization of waterborne coatings has been identified as a
potential source of N-nitrosamines. N-nitrosamines are considered to be
among the most potent and versatile of all chemical carcinogenic agents.
The amines released from waterborne coatings may contribute to the formation
of N-nitrosamines in the atmosphere. No data are available on emission
rates of these compounds, however, based on ambient data reported in
Reference 7, the health hazard associated with the amine emissions is
minimal. Therefore, until other data can be obtained it is assumed in this
report that emission of amines from waterborne coatings does not appear to
be a significant health hazard.
6-6
-------
6.2 WATER POLLUTION IMPACT
This section addresses water quantities and qualities impacted by the
control option for a coating line.
Processes on the coating line that use water are listed below:
Process Coating type
Pretreatment All coating types
Spray booth Conventional organic
solvent-borne, some
high solids, some
waterborne.
Dip tank Waterborne, conventional
solvent-borne.
Electrodeposition tank Waterborne
Only water pollution associated with the above processes is considered
in this section.
Table 6-4 shows "typical" waste effluents from coating lines (not
necessarily the metal furniture) in metal finishing facilities that have
o
been studied. It is assumed for this evaluation that the metal furniture
facilities using conventional organic solvent-borne coatings fall within
the effluent ranges shown in the table. The effluent concentration and
chemical composition is due to process water from the metal pretreatment
and application areas. In this industry process water reuse seems to be the
general rule of operation. Water usage from the pretreatment area increases
or remains the same for all of the control options. For high solids and
waterborne coatings, water usage associated with pretreatment may actually
increase due to the need for more pretreatment.
Spray booths are usually equipped with water curtains which aid in
particulate capture and removal of overspray. The utilization of water
curtains for existing lines that are modified or reconstructed will pro-
bably continue unless the metal parts are coated with powder. This is a
problem for waterborne spray coatings containing water-miscible solvents
which require removal by ultrafiltration. For new coating lines employing
coating formulation changes such as high solids, waterborne or powder,
spray booths will be designed without water curtains. Some high solids and
waterborne spray booths are equipped with filter pads while all powder
6-7
-------
Table 6-4. QUALITY OF WATER DISCHARGE
Subcategory 7 - Material Coating (variations among plants)
Parameter3'
PH
Turbidity (JTU)C
Temperature
Dissolved oxygen
Sulfide
Cyanide
Total solids
Total suspended solids
Settleable solids
Cadmi urn
Chromium, total
Chromium, hexavalent
Copper
Fluoride
Iron, total
Iron, dissolved
Lead
Oil, grease
COD
Total phosphates
Zinc
Boron
Mercury
Nickel
Silver
Flow (for a production
Minimum
1.5
0.300
282K
1.0
0.010
0.010
35
0.200
0.200
0.002
0.005
0.005
0.011
0.130
0.130
0.003
0.006
0.500
3.7
0.200
0.020
0.050
0.002
0.007
0.002
floor area
Maximum
11.3
3800
336K
12.0
24
1.6
63,090
28,390
40
60.9.
400
36.4
1060
110
422.2
367.7
102.8
13,510
40,000
62.4
86.5
21.3
0.055
0.950
0.100
of 107,000 ft2) - 108,000
Mean
395.6
296. 3K
7.0
1.3
1.03
2917.9
917.8
10.5
2.1
20.1
1.5
21.1
6.8
21.6
17.9
1.7
545.2
1837
9.5
4.6
2.5
0.012
0.207
0.007
GPD
aAll parameters measured in mg/liter except pH, turbidity, and temperature.
bMany of these pollutants are under consideration.
cJackson Turbidity Units.
6-8
-------
spray booths utilize an exhaust gas filtration system. This reduction in
water usage should benefit facilities having to comply with water pollution
control regulations.
Coating lines employing dip or electrodeposition tanks have a water
pollution problem because of dragout. Dragout is defined as the volume of
solution carried over the edge of a process tank by an emerging piece of
work. The solution usually ends up in water used to clean the application
area, or in process drains. Switching to a control option such as powder
(fluidized-bed) will reduce or eliminate this problem.
The use of electrodeposition, however, presents a somewhat different
problem due to the difference in paint formulation. Because of this,
ultrafiltration is usually an integral part of an electrodeposition process.
This is quite effective in removing paint solids from the waste streams.
Table 6-5 qualitatively summarizes water usage for Model Plant A
concerning each control option. Projections are not presented for water
usage for this industry because it is difficult to differentiate water flow
data into recycled or fresh water. Also, Table 6-6 provides a qualitative
evaluation of some of the pollutant flows from Table 6-4 versus control
options.
Water pollution regulations for this and other industries are governed
by the Federal Water Pollution Control Act. This Act specifies several
levels of control that are applicable to industries including the metal
furniture coating industry. These levels of control are:
1. For existing plants, best practicable control technology currently
available (BPCTCA/BPT) by 1977.
2. For existing plants, best available technology economically
achievable (BATEA/BAT) by 1983.
3. For new sources, New Source Performance Standards considering
costs and any non-water quality environmental impact and energy requirements.
4. The Act allows States to establish more stringent than Federal
standards if desired.
Methods that facilities can employ to reduce or eliminate water pollution
include in-plant controls and wastewater treatment. In-plant controls
reduce water pollution treatment costs by minimizing pollutants to be
6-9
-------
Table 6-5. QUALITATIVE ANALYSIS FOR WATER USAGE AT MODEL PLANT A
Control
option
Powder
Waterborne
High solids
Thermal incinerator
Pretreatment
area
Unchanged
Increased or
unchanged
Increased or
unchanged
Increased or
Application
area
Reduced or
eliminated
Unchanged
or reduced
Unchanged
or reduced
Unchanged or
Overall
water usage
Reduced
Unknown
Unknown
Unknown
plus high solids unchanged
reduced
6-10
-------
Table 6-6. QUALITATIVE ANALYSIS FOR POLLUTANT DISCHARGE RATES IN WATER
EFFLUENTS VERSUS COATING FORMULATION CHANGES
Pollutant
Sulfide
Cyanide
Total solids
Total suspended
solids
Cadmi urn
Chromium,
total
Iron, total
Lead
COD
Powder3
spray
Reduced
Reduced
Reduced
Reduced
Reduced
Reduced
Unchanged
Reduced
Reduced
Powder3
fluidized bed
Reduced
Reduced
Reduced
Reduced
Reduced
Reduced
Unchanged
Reduced
Reduced
Waterborne3 to
spray
Unknown
Unknown
b
b
Unknown
Increased
or unchanged
Increased
or unchanged
Unknown
Increased
/aterborne h
dip
Unknown
Unknown
b
b
Unknown
Increased
or unchanged
Increased
or unchanged
Unknown
Increased
ligh solids3
spray
Unknown
Unknown
b
b
Unknown
Increased
or unchanged
Increased
or unchanged
Unknown
Increased
3Control options presented in Chapter 5.
May depend on whether the coating line is new or existing.
-------
treated. In-plant controls include reducing process flow, improving house-
keeping, separating nonprocess and process water, employing counter current
concept, equalizing water flow, and reusing and recycling water. After
in-plant controls have been applied to the practical limit, wastewater
treatment may be necessary to satisfy permits or municipal requirements.
These treatment technologies have been divided into categories of primary
treatment, physical/chemical treatment, biological treatment, membrane
technologies, and sludge treatment. Primary treatment is the method chosen
by those plants that merely separate solids from wastewater without chemical
conditioning, and it is often a first treatment step for those that treat
the wastes further. Physical/chemical treatment involving chemical addition
to enhance precipitation, separation, etc., is the most widely practiced of
the treatment options. Biological treatment in aerated lagoons is applicable
to waterborne wastes and has been practiced. It is particular relevance
for direct dischargers when BOD and COD would not otherwise be sufficiently
reduced. Membrane treatment technologies of ultrafiltration and reverse
osmosis are described as potentially effective methods for the treatment of
painting wastewater. Sludge treatment describes the methods used to thicken,
dewater, and chemically treat the sludge solids generated by the solids
separation treatment technology used.10
6.3 SOLID WASTE IMPACT
Table 6-7 shows quantities of soViu «aste that are produced from the
model plants for each control option. These data are based on a material
balance performed on each model plant. The following assumptions were
employed during development of the solid waste estimates.
1. Transfer efficiencies and paint consumption data reported in
Chapter 5 were utilized in the calculations.
2. Solid waste estimates are limited to those for the application
area of the coating line.
3. Solid waste generated from pretreatment areas on a coating line is
considered to be negligible.
Other solid waste produced in the application area but not estimated
include filter pads and dry filter media. Filter pads are used instead of
water curtains on spray booths for coating formulations such as high solids
6-12
-------
I
CO
Table 6-7. SOLIDS WASTE ESTIMATES FOR MODEL PLANTS
Kg per Year
Model
Plant
p
r
T
1
i
J
Solvent-3 High solids
borne 60% 65% 70%
ninn QQ onn oocnn oocnn
, 1UU oo , oUU oo , bill) oo , bUU
10 , yuu i/ , ^uu i/ , ^uu -L' j j-UU
O£O 0~M O"7O O~M
-------
and waterborne. Dry filter media are installed on spray booths and fluidized
beds applying powder coatings to metal parts. This waste is removed to a
landfill. The amount of waste from these sources cannot be quantified since
these data have not been reported in the literature.
The chemical composition of the solid waste presented in Table 6-7
depends upon tne type of film formers, pigments, and additives contained in
the applied paint. The film formers contain the synthetic organic resins
(e.g., alkyd, vinyl, acrylic, etc.) that produce the protective covering of
the metal part. The pigments are inorganic or organic compounds which give
the formed film color. Inorganic pigments are sources of elements such as
zinc, lead, arsenic, bismuth, tin, and cadmium. Additives contain organic
and inorganic compounds which provide surface agents, driers, thickeners,
flame retardants, etc., and are very important for coatings such as water-
borne and high solids. Solid wastes produced from coating lines are dis-
posed of in three ways: (1) incineration, (2) landfill, and (3) stockpiling.
While combustible waste recovered from a coating line can be incinerated,
trace elements may be emitted as air pollutants. Also, incineration of some
q
powder coatings may be impractical. Most industries use the second method
of disposal, landfill. However, many landfill operators are beginning to
reject solid waste from industry because of some of the elements present in
the waste. The last method of solid waste disposal is stockpiling or
dumping of material on property owned by the facility which produced the
solid wastes. Solid waste stored in this manner could be concentrated in
rain water runoff, however, and therefore presents an adverse impact.
Projections of solid waste over a five year period were not done since
the estimates would show the same impacts as displayed in Table 6-7. Those
primary impacts are summarized as:
1. Sprayed high solids and waterborne coatings produce more solid
waste because of lower transfer efficiencies.
2. Solid waste generated from powder coatings sprayed on parts is a
function of the number of color changes and total amount of powder utilized.
3. For dip coating operations powder applied by the fluidized bed
technique is the biggest producer of solid waste. The lowest amount of
solid waste produced for this coating technique is from electrodeposition
applying waterborne paints.
6-14
-------
4. Solid wastes generated from 60, 65, and 70 percent-by-volume high
solids coatings are comparable.
6.4 ENERGY IMPACT
Table 6-8 shows energy consumption estimates for the model plants by
control options. These data are based on References 1-15 of Chapter 5.
For each control option total energy consumption is less than for the
uncontrolled case (solvent-borne). The only exception consists of water-
borne coatings applied by the electrodeposition process. Though it might
not be expected that thermal incineration would consume less energy than
the uncontrolled case, it does because the incinerator is utilized on a
coating line applying high solids (60 percent by volume) rather than a
conventional solvent-borne coating.
Explanations for the lower energy consumption for powder, high solids,
and waterborne coatings when compared with organic solvent-borne coatings
are shown quantitatively in Table 6-9.
Energy consumption projections for 1979 and 1983 are shown in Table 6-10.
The projections are for a five year period covering SIP and NSPS regulations.
Equation 6-3 is employed for projecting energy consumption for spray coating
lines.
(EE)RA (EE)SIPs
(Energy)yr = — ff- (energy)RA + — -f— (energy)sips
UE R(energy),,r (6-3)
(UE)B
Where, (Energy) = energy consumed in any one year (1979-1983), joules.
(EE)RA and (EE)5jps = emission estimates from equation 6-1 for each control
option and SIP regulation, respectively.
B B
(EE)RA and (EE)Sjps = emission estimates from Table 5-2 (Model Plant B) for
each control option and SIP regulation, respectively.
(energy)RA, (energy)sips and (energy)^ = energy consumption estimates from
Table 6-8 for each control option, SIP regulation,
and solvent-borne, respectively.
P
UE and (LIE) = uncontrolled emission estimates from Table 6-1 and
Table 5-2, respectively.
6-15
-------
en
i
Table 6-8. ENERGY CONSUMPTION ESTIMATES FOR MODEL PLANTS
1010 Joules per year3
Model
plants
A
B
C
D
E
F
G
H
I
J
Solvent-
borne
918
1,530
116
116
47
47
100
17
4
5
(3,540)
(5,896)
( 870)
( 870)
( 366)
( 366)
(5,900)
( 870)
( 366)
( 366)
High sol
(60, 65,
872 (2
1,450 (3
110 (
110 (
34 (
34 (
ids0
70%)
,370)
,950)
583)
583)
245)
245)
c
O
Water-0
borne
1,060
1,760
133
54
54
54
& 500
& 85
& 20
6
(2,
(3,
(
(
(
(
(3,
(
370)
950)
583)
245)
245)
254)
950)e
583 )e
245 )e
245)
Powder0 Thermal0'01
incinerator
872
1,450
110
34
34
34
130
22
5
(1,770) 872
(2,950) 1,450
( 435) 110
( 1 QO"\
V. looj
/ IQ-^
V J.OO )
( TQ^\
^ J.OJJ —--
(2,950) 100
( 435) 17
183)
(2,590)
(4,130)
( 635)
(4,020)
( 688)
a
First set of numbers are for total electric usage and numbers inside parentheses are total additional
natural gas usage.
Estimates for uncontrolled plant.
Estimates for control options presented in Chapter 5.
For thermal incinerators utilizing 50 percent energy recovery.
p
The range of electric usage rates for dip and electrodeposition, respectively.
-------
Table 6-9. QUALITATIVE ANALYSIS OF ENERGY CONSUMPTION ON A COATING LINE
Coating type3 Pretreatment area Dry-off oven Application area Flash-off area Bake oven
Powder
Same as organic
solvent-borne.
Same as organic Energy reduction
solvent-borne. because of less
make-up air.
Energy reduction
because there is
no flash-off area.
Energy reduc-
tion because
of elimination
of heat-up
zone.
High solids
en
A possible
increase in
energy con-
sumption, or
remain the
same.
Same as
organic
solvent-borne.
Energy reduction
because of less
make-up air.
Energy reduction
because of less
solvent applied.
Energy reduc-
tion because
of possible
lower curing
temperature.
Waterborne
A possible
increase in
energy con-
sumption, or
remain the
same.
Energy reduc-
tion because
this step is
not always
necessary.
Energy reduction
because of less
make-up air.
Same as organic Increase of
solvent-borne. energy con-
sumption
because of
water.
Boating formulation changes that are some of the control options presented in Chapter 5.
-------
Table 6-10. PROJECTIONS OF ENERGY CONSUMPTION FOR EACH CONTROL OPTION
Joules (1014) per Year
Year
1979
1980
1981
1982
1983
Conventional
solvent-borne
272
281
291
302
314
High solids
(60, 65, and 70%)
251
240
229
219
225
Waterborne
251
241
232
223
227
Powder
251
232
212
193
171
Thermal ,
incinerator '
251
241
232
223
229
Estimates industrywide for uncontrolled plants.
Estimates obtained after each control option (see Chapter 5) has been applied industrywide.
cThis control option should vary more than any control option when considering energy
consumption.
-------
The primary impact of the control options according to Equation 6-3
seems to occur after year 1982. For all regulatory alternatives except
powder, energy consumption will begin to increase during 1983. However,
the amount of energy consumed is still less in each case than for conven-
tional solvent-borne coatings.
Although discussion in this section has been limited to energy consump-
tion associated with the coating line, energy consumption related to producing
and shipping each control option must also be addressed. Energy consumption
associated with producing different coating formulations has not been
compiled. However, it is known that powder and high solids coatings require
less energy to ship than any other alternative since fewer drums have to be
shipped to perform a coating job. In addition, waterborne coatings require
less shipment energy due to the reduced need for additional solvent.
6.5 OTHER ENVIRONMENTAL IMPACTS
Some electrodeposition coatings that contain amines may cause visible
emissions from a bake oven. Some automobile coating plants have, as a
result, utilized incinerators on bake exhaust streams to eliminate visible
emissions and odors associated with these amines. Such a problem has not
been witnessed at a metal furniture coating facility.
The only other possible environmental impact is associated with visible
emissions resulting from powder coatings. During one plant trip, visible
emissions were observed from a fluidized bed process in which metal parts
were coated with powder. This particular case occurred because the baghouse
Q
attached to the fluidized bed was not operating.
6.6 OTHER ENVIRONMENTAL CONCERNS
6.6.1 Irreversible and Irretrievable Commitment of Resources
Regardless of which alternative emission control system is selected,
additional equipment will be required. Thus, additional steel and other
raw materials will be consumed. This commitment of resources is small
compared to the national usage of each resource. However, a good quantity
of these resources will ultimately be salvaged and recycled. Also, the
commitment of land on which to locate additional control devices or applica-
tion equipment or both is expected to be minor.
6-19
-------
Without heat recovery, significant energy would be lost. Thus, the
use of primary and secondary heat recovery would enhance the value of
incineration.
6.6.2 Environmental Impact of Delayed Standards
Increased emissions of VOC based on growth projections for the metal
furniture industry are discussed in Section 6.1 of this chapter. If a new
source performance standard is delayed, VOC emissions would continue to
increase even though SIP regulations now exist. Also, the amount of energy
consumed on a coating line will continue to increase after 1982.
The only possible negative environmental impacts associated with the
control options are for water and solid waste. The use of some waterborne
coatings may require ultrafiltration to remove dissolved solids. All of
the coating formulation changes, except powder, could cause an increase in
the amount of solid waste generated by the industry. However, both impacts
are considered to be minor compared to the environmental gains achievable
by reduction of VOC emissions into the air.
6-20
-------
REFERENCES FOR CHAPTER 6
1. Sources and Consumption of Chemical Raw Materials in Paints and
Coatings - Type and End-Use. Stanford Research Institute.
November 1974.
2. Ocko, B. Modern Paint and Coating Magazine. March 1977. p. 61.
3. Gallagher, V. N. and J. Pratapas. Control of Volatile Organic Emissions
from Existing Stationary Sources. Volume III: Surface Coating of
Metal Furniture. EPA-450/2-77-032. U. S. Environmental Protection
Agency, Research Triangle Park, North Carolina. December 1977.
4. California Air Resources Board Survey of Metal Furniture Coating
Plants. 1978.
5. NEDS Emission Inventory Data. NADB, Research Triangle Park, North
Carolina.
6. Fugita, E. M. and L. G. Shepard. Consideration of Model Rule for the
Control of Volatile Organic Compound Emissions from Metal Furniture
and Fixture Coating Operations. State of California Air Resources
Board. June 29, 1978.
7. Bachmann, J. D. and J. B. Cohen. In situ Investigation of Atmospheric
Nitrosamine Formation. American Chemical Society Meeting, Division of
Environmental Chemistry. Anaheim, California. March 1978.
8. Suther, B. J. (Foster D. Snell) and Uday Potasku (JACA Corp.) Controlling
Pollution from the Manufacturing and Coating of Metal Products—Metal
Coating Air Pollution Control, Volume 1. EPA-624/3-77-009. May 1977.
9. Nunn, A. B. and D. L. Anderson. Trip Report - Steelcase, Inc., Grand
Rapids, Michigan. TRW, Inc., Durham, North Carolina. March 27-28, 1979.
10. Contractor Report for Development of Effluent Limitations Guidelines
for Paint Application Processes Used in the Mechanical and Electrical
Products Industries. U.S. Environmental Protection Agency,
Washington, D.C., July 1979.
11. Gabris, T. Trip Report - Ford Motor Co., Milpitas, California. Spring-
born Laboratories, Inc., Enfield, Connecticut. Trip Report No 112
April 7, 1976.
6-21
-------
7. ECONOMIC IMPACT
7.1 INDUSTRY PROFILE
This section profiles the metal furniture manufacturing industry. The
information contained herein is intended as an input to the analysis of
economic impact that results from the control of volatile organic compound
(VOC) emissions from metal furniture coating operations. The manufacturing
industry is of concern because the amount of metal furniture coating and
painting performed is highly correlated with industry output. Because
manufacturers perform most of the coating themselves, the main burden of
control costs falls on them. A small percentage of furniture is sent to
independent jobbers who coat items that they do not manufacture. This type
of operation is largely undocumented; for instance, although jobbers are
covered by Standard Industrial Classification (SIC) 3479 (metal coating,
engraving, and allied services), published data do not separate them speci-
fically from sandblasters, galvanizers, and other operations. It is
believed that the volume of metal furniture painted by jobbers is small and
that these operations are relatively few in number.
The metal furniture industry is covered by four SIC codes:
1. Metal household furniture (SIC 2514);
2. Metal office furniture (SIC 2522);
3. Public building and related furniture (SIC 2531);
4. Metal partitions and fixtures (SIC 2542).
A finer breakdown of the four categories can be found in section 2.1.
7.1.1 Industry Structure
In 1976, the metal furniture industry included approximately 1400
establishments, employed about 100,000 people and made shipments valued at
$3,657 million (see Table 7-1). Figures on the four segments of the industry
show that three of them have a similar small business orientation.
-------
ro
Table 7-1. METAt FURNITURE WKJFACTURIN6 INDUSTRY, 1976-1977
Number of
establishments
1976*
1977
Value of
frodti&tpy stotpmerts
(nrmtorre of doTTars)1
T976C %
T§76
Number of Average shipments
employees per establishment
(thousands) (millions of dollars)
d % 1977b
1976
1977
Metal household
furniture
(SIC 2514) 391
Metal office
furniture
(SIC 2522) 177
Public building
and related
28 441 991.6 27 1256.7
13 185 1073.1 29 1375.5
30.5 31 32.2
25.7 36 28.4
rurniture
(SIC 2531) 377
Metal partitions
and fixtures
(SIC 2542) 449
Total 1394
27
32
415
NA
716.2
875.8
3656.7
20
24
764.8
NA
20.6
21.9
98.7
21
22
19. .6
NA
2.5
6.1
1.9
2.0
2.8
7.4
1.8
NA
Bounty Business Patterns, 1976. U.S. Sumnttry Statistics, Department of Commerce. Washington, D. C.
bMptal Household Furniture T977 QHTSUS of Manufactures Preliminary Report. Department of Commerce.
™f^W^U52tt S3TS* ,T
1977 Census of Manufactures Preliminary Report, Department of Commerce, Washington, D.C. May 19/y. P. t.
cAnnual Survey of Manufactures. General Statistics for Industry Groups awd Industries. Department of
Commerce. Washington, D. C. December 1977.
dAnnual Survey of Manufactures. TS76 Value of Product Shipments. Department of Commerce, Washington, D.C.
December 1977.
NOTE: Because 1976 figures for establishments and shipments are from separate sources, they may not be
entirely compatible.
-------
The fourth segment - the metal office furniture category - is smaller in
terms of number of establishments but operates on a somewhat larger
scale than do the other segments.
In 1976, for instance, metal household furniture, public building
and related furniture, and metal partitions each had around 400 establish-
ments and between $700 million and one billion dollars in shipments.
Metal office furniture had only 177 establishments and over one billion
dollars in shipments, putting its average shipments per establishment at
over six million dollars, versus approximately two million dollars for
the other sectors (Table 7-1). Preliminary figures for 1977 show this
trend continuing.
Historical data confirm the disparity between metal office furni-
ture and the other three sectors. In terms of concentration, the
industry's shipments are dispersed among a number of companies, with
less than 20 percent of shipments made by the top four firms in 1972
(see Table 7-2) except in the case of metal office furniture. Here,
concentration is much greater, with 37 percent of shipments made by four
firms and 88 percent made by the 50 largest companies.
Metal office furniture is much more heavily weighted towards multi-
unit companies than are the other three segments (Table 7-3). Metal
office furniture has only 17 percent of its shipments made by single-
unit firms versus 40 percent for the other three segments.
Similarly, metal office furniture has fewer firms with a low number
of employees. As shown in Table 7-4, the other segments have over 50
percent of their establishments falling into the category of less than
20 employees, while office furniture has only 39.1 percent of its
establishments in that category.
Even though office furniture companies tend to operate on a larger
scale, private ownership is prevalent in this sector, as it is in the
remaining three. In terms of legal organization, approximately 80
percent or more of the firms in all sectors were incorporated in 1972
(see Table 7-5).
7.1.1.1 Geographic Distribution of Industry. Metal furniture
manufacturing establishments are spread throughout the United States,
7-3
-------
Table 7-2. CONCENTRATION RATIOS IN METAL FURNITURE MANUFACTURING
Percent of value of shipments
accounted for by:
Metal household furniture
(SIC 2514)
1972
1967
1963
1958
Metal office furniture
(SIC 2522)
1972
1967
1963
1958
Public building and
related furniture
(SIC 2531)
1972
1967
1963
19B8
Metal partitions and
fixtures
(SIC 2542)
1972
1967
1963
1958
4 largest
companies
14
12
12
12
37
32
39
33
18
18
21
24
13
19
19
(NA)
8 largest
companies
23
21
18
19
49
45
45
49
26
30
32
34
22
27
26
(NA)
20 largest
companies
41
35
31
33
70
69
69
73
40
46
45
47
39
43
31
(NA)
50 largest
companies
65
56
53
52
88
88
88
89
-
59
64
62
65
59
64
61
(NA)
Source: U. S. Department of Commerce. Census of Manufactures. 1972.
NA - Not available.
7-4
-------
Table 7-3. PERCENT OF VALUE OF INDUSTRY SHIPMENT IN METAL FURNITURE
MANUFACTURING MADE BY MULTI-UNIT AND SINGLE-UNIT COMPANIES, 1972
Multi-unit Single-unit
companies companies
(percent) (percent)
Metal household furniture
(SIC 2514) 62 38
Metal office furniture
(SIC 2522) 83 17
Public building and
related furniture
(SIC 2531) 56 43
Metal partitions and
fixtures
(SIC 2542) 58 42
Source: U.S. Department of Commerce. Census of Manufactures. 1972.
7-5
-------
CTl
Table 7-4. DISTRIBUTION OF ESTABLISHMENTS IN THE METAL FURNITURE
MANUFACTURING INDUSTRY BY FIRM SIZE, 1972
Firm size,
number of
employees per
establishment
1 to 19
20 to 49
50 to 99
100 to 249
250 to 499
500 to 999
1000 to 2499
2500 or more
Metal household
furniture
(SIC 2514)
50.7
18.0
10.3
13.1
6.2
1.3
0.4
—
Metal office
furniture
(SIC 2522)
39.1
14.1
15.6
18.2
6.3
4.2
2.1
0.5
Public building and
furniture
(SIC 2531
53.8
20.9
11.4
10.2
2.8
0.7
0.2
Metal partitions and
fixtures
(SIC 2542)
52.3
22.5
12.0
8.9
2.4
1.4
—
. — — —
Source: U. S. Department of Commerce. Census of Manufactures. 1972.
-------
Table 7-5. LEGAL FORM OF ORGANIZATION FOR METAL FURNITURE MANUFACTURERS, 1972
Metal household
furniture
Corporate
Noncorporate total
Individual
Partnership
Other and unknown
Number of
estabs.
401
66
29
13
24
%
86
14
6
3
5
Metal
furni
Number
estabs
167
26
18
3
5
office
ture
of
%
87
13
9
2
2
Public
related
Number
estabs.
331
91
52
15
24
building and
furniture
of
%
78
22
12
4
6
Metal partitions
fixtures
Number of
estabs.
425
82
46
14
22
and
%
84
16
9
3
4
1972 Census of Manufactures. Department of Commerce. Washington, D.C. January 1975.
p. SR3-33 to SR3-34.
-------
although there is light representation in Pacific Division states other
than California (see Table 7-6). About 70 percent of establishments in
1976 were located in nine states:
New York 16 percent New Jersey 5 percent
California 16 percent Texas 4 percent
Illinois 8 percent Michigan 4 percent
Pennsylvania 7 percent Florida 4 percent
Ohio 6 percent
7.1.1.2 Product Mix. Table 7-7 shows the product mix for all
sectors from 1963 through 1976. This mix has remained quite stable over
time. Tables 7-8, 7-9, and 7-10 give a more detailed product breakdown
for each sector in 1977 except metal partitions. The tables help to
identify the various surface types that are coated by the industry.
7.1.1.3 Capacity Utilization Rate. Table 7-11 summarizes the
capacity utilization situation in the metal furniture industry as of the
fourth quarters of 1976 and 1977. This table shows the practical rate
of utilization, which is the highest possible percentage utilization,
given cost and other constraints. The preferred rate, shown as a
percent of the practical rate, is a point between the actual and
practical rates which could be defined as optimal.
Because of the standard error of the 1977 practical rate estimates,
it is difficult to cite a trend with much confidence. The numbers do
indicate that the actual rate of utilization in 1977 is likely to be
less than 70 percent for each sector. (This is based on the assumption
that the actual rate is lower than the preferred rate, which can be
expressed in terms of total available capacity by multiplying the
preferred rate in the table by the practical rate).
7.1.2 Trends in the Industry
7.1.2.1 Establishments and Employees. Changes in the number of
establishments and employees are depicted in Figure 7-1 through 7-4,
plotted from numbers in Table 7-12. These graphs show a downward trend
in the number of establishments between 1972 and 1976. Preliminary 1977
figures for the household, office, and public building sectors show an
upturn in number of establishments. Although the curves for each sector
7-8
-------
Table 7-6. GEOGRAPHIC DISTRIBUTION OF METAL
FURNITURE ESTABLISHMENTS, 1976
Region and State
New England
Maine
Massachusetts
Connecticut
New Hampshire
Rhode Island
Middle Atlantic
New York
New Jersey
Pennsylvania
East North Central
Ohio
Indiana
Illinois
Michigan
Wisconsin
West North Central
Minnesota
Iowa
Missouri
Kansas
Nebraska
South Atlantic
Maryland
Delaware
Virginia
North Carolina
South Carolina
Georgia
Florida
West Virginia
East South Central
Kentucky
Tennessee
Alabama
Mississippi
Metal
household
furniture
(SIC 2514)
13
5
1
—
66
14
24
12
4
31
8
6
3
—
6
—
—
6
—
8
13
3
5
30
—
5
9
9
4
Metal
office
furniture
(SIC 2522)
—
4
—
0
—
27
9
17
9
6
11
8
4
3
1
6
3
—
—
1
3
5
—
7
3
—
2
3
4
—
(continued)
7-9
Public
building
and related
furniture
(SIC 2531 )a
1
8
4
1
—
20
7
24
27
11
23
17
17
6
8
—
4
—
—
—
7
16
2
—
12
—
5
18
6
3
Metal
partitions
and fixtures
(SIC 2543)
—
9
—
0
4
93
29
26
32
7
41
23
6
9
1
11
5.
2
—
—
—
4
4
7
8
3
3
6
6
3
Total
1
34
9
2
4
206
59
91
80
28
105
56
33
21
10
23
12
2
6
1
19
38
9
19
53
3
15
36
25
10
-------
Table 7-6. Concluded
Region and State
West South Central
Arkansas
Texas
Oklahoma
Mountain Division
Utah
Colorado
Pacific Division
Oregon
Washington
California
United States Total
Metal
household
furniture
(SIC 2514)
2
16
4
_ __
—
—
69
391
Metal
office
furniture
(SIC 2522)
0
6
—
—
—
—
30
188
Public
building
and related
furniture
(SIC 2531 )a
19
22
—
2
3
5
50
377
Metal
partitions
and fixtures
(SIC 2543)
3
15
2
—
3
3
67
449
Total
24
c r\
59
2
8
7
216
1394
Source: U. S. Department of Commerce. County Business Patterns (by State).
Includes wood, metal, and plastic furniture.
7-10
-------
Table 7-7. METAL FURNITURE PRODUCT MIX, 1963-1976
(as a percent of total industry shipments)
Metal household
furniture
(SIC 2514)
Dining, breakfast
Kitchen
Porch, lawn, outdoor
Other
N.s.k.
Metal office
furniture
(SIC 2522)
Office seating
Desks
Cabinets, cases
Other
N.s.k.
Public building
related furniture
(SIC 2531)
School furniture
Non-school furniture
Other
Metal partitions
and fixtures
(SIC 2542)
Partitions
Shelving and lockers
Storage racks
Fixtures
Other
1976a
27.1
7.4
2.0
7.3
9.7
0.6
29.3
7.3
4.6
10.6
6.0
0.8
19.6
6.6
12.5
0.3
24.0
2.0
8.2
5.2
6.8
1.6
1975a
28.1
9.2
1.7
6.8
10.5
—
27.8
7.0
4.5
10.9
5.4
—
19.5
7.2
11.8
0.5
24.7
3.4
8.0
4.7
6.6
1.9
1974a
28.1
8.9
1.7
6.8
10.7
—
29.5
7.7
5.5
11.2
5.1
—
17.4
6.7
10.1
0.6
25-.0
3.1
7.8
5.5
6.6
2.1
1973a
29.9
8.5
2.7
6.1
12.5
—
28.9
7.5
5.5
11.4
4.5
—
17.3
6.3
9.7
1.3
24.0
2.5
8.2
3.4
8.3
1.5
1972b
30.1
8.6
2.5
6.2
12.8
—
27.4
6.8
5.4
10.5
4.8
—
17.4
6.4
9.8
1.2
25.0
2.8
8.3
3.3
7.6
3.0
1967b
28.3
7.9
2.7
5.3
12.4
—
28.2
6.4
7.3
9.6
4.9
—
18.8
7.6
10.1
1.0
24.7
NA
NA
NA
NA
NA
1963b
22.9
9.4
4.2
6.8
13.5
—
23.9
4.9
5.9
9.6
3.6
—
17.6
7.9
9.0
0.7
24.6
NA
NA
NA
NA
NA
N.s.k. = Not specified by kind.
NA = Not available.
a
Annual survey of Manufactures. 1976 Value of Product Shipments. Department
of Commerce, Washington, D.C. December 1977.
Census of Manufactures. 1972 and 1967 (separate volumes). Department of
Commerce. Washington, D. C.
7-11
-------
Table 7-8. 1977 PRODUCT BREAKDOWN FOR METAL HOUSEHOLD FURNITURE (SIC 2514)
Shipments Percent
(millions of dollars) (of total)
Total H47.7 100.0
Metal household dining, dinette, and
breakfast furniture 309.1 26.9
Tubular metal, including chairs whether
padded or plain:
• Sets (tables and chairs) 236.1 20.6
0 Tables (not sold with a set) . 16.9 1.5
§ Chairs (not sold with a set) 13.4 1.2
Other metal dining, dinette, and
breakfast furniture 35.7 3.1
Metal household dining, dinette, and
breakfast furniture, n.s.k 7.0 0.6
Metal kitchen furniture . . .' 73.3 6.4
Kitchen furniture, excluding breakfast
furniture reported as "dining, dinette,
and breakfast furniture":
0 Cabinets such as base, top, and base
- wall, utility, etc 49.5 4.3
0 Stools, padded and plain 17.2 1.5
0 Tables, including hostess carts 5.5 0.5
Metal kitchen furniture, n.s.k 1.1 0.1
Metal porch, lawn, outdoor, and casual
furniture 262.9 22.9
Tubular aluminum:
0 Chairs, rockers, benches, chaise lounges,
and settes 122.5 10.7
0 Other tubular aluminum porch, lawn, and
outdoor furniture, including gliders,
swings, and hammocks 20.0 1-7
Cast and wrought iron:
0 Chairs, rockers, benches, chaise lounges,
and settes 44.3 3.9
0 Other cast and wrought iron porch, lawn,
and outdoor furniture, including
gliders, swings, and hammocks 12.6 1.1
Other metal porch, lawn, outdoor, and
casual furniture, including picnic
tables 37.4 3.3
Metal porch, lawn, outdoor, and casual
furniture, n.s.k 26.1 2.3
" (continued) ~ ~~~
7-12
-------
Table 7-8. Concluded
Shipments Percent)
(millions of dollars) (of total)
Other metal household furniture 391.2 34.1
Folding cots, reliable cots, army cots,
and other metal beds 10.5 0.9
Metal bed frames (complete metal bed frames
sold separately, with or without a
headboard 57.0 5.0
Upholstered metal household furniture. . . 12.4 1.1
Card tables and chairs (a)
Medicine cabinets, including "wall type"
and "insert type" 60.2 5.2
Metal radio, phonograph, TV, and hi-fi
cabinets 5.0 0.4
Infants' high chairs 12.1 1.1
Infants' car seats 13.6 1.2
Other infants' and children's metal
furniture, including chairs, tables,
playpens, play yards, and portable
cribs 46.2 4.0
Metal folding tray tables (a)
Other metal household furniture 110.1 9.6
Other metal household furniture, n.s.k. . 22.5 2.0
Metal household furniture, n.s.k., typically
for companies with 5 employees or more. ... 81.4 7.1
Metal household furniture, n.s.k., typically
for companies with less than 5 employees. . . 29.8 2.6
(a) Withheld to avoid disclosing operations of individual companies.
n.s.k. = Not specified by kind.
Metal Household Furniture. 1977 Census of Manufactures. Preliminary
Report. U. S. Department of Commerce, Washington, D.C. April 1976.
p. 3.
7-13
-------
Table 7-9. 1977 PRODUCT BREAKDOWN FOR METAL OFFICE FURNITURE (SIC 2522)
Shipments Percent
(millions of dollars) (of total)
Total 1334.6 100.0
Metal office seating, including upholsteres:
As reported in census of manufactures. . . 386.2 28.9
As reported in Current Industrial Report
MA-25H:
• Office furniture 377.7 28.3
• Stacking chairs 74.6 5.6
t Secretarial posture chairs 59.6 4.5
• Executive chairs 123.4 9.2
• Chairs, side and arm 138.4 10.4
• Sofas, couches, settees, stools, etc.
including:
Upholstered 11.7 0.9
• Tandem seating 7.8 0.6
• Metal office seating, including
upholstered, n.s.k (a) .
Desks, including modular unit desks:
As reported in census of manufactures. . . 226.1 16.9
As reported in Current Industrial Report
MA-25H:
• Office furniture 227.3 17.0
t Executive-type desks 61.8 4.6
• Clerical and secretarial desks, with
or without typewriter mechanism 148.7 11.1
• Desks, n.s.k 16.8 1.3
Filing cabinets and cases:
As reported in census of manufactures. . . 477.9 35.8
As reported in Current Industrial Report
MA-25H:
• Office furniture 479.0 35.9
• Vertical filing cabinets, noninsulated,
nonmechanical, nonvisible, including
security files:
Letter 133.9 10.0
Legal 69.1 5.2
Other, except letter and legal .... 29.1 2.2
• Horizontal filing cabinets, noninsulated,
mechanical, nonvisible, including
security files 99.4 7.4
• Mechanical nonvisible files, all sizes,
manual and electrical 24.3 1.8
• Insulated filing, film, and tape cabinets,
and security files, excluding stores . . 26.4 2.0
(continued)
7-14
-------
Table 7-9. Concluded
Shipments Percent
(millions of dollars) (of total)
• Visible equipment (other than
insulated), including vertical
and rotary units:
Nonmechanical, including
cabinets, reference panel
type chart boards, book
type, etc 31.9 2.4
• Mechanical, including card size
and reference type, manually or
electrically operated 4.5 0.3
• Filing cabinets and cases, n.s.k. . . . 60.4 4.5
Other metal office furniture, including
tables, stands, etc.:
As reported in census of manufactures. .. 218.0 16.3
As reported in Current Industrial
Report MA-25H:
• Office furniture 211.1 15.8
• Metal tables and stands 51.6 3.9
Modular service units, except desks. . . . 30.6 2.3
t Metal furniture panel systems:
Panels or screens as space dividers
only
Panels with capability of accepting
hangers
Panel-supported work surfaces
Panel-supported files
Panel-supported storage and
accessories 54.4 4.1
0 Metal systems office furniture:
Systems desk/work surface
Systems storage
Systems panels
• Other metal office furniture, including
bookcases, storage cabinets, costumers,
etc 91.1 7.2
• Other metal office furniture, including
tables, stands, etc., n.s.k (a)
Metal office furniture, n.s.k., typically for
establishments with 5 employees or more ... 12.5 0.9
Metal office furniture, n.s.k., typically for
establishments with less than 5 employees . . 13.9 1.0
aTo be revised.
n.s.k. = Not specified by kind.
7-15
-------
Table 7-10. 1977 PRODUCT BREAKDOWN FOR PUBLIC BUILDING
AND RELATED FURNITURE (SIC 2531)
Shipments Percent
(millions of dollars) (of total)
Total 712.3 100.0
School furniture, except stone, concrete,
and library furniture 193.7 27.2
• Single pupil units 34.9 4.9
• Chairs, all purpose (nonfolding) 22.3 3.1
• Storage cabinets 45.3 6.4
• Other school furniture designed
specifically for use in schools, including
two or more pupil desks and tables,
combination folding tables and benches,
tables, teacher desks, study carrels,
chalk boards, etc 83.2 11.7
t School furniture, n.s.k 8.0 1.1
Public building and related furniture,
except for school and restaurant 457.2 64.2
• Seats for public conveyances,
automobile, trucks, aircraft,
and buses 166.2 23.3
• Church pews 32.9 4.6
• Other church furniture (pulpits,
altars, lecterns, etc.) 10.9 1.5
• Folding tables, including folding
banquet tables 33.0 4.6
t Chairs and seats, including theater
and auditorium:
Fixed 26.8 3.8
Portable folding chairs, single or
ganged 21.3 3.0
• Stadium bleacher seating, including
grandstands 43.8 6.1
• Library furniture, all types, including
chairs, charging desks, study carrels,
reading tables, etc 24.3 3.4
• Other public building furniture 56.6 7.9
• Public building and related furniture,
except school, n.s.k 14.0 2.0
Public building furniture, n.s.k., typically
for establishments with 5 employees or more . . 33.4 4.7
Public building furniture, n.s.k., typically
for establishments with less than 5 employees 28.0 3.9
n.s.k. = Not specified by kind.
Public Building and Related Furniture. 1977 Census of Manufactures.
Preliminary Report. U.S. Department of Commerce. Washington, D.C. May 1979.
P. 3.
7-16
-------
Table 7-11. CAPACITY UTILIZATION RATES: FOURTH QUARTERS, 1977 and 1976
1977 1976
Standard error
Preferred Practical Practical of 1977 practical
rate3 rate rate rate
Metal household
furniture
(SIC 2514) 91 77 70 19
Metal office
furniture
(SIC 2522) 88 73 76 15
Public building and
related furniture
(SIC 2531) 92 70 69 21
Metal partitions
and fixtures
(SIC 2542) 90 68 69 19
aShown as a percent of the practical rate.
Survey of Plant Capacity. 1977 Current Industrial Report.
U. S. Department of Commerce. Washington, B.C. August 1978.
p. 4.
7-17
-------
1000
900
800
700
M 600
5 500
I
42 400
5 300
fc 200
100
100
90
80
70
60
50
40
30
20
1956 60 62
64
66 68 70 72 74 76
10
1978
Figure 7-1. Trends in numbers of establishments and employees in
the Metal Household Furniture Industry (SIC 2514).
3
T3
(D
in
3-
O
c.
in
EU
3
O.
in
Figure 7-2. Trends in numbers of establishments and employees in
the Metal Office Furniture Industry (SIC 2522).
-a
o
n>
re
o
c
(SI
3
O-
7-18
-------
c
(U
I/)
1000
900
300
700
cnn
ODD
Rnn
A nn
4UU
onn
oUU
?nn
cUU
100
1(
• i"
358 6(
•
3 62
m
__,
> 6'
Ej- -t-Tih '
stao
•" i
I 6t
- i
i
1
j
i
i
!
. i
. ! 4^ "
1
i
1
1 X ^
1 i /
inployees
i
> 68 7C
1
•v —
) 72
-
***-^
^
^ — "* •
! 11-
>-
\ K
~"
^
^
j 1?
100
on
yu
on
oU
70
60
sn
40
30
in
)78
Figure 7-3. Trends in numbers of establishments and employees ii
the Public Building and Related Furniture Industry (SIC 2531).
1000
900
300
700
600
500
to
;z 400
300
200
100
-Employees
100
90
80
70
60
50
40
30
20
10
1958 60
62
64
66
63
70
72
74
76
1978
Figure 7-4. Trends in numbers of establishments and employees in
the Metal Partitions and Fixtures Industry (SIC 2542).
rtl
CD
O
Z3
CL
o
I/)
3
Q.
(/l
7-19
-------
Table 7-12. NUMBER OF ESTABLISHMENTS AND EMPLOYEES IN METAL FURNITURE MANUFACTURING INDUSTRY, 1958-1977
ro
o
(SIC 2514)
Metal household
furniture
Year
1977
1976C
1975
1974
1973
1972
1971
1970
1969
1968
1967
1963
1958
Estab.a
441
391
NA
NA
NA
467
NA
NA
NA
NA
486
517
626
Emp.
32.2
30.5
28.1
35.4
36.9
34.4
31.5
32.4
32.8
32.1
31.0
29.3
30.3
(SIC 2522)
Metal office
furniture
Estab.a
185
177
NA
NA
NA
192
NA
NA
NA
NA
187
170
151
Emp.b
28.4
25.7
25.2
31.1
30.1
27.6
25.0
27.6
30.5
27.1
27.0
19.9
17.5
(SIC 2531)
Public building
related furniture
Estab.a
415
377
NA
NA
NA
422
NA
NA
NA
NA
438
429
390
Emp.
19.6
20.6
20.0
21.6
22.2
21.4
21.0
23.1
23.4
21.0
22.6
16.9
16.0
(SIC 2542)
Metal partitions
and fixtures
Estab.a
NA
449
NA
NA
NA
507
NA
NA
NA
NA
500
513
NA
Emp.
NA
21.9
21.0
25.6
26.3
26.2
22.2
22.7
25.2
23.4
22.7
20.3
NA
Establishments
Employees (thousands)
C1976 data for establishments:
NA = Not available.
U. S. Department of Commerce. County Business Patterns, 1976.
Source for remaining data: U. S. Department of Commerce. Census of Manufactures, 1972.
Report. Annual Survey of Manufactures, 1973, 1974, 1975, 1976.
1977 Preliminary
-------
over the past 18 years differ from each other in shape, they are similar
in the sense that the percent changes between the points are small.
These small differences indicate that the industry is relatively stable
with moderate rates of exit and new entry.
Numbers of employees have varied quite a bit over recent years for
all sectors. Each sector shows an increase in employees in 1976,
signaling an upturn that is mirrowed in large part by industry shipments.
For the household and office furniture sectors, this trend continued
through 1977.
7-1-2.2 Value of Industry Shipments. Figures 7-5 through 7-8,
derived from Table 7-13, show trends in the value of shipments for the
four sectors in current dollars and in constant 1967 dollars scaled by the
wholesale price indices for household and commercial furniture. The current
dollar trend lines show steady growth interrupted in 1970 and 1975 by
slowing or a downturn in shipment growth. The public building and related
furniture sector shows the effect of slowing the least of any sector,
possibly because of its dependence on government spending.
By plotting shipments in constant dollars, the effect of inflation
is suppressed and the figures better reflect unit shipments. The trend
lines for these values show that there has been little real growth in the
industry as a whole over the past ten years. Instead, the value of
industry shipments have moved cyclically, with peaks occurring in 1969
and 1972-1973. The average industry growth between those peaks is
approximately three percent per year.
In order to evaluate the four sectors' relation to gross national
product, the trends in percent changes in real GNP and in constant dollar
shipments shown in Table 7-14 are plotted in Figures 7-9 through 7-12. In
general, the industry mirrors GNP, but its changes are more volatile, i.e.,
industry shipments expand more rapidly during a period of growth and
contract more quickly during a decline. The metal office furniture sector
is the most volatile and the public building sector the least.
7.1.2.3 Factors Affecting Future Growth of the Industry. The factors
that affect growth in the future differ for the four sectors. Purchases
of metal household furniture are connected to the number of new households
and to consumer discretionary income. Patio and recreational furniture, as
7-21
-------
1200
1100
1000
c
o
00
600
500
400
1967 68 69 70 71 72 73 74 75 76 77 1978
Figure 7-5. Trends in the value of shipments for the
Metal Household Furniture Industry (SIC 2514) in current
and constant dollars.
1400
1967 68 69 70 71 72 73 74 75 76 77 1978
Figure 7-6. Trends in value of shipments for the
Metal Office Furniture Industry (SIC 2522) in current
and constant dollars.
7-22
-------
to
c
o
1/5
to
E
O
800
750
700
650
.7 600
550
500
450
400
t
Curjrerit
x
>s
5Z
z
-t-
1967 68 69 70 71 72 73 74 75 76 77 1978
Figure 7-7. Trends in the value of shipments for the Public
Building and Related Furniture Industry (SIC 2531) in current
and constant dollars.
900
800
700
c
OJ
450
77 1978
Figure 7-8. Trends in the value of shipments for the Metal
Partitions and Fixtures Industry (SIC 2542) in current
and constant dollars.
7-23
-------
Table 7-13. INDUSTRY SHIPMENTS FOR METAL FURNITURE MANUFACTURING IN
CURRENT AND CONSTANT DOLLARS, 1967-1977
(millions of dollars)
^-J
IN3
1967 1968 1969 1970 1971 1972 1973 1974 1975 1976 1977
Wholesale price index for
commercial furniture
100.0 103.8 108.1 114.5 118.1 120.2 129.4 152.4 166.7 173.3 185.9
100.0 103.9 108.4 111.7 114.9 117.3 123.0 136.6 146.3 153.6 162.2
537.4 604.3 657.0 650.7 693.1 859.3 970.7 934.0 895.3 991.6 1147.7
Industry price index for
household furniture
Metal household furniture
current dollars^5
Constant dollars
(using household furniture
index)0
Metal office furniture
current dollarsb
Metal office furniture
constant dollars0
Public building and .
related current dollars
Public building and
related constant dollars
Metal partitions and b
fixtures current dollars
Metal partitions and
fixtures constant dollars0 512.0 504.9 540.1 505.7 491.2 611.1 596.4 557.7 487.5 505.4 NA
537.4 581.6 606.1 582.5 603.2 732.6 789.2 683.8 612.0 645.6 707.6
622.9 654.2 764.5 682.1 682.5 850.7 927.1 1001.8 948.3 1073.1 1375.5
622.9 630.3 707.2 595.7 577.0 707.7 716.5 657.3 568.9 619.2 739.9
421.2 432.5 468.5 462.6 471.8 535.3 555.0 592.1 639.2 716.2 764.8
421.2 416.5 433.4 404.0 399.5 445.3 428.9 388.5 383.4 413.3 411.4
512.0 524.1 583.8 579.0 580.1 734.5 771.8 850.0 812.6 875.8 NA
NA = Not available
a
Statistical abstract of the U.S. Department of Commerce. Washington, D.C.
)1967-1972: Census of Manufactures, 1972.
1973-1976: Annual Survey of Manufactures, (respective years).
1977- : Census of Manufactures, Preliminary Report.
"Constant dollars =
(current dollars * price
index) X 100.
-------
Table 7-14. PERCENT CHANGES FROM PREVIOUS YEAR IN REAL GROSS NATIONAL PRODUCT
AND CONSTANT METAL FURNITURE MANUFACTURING INDUSTRY SHIPMENTS
1968 1969 1970 1971 1972 1973 1974 1975 1976 1977
Percent change in
real GNPa 4.38 2.57 .0.32 2.99 5.74 5.32 -1.84 -1.57 6.15 4.90
$ Change in metal
household, furniture
shipments0 8.2 4.2 - 3.9 3.6 21.5 7.7 -13.4 -10.5 5.5 9.6
Percent change in
metal office ,
furniture shipments0 1.1 12.3 -15.8 -3.0 22.5 1.2 8.2 -13.5 8.8 19.5
Percent change in
--j public building and
r\3 related furniture
shipments5 -1.2 4.2 -6.9 -1.1 11.5 -3.7 -9.4 -1.3 7.8 -0.5
Percent change in
metal partitions
shipments0 - 1.4 7.1 - 6.4 - 2.9 24.5 - 2.4 - 6.5 -12.6 3.7 NA
NA = Not available.
aSource: Statistical Abstract of the United States, 1977.
Source: Table 7-13.
-------
c
OJ
o
!~
01
CD
O
QJ
Q.
25
20
15
10
- 5
-10
-15
1968 69
71
72 73 74 75 76 77 1978
Figure 7-9. Percent changes from previous year in real
gross national product and constant Metal Household
Furniture Industry shipments (SIC 2514).
' 1968 69 70 71 72 73 74 75 76 77 1978
Figure 7-10. Percent changes from previous year in real
gross national product and constant Metal Office
Furniture Industry shipments (SIC 2522).
7-26
-------
1 J
10
5
+•>
§ 0
OJ
Q_
- 5
-10
-15
Pub
Reli
-
r
*»s
_J
fc ^
?**•
7-
*(? B
ited
1968
^X
s:
-1--
atV
11 1d3
Fufni
-
- , —
;-
.
- --
**
k
-— + ---
a?
ture
•'
69 70
/
••?
/
^
/
~'-
cf
—
Ship
- :
.'
v
:..-
I
r~i
• - \-.\
---[-^
.- 1
nents
1
— i —
r
rojss
HH&R
rsL
-::P4|
"
\
%
i
1
Nalti
"*• i
i
M-^
. i f
: ~jr
/ I
j
snai t
/
,J/
Y \
i
i
;
- -_:
A
^
N
s
"-
-- -: ;
72 73 74 75 76 77 19
73
O)
D.
Figure 7-11. Percent changes from previous year in real
gross national product and constant Public Building
and Related Furniture Industry shipments (SIC 2531).
1968
74 75 76 77 1978
Figure 7-12. Percent changes from previous year in real
gross national product and constant Metal Partitions and
Fixtures Industry shipments (SIC 2542).
7-27
-------
luxury items, may be more susceptible to general economic conditions
than kitchen furniture, the other major type of metal household furni-
ture.
Metal office furniture shipments are tied to new office building
construction and the financial prospects for businesses considering
replacement of ^ld furniture. If necessary, new purchases can be
delayed, or old furniture renovated.
As mentioned above, public building and related furniture purchases
are related to government spending. For this reason, steady sales seem
assured. The only factor that might change this situation is a move
toward austerity in government budgets.
Purchases of metal partitions and fixtures may depend on conflicting
factors. Partitions may be used to facilitate locating a greater number
of workers in a small space as an economy measure. On the other hand,
workers can be crowded together without the use of partitions if a
business is not concerned with the quality of the work environment.
7.1.2.4 Recent Developments in the Industry. The graphs of
industry shipments show a substantial upturn for all four sectors in
1976, even in constant dollars. Preliminary figures for three sectors
show that the upturn continued for household and office furniture in
1977. These increases were 9.6 percent and 19.5 percent, respectively,
in real terms. Shipments in constant dollars for the public building
sector decreased slightly. Figures for 1977 and 1978 are available from
the Business and Institutional Furniture Manufacturers Association
(BIFMA), whose membership includes firms from each of the sectors except
household furniture. These data show a 26.4 percent increase in constant
dollar shipments for wood and metal furniture combined during 1977.2
During the first 11 months of 1978 constant dollar shipments of products
other than wood (presumably metal, primarily) were up 10 percent over
the first 11 months of 1977.3
7.1.3 Industry Operating Statistics
Table 7-15 shows that labor and fuel costs represented roughly a
constant percentage of the value of shipments from 1958 to 1975. As
shown in Table 7-16, coating material costs decreased between 1967 and
1972 as a percent of cost of materials in all segments except public
7-28
-------
Table 7-15. LABOR AND MATERIALS COSTS IN METAL FURNITURE
MANUFACTURING RELATIVE TO VALUE OF INDUSTRY SHIPMENTS
Year
1975
1974
1973
1972
1971
1970
1969
1968
1967
1963
1958
Production workers'
wages3
17.0
18.2
18.6
19.0
18.6
19.4
19.8
19.1
19.4
19.9
20.2
Cost of materials
fuel9
46.6
46.7
45.2
45.6
44.8
44.4
44.6
44.3
44.4
47.1
48.7
Percentage of value of shipments.
Source: U. S. Department of Commerce. Census of Manufactures, 1972.
7-29
-------
Table 7-16 METAL FURNITURE COATING MATERIALS COSTS VERSUS TOTAL MATERIALS
COSTS AND VALUE OF SHIPMENTS, 1972 AND 1967
r.nating Materials Costs
Percent of
cost of
materials
1972
Percent of
value of
industry
shipments
1967
Percent of
Percent of value of
cost of industry
materials shipments
Metal household
furniture
(SIC 2514) 1.7
Metal office
furniture
(SIC 2522) 3.2
Public building
and related
furniture
(SIC 2531) 1.9
Metal partitions
and fixtures
(SIC 2542) 3.6
0.8
1.0
0.8
1.4
2.1
4.2
1.9
4.7
1.0
1.3
0.8
1.8
Source: U. S. Department of Commerce. Census of Manufactures, 1972.
7-30
-------
buildings and fixtures, in which they remained constant. The identical
phenomenon occurred with respect to coating materials as a percent of
value of industry shipments.
The industry as a whole includes many sizes and types of firms so
that the financial performance varies widely. Tables 7-17 and 7-18
summarize the historical profitability of the business and institutional/
office furniture and metal household furniture sectors, respectively.
In general, it can be noted from these figures that for the metal house-
hold furniture sector, profitability suffered in 1970 and again in 1974,
and recovered in 1976 and 1977. The same phenomenon occurred for the
metal office furniture sector in 1974 and 1976/1977. Members of BIFMA,
which include wood furniture manufacturers, seem to enjoy consistently
higher profitability than the office furniture sector. No real relation-
ship can be assumed, however, because the samples used to derive the
figures may not be representative, and may not be comparable to each
other. The figures do seem to indicate that when shipments drop,
profitability also dips, as would be expected.
7.1.4 Imports and Exports
Exports of metal furniture are in the range of one to two percent
4
of the total value of industry shipments. Imports of metal furniture
per s£ are not recorded, but indications are that they have minimal
impact on the industry as a whole.
7.1.5 Projections of Affected Facilities
The New Source Performance Standards (NSPS) apply to facilities
(defined in this study as individual paint lines) that are constructed
in a new plant, as part of an expansion of an existing plant, or as a
replacement for retired equipment. In order to assess the impact of the
standard on the industry, it is necessary to project how many facilities
would be constructed in the absence of a regulation. This section
develops a methodology and makes those projections for the four metal
furniture SIC categories.
To some extent, new facilities are related to growth in demand for
metal furniture. Manufacturers' expectations about future demand are an
important factor too, because investment decisions must be made in
7-31
-------
Table 7-17. PROFIT BEFORE TAXES OVER TOTAL ASSETS FOR HOUSEHOLD FURNITURE MANUFACTURES
High quartile
Median
Low quartile
No. of firms
surveyed
1967
NA
8.5
NA
41
1968
NA
13.9
NA
30
1969
NA
11.3
NA
29
1970
NA
7.8
NA
20
1971
NA
8.7
NA
25
1972
NA
14.1
NA
25
1973
15.6
11.9
5.8
28
1974
15.5
5.8
2.1
34
1975
16.3
5.5
0.9
30
1976
19.5
iO.5
3.4
35
1977
17.8
13.0
4.6
35
RMA Annual Statement Studies (respective years). Robert Morris Associates. Philadelphia, Pennsylvania,
NA = Not available.
-------
Table 7-18. PROFIT BEFORE TAXES OVER TOTAL ASSETS FOR METAL OFFICE
FURNITURE MANUFACTURERS AND BUSINESS AND
INSTITUTIONAL FURNITURE MANUFACTURERS
(percent)
1972 1973 1974 1975 1976 1977
Percent profit before
taxes/total assets
BIFMA members3 13.04 19.38 18.64 11.33 11.66 17.51
Metal office
furniture'3
Upper quartile
Median
Lower quartile
Number of firms
surveyed
NA
NA
NA
NA
12.2
7.0
2.7
30
15.5
6.7
2.1
31
11.1
4.8
0.3
38
9.4
5.7
1.0
31
11.7
6.6
0.5
27
BIFMA Annual Statistics. Industry Performance - 1976 and 1977. Business
and Institutional Furniture Manufacturers Association. Grand Rapids,
Michigan. May 1977 and May 1978.
RMA Annual Statement Studies, 1974-1978. Robert Morris Associates.
Philadelphia, Pennsylvania.
NA = Not available.
NOTE: The sample sizes for both sources of data are small and may not be
representative of the industry as a whole. BIFMA includes companies
that manufacture wood as well as metal furniture.
7-33
-------
advance of actual orders. Capacity utilization in the industry also plays
a big role in the number of new facilities that could be built. If the
industry has been depressed for some time, or if the new facilities were
constructed to fill orders that never materialized, the resultant excess
capacity can absorb some growth in demand before additional facilities are
required.
7.1.5.1 Growth Rates. Most growth projections for the metal
furniture industry sectors are made in terms of percent growth in
constant dollar shipments. In order to make these projections more
reflective of unit shipments, an inflation factor must be subtracted
out. Seven percent is generally used to approximate future inflation.
An industry study5 has projected a six to eight percent per year
growth rate for metal office furniture through 1990. The same study
estimated growth for the metal household furniture sector at three to
four percent per year over the same period. A third designation, "panel
systems," was projected at 16.4 percent annual growth. This growth
probably will be felt to some degree in the office and public building
sectors as well as the partition segment. Several growth estimates for
the household sector available from other sources suggest that shipments
are likely to increase in the range of six to eight percent per year.
For the purpose of estimating new affected facilities, these
estimates have been manipulated somewhat to reflect qualitative concerns.
According to an industry spokesman, household furniture growth will
probably be lower than that for both office and public sector furni-
ture.7 In addition to this consideration, some of the growth attributed
to the partition sector was shifted to the office and public sector
furniture categories. Finally, price increases of approximately seven
percent were subtracted out of the growth estimates. The resulting
projections are: zero growth through 1980 for the metal household
furniture sector followed by one percent growth through 1985; four
percent growth through 1985 for the metal office furniture sector; two
percent growth through 1985 for the public building furniture sector;
seven percent growth through 1985 for the metal partition sector.
7.1.5.2 Projection Methodology. The methodology used to determine
the number of affected facilities through 1985 is based in the paint use
7-34
-------
of a medium size plant in each of the sectors in 1976, which was discussed
in Chapter 6. The growth rates developed above were applied to the
number of facilities in 1976 to escalate them to 1980 levels. Growth
rates were then applied to the 1980 figures to determine an estimate of
affected facilities for 1985. The difference between the 1980 and 1985
estimates represent the new affected facilities. To account for replacement
of retired lines, one-third of the 1980 number was added to the total
new facilities (the one-third arises from the assumption that equipment
life is fifteen years; if one-fifteenth of the equipment is retired each
year, then between 1980 and 1985, five-fifteenths or one-third will be
retired or replaced).
7.1.5.3 Results. The calculation of affected facilities in each
sector is shown in Table 7-19. The results show 338 new lines in the
household sector, 254 lines in the office sector, 400 lines in the
public building sector, and 971 lines in the metal parition sector for a
total of 1 963 total new lines between 1980 and 1985. An industry
spokesman for business and institutional furniture manufacturers indicates
that in general, small firms tend to increase capacity by means of on-
o
site expansions whereas larger firms are more likely to build new plants.
7.2 METAL FURNITURE COST ANALYSIS
This section develops cost estimates for emission control techniques
that can be applied to the model plants described in Chapter 5. These
costs are based on engineering estimates that were made using vendor
quotes, figures from actual installations and previous studies, and
adjusting formulas for plant capacity. For the model plant assumptions
made, the estimates are considered accurate to within ± 30 percent.
This section also estimates the cost effectiveness of each alterna-
tive. Cost effectiveness is estimated by dividing the total annualized
control cost by the annual reduction of emissions achieved. In this
way, the various control alternatives may be ranked on a relative basis.
7.2.1 New Facilities
7.2.1.1 Model Plants/Control Options Description. As is explained
in Chapter 5, the ten model plants were developed to be representative
of metal furniture coating facilities that will be built in the future.
The models cover three capacity sizes, three coating application methods,
7-35
-------
Table 7-19. CALCULATION OF TOTAL AFFECTED FACILITIES, 1980-1985
OJ
CT>
© ~"
Total
paint
used
per yr
mil. liters
(mil. gal)
Household
SIC 2514
34.24
(10.12)
Office
SIC 2522
20.82
( 6.15)
Public
SIC 2531
29.14
( 8.61)
Partitions
SIC 2541
45.99
(13.59)
® ®
Paint used
per yr in No. of
medium lines in
size plant medium
liters size
(gallons) plant
87,055 2
(23,000)
117,335 2
(31,000)
77,290 2
(20,420)
102,195 2
(27,000)
® © © © ® ® ® ©
Lines in Total
Lines in Growth Lines in Growth Lines in 1980 x affected
1976 rate 1980 rate 1985 New lines 5/15 facilities
(t) * (2) thru (3)x /, thru © x ,- 1980-1985 replace- 1980-1985
x© 1980 (1 + (§)) 1985 (1 +(28 © - © ment (9) + ©
880 0 880 1% 925 45 293 338
396 4% 463 4% 563 100 154 254
844 2% 914 2% 1,009 95 305 400
1 006 7% 1,319 7% 1,850 531 440 971
1,963
-------
and two types of furniture - flat and complex. All uncontrolled plants
are assumed to use 35 percent solids (as applied) organic solvent-based
paint.
The purpose of the three size categories is to cover the size
diversity of the industry. The reason for estimating the costs of the
three application techniques is to show the difference in annualized
capital and operating costs among the various techniques. In addition,
there are some control alternatives which are applicable to only one
application technique. It is necessary, therefore, to estimate the
costs for spray, dip, and flow coating separately.
The effect of metal furniture part complexity on the annualized
capital and operating costs of spray coating lines is substantial and is
therefore presented in the cost analysis. Complex parts generally
require more space on a coating line and as a result, fewer items can be
coated per day for each line. More capital equipment is needed,
therefore, to paint complex items than is needed to paint flat items.
In addition, spray coating transfer efficiency is lower for complex
items than for flat items. Paint consumption is, therefore, higher
resulting in higher operating costs.
7.2.1.2 Base Case Model Plants. The Clean Air Act Amendments of
1977 require the states to develop revisions to their State Implementation
Plans (SIPs). Many of the SIP revisions (including those for states
having the majority of the metal furniture manufacturing facilities)
submitted for Federal approval include standards of metal furniture
coating emissions. Therefore, this analysis estimates the incremental
costs incurred above the SIP for several control options. To measure
that incremental cost, a "base case" that meets SIP levels was developed
and costed for each model plant.
An SIP level of 0.36 kg of organic solvent per liter of coating
(3.0 pounds per gallon) at application was assumed because that level
has been proposed by several heavily industrialized states (see section
7.3). To meet that level, the base cases are assumed to use 60 percent
solids paint (as applied) for spraying and 63/37 waterborne paint for
dip and flow coating, rather than the 35 percent solids paint associated
7-37
-------
with the uncontrolled model plants. The paint substitution necessitates
equipment changes that are reflected in the costs developed for each base
case.
7.2.1.3 Control Cost Bases. This section summarizes the assumptions
used in developing the control costs for the model plants and control
options. The technical operating parameters which serve as the basis for
the cost estimates (i.e., coating thickness, exhaust flow rates, line
configuration, etc.) are presented in Chapter 5 and are not repeated here.
Several types of costs are included in the total cost for a control
option. The first is the initial investment required for equipment and
installation. From this investment one can estimate such capital related
charges as depreciation, interest, property taxes, insurance and general
administration. Expressed on an annual basis, these charges are called
annualized capital costs. To them are added recurring costs such as
utilities, materials, and labor for operation and maintenance of the
equipment during its life. The sum of these capital related costs and
operating costs is the total annualized cost of the control alternative.
Coating line and control equipment costs are estimated on the basis of
vendor estimates on the basis of trade association and industry survey
data. The remaining assumptions used in calculating control costs are
shown in Table 7-20.9~17
The annual cost factors used for the model plant cost analysis are
presented in Table 7-21.
7.2.1.4 Control Costs and Cost Effectiveness. Tables 7-22 through
7-31 display the control cost estimates for each plant. The use of high
solids content paint appears to result in a lower total annualized cost
than the uncontrolled model plants, even though the coating material is
18—23
more expensive on a volume basis than low solids paint. This savings
results mainly because high solids paint covers a greater area per unit of
volume applied.
Cost effectiveness plots for controls applied to the base case model
plants are presented in Figures 8-13 and 8-14. As can be seen, the cost
effectiveness ratios for the waterborne option is much higher for the spray
coating lines than are the other control options. The powder option is
7-38
-------
Table 7-20. BASES FOR CONTROL COST ESTIMATES
Control
technique
Powder
Capital
Equipment
Vendor
estimates
costs
Building
Equal to
uncontrolled
Operating
Electricity
Uncontrolled
- 5 percent
costs
Fuel
Uncontrolled
- 50 percent
Waterborne
60% and 70%
High solids
Thermal
incinerator
Fluidized
bed
Electrodeposition
Base case
(SIP level)
Uncontrolled
Uncontrolled
+ 30 percent
Equal to
uncontrolled
Vendor
estimates
Vendor
estimates
Vendor
estimates
Vendor
estimates
Vendor
estimates
Uncontrolled
+ 10 percent
Equal to
uncontrolled
Equal to
uncontrolled
Equal to
base case
Base case
+ 10 percent
Equal to
Uncontrolled
Survey
information
Uncontrolled
+ 15 percent
Uncontrolled
- 5 percent
Base case
+ 5 percent
Uncontrolled
+ 30 percent
5 X
Uncontrolled
Uncontrolled
- 5 percent
Survey
information
Uncontrolled
- 33 percent
Uncontrolled
- 33 percent
Vendor
estimates
Uncontrolled
- 50 percent
Equal to
base case
Uncontrolled
- 33 percent
Survey
information
7-39
-------
Table 7-21. MODEL PLANT ANNUAL CONTROL COST FACTORS9
Operating schedule 2 000 hours/year
Electricity $0.08/107 joule ($0.03/KWH)
Natural Gas $1.89/109 joule ($2.00/106 Btu)
Paint:
Conventional solvent-borne (35% solids) $1.85/liter ($7.00/gallon)
High solids (60 to 70% solids) $2.80/liter ($10.75/gallon)
63/37 Waterborne $1.98/liter ($7.50/gallon)
80/20 Waterborne $2.10/liter ($8.00/gallon)
Powder5 $3.53/kg ($1,60/pound)
Labor $6.70/manhour
Capital recovery factor assumptions
(Equipment life and interest rate):
Coating line equipment 15 years at 10% interest
Building 25 years at 10% interest
Add-on control equipment 10 years at 10% interest
Taxes, insurance and G&A 4% of total installed cost
Maintenance labor 10% of direct labor
Maintenance material 1.5% of equipment cost
Overhead " 80% of direct labor cost
aSee Appendix E to this BID for additional cost and economic analyses.
bPowder costs presented in Tables 7-22 through 7-50 are based on a film
thickness of 6.35 x 10 cm (2.5 mil). However, based on the data
presented in Appendix E powder costs are reduced significantly at a
film thickness of 3.81 x 10 cm (1.5 mil).
7-40
-------
Table 7-Z2. CONTROL COSTS FOR MODEL PLANT A - LARGE SPRAY COATING
FACILITY FOR FLAT METAL FURNITURE SURFACES
A-l A-2
Control options'
A-3 A-4 A-5
A-6 A-U
INSTALLED CAPITAL COSTS ($ 1000)
Line(s)
Add-on control equipment
Building
Total capital costs
Annualized capital costs
Insurance, taxes and G & A
Total annualized capital costs
OPERATING COSTS ($ 1000/yr)
Direct labor
Maintenance labor
Overhead
Maintenance Materials
Paint
Electricity
Natural gas
Total operating costs
1810 2041 1570 1570 1570 1570 1570
130
2063 2270 2063 2063 2063 2063 2063
3873 4311 3633 3763 3633 3633 3633
444 495
155 172
599 667
413
145
558
433 413
151 145
584 558
413
145
558
Cost (credit) per kg of emission
reduction versus uncontrolled
plant ($/kg)
Cost (credit) per kg of emission
reduction versus base case
($/kg)
Cost per area covered
($/1000 i/)
413
145
558
600 600 600 600 600 600 600
60
480
24
507
69
45
2565 2060 1785 I88T T824" 1871 1936
TOTAL ANNUALIZED COSTS ($ 1000/yr) 3164 2727 2343 2465 2382 2429 2494
3.4 1.5 (1.0) (0.2) (0.8) (0.5) N/A
10.3 8.0 (3.2) 1.6 (3.3) N/A N/A
791 682 586 616 596 607 624
^\-l Powder
A-2 Waterborne
A-3 70 percent high solids
A-4 Incinerator on base case line(s)
A-5 65 percent high solids
A-6 Base case—typical SIP
A-U Uncontrolled plant
N/A Not applicable
cm
This cost for powder is based on a film thickness of 6,35 x 10"
(2.5 mil). However, at a film thickness of 3.81 x 10 cm (1.5 mil)
the cost changes significantly (see Appendix E).
7-41
-------
Table 7-23. CONTROL COSTS FOR MODEL PLANT B - LARGE SPRAY COATING
FACILITY FOR COMPLEX METAL FURNITURE SURFACES
B-l B-2
Control options
B-3 B-4 B-5
B-6 B-U
INSTALLED CAPITAL COSTS ($ 1000)
Lines(s)
Add-on control equipment
Building
Total capital costs
Annualized capital costs
Insurance, taxes and G&A
Total annualized captial costs
OPERATING COSTS ($ 1000/yr)
Direct labor
Maintenance labor
Overhead
Maintenance materials
Paint
Electricity
Natural gas
Total operating costs
3197 3614 2780 2780 2780 2780 2780
130
2096 2306 2096 2096 2096 2096 2096
5293 5920 4876 5006 4876 4876 4876
630
212
706
237
575
195
595
200
575
195
575
195
100 100
800 800
48L 54
100
800
42
1295U 1014 675
116 140 116
56 74 74
100 100
800 800
44
790
116
78
42
725
116
74
100
800
42
790
116
74
Cost (credit) per kg of emission
reduction versus uncontrolled
plant ($/kg)
Cost (credit) per kg of emission
reduction versus base case
($/kg)
Cost per area covered
($/1000 mz)
575
195
842 943 770 795 770 770 770
1000 1000 1000 1000 1000 1000 1000
100
800
42
826
122
116
3415 3182 2807 2928 2857 2922 3001
TOTAL ANNUALIZED COSTS ($1000/yr) 4257 4125 3577 3723 3627 3692 3771
1.9 1.7 (1.0) (0.3) (0.8) (0.5) N/A
5.9 8.9 (3.2) 1.1 (3.4) N/A N/A
1064 1031 894 931 907 923 943
as-1 Powder
B-2 Waterborne
B-3 70 percent high solids
B-4 Incinerator on base case line(s)
B-5 65 percent high solids
B-6 Base case—typical SIP
B-U Uncontrolled plant
N/A Not applicable
This cost for powder is based on a film thickness of 6.35 x 10~°cm (2.5 mil)
However, at a film thickness of 3.81 x 10" cm (1.5 mil) the cost changes
significantly (see Appendix E). .
7-42
-------
Table 7-24. CONTROL COSTS FOR MODEL PLANT C - MEDIUM SIZE SPRAY
COATING FACILITY FOR FLAT METAL FURNITURE SURFACES
C-l C-2
Control options
C-3 C-4 C-5
C-6 C-U
INSTALLED CAPITAL COSTS ($ 1000)
Line(s)
Add-on control equipment
Building
Total capital costs
Annual ized capital costs
Insurance, taxes and G&A
Total annual ized capital costs
626
402
1028
127
41
164
706
442
1148
137
46
183
543
402
945
112
38
150
543
no
402
1055
129
42
171
543
402
945
112
38
150
543
402
945
112
38
150
543
402
945
112
38
150
OPERATING COSTS ($ 1000/yr)
Direct labor
Maintenance labor
Overhead
Maintenance materials
Paint
Electricity
Natural gas
Total operating costs
TOTAL ANNUALIZED COSTS ($ 1000/yr) 728 638 562 603 569 579 591
Cost (credit) per kg of emission
reduction versus uncontrolled
plant ($/kg) 3.7
150
15
120
9b
253
9
8
T64
150
15
120
10
139
10
11
455
150
15
120
8
99
9
11
412
150
15
120
10
116
9
12
432
150
15
120
8
106
9
11
419
150
15
120
8
116
9
11
429
150
15
120
8
123
9
16
441
1.5 (1.0) 0.4 (0.9) (0.6) N/A
Cost (credit) per kg of emission
reduction versus base case
($/kg)
Cost per area covered
($/1000 m2)
10.8
933
8.4
818
(3.3) 5.9
721 779
(3.7) N/A N/A
729 742 758
-1 Powder
C-2 Waterborne
C-3 70 percent high solids
C-4 Incinerator on base case line(s)
C-5 65 percent high solids
C-6 Base case—typical SIP
C-U Uncontrolled plant
N/A Not applicable
h -?
This cost for powder is based on a film thickness of 6.35 x 10" cm (2.5 mil)
However, at a film thickness of 3.81 x 10~ cm (1.5 mil) the cost changes
significantly (see Appendix E).
7-43
-------
Table 7-25. CONTROL COSTS FOR MODEL PLANT D - MEDIUM SIZE SPRAY
COATING FACILITY FOR COMPLEX METAL FURNITURE SURFACES
D-l D-2
Control options9
D-3 D-4 D-5
D-6 D-U
OSTS ($ 1000)
,
pment
costs
id G&A
pita! costs
644
402
1046
125
42
167
728
442
1170
140
47
187
560
402
962
114
38
T52
560
i in
1 1 U
402
1072
131
43
174
560
402
962
114
38
152
560
402
962
114
38
152
560
402
962
114
38
152
Line(s)
Add-on control equipment
Building
Total capital costs
Annualized capital costs
Insurance, taxes and G&A
OPERATING COSTS ($ 1000/yr)
Direct labor
Maintenance labor
Overhead
Maintenance materials
Paint
Electricity
Natural gas
Total operating costs
TOTAL ANNUALIZED COSTS ($ 1000/yr) 732 702 597 644 607 619 631
150
15
120
10
253f>
9
8
565
150
15
120
11
198
10
11
515
150
15
120
8
132
9
11
445
150
15
120
10
154
9
12
470
150
15
120
8
142
9
11
455
150
15
120
8
154
9
11
467
150
15
120
8
161
9
16
479
Cost (credit) per kg of emission
reduction versus uncontrolled
plant ($/kg)
Cost (credit) per kg of emission
reduction versus base case
($/kg)
Cost per area covered
($71000 m2)
2.1 1.8 (0.9) 0.4 (0.7) (0.4) N/A
6.0 9.0 (3.1) 4.6 (3.2) N/A N/A
938 900 765 832 778 794 809
aD-l Powder
D-2 Waterborne
D-3 70 percent high solids
D-4 Incinerator on base case line(s)
D-5 65 percent high solids
D-6 Base case—typical SIP
D-U Uncontrolled plant
N/A Not applicable _3
This cost for powder is based on a film thickness of 6.35 x 10 cm (2.5 mil)
However, at. a film thickness of 3.81 x 10 cm (1.5 mil) the cost changes
significantly (see Appendix E).
7-44
-------
Table 7-26. CONTROL COSTS FOR MODEL PLANT E - SMALL SPRAY COATING
FACILITY FOR FLAT METAL FURNITURE SURFACES
E-l
Control options3
E-2 E-3 E-4 E-5
E-U
INSTALLED CAPITAL COSTS ($ 1000)
Line(s)
fill _ i.»j»y>vT A J-l 1 1 -4 (-V*V>*-\ Y\ 4-
Add-on control equipment
Building
Total capital costs
Annual ized capital costs
Insurance, taxes and G&A
Total annual ized capital costs
OPERATING COSTS ($ 1000/yr)
Direct labor
Maintenance labor
Overhead
Maintenance materials
Paint
Electricity
Natural gas
Total operating costs
TOTAL ANNUALIZED COSTS ($ 1000/yi
225
23
248
32
10
42
40
4
32
3
14b
4
4
101
r) 143
225
25
250
32
11
43
40
4
32
4
7
5
5
97
140
196
23
219
28
9
37
40
4
32
3
6
4
5
94
131
196
23
219
28
9
37
40
4
32
3
6
4
5
94
131
196
23
219
28
9
37
40
4
32
3
6
4
5
94
131
196
23
219
28
9
37
40
4
32
3
7
4
7
97
134
Cost (credit) per kg of emission
reduction versus uncontrolled
plant ($/kg) 4.2
Cost (credit) per kg of emission
reduction versus base case
($/kg) 15.1
Cost per area covered
($/1000 n»2)
3178
3.4 (1.8) (2.0) (2.2) N/A
22.2 0.0 0.0 N/A N/A
3111 2911 2911 2911 2977
E-l Powder
E-2 Waterborne
E-3 70 percent high solids
E-4 65 percent high solids
E-5 Base case—typical SIP
E-U Uncontrolled plant
N/A Not applicable
This cost for powder is based on a film thickness of 6.35 x 10~3cm (2.5 mil)
However, at a film thickness of 3.81 x 10 cm (1.5 mil) the cost changes
significantly (see Appendix E).
7-45
-------
Table 7-27.
CONTROL COSTS FOR MODEL PLANT F - SMALL SPRAY COATING
FACILITY FOR COMPLEX METAL FURNITURE SURFACES
F-l
Control options
F-2 F-3 F-4 F-5
F-U
INSTALLED CAPITAL COSTS ($ 1000)
Line(s)
Add-on control equipment
RUT 1 fHnn
Total capital costs
Annual ized capital costs
Insurance, taxes and G&A
Total annual ized capital costs
OPERATING COSTS ($ 1000/yr)
Direct labor
Maintenance labor
Overhead
Maintenance materials
Paint
Electricity
Natural gas
Total operating costs
248
23
271
35
11
46
40
4
32
4b
14b
4
4
102
281
25
306
39
12
51
40
4
32
4
13
5
T03
216
23
239
31
10
41
40
4
32
3
9
4
216
23
239
31
10
41
40
32
4
97
216
23
239
31
10
4T
40
32
97
216
23
239
31
10
41
40
32
7
"99
TOTAL ANNUALIZED COSTS ($ 1000/yr) 148 154 138 138 138 140
Cost (credit) per kg of emission
reduction versus uncontrolled
plant ($/kg)
Cost (credit) per kg of emission
reduction versus base case
($/kg)
Cost per area covered
($/1000 m2)
2.9 6.3 (1.0) (1.1) (1.2) N/A
9.3 22.1 0.0 0.0 N/A N/A
3289 3422 3067 3067 3067 3111
aF-l Powder
F-2 Waterborne
F-3 70 percent high solids
F-4 65 percent high solids
F-5 Base case—typical SIP
F-U Uncontrolled plant
.N/A Not applicable _3
bThis cost for powder is based on a film thickness of 6.35 x 10 cm (2.5 mil)
However, at a film thickness of 3.81 x 10~Jcm (1.5 mil) the cost changes
significantly (see Appendix E).
7-46
-------
Table 7-28. CONTROL COSTS FOR MODEL PLANT 6 - LARGE DIP COATING
FACILITY FOR METAL FURNITURE
G-l
Control options
G-2 6-3 6-4 6-5
G-U
INSTALLED CAPITAL COSTS ($ 1000)
Line(s)
• i i .
-------
Table 7-29.
CONTROL COSTS FOR MODEL PLANT H - MEDIUM SIZE DIP
COATING FACILITY FOR METAL FURNITURE
Control options
H-l H-2 H-3 H-4 H-5 H-U
INSTALLED CAPITAL COSTS ($ 1000)
L1ne(s)
Add-on control equipment
Building
Total capital costs
Annual ized capital costs
Insurance* taxes and G&A
Total annual ized capital costs
520
240
760
92
30
122
1100
-264
1364
171
55
226
540
nn
1 1 U
240
890
112
35
147
540
240
780
95
31
126
540
240
780
95
31
126
415
218
633
79
25
104
OPERATING COSTS ($ 1000/yr)
Direct labor
Maintenance labor
Overhead
Maintenance
Paint
Electricity
Natural gas
Total operating costs
TOTAL ANNUALIZED COSTS ($ 1000/yr) 582 641 579 563 555 528
150
15
120
17
97
5
11
4T5
150
15
120
9
124
1
13
432
150
15
120
8
132
1
11
437
150
15
120
8
124
1
11
429
150
15
120
6
116
1
16
424
Cost (credit) per kg of emission
reduction versus uncontrolled
plant ($/kg)
Cost (credit) per kg of emission
1.6
3.3 1.7 1.2 1.3 N/A
ICUUl»blV»l »CI JUWJ L/UJ>- %»u.*«-
($/kg)
Cost per area covered
($/1000 m2)
2.1
746
6.8
822
2.9
742
1.0
722
N/A
712
N/A
677
H-l Fluidized bed
H-2 Electrodeposition
H-3 Incinerator on base case line(s)
H-4 Haterborne
H-5 Base case—typical SIP
H-U Uncontrolled plant
N/A Not applicable
7-48
-------
Table 7-30.
CONTROL COSTS FOR MODEL PLANT I - SMALL DIP COATING
FACILITY FOR METAL FURNITURE
1-1
Control options
1-2 1-3 1-4
Cost (credit) per kg of emission
reduction versus uncontrolled
plant ($/kg)
Cost (credit) per kg of emission
14.1
21.8 5.9
8.1
L-l Fluidized bed
1-2 Electrodeposition
1-3 Waterborne
1-4 Base case—typical SIP
I-U Uncontrolled plant
N/A Not applicable
I-U
INSTALLED CAPITAL COSTS ($ 1000)
Line(s)
Add-on control equipment
Building
Total capital costs
Annual ized capital costs
Insurance, taxes and G&A
Total annual ized capital costs
OPERATING COSTS ($ 1000/yr)
Direct labor
Maintenance labor
Overhead
/ Maintenance materials
Paint
/Electricity
/ Natural gas
Total operating costs
TOTAL ANNUALIZED COSTS ($ 1000/yr)
225
14
239
31
10
41
40
4
32
3
32
0
4
115
156
420
15
435
57
17
74
40
4
32
6
6
4
5
97
171
250
14
264
34
11
45
40
4
32
4
8
0
5
93
138
250
14
264
34
11
45
40
32
0
93
138
192
13
205
27
8
35
40
32
93
128
N/A
($/kg)
Cost per area covered
($71000 m2)
24.0
?467
45.0
3800
0.0
3067
N/A
3067
N/A
2844
7-49
-------
Table 7-31. CONTROL COSTS FOR MODEL PLANT J - SMALL FLOW COATING
FACILITY FOR METAL FURNITURE
Control options
J-l J-2 J-U
INSTALLED CAPITAL COSTS ($ 1000)
Line(s)
Add-on control equipment
Building
Total capital costs
Annual i zed capital costs
Insurance, taxes and G&A
Total annual ized capital costs
250
- —
14
264
34
11
45
250
— — —
14
264
34
11
45
192
_* —
13
205
27
8
35
OPERATING COSTS ($ 1000/yr)
Direct labor 40 40 40
Maintenance labor 444
Overhead 32 32 32
Maintenance materials 443
Paint 887
Electricity ' 000
Natural gas _5 _5_ _7
Total operating costs 93 93 93
TOTAL ANNUALIZED COSTS ($ 1000/yr) 138 138 128
Cost (credit) per kg of emission
reduction versus uncontrolled
plant ($/kg) 5.9 8.1 N/A
Cost (credit) per kg of emission
reduction versus base case
($/kg) 0.0 N/A N/A
Cost per area covered
($/1000 m2) 3067 3067 2844
J-l Waterborne
J-2 Base case—typical SIP
J-U Uncontrolled plant
N/A Not applicable
7-50
-------
30
25
tn
o
Waterborne - Complex surfaces
Powder - Complex surfaces
Thermal incinerator - Complex surfaces
65 and 70 percent high solids - Complex surfaces
500
-O
-G
-O
-O
3500 4000
2
1000 1500 2000 2500 3000
Total area coated per year - 1000m£
Figure 7-13. Spray coating cost effectiveness vs. base case.
-------
I
01
ro
u
T3
c
o
in
•r—
OJ
C7I
(U
Q.
\s>
I/)
(U
c
(U
U
(U
O)
o
o
Thermal incinerator
500 1000 1500 2000 2500 3000 3500 4000
2
Total area covered per year - 1000 m
Figure 7-14. Dip and flow coating cost effectiveness vs. base case.
-------
the second highest for spray coating lines but costs for the control option
can change significantly depending upon coating thickness and complexity of
the part coated. The material costs for powder are based upon 6.35 x 10 3 cm
(2.5 mil) film thickness. As a result of this film thickness, the powder
costs are high. However, based on a film thickness of 3.81 x 10 3 cm
(1.5 mil) powder can produce a savings for the metal furniture manufacturer.
This information is presented in Appendix E. For dip coating lines the
control options of electrodeposition and powder produce the highest cost
effectiveness ratios.
In almost all cases, the curves slope downward with increasing plant
size. This is particularly true for electrodeposition and incineration.
The reason for this phenomenon is that these options are rather capital
intensive. As plant size increases, the impact of the capital costs
decreases thereby decreasing the cost effectiveness ratio.
7.2.2 Modified or Reconstruction Facilities
As defined in Chapter 4 of this report, metal furniture coating
facilities may undergo "modification" or "reconstruction" thereby bringing
the facility under the purview of the NSPS. As a result of such actions,
the facility would incur certain costs or savings from the conversion to
the mode of operation necessary to achieve the standard. Presented in
Tables 7-32 through 7-41 are the costs for each model plant associated with
a switch from the base (CTG) level to each of the control options presented
in Chapter 5. The costs involved in a switch from the uncontrolled state
to each of the control options are presented in Tables 7-42 through 7-51.
All control cost factors presented in Table 7-21 are valid for the
conversion costs presented in this section. Capital costs are estimated on
the basis of the amount of coating line equipment that would have to be
replaced to comply with each control option. For spray coating lines there
are three options which would required a capital investment to switch from
the base case. Powder coating would require a complete change of the spray
coating equipment and spray booths. Waterborne coatings would require
modifications of the spray equipment (including insulation and isolation),
extension of the flash-off area, and an increase in the amount of climate
control equipment in the plant. The incineration option would require the
7-53
-------
Table 7-32. PLANT A - CONTROL COSTS FOR .MODIFICATION OR
RECONSTRUCTION OF SIP LEVEL FACILITIES
A-l
Control options
A-2 A-3 A-4
A-5
INSTALLED CAPITAL COSTS ($ 1000)
Line(s)
Add-on control equipment
Building
Total capital costs
Annual! zed capital costs
Insurance, taxes and G&A
Total annual i zed capital costs
OPERATING COSTS (SAVINGS) ($ 1000)
Direct labor
Maintenance labor
Overhead
Maintenance materials
Paint
Electricity
Natural gas
Total operating costs
TOTAL ANNUALIZED COSTS (SAVINGS) ($
Cost (savings) per area covered
($/1000 nf)
aA-l Powder
A-2 Waterborne
A-3 70 percent high solids
A-4 Incinerator on base line(s)
A-5 65 percent high solids
750
0
0
750
99
30
129
0
n
702 b
691
1000) 820
205
500
0
207
707
87
28
115
0
n
u
8
167
15
1
-------
Table 7-33. PLANT B -
CONTROL COSTS FOR MODIFICATION OR
RECONSTRUCTION OF SIP LEVEL FACILITIES
B-l
Control options
B-2 B-3 B-4
B-5
INSTALLED CAPITAL COSTS ($ 1000)
Line(s)
Add-on control equipment
Building
Total capital costs
Annual i zed capital costs
Insurance, taxes and G&A
Total annual i zed capital costs
OPERATING COSTS (SAVINGS) ($ 1000)
Direct labor
Maintenance labor
Overhead
Maintenance materials"
Paint
Electricity
Natural gas
Total operating costs
TOTAL ANNUALIZED COSTS (SAVINGS) ($ 1000)
Cost (savings) per area covered
($/1000 m2)
aB-l Powder
B-2 Waterborne
B-3 70 percent high solids
B-4 Incinerator on base case line(s)
LB-5 65 percent high solids
h — . .1 i f • ~t ... j_ L
1325 900
0 0
0 210
1325 1110
174 139
53 44
227 183
0 0
0 0
0 0
20. 14
505T 224
0 26
(37) 0
488 264
715 447
179 H2
0
0
0
0
0
0
0
0
0
(115)
0
rn5)
(115)
(29)
: oc « 1
0
130
0
130
20
5
25
0
0
0
6
8
33
8
1 l~\~^r-m
0
0
0
0
0
0
0
0
ri
(65)
I65T
(65)
(16)
lO C mi
is cost for powder is based on a film thickness of 6.35
S w i - .w . _.
However, at a film thickness of 3.81 x 10~3cm (1.5 mil) the cost changes
significantly (see Appendix E).
7-55
-------
TahlP 7-34 PLANT C - CONTROL COSTS FOR MODIFICATION OR
Table 7 34. PLAN! ^CONSTRUCTION OF SIP LEVEL FACILITIES
Control options
C-l C-2 C-3 C-4 C-5
INSTALLED CAPITAL COSTS ($ 1000)
Line(s) 2
Add-on control equipment
Building -;
Total capital costs '
Annual i zed capital costs
Insurance, taxes and G&A
Total annual i zed capital costs
OPERATING COSTS (SAVINGS) ($ 1000)
Direct labor
Maintenance labor
Overhead
Maintenance materials
Paint
Electricity
Natural gas
Total operatinq costs
TOTAL ANNUALIZED COSTS (SAVINGS) ($ 1000)
Cost (savings) per area covered
($/1000 m2)
^C-l Powder
C-2 Waterborne
C-3 70 percent high solids
C-4 Incinerator on base case nne(s)
C-5 65 percent high solids
b-rh-ic- /-net fnr> nnurlpr 15 based On 3 film 1
!50
0
0
>50
39
in
49
0
0
0
137b
J51
136
135
237
thickn
175
0
40
215
27
36
0
0
0
23
0
28
64
82
ess of
0
0
0
TJ
0
0
0
07)
0
Tiry
07)
(22)
6.35
0
110
0
no
17
21
0
0
n
u
1
3
24
31
x 10"3
0
0
0
0
0
0
0
Q
(10)
o
0
TToT
00)
03)
cm (2.5 mi
•This cost for powder is based on a mm imuiim*:. ui «.— *« «,. x^.- -
However, at a film thickness of 3.81 x 10-3cm (1.5 mil) the cost changes
significantly (see Appendix E).
7-56
-------
Table 7-35. PLANT D - CONTROL COSTS FOR MODIFICATION OR
RECONSTRUCTION OF SIP 1EVEL FACILITIES
Control options3
D-l D-2 D-l D-4
D-5
INSTALLED CAPITAL COSTS ($ 1000)
Line(s)
Add-on control equipment
Building
Total capital costs
Annual ized capital costs
Insurance, taxes and G&A
Total annual ized capital costs
OPERATING COSTS (SAVINGS) ($ 1000)
Direct labor
Maintenance labor
Overhead
Maintenance materials
Paint
Electricity
Natural gas
Total operating costs
TOTAL ANNUALIZED COSTS (SAVINGS) ($ 1000)
Cost (savings) per area covered
($/1000 nf)
^-l Powder
D-2 Waterborne
D-3 70 percent high solids
D-4 Incinerator on base case line(s)
,D-5 65 percent high solids
260
0
0
76T5
34
10
44
0
0
0
4
99 b
0
-15)
98
144
185
182
0
40
"222
28
9
37
0
0
0
3
44
2
0
86
no
0
0
0
0
0
0
0
0
0
0
0
(22)
0
0
722]
(22)
(28)
0
no
0
770
17
4
21
0
0
0
2
0
0
1.
3
24
31
..-3
0
0
0
0
0
0
0
0
0
0
0
(12)
0
0
TTT)
(12)
(15)
JThis cost for powder is based on a film thickness of 6.35 x 10 cm (2.5 mil),
However, at a film thickness of 3.81 x 10'^cm (1.5 mil) the cost changes
significantly (see Appendix E).
7-57
-------
Control options3
E-l E-2 E-3 E-4
INSTALLED CAPITAL COSTS <$ 1000)
Line(s) . 9n 0 0 0
Add-on control equipment n 2 0 0
Building on" 57 0 0
Total capital costs 3U
Annualized capital costs 11 7 0 0
Insurance, taxes and G&A 4 t jj. -
Total annualized capital costs 15 y u
OPERATING COSTS (SAVINGS) ($ 1000)
Direct labor n 0 0 0
Maintenance labor n 0 0 0
Overhead - i 1 0 0
Maintenance materials 'b i o 0
Paint n 1 0 0
Electricity (2) 0 P_ P_
Natural gas *-J- T o 0
Total operating costs '
TOTAL ANNUALIZED COSTS (SAVINGS) ($ 1000) 22 12 0 0
Cost (savings) per area covered
($/1000nf) 489 267 ° U
^-l Powder
E-2 Waterborne
E-3 70 percent high solids
.E-4 65 percent high solids _3
bThis cost for powder is based on a film thickness of 6.35 x 10 cm (2.5 mil;
However, at a film thickness of 3.81 x lQ-3cm (1.5 mil) the cost changes
significantly (see Appendix E).
7-58
-------
Table 7-37. PLANT F - CONTROL COSTS FOR MODIFICATION OR
RECONSTRUCTION OF SIP LEVEL FACILITIES
OPERATING COSTS (SAVINGS) ($ 1000)
Direct labor
Maintenance labor
Overhead
Maintenance materials
Paint
Electricity
Natural gas
Total operating costs
F-l
Control options3
F-2 F-3 F-4
INSTALLED CAPITAL COSTS ($ 1000)
Line(s)
Add-on control equipment
Building
Total capital costs
Annual i zed capital costs
Insurance, taxes and G&A
Total annual ized capital costs
100
0
0
100
13
4
17
70
0
2
72
9
3
12
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
I"
0
(21
5
0
0
0
1
4
1
0
6
Cost (savings) per area covered
($/1000
0
0
0
0
0
0
0
0
0
0
0
0
0
0
p_
0
TOTAL ANNUALIZED COSTS (SAVINGS) ($ 1000) 22 18 0 0
489
400
aF-l Powder
F-2 Waterborne
F-3 70 percent high solids
F-4 65 percent high solids 3
This cost for powder is based on a film thickness of 6.35 x 10" cm (2.5 mil),
However, at a film thickness of 3.81 x 10~3cm (1.5 mil) the cost changes
significantly (see Appendix E).
7-59
-------
Table 7-38 PLANT G - CONTROL COSTS FOR MODIFICATION OR
RECONSTRUCTION OF SIP LEVEL FACILITIES
Control options
G-l G-2 G-3 6-4
INSTALLED CAPITAL COSTS ($ 1000)
Line(s)
Add-on control equipment
RIII 1 rH nn
ui4 i i u 1 1 iy
Total capital costs
Annual i zed capital costs
Tncnvanrp 1"AVP^ anH GXA
X I IO Ul I Gl 1 v»C J l»Q/\C J UIIU \dWn
Total annual ized capital costs
OPERATING COSTS (SAVINGS) ($ 1000)
Direct labor
Maintenance labor
Overhead
Maintenance materials
Paint
Electricity
Natural gas
Total operating costs
TOTAL ANNUALIZED COSTS (SAVINGS) ($ 1000)
Cost (savings) per area covered
($71000 nf)
1040
0
Q
1040
137
42
179
0
0
0
16
696
1
(39)
674
853
213
2500
0
126
2626
342
105
447
0
0
0
38
(141)
32
0
(71)
376
94
0
130
0
130
20
5
25
0
0
0
2
0
0
5
7
32
8
0
0
0
0
0
0
0
0
0
37
0
0
37
37
G-l Fluidized bed
G-2 Electrodeposition
G-3 Incinerator on base case line(s)
G-4 Waterborne
7-60
-------
Table 7-39. PLANT H - CONTROL COSTS FOR MODIFICATION OR
RECONSTRUCTION OF SIP LEVEL FACILITIES
Control options
H-l H-2 H-3 H-4
INSTALLED CAPITAL COSTS ($ 1000)
Line(s)
Add-on control equipment
Building
Total capital costs
Annual i zed capital costs
Insurance, taxes and G&A
Total annual ized capital costs
210
0
0
210
28
8
36
550
0
354
904
107
36
143
0
110
0
no
17
4
21
0
0
0
0
0
0
0
OPERATING COSTS (SAVINGS) ($ 1000)
Direct labor 0000
Maintenance labor 0000
Overhead 0000
Maintenance materials 3820
Paint 34 (27) (8) 8
Electricity 1800
Natural gas (6) 0 2 0
Total operating costs 32 (11) T4J 8
TOTAL ANNUALIZED COSTS (SAVINGS) ($ 1000) 63 132 17 8
Cost (savings) per area covered
($/1000 m2) 87 169 22 10
H-l Fluidized bed
H-2 Electrodeposition
H-3 Incinerator on base case line(s)
H-4 Waterborne
7-61
-------
Table 7-40 PLANT I - CONTROL COSTS FOR MODIFICATION OR
Table 4U. PLANl RECONSTRUCTION OF SIP LEVEL FACILITIES
Control options
1-1 1-2 1-3
INSTALLED CAPITAL COSTS ($ 1000)
Line(s) 90 210 0
Add-on control equipment 0 0 u
Building _JL —i £
Total capital costs 90 211 0
Annual!zed capital costs 12 28 0
Insurance, taxes and G&A JL -| %
Total annual i zed capital costs 16 Jo u
OPERATING COSTS (SAVINGS) ($ 1000)
Direct labor n 0 0
Maintenance labor n o 0
Overhead i 3 0
Maintenance materials ' m n
Paint 2£ U> o
Electricity ,^ 0 Q
Natural gas •£-*• -5 Q
Total operating costs "
TOTAL ANNUALIZED COSTS (SAVINGS) ($ 1000) 39 40 °
Cost (savings) per area covered
($/1000m2) 867
1-1 Fluidized bed
1-2 Electrodeposition
1-3 Waterborne
7-62
-------
Table 7-41. PLANT J - CONTROL COSTS FOR MODIFICATION OR
RECONSTRUCTION OF SIP LEVEL FACILITIES
Control options
J-1
INSTALLED CAPITAL COSTS ($ 1000)
Line(s) 0
Add-on control equipment 0
Building 0.
Total capital costs 0
Annualized capital costs 0
Insurance, taxes and 6&A 0.
Total annualized capital costs , 0
OPERATING COSTS (SAVINGS) ($ 1000)
Direct labor 0
Maintenance labor 0
Overhead 0
Maintenance materials 0
Paint 0
Electricity °
Natural gas P_
Total operating costs 0
TOTAL ANNUALIZED COSTS (SAVINGS) ($ 1000) 0
Cost (savings) per area covered
($/1000 m2) 0
J-1 Waterborne
7-63
-------
Table 7-42.
PLANT A r CONTROL COSTS FOR MODIFICATION OR
RECONSTRUCTION OF UNCONTROLLED FACILITIES
A-l
Control options3
A-2 A-3 A-4
A-5
INSTALLED CAPITAL COSTS ($ 1000)
Line(s)
Addron control equipment
Building
Total capital costs
Annual i zed capital costs
Insurance, taxes and G&A
Total annual i zed capital costs
OPERATING COSTS (SAVINGS) ($ 1000)
Direct labor
Maintenance labor
Overhead
Maintenance materials
Paint
I U 1 1 1 IF
Electricity
Natural gas
Total operating costs
TOTAL ANNUALIZED COSTS (SAVINGS) ($ 1000)
Cost (savings) per area covered
($/1000 m2)
aA-l Powder
A- 2 Haterborne
A-3 70 percent high solids
A-4 Incinerator on base case line(s)
A-5 65 percent high solids
750
0
0
750
99
30
129
0
0
0
663b
(4)
(42)
628
757
189
500
0
207
707
87
28
Tf5
0
0
0
8
128
11
(20)
242
61
f f
180
0
0
180
24
7
31
0
0
0
(125)
(4)
(20)
0461
(115)
(29)
*ir
180
1f\f\
30
0
310
44
12
56
0
0
0
(39)
(4)
(15)
T531
(3)
1
1 f\ ™*^ nw*
180
180
24
7
31
0
0
0
(86)
(4)
(20)
0071
(76)
(19)
/o c m-;
cost for powder is based on a film thickness of 6.35 x
However, at a film thickness of 3.81 x Krjcm (1.5 mil) the
significantly (see Appendix E).
cost changes
7-64
-------
Table 7-43.
PLANT B - CONTROL COSTS FOR MODIFICATION OR
RECONSTRUCTION OF UNCONTROLLED FACILITIES
B-l
Control options3
B-2 B-3 B-4
B-5
INSTALLED CAPITAL COSTS ($ 1000)
Line(s)
Add-on control equipment
Building
Total capital costs
Annual i zed capital costs
Insurance, taxes and G&A
Total annuali zed capital costs
1325
0
0
1325
174
53
227
900
0
210
1110
139
44
183
300
0
0
300
39
12
51
300
130
0
430
59
17
76
300
0
0
300
39
12
51
OPERATING COSTS (SAVINGS) ($ 1000)
Direct labor
Maintenance labor
Overhead
Maintenance materials
Paint
Electricity
Natural gas
Total operating costs
TOTAL ANNUALIZED COSTS (SAVINGS) ($ 1000) 639 371 (135) 12 (85)
0
0
0
20
,469 b
(7)
(70)
"412
0
0
0
14
188
19
(33
188
Cost (savings) per area covered
($/1000 nf)
150 93 (34) 3 (21)
B-l Powder
B-2 Waterborne
B-3 70 percent high solids
B-4 Incinerator on base case line(s)
,B-5 65 percent high solids
-3.
bThis cost for powder is based on a film thickness of 6.35 x 10" cm (2.5 mil)
However, at a film thickness of 3.81 x
significantly (see Appendix E).
10"3cm (1.5 mil) the cost changes
7-65
-------
Table 7-44. PLANT C - CONTROL COSTS FOR MODIFICATION OR
RECONSTRUCTION OF UNCONTROLLED FACILITIES
C-l
Control optionsa
C-2 C-3 C-4
C-5
INSTALLED CAPITAL COSTS ($ 1000)
Line (s)
Add-on control equipment
Building
Total capital costs
Annual i zed capital costs
Insurance, taxes and 6&A
Total annual ized capital costs
OPERATING COSTS (SAVINGS) ($ 1000)
Direct labor
Maintenance labor
Overhead
Maintenance materials
Paint
Electricity
Natural gas
Total operating costs
TOTAL ANNUALIZED COSTS (SAVINGS) ($ 1000)
Cost (savings) per area covered
($/1000 m2)
aC-l Powder
C-2 Waterborne
C-3 70 percent high solids
C-4 Incinerator on base case line(s)
C-5 65 percent high solids
250
0
0
250
39
10
49
0
0
0
4.
130b
(1)
Up)
123~
172
221
175
0
40
215
27
9
36
0
0
0
3
16
1
151
15
51
65
f ^ *^ r*
60
0
0
60
8
2
10
0
0
0
1
(24)
(1)
Jk
TvT)
(7)
(9)
<* r\ ~:
60
110
0
170
25
7
32
0
0
0
3
(7)
(1)
{4)
(9)
23
29
3.... /„
60
0
0
60
8
2
10
0
0
0
1
(17)
(1)
J51
(22)
(12)
(_ ._ V
15)
This cost for powder is based on a film thickness of 6.35 x 10
However, at a film thickness of 3.81 x 10~3cm (1.5 mil) the cost changes
significantly (see Appendix E).
7-66
-------
Table 7-45. PLANT D -CONTROL COSTS -FOR MODIFICATION DR
RECONSTRUCTION OF UNCONTROLLED FACILITIES
D-'l
Control options3
D-2 D-3 D-4
D-5
INSTALLED CAPITAL COSTS ($ 1000)
Line(s)
Add-on control equipment
Bui 1 ding
Total capital costs
Annuali zed capital costs
Insurance, taxes and G&A
Total annual ized capital costs
OPERATING COSTS (SAVINGS) ($ 1000)
Direct labor
Maintenance labor
Overhead
Maintenance materials
Paint
Electricity
Natural gas
Total operating costs
TOTAL ANNUALIZED COSTS (SAVINGS) ($ 1000)
Cost (savings) per area covered
($71000 nf)
aD-l Powder
D-2 Waterborne
D-3 70 percent high solids
D-4 Incinerator on base case line(s)
D-5 65 percent high solids
260
0
0
260
34
10
44
0
0
0
4,
92 b
(D
HPJ
85
129
165
182
0
40
222
28
9
37
0
0
0
3
37
1
15}
36
73
94
60
0
0
60
8
2
10
0
0
0
1
(29)
(D
15J
(34)
(24)
(31)
60
no
0
170
25
7
32
0
0
0
3
(7)
(D
ID
(9)
23
29
3
60
0
0
60
8
2
10
0
0
0
1
(19)
(D
_L5J
(24)
(14)
(18)
10
However, at a film thickness of 3.81 x
significantly (see Appendix E),
10~3cm (1.5 mil) the cost changes
7-67
-------
Table 7-46. PLANT E - CONTROL COSTS FOR MODIFICATION OR
RECONSTRUCTION OF UNCONTROLLED FACILITIES
Control options
E-l E-2 E-3 E-4
INSTALLED CAPITAL COSTS ($ 1000)
Line(s)
Add-on control equipment
Building
Total capital costs
Annual i zed capital costs
Insurance, taxes and G&A
Total annual ized capital costs
OPERATING COSTS (SAVINGS) ($ 1000)
Direct labor
Maintenance labor
Overhead
Maintenance materials
Paint
Electricity
Natural gas
Total operating costs
TOTAL ANNUALIZED COSTS (SAVINGS) ($ 1000)
Cost (savings) per area covered
($/1000 nf)
90
0
0
90
11
4
15
0
0
0
7b
0
.(.41
19
422
55
0
2
57
7
2
9
0
0
0
1
0
0
9
200
5
0
0
5
1
0
1
0
0
0
(1)
If}
(3)
(2)
(44)
5
_
5
1
_
1
0
(1)
*• '
(2)
(44)
aE-l Powder
E-2 Waterborne
E-3 70 percent high solids
.E-4 65 percent high solids 3
bThis cost for powder is based on a film thickness of 6.35 x 10 cm (2.5 mi I)
However, at a film thickness of 3.81 x lO^cm (1.5 mil) the cost changes
significantly (see Appendix E).
7-68
-------
Table 7-47 PLANT F - CONTROL COSTS FOR MODIFICATION OR
RECONSTRUCTION OF UNCONTROLLED FACILITIES
Control options3
F-l F-2 F-3 F-4
INSTALLED CAPITAL COSTS ($ 1000)
Line(s)
Add-on control equipment
Building
Total capital costs
Annual i zed capital costs
Insurance, taxes and G&A
Total annual ized capital costs
OPERATING COSTS (SAVINGS) ($ 1000)
Direct labor
Maintenance labor
Overhead
Maintenance materials
Paint
Electricity
Natural gas
Total operating costs
TOTAL ANNUALIZED COSTS (SAVINGS) ($ 1000)
Cost (savings) per area covered
(S/1000 mz)
100
0
0
100
13
4
17
0
0
0
2
5b
0
~r
20
444
70
0
2
72
9
3
12
0
0
0
1
4
1
(2)
4"
16
356
5
0
0
5
1
0
1
0
0
0
0
0
0
(2)
(2)
(1)
(22)
5
0
0
5
1
0
1
0
0
0
0
0
0
- (2)
/ — M. \
TZT
(i)
(22)
aF-l Powder
F-2 Waterborne
F-3 70 percent high solids
F-4 65 percent high solids „
This cost for powder is based on a film thickness of 6.35 x 10 cm (2.5 mil),
However, at a film thickness of 3.81 x 10"3cm (1.5 mil) the cost changes
significantly (see Appendix E).
7-69
-------
Table 7-48. PLANT G - CONTROL COSTS FOR MODIFICATION OR
RECONSTRUCTION OF UNCONTROLLED FACILITIES
Control
G-l G-2
INSTALLED CAPITAL COSTS ($1000)
Line(s)
Add-on control equipment
Bui Iding
Total capital costs
Annual i zed capital costs
Insurance, taxes and G&A
Total annual ized capital costs
OPERATING COSTS (SAVINGS) ($ 1000)
Direct labor
Maintenance labor
Overhead
Maintenance materials
Paint
Electricity
Natural gas
Total operatinq costs
TOTAL ANNUALIZED COSTS (SAVINGS) ($ 1000)
Cost (savings) per area covered
1040
0
1040
137
42
179
0
n
"
16
720
i
i
664
843
2,1
2500
126
2626
342
105
447
0
n
n
u
\
(117)
"V?
"ToTT
366
92
options
G-3 G-4
625
118
873
114
35
149
0
o
n
1 '
n
/ pQ ^
-^~cL
155
39
625
n
118
743
94
124
0
0
n
' '
0
:?8
162
41
G-l Fluidized bed
G-2 Electrodeposition
G-3 Incinerator on base case line(s)
G-4 Waterborne
7-70
-------
Table 7-49. PLANT H - CONTROL COSTS FOR MODIFICATION OR
RECONSTRUCTION OF UNCONTROLLED FACILITIES
Control options
H-l H-2 H-3 H-4
INSTALLED CAPITAL COSTS ($ 1000)
Line(s)
Add-on control equipment
Building
Total capital costs
Annualized capital costs
Insurance, taxes and G&A
Total annualized capital costs
210
0
0
210
28
8
36
550
0
354
904
107
36
143
125
no
22
257
35
10
45
125
0
22
147
18
6
24
OPERATING COSTS (SAVINGS) ($ 1000)
Direct labor 0000
Maintenance labor 0000
Overhead 0000
Maintenance materials 3822
Paint 42 (19) 8 8
Electricity 1800
Natural gas (11) (5) (3) (5)
Total operating costs 35 (8) 7 5
TOTAL ANNUALIZED COSTS (SAVINGS) ($ 1000) 71 135 52 29
Cost (savings) per area covered
($71000 nf) 91 173 67 37
H-l Fluidized bed
H-2 Electrodeposition
H-3 Incinerator on base case line(s)
H-4 Waterborne
7-71
-------
Table 7-50 PLANT I - CONTROL COSTS FOR MODIFICATION OR
RECONSTRUCTION OF UNCONTROLLED FACILITIES
Control options
1-1 1-2 1-3
INSTALLED CAPITAL COSTS ($ 1000)
Line(s) 90 210 58
Add-on control equipment 000
Building _0 1 _L
Total capital costs 90 211 59
Annual!zed capital costs 12 28 8
Insurance, taxes and G&A _4 _8 _2
Total annualized capital costs , 16 36 10
OPERATING COSTS (SAVINGS) ($ 1000)
Direct labor 000
Maintenance labor 000
Overhead ° 2 ?
Maintenance materials 1 3 ]
Paint 25 0) 1
Electricity « J u
Natural gas \7/
Total operating costs 22
TOTAL ANNUALIZED COSTS (SAVINGS) ($1000) 38 39 10
Cost (savings) per area covered
($/1000 nf) 844 867 222
1-1 Fluidized bed
1-2 Electrodeposition
1-3 Waterborne
7-72
-------
Table 7-51. PLANT J - CONTROL COSTS FOR MODIFICATION OR
RECONSTRUCTION OF UNCONTROLLED FACILITIES
Control options
J-l
INSTALLED CAPITAL COSTS ($ 1000)
Line(s) 58
Add-on control equipment 0
Building ]
Total capital costs "59
Annualized capital costs 8
Insurance, taxes and G&A _2
Total annualized capital costs 10
OPERATING COSTS (SAVINGS) ($ 1000)
Direct labor • 0
Maintenance labor 0
Overhead 0
Maintenance materials. 1
Paint 1
Electricity 0
Natural gas (2)
Total operating costs 0
TOTAL ANNUALIZED COSTS (SAVINGS) ($ 1000) 10
Cost (savings) per area covered
($/1000 nf) 222
0-1 Waterborne
7-73
-------
addition of a thermal incinerator to the curing oven exhaust. All other
costs associated with the change would be related to operating costs.
There are also three options for dip coating lines which would require
capital expenditures. For the fluidized bed powder coating option most of
the line would have to be replaced with the exception of the pretreatment
area. Electrodeposition (EDP) requires a large capital investment due to
the need for more pretreatment and the great expense of an EDP tank and
filtration system. As with spray lines, the only capital expense associated
with the incineration option is the incinerator itself.
The flow coating model plant has only one option which would require
no investment when switching from the base case.
7.3 OTHER COST CONSIDERATIONS
This section deals with two subjects: the costs borne by metal
furniture coating facilities in complying with current regulatory require-
ments and the impact of a New Source Performance Standard on state and
local regulatory enforcement agencies.
7.3.1 Water Treatment
As explained in Chapter 6, metal furniture coating facilities have a
limited potential to pollute water. For economic reasons, water which is
used in the pretreatment section of the coating line and in the water wash
spray booths is recirculated with only make-up water being added, as needed,
due to evaporation. One source of water pollution is clean-up water which
falls through process area drains.
The overall cost of water treatment to the metal furniture coater is
minimal. There is a possibility of a slight increase due to the use of
waterborne paint, however, this has no appreciable impact on the overall
cost of operation of a coating line.
7.3.2 Solid Waste Disposal
Solid waste disposal which results from overspray in the application
area of a coating line must be collected and disposed of periodically. As
with water treatment, these disposal costs are minimal. The use of high
solids paint results in a more difficult clean-up, however, there is no
significant increase in the actual amount of solid waste which must be
disposed of. Waterborne paints may create somewhat more solid waste however
the increase is not significant.
7-74
-------
7.3.3 OSHA Requirements
Occupational Safety and Health Administration (OSHA) regulations for
metal furniture coating facilities specify air flow requirements through
spray booths in order to keep the VOC concentration below the threshold
limit value (TLV). In addition, oven exhaust flow rates are regulated in
order to keep VOC concentrations below the lower explosive limit (LEL).
Waterborne paints present a problem for spray coating facilities due
to the electrical shock potential. Certain costs would be incurred in
providing proper insulation from such hazards. These costs are also
included in the overall costs presented in Section 7.2.
7.3.4 Regulatory Agency Manpower Requirements
The burden of enforcement of NSPS falls on state and local agencies.
In accordance with the Clean Air Act amendments of 1977, states are already
under obligation to propose, adopt, and enforce State Implementation Plans
for the reduction of VOC emissions. Most of these SIPs include regulations
on emissions from metal furniture painting operations. At least six states
have proposed a level of permissible emissions of 0.36 kilograms of organic
solvent per liter of coating (3.0 pounds per gallon) at application. These
states are highly industrialized, as are the states in which most metal
furniture manufacturers are located (see Section 2.1 and 7.1). It is
expected that such states will already have a regulatory framework for the
enforcement of state environmental laws either previous to or as a result
of the Clean Air Act amendments. In the event that the NSPS is less strict
than an existing state regulation, the regulatory agency manpower impact
will be negligible. In states where NSPS is stricter than the state
regulation the incremental manpower requirements should be minimal.
7.4 ECONOMIC IMPACT ASSESSMENT
7.4.1 Introduction and Summary
7.4.1.1 Introduction. This section analyzes the potential inhibiting
effects of NSPS controls on investment in new, modified, and reconstructed
surface coating facilities in the metal furniture industry. Two measures
of potential impacts used in the analysis are changes to profit and capital
availability.
7-75
-------
As part of the analysis, several basic questions are addressed:
• Which of the control options have the greatest impacts upon the
i ndustry?
• How do impacts vary from one type of plant to another?
• How do impacts vary by size of plant?
• How might the structure of the industry be affected by the control
options?
• What magnitude of industry-wide compliance costs might be antici-
pated?
The analysis is divided into four major sections. Section 7.4.2
establishes the general context for the analysis by covering the subject of
industry expansion. Section 7.4.3 summarizes the methodology used in the
analysis. Section 7.4.4 discusses the results of the analysis. Finally,
Section 7.4.5 summarizes industry-wide compliance costs. Aggregate effects
on industry structure, employment, inflation, and energy are analyzed in
Section 7.5.
7.4.1.2 Summary. The impact assessment was performed using a model
plant approach. Ten model plants were employed. Of this total, three were
shelving plants, and seven were chair plants. Shelves and chairs were
chosen to represent the flat and complex surfaces that would be coated.
The characteristics of the plants in terms of size and coating method used
are given in Tables 7-52 and 7-53.
All of the shelving plants are spray-coating operations, while the
chair plants are divided between spray coating, dip coating, and flow
coating operations. Only one model plant (Plant J) is used for flow
coating.
The impact analysis was performed for both new and modified/reconstructed
facilities, and compared estimated profit and capital availability after
NSPS controls to both SIP and uncontrolled baseline.
The potential of the control options for reducing plant profits was
examined using a form of "worst case" analysis which assumed that incremental
annualized control costs would be fully absorbed by the model plants. The
analysis indicated major profit reduction for all shelving plants (Plants
A, C, and E) for the powder options. (A "major" impact is defined as an
7-76
-------
Table 7-52. MODEL SHELVING PLANTS
Plant
Size
Area coated per year
Coating method
A
C
E
Large
Medium
Small
4,000,000 m2
780,000 m2
45,000 m2
Spray
Spray
Spray
Table 7-53. MODEL CHAIR PLANTS
Plant
B
D
F
G
H
I
J
Size
Large
Medium
Small
Large
Medium
Small
Small
Area coated per year
4,000,000 m2
780,000 m2
45,000 m2
4,000,000 m2
780,000 m2
45,000 m2
45,000 m2
Coating method
Spray
Spray
Spray
Dip
Dip
Dip
Flow
7-77
-------
impact which can result in a decision not to invest in a new source.)
However, based upon data presented in Appendix E, this is not true if
powder is applied at film thickness of 3.81 x 10"3cm (1.5 mil) or less. In
the case of Plant A, major profit reductions were exhibited for modified/
reconstructed facilities relative to both the SIP and uncontrolled baselines.
For Plants C and E, major impacts were indicated for both new and modified/
reconstructed facilities, relative to both baselines. (A profit reduction
of 15 percent or more was determined as constituting a "major" impact. The
rationale for this criterion is developed in Section 7.4.3.3.) Plant E,
the smallest shelving plant, was also found to be subject to major impact
by the waterborne options for new facilities relative to the SIP baseline,
and for modified/reconstructed facilities relative to both baselines. In
the case of the 70 percent high solids options, none of the shelving plants
were subject to major impacts - in fact, profits in all situations were
either favorably affected or not affected at all. The results were similar
for the 65 percent high solids option. For incineration with RACT coating,
profit reductions were relatively small (largest reduction was 2.79 percent).
A summary of the major impacts is given in Table 7-54.
Of the seven chair plants, Plant I (small dip-coating plant) was the
only one found to be subject to major profit impacts. These impacts were
associated with the powder and electrodeposition control options. In the
case of powder, the major impacts were exhibited for modified/ reconstructed
facilities relative to both the SIP and uncontrolled baselines. For electro-
deposition, major profit reductions were indicated for both new and modified/
reconstructed facilities relative to both baselines. Among all of the
chair plants, no profit reduction was associated with the 70 percent and
65 percent high solids options. For incineration with RACT coating, the
largest impact was relatively minor (only 2.56 percent). With respect to
waterborne, the greatest profit reduction was 8.60 percent. A summary of
the major impacts is given in Table 7-55.
In general, for both shelves and chairs, it was found that the severity
of profit reduction associated with a given control option tends to vary
inversely with the size of the plant. Thus, in a situation where two
plants of unequal size employ the same control option, the smaller is
likely to be at a competitive disadvantage relative to the larger.
7-78
-------
Table 7-54 SUMMARY OF MAJOR IMPACTSa
SHELVING PLANTS
Plant
A
Large
Spray
o
Control
Option
Powder (spray)
Waterborne
70% High solids
Incinerator &
RACT coating
65% High solids
Profit impact
Modified/
New Reconstruc.
SIP Uncon SIP Uncon.
X X
Capital availability impact
Modified/
New Reconstruc.
SIP Uncon. SIP Uncon.
Waterborne
Medium 70% High solids
Spray Incinerator &
RACT coating
65% High solids
E Powder (spray)
Waterborne
Small 70% High solids
Spray 65% High solids
x
x
x
x
x
x
x
x
x
x
a"X" indicates major impact.
NOTE: Under each of the impact headings in the table, a distinction is made between
new facilities and modified/reconstructed facilities. In turn, within each
of these categories of facilities, a further distinction is made between
impacts relative to the SIP baseline, and those relative to the uncontrolled
baseline.
This is not the case for powder applied at a
(1.5 mil) or less (see Appendix E).
film thickness of 3.81 x
10"3cm
7-79
-------
Table 7-55. SUMMARY OF MAJOR IMPACTS9 CHAIR PLANTS
Plant
B
Large
Spray
Control
Option
Powder (spray)
Waterborne
70% High solids
Incinerator &
RACT coating
65% High solids
Profit impact
Modified/
New Reconstruc.
SIP Uncon SIP Uncon.
Capital avai
New
SIP Uncon.
lability impact
Modified/
Reconstruc.
SIP Uncon
D Powder (spray)
Waterborne
Medium 70% High solids
Spray Incinerator &
RACT coating
65% High solids
F Powder (spray)
Waterborne
Small 70% High solids
Spray 65% High solids
Large
Dip
H
Powder (fid.bed)
Electrodepositi on
Incinerator &
RACT coating
Waterborne(conv.)
Powder(fid.bed)
Electrodeposition
Medium Incinerator &
Dip RACT coating
Waterborne(conv.)
I
Small
Dip
J
Small
Flow
Powder(fid.bed)
Electrodeposition
Waterborne(conv.)
Waterborne
x
x
x
x
a"X" indicates major impact.
NOTE: Under each of the impact headings in the table, a distinction is made between
new facilities and modified/reconstructed facilities. In turn, within each
of these categories of facilities, a further distinction is made between
impacts relative to the SIP baseline, and those relative to the uncontrolled
baseline.
7-80
-------
In analyzing the effects of the control options on capital availability,
associated increases in capital requirements of 10 percent or more were
considered to be major. (The rationale for this criterion is developed in
Section 7.4.4.4.) For shelving, the smallest plant (Plant E) was subject
to major impact by the waterborne options and by powder (spray) if applied
-3
at 6.35 x 10 cm (2.5 mil). In both situations, this was for modified/
reconstructed facilities relative to both baselines. For chairs, the small
dip-coating plant (Plant I) was subject to major impact by electrodeposition
for new facilities relative to the uncontrolled baseline, and for modified/
reconstructed facilities relative to both baselines. Again for any given
control option, the magnitude of impacts tended to vary inversely with
plant size. The phenomenon is especially pronounced with Plants E and I.
Based on the results obtained in the analyses of profit reduction and
capital availability, another analysis was performed to assess differentials
in impacts between the smallest and largest plants producing the same
product for each of the control options. In virtually all cases, for both
profit reduction and capital availability, the impact for the smallest
plant was found to be greater than the impact for the largest plant. In
several cases, the differences in impacts were large. For example, in
comparing Plant I (small dip-coating plant) with Plant G (large dip-coating
plant) with regard to the electrodeposition option, the following types of
differences were found for the modified/reconstructed facilities - SIP
baseline combination:
Profit reduction:
Plant I: 17.29 percent
Plant G: 1.88 percent
Difference: 15.41 percent
Capital availability:
Plant I: 7.98 percent
Plant G: 1.13 percent
Difference: 6.85 percent
7-81
-------
These differences underscore the fact that Plant I is clearly disadvantaged
relative to its larger dip-coating competitors. As Table 7-55 shows,
Plant I is already subject to major profit impacts for powder and electro-
deposition, and major capital availability impacts for electrodeposition.
Waterborne is the only control option available to Plant I which is not
connected with some form of major impact.
With regard to the case of shelving plants, one effect of the major
impacts (either profit or capital availability) is that either small shelving
plants would be built or reconstructed having fewer control options available,
or that the tendency would be to build or modify/reconstruct larger shelving
plants. Similarly, new small dip-coating plants (like Plant I) would have
only one control option available, or the tendency would be to build or
reconstruct larger dip-coating plants.
It should be noted that even in situations where major impacts are not
involved, the existence of large differentials are likely to lead to shifts
within the size distribution of plants towards greater proportional
representation by larger plants.
In summary, as Tables 7-54 and 7-55 show, the powder options (spray
and fluidized bed) cause major impacts for four of the model plants (A, C,
E, and I). However, this is only true if powder is applied at a film
thickness of 6.35 x 10"3 cm (2.5 mil) or greater (see Appendix E). In only
one case (Plant I) does electrodeposition cause major impacts. Likewise,
waterborne cause major impacts only in the case of Plant E. No major
impacts are associated with the other control options.
In order to provide an estimate of the range over which industrywide
compliance costs might vary, cost calculations were carried out for four of
the various combinations of control options that might be employed. The
combinations are as follows:
t Combination #1
Spray-coating plants: all six types of plants (A-F) use 70 percent
high solids.
Dip-coating plants: all three types of plants (G, H, I) use
conventional waterborne.
Flow-coating plants: the one type of plant (J) uses waterborne.
7-82
-------
• Combination #2
Spray-coating plants:
Dip-coating plants:
Flow-coating plants:
• Combination #3
Spray-coating plants:
Dip-coating plants:
Flow-coating plants:
Combination #4
all six types of plants (A-F) use powder.
all three types of plants (G, H, I) use
electrodepos i ti on.
the one type of plant (J) uses waterborne.
four types of plants (A-D) use incinerator
with RACT coating, the other two types of
plants (E & F) use waterborne.
all three types of plants (G, H, I) use
conventional waterborne.
the one type of plant (J) uses waterborne.
Dip-coating plants:
Flow-coating plants:
Spray-coating plants: all six types of plants (A-F) use 70 percent
high solids, powder, and waterborne
(options equally represented).
all three types of plants (G, H, I) use
conventional waterborne.
the one type of plant (J) uses waterborne.
Through the use of a methodology described in Section 7.4.5, industrywide
incremental annualized control costs (relative to the SIP baseline) were
estimated for each of the above combinations of control options, with the
estimations being based upon the number of new and replacement coating
lines projected for 1985 (as presented in Section 7.1.5.3). The costs are
as follows:
Combination #1:
Combination #2:
Combination #3:
Combination #4:
From Tables 7-78,
7-79. and 7-80
($14.7 million)
$126 million
$17.6 million
i
$54.8 million
From Tables 7-78, E-8,
and E-9 of Appendix E
($18 million)
($1.7 million)
$17 million
$11 million
7-83
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At $126 million, Combination #2 is by far the most costly of the four, and
exceeds by $26 million the threshold for a Significant Action Analysis (as
articulated in Executive Order 12044). However, costs associated with
Combination #2 change significantly if powder is applied at film thicknesses
of 3.81 x 10"3cm (1.5 mil) or less (see Appendix E).
7.4.2 Industry Expansion
A detailed profile of the metal furniture industry has been presented
in Section 7.1 of this document. This section builds upon that material
and presents an examination of factors which will have an important bearing
upon the future expansion of the industry. The purpose of the discussion
is to provide baseline context for the impact analysis which follows in
Section 7.4.4.
This section is divided into two parts, one dealing with the household
furniture component of the industry (SIC 2514), and the other with the
business and institutional furniture component (comprised of SIC groups
2522, 2531, and 2542).
7.4.2.1 Metal Household Furniture. The metal household furniture
industry (SIC 2514) is comprised of nearly 400 establishments.24 Major
products of the industry include: indoor dining, dinette, and breakfast
furniture; porch, lawn, outdoor, and casual seating and tables; kitchen
cabinets and stools; bed frames; medicine cabinets; and infants' furniture.
Demand. As discussed in Section 7.1.5.1, it is anticipated that
between now and 1985, shipments of metal household furniture will exhibit a
pattern of no growth through 1980, followed by growth on the order of one
percent per year through 1985.
Looking at the growth potential of particular product areas, it appears
likely that the fastest growth will occur in the area of summer and casual
furniture. Two basic reasons for this expectation are the trend towards
increasingly casual lifestyles, and the relatively low prices charged for
this type of furniture.
There are several critical factors underlying the overall demand for
metal househould furniture. These include: demographic trends influencing
the rate of new household formation; disposable personal income and consumer
spending on durable goods; housing starts and sales; interest rates; consumer
confidence; and, outstanding consumer installment debt.
7-84
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Due to a lack of quantitative studies on the subject, nothing definite
can be said about the price elasticity of demand for metal household furni-
ture. On the basis of economic principles, however, one might expect that
the elasticity could vary somewhat from one type of metal household furniture
to another. Generally speaking, the more substitutes a particular type of
furniture has, and the higher its price, the greater will tend to be the
price elasticity of demand. Variation is also possible within a given type
of furniture -- i.e., the price elasticity of demand for the product of one
manufacturer may differ from the elasticity for the product of another
manufacturer.
From the standpoint of the impact analysis which follows, price
elasticity of demand is an important factor in two respects. First, the
extent to which a firm can pass through incremental control costs to the
consumer is reflective of the price elasticity of demand for the particular
product which the firm manufactures. If the demand for the firm's product
is inelastic, the firm may be able to pass through much or all of the
incremental costs to the consumer. The extent to which this is possible
would depend upon intra-industry competitive factors. Locational considera-
tions would be most important in this regard. If the demand for the firm's
product tends to be elastic, the potential for cost pass-through is reduced.
The second reason why price elasticity of demand is important to the
impact analysis is that it has a major bearing on the inflationary effects
of NSPS regulations. If the demand for metal household furniture tended to
be inelastic with respect to price increases, the inflationary impact upon
the economy would be greater than if the demand were elastic (since price
increases would be resisted in the latter situation).
According to a U.S. Department of Commerce representative, price has
not been a critical factor in demand for metal furniture versus furniture
of other materials. One reason given is that in the past, metal household
furniture price increases have been consistent with price increases for
household furniture made from other materials. Another is that the general
state of the economy is typically a more important factor in demand shifts
.. 25
than price increases.
Supply. The metal household furniture industry is characterized by
diversification and a small business orientation. In 1976, the industry
7-85
-------
had 391 establishments and employed approximately 31,000 workers, with
26
shipments valued at $992 million. Vertical integration is not common
within the industry. The majority of firms purchase raw materials and
other inputs from external sources, and are not forwardly integrated into
marketing.
According to a trade association representative, the future size
distribution of firms within the industry will consist predominately of
large and small firms, with the number of medium-sized companies substan-
tially reduced. Small firms will continue to exist because of the ease of
entry characteristic of certain types of metal household furniture manufac-
ture (for example, the capital requirements of the manufacture of tubular
aluminum lawn furniture are relatively modest) and transportation cost
advantages stemming from plant location near retail markets.
As discussed in Section 7.1.1.3, the actual rate of capacity utilization
in the metal household furniture industry was perhaps less than 70 percent
in 1977. Given this level of utilization and the anticipated demand trends
discussed above, it would appear that no additional capacity will be needed
until after 1980.
7.4.2.2 Business and Institutional Furniture. The business and
institutional component of the metal furniture industry is comprised of
three SIC groups: SIC 2522 (metal office furniture); SIC 2531 (public
building and related furniture); and SIC 2542 (metal partitions and fix-
tures). Major products of the office furniture component include chairs,
desks, filing and storage cabinets, and panel systems. The public building
and related component produces items such as benches, bleacher seating,
folding chairs, and seating for automobiles and public conveyances. The
metal partitions and fixtures component produces items including room
dividers, shelves, lockers, and storage bins.
Demand. In recent years, the business and institutional furniture
industry (including both wood and metal furniture) has enjoyed a steady
growth in demand. As mentioned in Section 7.1.2.4, following a substantial
upturn in 1976, shipments of business and institutional furniture in constant
dollars continued to increase through 1977 and 1978. The trend is expected
to continue at least through the near future. According to the Business
7-86
-------
and Institutional Furniture Manufacturers' Association (BIFMA), the market
is likely to remain strong, given the general trend towards increasing
construction of commercial office buildings in many cities across the
2
country. Superimposed upon this general trend, however, are the high
interest rates which have resulted from the federal government's efforts to
strengthen the dollar. These rates will probably have a dampening effect
upon the rate of new office building construction. In the opinion of
BIFMA, however, this impact may be partially offset by increased demands
for remodeled facilities since there still appears to be a shortage of
office space. As discussed earlier in Section 7.1.5.1, the anticipated
annual growth rates for demand through 1985 are four percent for metal
office furniture, two percent for the public building component, and seven
percent for the metal partition component.
By all indications, the industry's growth potential is greatest in the
area of panel systems. A recent development, such systems are modular
units containing panels, desks or work surfaces, files, and storage
accessories. One study projects growth in value of shipments through 1990
at 16.4 percent on a current dollar basis.
The factors underlying the demand for business and institutional
furniture are varied. In the case of office furniture for example, some of
the more important factors include: construction of new office buildings
and renovation of existing facilities; growth of the white collar work
force; prospects for replacement of old furniture; and concern over the
quality of the white collar working environment.
As was the case with metal household furniture, there are no quantita-
tive studies available on the price elasticity of demand for business and
institutional furniture. No definite statement can therefore be made as to
whether demand tends to be elastic or inelastic. It would seem, however,
that purchases of business and institutional furniture tend to be influenced
more by factors relating to operational necessity and general business and
economic conditions rather than changes in price. The implications of
price elasticity with respect to cost pass through and inflation are the
same as those discussed above in connection with metal household furniture.
The price cross-elasticity of demand for metal office furniture is
relatively low with respect to office furniture made from other materials
7-87
-------
(mainly wood). According to a BIFMA representative, consumers do not
choose between metal and wood business and institutional furniture on the
basis of price alone. Design and material itself are critical relative
demand factors. Wood is a prestige item, valued for its rich appearance,
and tends to be purchased for upper level management only. Although
substitution may take place if there are supply shortages, the markets for
wood and metal business and institutional furniture are essentially segmented.
Supply. In 1976, there were 1,003 manufacturing establishments in the
business and institutional component of the metal furniture industry. The
breakdown was as follows: metal office furniture (SIC 2522), 177; public
building and related furniture (SIC 2531), 377; and metal partitions and
fixtures (SIC 2542), 449. Together, the three SIC groups employed
24
approximately 68,000 workers and had shipments valued at nearly $2.7 billion.
Of the three industry groups, metal office furniture (SIC 2522) is by
far the most concentrated. In 1972, 37 percent of the value of shipments
for the metal office furniture component was accounted for by the four
largest companies. The comparable figures for the public building and
related component and the metal partitions and fixtures component were 18
percent and 13 percent, respectively. The metal office furniture component
is also much more heavily weighted towards multi-plant firms than are the
other two components. Census data show that in 1972, 83 percent of the
value of shipments for the metal office furniture component was accounted
for by multi-plant companies. The comparable figures for the public building
27
and metal partitions components were 56 percent and 58 percent, respectively.
Vertical integration is not widespread in any of the three industry
groups. Raw materials and other inputs tend to be obtained largely from
external sources, and only the largest companies are forwardly integrated
into marketing. Distribution to end users is generally accomplished through
local dealers who handle the products of a number of different manufacturers.
The business and institutional furniture industry is currently stable.
There have been few entries or exits of firms.
According to BIFMA, manufacturers of business and institutional furniture
29
have been operating at near capacity levels. Additional capacity is now
required not only to meet anticipated growth in demand, but to also create
7-88
-------
a sufficient buffer. No serious production bottlenecks are anticipated,
however, supply is expected to keep up with demand. It is likely that much
of the new capacity in the industry will be devoted to the manufacture of
panel systems.
7.4.3 Methodology
This section presents a summary of the steps and procedures used in
assessing the potential impacts of the control options at the level of the
individual plant.
The assessment was performed using a model plant approach, in which
ten different model plants were subjected to analysis. Details of these
plants are given in Table 7-56. Three of the model plants are shelving
plants, while the other seven are chair plants. Shelves and chairs were
chosen to represent the flat and complex surfaces that would be coated.
Plant size is expressed in terms of surface area coated per year and the
2
equivalent number of shelves or chairs (assuming coated areas of 1.0 m for
2
shelves, and 0.33 m for chairs). The shelving plants are of three different
sizes. All, however, are spray-coating operations. The chair plants are
differentiated in terms of both size and coating method. Three types of
coating methods are represented: spray, dip, and flow. The spray and dip
categories are each represented by three different sizes of plants. There
is only one plant for the flow category.
The analysis examines impacts on both new facilities and modified/
reconstructed facilities. Within each of these categories of facilities,
the impacts are measured relative to both an SIP baseline and an "uncon-
trolled" baseline. As discussed in Chapter 5, a total of six different
control options are considered.
Two types of impacts are examined in the analysis:
• Profit impairment
• Adverse effects upon capital availability.
The methodologies used in examining these impacts are described fully in
Sections 7.4.4.3 and 7.4.4.4, and need not be detailed at this point. A
few words are in order, however. In the analysis of profit impairment, the
objective is to determine the extent to which the profits of the model
plants would be reduced under the various NSPS control options. To simplify
7-89
-------
Table 7-56. MODEL SHELVING AND CHAIR PLANTS
Plant
A
C
E
Plant
B
D
F
G
H
I
J
Coating
method
Spray
Spray
Spray
Coating
method
Spray
Spray
Spray
Dip
Dip
Dip
Flow
Shelving
Area coated
per year
(sq. meters)
4,000,000
780,000
45,000
Chair
Area coated
per year
(sq. meters)
4,000,000
780,000
45,000
4,000,000
780,000
45,000
45,000
Plants:
No. of shelves
coated per year
4,000,000
780,000
45,000
Plants:
No. of chairs
coated per year
12,000,000
1,181,800
136,360
12,000,000
1,181,800
136,360
136,360
Correspondi ng
SIC group
2522
2514,2522,2531,
2514,2522,2531,
Corresponding
SIC group
2522
2514,2522,2531
2514,2522,2531
2522
2514,2522,2531
2514,2522,2531
2514,2522,2531
2542
2542
,2542
,2542
,2542
,2542
,2542
7-90
-------
the analysis, the impacts are examined using a "worst case" approach which
assumes that incremental annualized control costs are fully absorbed by the
plants. In evaluating the impacts, a profit reduction of 15 percent or
more is judged to be a major impact. (The derivation of this criterion is
discussed in Section 7.4.4.3.) A "major" impact is here defined as an
impact which could result in a decision not to invest in a new source.
In the analysis of capital availability, effort focuses on determining
the extent to which the capital requirements of the model plants would be
increased under the various control options. For purposes of evaluation,
increases in capital requirements of 10 percent or more are considered to
be major. (The derivation of this criterion is discussed in Section 7.4.4.4.)
Based on results obtained from the analyses of profit reduction and
capital availability, another analysis is performed to assess differentials
in impacts between the smallest and largest plants producing the same
product for each of the control options. The discussion is presented in
Section 7.4.4.5.
7.4.4 Plant-Level Impact Analysis
7.4.4.1 Product Price Determination. One of the basic preliminary
steps in the model plant analysis was that of determining prices for the
shelves and chairs manufactured by the model plants.
Two types of prices were determined - F.O.B. (i.e. producer price at
the plant) and retail list. In the sections which follow, the F.O.B.
prices are used in estimating model plant revenues, and determining the
extent of profit impairment associated with the various control options.
The retail list prices are used in measuring the inflationary impacts of
the control options.
Shelves. The shelf size assumed for the model plant is 1.2 m x 0.5 m,
or approximately 4' x 20". The surface coating area is approximately one
square meter.
The F.O.B. and retail list prices for shelving of this size were
OQ
developed from information contained in the GSA Federal Supply Schedule.
On the basis of an examination of three different sets of prices contained
in the Schedule, a representative F.O.B. price of $25.55 was developed.
Given this F.O.B. price, a retail list price of $38.33 was derived by
7-91
-------
assuming a markup of 50 percent. This markup was determined as being
representative on the basis of industry information.
Chairs. The type of chair assumed for the model plants is a stackable
stationary (i.e., not a swivel or rolling model) office chair with arms.
Only the frame, and not the seat or back, is assumed to be painted. The
surface coating area is 0.33 square meters.
Prices were determined from a survey of retail prices as presented in
office furniture catalogues. Only chairs having roughly the same surface
coating requirements as those specified in the model plant parameters were
considered. In all, 21 different prices were obtained. The price of
$52.50 was the representative mean. An F.O.B. price of $35.00 was obtained
by assuming that the retail list price represented a 50 percent markup.
7.4.4.2 Comparison of Per-Unit-Of-Product Costs for Control Options.
As pointed out in Section 7.4.3, six types of control options are considered
in the analysis. In this section, the costs of these options are compared
on a per-unit-of-product basis (i.e., per shelf or chair). The comparisons
are intended to provide a frame of reference for the impact analyses which
follow. The cost data are presented in Tables 7-57 to 7-64. The data are
in incremental form, and express additional costs or savings per shelf or
chair relative to the baseline (SIP or uncontrolled). The data were derived
from the control costs presented in Section 7.2, by dividing the total
incremental annualized costs for each model plant by the number of items
coated per year (as obtained from Chapter 5). The shelves and chairs are
the same as those defined in Section 7.4.4.1.
Cost for shelving plants. Powder (spray) applied at a film thickness
of 6.35 x I0"3cm (2.5 mil) is the most expensive of the control options,
with incremental costs per shelf ranging from $.17 to $.49. However, at a
film thickness of 3.81 x 10"3cm (1.5 mil) the incremental costs change
significantly (see Appendix E). This is followed by waterborne, for which
figures vary from $.06 to $.27. In the case of the 70 percent high solids
control option, cost savings are experienced in all of the situations
except one, in which there is no change in cost from the baseline case.
The costs for incineration plus RACT coating are relatively low, and in two
situations (involving Plants A and E) cost savings are experienced. With
7-92
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Table 7-57. PROFIT IMPACT
SHELVING PLANTS - NEW FACILITIES
SIP BASELINE
Plant
A
C
E
Incremental
annualized
Control control cost9
Option ($000)
Powder (spray)
Waterborne
70% High solids
Incinerator &
RACT coating
65% High solids
Powder (spray)
Waterborne
70% High solids
Incinerator &
RACT coating
65% High solids
Powder ( spray ).
Waterborne
70% High solids
65% High solids
735
298
(86)
36
(47)
149
59
(17)
24
(10)
12
9
0
0
# Shelves
coated
(000)
4000
4000
4000
4000
4000
780
780
780
780
780
45
45
45
45
Incremental
annualized
control cost
per shelf
coated3 ($)
.18
.07
(.02)
.01
(-01)
.19
.08
(.02)
.03
(.01)
.27
.20
c
c
Profit margin impact
F.O.B. price
per shelf ($) $
25.55
25.55
25.55
25.55
25.55
25.55
25.55
25.55
25.55
25.55
25.55
25.55
25.55
25.55
.70
.27
d
.04
d
.74
.31
d
.12
d
1.06
.78
d
d
^Parentheses indicate decrease from baseline case.
The profit impact changes significantly from the powder option based on
data presented in Appendix E.
jNo change in cost from baseline case.
No negative impact on profit margin.
7-93
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Table 7-58. PROFIT IMPACT
SHELVING PLANTS - NEW FACILITIES
UNCONTROLLED BASELINE
Plant
A
C
E
Incremental
annuali zed
Control control costa
Option ($000)
Powder (spray)
Waterborne
70% High solids
Incinerator &
RACT coating
65% High solids
Powder (spray)
Waterborne
70% High solids
Incinerator &
RACT coating
65% High solids
Powder (spray)
Waterborne
70% High solids
65% High solids
670
233
(151)
(29)
(112)
137
47
(29)
12
(22)
9
6
(3)
(3)
# Shelves
coated
(000)
4000
4000
4000
4000
4000
780
780
780
780
780
45
45
45
45
Incremental
annual i zed
control cost
per shelf
coateda ($)
.17
.06
(.04)
(.01)
(.03)
.18
.06
(.04)
.02
(.03)
.20
.13
(.07)
(.07)
Profit margin
F.O.B. price
per shelf ($)
25.55
25.55
25.55
25.55
25.55
25.55
25.55
25.55
25.55
25.55
25.55
25.55
25.55
25.55
impact
%
.67
.23
c
c
c
.70
.23
c
.08
c
.78
.51
c
c
^Parentheses indicate decrease from baseline case.
DThe profit impact changes significantly from the powder option based on
data presented in Appendix E.
SNO change in cost from baseline case.
No negative impact on profit margin.
7-94
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Table 7-59. PROFIT IMPACT
SHELVING PLANTS - MODIFIED/RECONSTRUCTED FACILITIES
SIP BASELINE
Plant
A
C
E
Incremental
annual ized
Control control cost9
Option ($000)
Powder (spray) ^
Waterborne
70% High solids
Incinerator 8
RACT coating
65% High solids
Powder (spray) °
Waterborne
70% High solids
Incinerator &
RACT coating
65% High solids
Powder (spray)
Waterborne
70% High solids
65% High solids
820
305
(86)
30
(47)
185
64
(17)
24
(10)
22
12
0
0
# Shelves
coated
(000)
4000
4000
4000
4000
4000
780
780
780
780
780
45
45
45
45
Incremental
annual ized
control cost
per shelf
coated9 ($)
.21
.08
(.02)
.01
(.01)
.24
.08
(.02)
.03
(.01)
.49
.27
c
c
Profit margi
n impact
F.O.B. price
per shelf ($) %
25.55
25.55
25.55
25.55
25.55
25.55
25.55
25.55
25.55
25.55
25.55
25.55
25.55
25.55
.82
.31
d
.04
d
.94
.31
d
.12
d
1.92
1.06
d
d
aParentheses indicate decrease from baseline case.
bThe profit impact changes significantly from the powder option based on data
presented in Appendix E.
GNo change in cost from baseline case.
negative impact on profit margin.
7-95
-------
Table 7-60. PROFIT IMPACT
SHELVING PLANTS - MODIFIED/RECONSTRUCTED FACILITIES
UNCONTROLLED BASELINE
Plant
A
C
E
Incremental
annual ized
Control control cost8
Option ($000)
Powder (spray) b
Waterborne
70% High solids
Incinerator &
RACT coating
65% High solids
Powder (spray) b
Waterborne
70% High solids
Incinerator &
RACT coating
65% High solids
Powder (spray) b
Waterborne
70% High solids
65% High solids
757
242
(115)
(3)
(76)
172
51
(7)
23
(12)
19
9
(2)
(2)
# Shelves.
coated
(000)
4000
4000
4000
4000
4000
780
780
780
780
780
45
45
45
45
Incremental
annual ized
control cost
per shelf
coated9 ($)
.19
.06
(.03)
d
(.02)
.22
.07
(.01)
.03
(.02)
.42
.20
(.04)
(.04)
Profit margin impact
F.O.B. price
per shelf ($) %
25.55
25.55
25.55
25.55
25.55
25.55
25.55
25.55
25.55
25.55
25.55
25.55
25.55
25.55
.74
.23
c
c
c
.86
.27
c
.12
c
1.64
.78
c
c
^Parentheses indicate decrease from baseline case.
The profit impact changes significantly from the powder option based on data
presented in Appendix E.
SNO change in cost from baseline case.
No negative impact on profit margin.
7-96
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Table 7-61. PROFIT IMPACT
CHAIR PLANTS - NEW FACILITIES
SIP BASELINE
Incremental
Incremental annual ized
annuali zed # Chairs control cost
Control control cost9 coated per chair
Plant Option ($000) (000) coated^ ($)
B
D
F
G
H
Powder (spray)
Waterborne
70% High solids
Incinerator &
RACT coating
65% High solids
Powder (spray)
Waterborne
70% High solids
Incinerator &
RACT coating
65% High solids
Powder (spray)
Waterborne
70% High solids
65% High solids
Powder (Fid. Bd.)
Elect rodeposition
Incinerator &
RACT coating
Waterborne (Convent.)
Powder (Fid. Bd.)
Electrodeposition
Incinerator &
RACT coating
Waterborne (Convent.)
565
433
(115)
31
(65)
113
85
(22)
25
(12)
10
16
0
0
667
335
30
38
27
86
24
8
12,000
12,000
12,000
12,000
12,000
1,182
1,182
1,182
1,182
1,182
136
136
136
136
12,000
12,000
12,000
12,000
1,182
1,182
1,182
1,182
.05
.04
(.01)
(.01)
.10
.07
(.02)
.02
(.01)
.07
.12
c
c
.06
.03
e
e
.02
.07
.02
.01
Profit margin impact
F.O.B. price
per chair ($)
35.00
35.00
35.00
35.00
35.00
35.00
35.00
35.00
35.00
35.00
35.00
35.00
35.00
35.00
35.00
35.00
35.00
35.00
35.00
35.00
35.00
35.00
%
.14
.11
d
.01
d
.29
.20
d
.06
d
.20
.34
d
d
.17
.09
.01
.01
.06
.20
.06
.03
7-97
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Table 7-61. PROFIT IMPACT
CHAIR PLANTS - NEW FACILITIES
SIP BASELINE
(Continued)
Plant
Control
Option
Incremental
annualized
control cost3
($000)
Incremental
annual ized
# Chairs control cost Profit margin impact
coated per chair F.O.B. price
(OOP) coated3 ($) per chair ($) %
I Powder (Fid. Bd.) 18
Electrodeposition 33
Waterborne (Convent.) 0
J Waterborne 0
136
136
136
136
.13
.24
b
35.00
35.00
35.00
35.00
.37
.69
c
.Parentheses indicate decrease from baseline case.
The profit impact changes significantly from the powder option based on data
presented in Appendix E.
SNO change in cost from baseline case.
No negative impact on profit margin.
eLess than $.01.
7-98
-------
Table 7-62. PROFIT IMPACT
CHAIR PLANTS - NEW FACILITIES
UNCONTROLLED BASELINE
Incremental
annual ized # Chairs
Control control costa coated
Plant Option ($000) (000)
B
D
F
G
H
Powder (spray) ^
Waterborne
70% High solids
Incinerator &
RACT coating
65% High solids
Powder (spray)
Waterborne
70% High solids
Incinerator &
RACT coating
65% High solids
Powder (spray) b
Waterborne
70% High solids
65% High solids
Powder (Fid. Bd.)
Electrodeposition
Incinerator &
RACT coating
Waterborne (Convent.)
Powder (Fid. Bd.)
Electrodeposition
Incinerator &
RACT coating
Waterborne (Convent.)
486
354
(194)
(48)
(144)
101
73
(34)
13
(24)
8
14
(2)
(2)
790
458
153
161
54
113
51
35
12,000
12,000
12,000
12,000
12,000
1,182
1,182
1,182
1,182
1,182
136
136
136
136
12,000
12,000
12,000
12,000
1,182
1,182
1,182
1,182
incremental
annual ized
control cost
per chair
coateda ($)
.04
.03
(-02)
c
(.01)
.09
.06
(.03)
.01
(.02)
.06
.10
(.01)
(.01)
.07
.04
.01
.01
.05
.10
.04
.03
Profit margi
F.O.B. price
per chair ($
35.00
35.00
35.00
35.00
35.00
35 00
\S\s • \J \J
35.00
35.00
35.00
35.00
35.00
35.00
35.00
35.00
35.00
35.00
35.00
35.00
35.00
35.00
35.00
35.00
n impact
) %
1 1
• J. J.
no
• \J 3
d
d
U
d
?fi
. L.U
.17
• i /
d
.03
» V w>
d
1 7
• -L /
.29
• (_ — '
d
d
?n
• cu
.11
.03
.03
.14
• A r
.29
.11
.09
7-99
-------
Table 7-62. PROFIT IMPACT
CHAIR PLANTS - NEW FACILITIES
UNCONTROLLED BASELINE
(Continued)
Plant
Control
Option
Incremental
annualized
control costs
($000)
# Chairs
coated
(OOP)
Incremental
annualized
control cost
per chair
coated9 ($)
Profit margin impact
F.O.B. price
per chair ($) %
I Powder (Fid. Bd.) 28
Electrodeposition 43
Waterborne (Convent.) 10
J Waterborne 10
136
136
136
136
.21
.32
.07
.07
35.00
35.00
35.00
35.00
.60
.91
.20
.20
parentheses indicate decrease from baseline case.
The profit impact changes significantly from the powder option based on data
presented in Appendix E.
.Decrease less than $.01.
No negative impact on profit margin.
7-100
-------
Table 7-63. PROFIT IMPACT
CHAIR PLANTS - MODIFIED/RECONSTRUCTED FACILITIES
SIP BASELINE
Incremental
Incremental annual ized
annual ized # Chairs control cost
Control control cost9 coated per chair
Plant Option ($000) (000) coateda ($)
B
D
F
G
H
Powder (spray)
Waterborne
70% High solids
Incinerator &
RACT coating
65% High solids
Powder ( spray )b
Waterborne
70% High solids
Incinerator &
RACT coating
65% High solids
Powder (spray)'3
Waterborne
70% High solids
65% High solids
Powder (Fid. Bd.)
El ect rodepos i t i on
Incinerator &
RACT coating
Waterborne (Convent.)
Powder (Fid. Bd.)
Electrodeposition
Incinerator &
RACT coating
Waterborne (Convent.)
715
447
(115)
33
(65)
144
86
(22)
24
(12)
22
18
0
0
853
376
32
37
68
132
.17
8
12,000
12,000
12,000
12,000
12,000
1,182
1,182
1,182
1,182
1,182
136
136
136
136
12,000
12,000
12,000
12,000
1,182
1,182
1,182
1,182
.06
.04
(.01)
e
(.01)
.12
.07
(.02)
.02
(.01)
.16
.13
c
c
.07
.03
e
e
.06
.11
.01
.01
Profit margin impact
F.O.B. price
per chair ($)
35.00
35.00
35.00
35.00
35.00
35.00
35.00
35.00
35.00
35.00
35.00
35.00
35.00
35.00
35.00
35.00
35.00
35.00
35.00
35.00
35.00
35.00
%
.17
.11
d
.01
d
.34
.20
d
.06
d
.46
.37
d
d
.20
.09
.01
.01
.17
.31
.03
.03
7-101
-------
Table 7-63. PROFIT IMPACT
CHAIR PLANTS - MODIFIED/RECONSTRUCTED FACILITIES
SIP BASELINE
(Continued)
Plant
Control
Option
Incremental
annualized
control cost3
($000)
# Chairs
coated
(OOP)
Incremental
annualized
control cost
per chair
coateda ($)
Profit margin impact
F.O.B. price
per chair ($) %
I Powder (Fid. Bo1.) 39
Electrodeposition 40
Waterborne (Convent.) 0
J Waterborne 0
136
136
136
136
.29
.29
c
35.00
35.00
35.00
35.00
.83
.83
d
^Parentheses indicate decrease from baseline case.
b
The profit impact changes significantly from the powder option based on data
presented in Appendix E.
No negative impact on profit margin.
Less than $.01.
7-102
-------
Table 7-64. PROFIT IMPACT
CHAIR PLANTS - MODIFIED/RECONSTRUCTED FACILITIES
UNCONTROLLED BASELINE
Incremental
annual ized # Chairs
Control control costa coated
Plant Option ($000) (000)
B
D
F
G
H
Powder (spray)
Waterborne
70% High solids
Incinerator &
RACT coating
65% High solids
Powder (spray) b
Waterborne
70% High solids
Incinerator &
RACT coating
65% High solids
Powder (spray)
Waterborne
70% High solids
65% High solids
Powder (Fid. Bd.)
Elect rodeposition
Incinerator 8
RACT coating
Waterborne (Convent.)
Powder (Fid. Bd.)
Electrodeposition
Incinerator &
RACT coating
Waterborne (Convent.)
639
371
(135)
12
(85)
129
73
(24)
23
(14)
20
16
(1)
(D
843
366
155
162
71
135
52
29
12,000
12,000
12,000
12,000
12,000
1,182
1,182
1,182
1,182
1,182
136
136
136
136
12,000
12,000
12,000
12,000
1,182
1,182
1,182
1,182
Incremental
annual ized
control cost
per chair
coateda ($)
.05
.03
(.01)
c
(.01)
.11
.06
(.02)
.02
(-01)
.15
.12
(.01)
(.01)
.07
.03
.01
.01
.06
.11
.04
.02
Profit margin impact
F.O.B. price
per chair ($) %
35.00
35.00
35.00
35.00
35.00
35.00
35.00
35.00
35.00
35.00
35.00
35.00
35.00
35.00
35.00
35.00
35.00
35.00
35.00
35.00
35.00
35.00
.14
.09
d
e
d
.31
.17
d
.06
d
.43
.34
d
d
.20
.09
.03
.03
.17
.31
.11
.06
7-103
-------
Table 7-64. PROFIT IMPACT
CHAIR PLANTS - MODIFIED/RECONSTRUCTED FACILITIES
UNCONTROLLED BASELINE
(Continued)
Plant
Control
Option
Incremental
annualized
control cost9
($000)
Incremental
annualized
# Chairs control cost Profit margin impact
per chair F.O.B. price
rnatPda ($) per chair ($) %
coated
(OOP)
I Powder (Fid. Bd.) 38
Electrodeposition 39
Waterborne (Convent.) 10
J Waterborne 10
136
136
136
136
.28
.29
.07
.07
35.00
35.00
35.00
35.00
.80
.83
.20
.20
^Parentheses indicate decrease from baseline case.
The profit impact changes significantly from the powder option based on data
presented in Appendix E.
Uess than $.01.
No negative impact on profit margin.
'Negative impact on profit margins less than .01 percent.
7-104
-------
the 65 percent high solids option, savings are experienced in all but two
situations, in which there is no change in cost from the baseline case.
For any given control option, costs tend to vary inversely with the size of
the plant.
Cost for chair plants. As pointed out earlier, in the case of the
chair plants, separate models have been developed for spray, dip-coating,
and flow-coating operations.
Plants B, D, and F employ the spray-coating method. For Plants B and
D, the most expensive control option is powder, (applied at a film thickness
of 2.5 mil) for which the incremental costs per chair range from $.04 to
$.12. However, based on data presented in Appendix E, the powder option
may produce a savings for Plant D. This is followed by waterborne whose
costs vary from $.03 to $.07 per chair coated. In the case of Plant F, the
most expensive option for new facilities is waterborne ($.12 per chair for
SIP baseline and $.10 per chair for uncontrolled baseline). Among the
three plants, savings are experienced with the 70 percent high solids
option in all but two situations, where there is no change in cost from the
baseline case. For incineration plus RACT coating (does not apply to Plant
F), costs range from a saving in one situation to a maximum of $.02 per
chair. The 65 percent high solids option results in savings in all but two
situations where there is no change in cost from the baseline situation.
Plants G, H, and I employ the dip-coating method. The control options
are conventional waterborne, incinerator plus RACT coating, powder (fluidized
bed), and waterborne with electrodeposition. For Plant G, the most expensive
option is powder (fluidized bed), for which the incremental cost per chair
coated is $.06 for new facilities relative to the SIP baseline, and $.07
for the other three facility/baseline combinations. This is followed by
electrodeposition, the costs of which $.04 per chair in one case, and $.03
in the other three cases. With respect to Plants H and I, the most expensive
control option is electrodeposition. Among these two plants, the cost of
this option ranges from $.07 to $.32 per chair coated. Powder is next,
with costs ranging from $.02 to $.29 per chair. For all three of the
plants, the costs of the conventional waterborne option are relatively low,
ranging from a situation of no change in cost from the baseline to $.07 per
7-105
-------
chair coated. The option involving incineration plus RACT coating has
costs varying from less than $.01 to $.04 (this option does not apply to
Plant I).
In the case of Plant J, which employs dip-coating, the only control
option considered is conventional waterborne. The incremental costs for
this option range from zero to $.07 per chair.
7.4.4.3 Profit Impact. The impact of the control options on model
plant profits was examined using a form of "worst case" analysis which
assumed that the incremental annualized control costs would be fully
absorbed by the plants. Measurement of impact was carried out in two
steps. The first step involved calculating the extent to which the profit
margin on sales for each shelf or chair would be affected by the incremental
control costs. This was done as follows:
Incremental Annualized Control
Cost Per Shelf or Chair
x 100 = Profit Margin Impact Per
F.O.B. Price Per Shelf or Chair She]f Qr Chai>
The data used for this calculation are presented in the third through sixth
columns in Tables 7-57 to 7-64. The F.O.B. price used for shelves is
$25.55; for chairs; $35.00. The impacts, expressed as percentages, are
given in the seventh column in each of the tables. These percentages are
the amounts by which the profit margins for the shelves or chairs would be
reduced if the incremental control costs were fully absorbed, rather than
being passed on to the consumer in the form of a price increases. (Note
that when interpreted differently, this type of calculation can be used to
determine maximum price increase.) It will be noted that in the seventh
column, impact figures are not given for some of the control options. In
these cases, the impact of the option on the profit margin is either posi-
tive because of attendant cost savings or neutral because of there being no
change in cost from the baseline case.
In the second step, the impact on total model plant profits was
determined as follows:
Profit Margin Impact Per Shelf or Chair 10Q = j t Qn Model R1ant
Average Profit Rate on Sales for Industry r Profits
7-106
-------
This calculation was performed for every plant control option combination
exhibiting impairment of profit in the first step above. The profit
rate (on sales) used in the divisor were determined by the industry
group affiliation of the model plant in question. The profit rates were
obtained from the 1978 edition of Annual Statement Studies, published by
Robert Morris Associates. The rates used were as follows: SIC 2514,
5.6 percent; SIC 2522, 4.8 percent; and SIC 2542, 4.3 percent. No rate
for SIC 2531 was available. With the exception of cases involving
Plants A, B, and G, the figures on profit margin impact per shelf or
chair were divided by all three of the profit rates. This is due to the
fact that with the exception of A, B, and G, all of the model plants are
associated with all four of the SIC groups comprising the metal furniture
industry. Plants A, B, and G are associated only with SIC 2522. The
percentage figures resulting from the calculations are indicative of the
extent to which plant profits would be reduced as a result of having to
fully absorb the incremental control costs involved.
The results of the analysis are presented in Tables 7-65 to 7-68.
An impact on a plant was said to be "major" if the impairment to profits
amounted to 15 percent or more. The rationale for determining that a 15
percent reduction in profits constitutes a major impact was established
as follows: A general criterion applicable to the four SIC groups and
the control options involved was established on the basis of the degree
of impact that would lead to a decision not to invest in a new source in
the most marginal of the four SIC groups. After selecting the least
profitable SIC group (as based on the published data), a discounted cash
flow (DCF) analysis was performed to determine what percent increase in
operating costs would cause the investment to be rejected on economic
grounds, when it would otherwise be justified before controls.
The DCF technique estimates and compares cash inflows and outflows
over the life of the project (i.e., new, modified, or reconstructed
metal furniture coating lines). The changing value of money over time
is considered in the comparisons by discounting those cash flows to the
present time. The discount rate used is the firm's cost of capital. If
the present value of the discounted cash outflows, the project is
economically justified.
7-107
-------
Table 7-65. PROFIT IMPAIRMENT
SHELVING PLANTS - NEW FACILITIES
SIP AND UNCONTROLLED BASELINES
% Impairment at
Control
Plant Option
A Powder (spray)3
Waterborne
70% High solids
Incinerator & RACT
coating
65% High solids
C Powder (spray)3
Waterborne
70% High solids
Incinerator & RACT
coating
65% High solids
E Powder (spray)3
Waterborne
70% High solids
65% High solids
SIP baseline
4.3%
b
b
b
b
b
17.20
7.21
c
2.79
c
24.65
18.14
d,
d
4.8%
14.58
5.63
c
0.83
c
15.41
6.46
c
2.50
c
22.08
16.25
d
d
5.6%
b
b
b
b
b
13.21
5.54
c
2.14
c
18.93
13.73
d
d
profit rates below
Uncontrolled baseline
4.3%
b
b
b
b
b
16.28
5.35
c
1.86
c
18.13
11.86
c
c
4.8%
13.95
4.79
c
c
c
14.58
4.79
c
1.67
c
16.25
10.63
c
c
5.6%
b
b
b
b
12.50
4.11
c
1.43
c
13.93
9.11
c
c
3The profit impairment changes significantly for the powder option based on data
.presented in Appendix E.
HProfit rate does not apply to this plant. .
% profit impairment involved. Incremental annualized cost for this control
•option is negative - i.e., there is a decrease in cost from the baseline case.
'llo profit impairment involved. Incremental annualized cost for this control
option is zero - i.e., there is no change in cost from the baseline case.
7-108
-------
Table 7-66. PROFIT IMPAIRMENT
SHELVING PLANTS - MODIFIED/RECONSTRUCTED FACILITIES
SIP AND UNCONTROLLED BASELINES
Control
Plant Option
A Powder (spray)3
Waterborne
70% High solids
Incinerator & RACT
coating
65% High solids
C Powder (spray)3
Waterborne
70% High solids
Incinerator & RACT
coating
65% High solids
E Powder (spray)9
Waterborne
70% High solids
65% High solids
SIP
4.3%
b
b
b
b
b
21.86
7.21
c
2.79
c
44.65
24.65
d
d
% Impairment at
baseline
4.8% 5.6%
17.08 b
6.46 b
c b
0.83 b
c b
19.58 16.79
6.46 5.54
c c
2.50 2.14
c c
40.00 34.29
22.08 18.93
d d
d d
profit rates below
Uncontrolled
4.3% 4.8%
b 15.42
b 4.79
b c
b c
b c
20.00 17.92
6.28 5.63
c c
2.79 2.50
c c
38.14 34.17
18.14 16.25
c c
c c
baseline
5.6%
b
b
b
b
b
15.36
4.82
c
2.14
c
29.29
13.93
c
c
The profit impairment changes significantly for the powder option based on data
.presented in Appendix E.
profit rate does not apply to this plant.
No profit impairment involved. Incremental annualized cost for this control
^option is negative - i.e., there is a decrease in cost from the baseline case.
rJo profit impairment involved. Incremental annualized cost for this control
option is zero - i.e., there is no change in cost from the baseline case.
7-109
-------
Table 7-67. PROFIT IMPAIRMENT
CHAIR PLANTS - NEW FACILITIES
SIP AND UNCONTROLLED BASELINES
— % Impairment at profit rates below
Control
Plant Option
B Powder (spray) a
Waterborne
70% High solids
Incinerator & RACT
coating
65% High solids
D Powder (spray)
Waterborne
70% High solids
Incinerator & RACT
coating
65% High solids
F Powder (spray)
Waterborne
70% High solids
65% High solids
G Powder (fluidized bed)
Electrodeposition
Incinerator & RACT
coati ng
Waterborne (Convent.)
H Powder (fluidized bed)
Electrodeposition
Incinerator & RACT
coating
Waterborne (Convent.)
SIP
4.3%
b
b
b
b
b
6.74
4.65
c
1.40
c
4.65
7.91
d
d
b
b
b
b
1.40
4.65
1.40
0.70
baseline
4.8%
2.92
2.29
c
0.21
c
6.04
4.17
c
1.25
c
4.17
7.08
d
d
3.54
1.88
0.23
0.23
1.25
4.17
1.25
0.63
5.6%
b
b
b
b
b
5.18
3.57
c
1.07
c
3.57
6.07
d
d
b
b
b
b
1..07
3.57
1.07
0.54
Uncontrolled baseline
4.3%
b
b
>b
b
b
6.05
3.95
c
0.70
c
3.95
6.74
c
c
b
b
b
b
3.26
6.74
2.56
2.09
4.8%
2.29
1.88
c
c
c
5.42
3.54
c
0.63
c
3.54
6.04
c
c
4.17
2.29
0.63
0.63
2.92
6.04
2.29
1.88
5.6%
b
b
b
b
b
4.64
3.04
c
0.54
c
3.04
5.18
c
c
b
b
b
b
2.50
5.18
1.96
1.61
7-110
-------
Table 7-67. PROFIT IMPAIRMENT
CHAIR PLANTS - NEW FACILITIES
SIP AND UNCONTROLLED BASELINES
(Continued)
Plant
Control
Option
% Impairment at profit rates below
SIP baseline
4.3% 4.8%
5.6%
Uncontrolled baseline
4.3%
4.1
5.6%
Powder (fluidized bed) 8.60 7.71 6.61
Electrodeposition 16.05 14.38 12.32
Waterborne (Convent.) d d d
Waterborne d d d
13.95
21.16
4.65
4.65
12.50
18.96
4.17
4.17
10.71
16.25
3.57
3.57
The profit impairment changes significantly for the powder option based on data
.presented in Appendix E.
Profit rate does not apply to this plant.
cNo profit impairment involved. Incremental annualized cost for this control
option is negative - i.e., there is a decrease in cost from the baseline case.
dNo profit impairment involved. Incremental annualized cost for this control
option is zero - i.e., there is no change in cost from the baseline case.
7-111
-------
Table 7-68. PROFIT IMPAIRMENT
CHAIR PLANTS - MODIFIED/RECONSTRUCTED FACILITIES
SIP AND UNCONTROLLED BASELINES
% Impairment at
Plant
B
D
F
G
H
Control
Option
Powder (spray)3
Waterborne
70% High solids
Incinerator & RACT
coating
65% High solids
Powder (spray)9
Waterborne
70% High solids
Incinerator & RACT
coating
65% High solids
Powder (spray)3
Waterborne
70% High solids
65% High solids
Powder (fluidized bed)
Electrodeposition
Incinerator & RACT
coating
Waterborne (Convent.)
Powder (fluidized bed)
Electrodeposition
Incinerator & RACT
coating
Waterborne (Convent.)
SIP
4.3%
b
b
b
b
b
7.91
4.65
c
1.40
c
10.70
8.60
d
d
b
b
b
b
3.95
7.21
0.70
0.70
baseline
4.8%
3.54
2.29
c
0.21
c
7.08
4.17
c
1.25
c
9.58
7.71
d
d
4.17
1.88
0.21
0.21
3.54
6.46
0.63
0.63
5.6%
b
b
b
b
b
6.07
3.57
c
1.07
c
8.21
6.61
d
d
b
b
b
b
3.04
5.54
0.54
0.54
profit rates below
Uncontrolled baseline
4.3%
b
b
b
b
b
7.21
3.95
c
1.40
c
10.00
7.91
c
c
b
b
b
b
3.95
7 21
2.56
0.70
4.8%
2.92
1.88
c
0.06
c
6.46
3.54
c
1.25
c
8.96
7.08
c
c
4.17
1.88
0.63
0.63
3.54
6.46
2.29
0.63
5.6%
b
b
b
b
b
5.54
3.04
c
1.07
c
7.68
6.07
c
c
b
b
3.04
5.54
1.96
0.54
7-112
-------
Table 7-68. PROFIT IMPAIRMENT
CHAIR PLANTS - MODIFIED/RECONSTRUCTED FACILITIES
SIP AND UNCONTROLLED BASELINES
(Continued)
Plant
Control
Option
% Impairment at profit rates below"
SIP baseline
4.3% 4.8%
5.6%
Uncontrolled baseline
4.3%
4.8% 5.6%
Powder (fluidized bed) 19.30
Electrodeposition
Waterborne (Convent.)
19.30
d
17.29
17.29
d
14.82
14.82
d
Waterborne
18.60
19.30
4.65
4.65
16.67
17.29
4.17
4.17
14.29
14.82
3.57
3.57
aThe profit impairment changes significantly for the powder option based on data
.presented in Appendix E.
Profit rate does not apply to this plant.
No profit impairment involved. Incremental annualized cost for this control
•option is negative - i.e., there is a decrease in cost from the baseline case.
No profit impairment involved. Incremental annualized cost for this control
option is zero - i.e., there is no change in cost from the baseline case.
7-113
-------
The DCF technique is considered appropriate for decision-making on
a profit maximizing basis, and has the capacity to address all of the
important economic variables involved in such a decision context. It is
recognized that factors other than profit maximization may exert considerable
influence in individual plant investment decision (maintenance or enhancement
of market share is one example); however, such factors are generally not
amenable to objective analysis.
According to Robert Morris Associates (RMA) data, SIC 2522 (metal
office furniture) has the lowest pre-tax profit rate on sales — 5.7 per-
cent — as averaged over the past four years. Based on this profit
rate and other RMA financial ratios for the same SIC group, a DCF analysis
was performed to compare the investment decision before and after the
imposition of pollution control. The analysis indicated that before
controls the investment in a metal furniture coating line would be
justified. However, if a 15 percent profit reduction were to occur
after controls the project would only return the minimum acceptable rate
of return on the investment and therefore be considered in the realm of
indifference. The calculations are shown in Table 7-69.
The table shows the derivation of cash flow estimates before and
after pollution control. The "after" column differences from the "before"
column occur in annualized costs, depreciation, interest, working capital,
and capital (investment) costs, and are all attributable to the control
costs. All the costs are expressed on a per unit chair basis.
The first cash inflow to derive is profit after taxes before and
after control. In the table, revenue remains constant before and after
since it is assumed that control costs will be absorbed. Production
costs and depreciation are subtracted from revenue to obtain profits
before taxes. The higher production cost figure "after" control is
attributable to control costs. The specific figure was derived on a
trial and error basis. The higher "after" depreciation figure was based
on an average (for the control options) of 15 percent of annualized
control costs being comprised of depreciation. The increase in annual
control costs (shown on the table as an increase in production costs) is
$.19. Depreciation is therefore 15 percent of $.19, or $.03.
7-114
-------
Table 7-69. DCF ANALYSIS FOR DETERMINING GENERAL CRITERIA
FOR MAJOR PROFIT IMPAIRMENT
Before
pollution control
After
pollution control
Revenue Per Chair
- Prod, costs
- Depr. (2% of revenue; before control
= Profits before taxes
(5.7% of sales, before control)
- Taxes (46%)
= Profit after taxes
+ Depr.
+ Interest x (1 - tax rate)
= Net cash inflow/year
x Discount factor for 15 years at
10% discount rate
+ Working capital recovery
+ Pollution control investment tax
credit
Net present value of cash inflows
Investment (cash outflow) at 2:1
sales to assets ratio (before
control )
Decision:
$ 25.55
23.58
.51
1.46
.67
.79
.51
.37
1.67
7.7688
12.97
.73
$ 13.70
$ 12.78
Invest
$ 25.55
23.77a'b
.54a'c
1.24
.57
.67
.54a
.39a
1.60
7.7688
12.43
.75a
.05a'e
$ 13.23
$ 13.23a'd
Indifferent
Including pollution control
Increase derived on iterative basis, i.e., trial and error.
Based on control depreciation being an average of 15% of annualized control
costs.
Incremental investment (i.e. difference between $13.23 and $12.78) equals
yearly increase in depreciation at $.03 times 15 years = $.45.
10% times incremental investment cost of $.45.
fTax rate = 46%
Source of Data: Annual Statement Sudies, Robert Morris Associates,
Philadelphia, PA.
7-115
-------
Since the DCF analysis is based on cash flows, the tax savings from
depreciation and the interest on borrowed money must be added to profits
after taxes. The higher "after" control figures for depreciation and
interest are attributable to pollution control.
The next cash inflow figure is on a yearly basis and must be multiplied
by the discount factor for 15 years. The figure is multiplied by 7.7688
years versus 15 years to take into account the reduced value of money over
time represented by the discount factor of 10 percent, which was not derived
but adopted as a reasonable cost of capital. Added to this running cash
flow figure is the present value of the working capital which is initially
invested and then recovered at the end of fifteen years. The $.73 is
derived as 25 percent of the initial investment times the 15-year discount
rate. The higher "after" figure for working capital recovery is that which
is added for control. The last cash inflow is the investment tax credit
attributable to the control capital (investment) cost of 10 percent times
$.45. The $.45 represents the average yearly depreciation of $.03 times 15
years.
The cash outflow line is represented by the initial investment which
on a per unit chair basis is one-half of the revenue. To that must be
added the $.45 investment derived above to reflect the incremental control
capital costs.
The last line of the table indicates a decision to invest before
control since the 13.70 cash inflow exceeds the 12.78 cash outflow. However,
the after control line shows indifference since cash outflows after control
equal the cash inflow. A 15 percent reduction in profits is what provided
the indifference level and is thus adopted as the criterion for major
profitability impact.
As can be seen in Tables 7-65 and 7-66, all shelving plants are subject
to a major profit impairment when powder is applied at a film thickness of
6.35 x I0"3cm (2.5 mil). However, the profit impairment is not significant
(see Appendix E) if powder (spray) is applied at a film thickness of 3.81 x
I0"3cm (1.5 mil). For the waterborne option, Plant E (the smallest) is the
only one subject to major impacts. In the case of the 70 percent high
solids option, none of the plants are subject to major impacts — in fact,
7-116
-------
all of the plants are either favorably impacted or not impacted at all.
The situation is similar for the 65 percent high solids option. For
incineration plus RACT coating (which does not apply to Plant E), the
profit reductions are relatively small. In general, for any given control
option, the magnitude of the impact tends to vary inversely with the size
of the plant. For example, in the case of new facilities relative to the
SIP baseline, the impact of the waterborne option varies (assuming a 4.8 per-
2
cent profit rate) from 16.25 percent for Plant E (45,000m /year coated), to
6.46 percent for Plant C (780,000m2/year coated), to 5.63 percent for Plant
2
A (4,000,000m /year coated). Thus, assuming that two plants of unequal
size employ the same control option, the smaller plant will usually be at a
disadvantage relative to the larger.
Profit impacts for the chair plants are presented in Tables 7-67 and
7-68. Of the seven chair plants, Plant I (small dip-coating plant) is the
only one subject to major impacts. These impacts are associated with the
powder and electrodeposition control options. In the case of powder, the
major impacts are exhibited for modified/reconstructed facilities relative
to both the SIP and uncontrolled baselines, and range in magnitude from
16.67 percent to 19.30 percent. In the case of electrodeposition, major
profit reductions are indicated for both new and modified/reconstructed
facilities, relative to both baselines. The reductions range in value from
16.05 percent to 21.16 percent. Among all of the chair plants, no profit
reduction is associated with the 70 percent and 65 percent high solids
options. For incineration with RACT coating, the largest impact is relatively
minor (only 2.56 percent). In the case of waterborne, the greatest profit
reduction is 8.60 percent. As with the shelving plants, for any given
control option, the severity of profit impairment exhibited among the chair
plants tends to vary inversely with plant size. For instance, in the case
of new facilities relative to the SIP baseline, the impact of the electro-
deposition control option ranges (assuming a 4.8 percent profit rate) from
14.38 percent for Plant I (780,000 m /year coated), to 1.88 percent for
Plant G (4,000 m /year coated).
7.4.4.4 Impact on Capital Availability. The impact of the control
options on the availability of capital was determined in the following way.
7-117
-------
First, annual sales were calculated for each of the ten model plants. This
was done by multiplying the number of shelves or chairs produced per year
by the F.O.B. price - $25.55 for shelves and $35.00 for chairs.
Next, the assets for each of the model plants were derived by utilizing
sales/total assets ratios obtained from the 1978 edition of Annual Statement
Studies, published by Robert Morris Associates. In situations where a
given model plant was said to correspond to more than one SIC group, different
ratios were applied to account for this factor. The ratios used were as
follows: SIC 2514, 2.2; SIC 2522, 1.8; and SIC 2542, 2.5. No ratio was
available for SIC 2531. The asset bases computed by this method are shown
in Table 7-70.
For each model plant, the impact of a given regulatory alternative on
capital availability was determined as follows:
Incremental Capital Cost
of Regulatory Alternative IQQ = j t on Cap1tal Availability
Total Assets
The incremental capital cost for a regulatory alternative is obtained by
subtracting the capital cost for the baseline case from the capital cost
for the alternative. The incremental costs are presented in Tables 7-71
and 7-72.
Results of the analysis are presented in Tables 7-73 and 7-74.
Increases in capital requirements of 10 percent or more were considered to
be major. The rationale for this criterion was established in the following
way. A general criterion applicable to the four SIC groups and the regula-
tory alternatives involved was established on the basis of the increase in
capital requirements that would cause the ratio of cash flow to current
maturities of long-term debt to fall below 2:1. This ratio is viewed by
the banking community as an indicator of the ability of cash flow to cover
debts. As a general rule of thumb, a ratio of 2:1 is considered marginal.
The circumstances of individual cases sometimes warrant that loans be made
when the ratio is less than 2:1; nonetheless, the ratio of 2:1 is an
indication of potential problems.
7-118
-------
Table 7-70. ESTIMATED ASSETS FOR MODEL PLANTS'
Plant
A
B
C
D
E
F
G
H
I
J
Sales
($000)
102,200
420,000
19,929
41,370
1,150
4,760
420,000
41,370
4,760
4,760
SIC 2514
b
b
9,059
18,805
523
2,164
b
18,805
2,164
2,164
Assets ($000)
SIC 2522
56,778
233,333
11,072
22,983
639
2,644
233,333
22,983
2,644
2,644
SIC 2542
b
b
7,972
16,548
460
1,904
b
16,548
1,904
1.904
aSales/total assets ratios used:
SIC 2514: 2.2
SIC 2522: 1.8
SIC 2542 2.5
bPlant is not associated with this SIC group.
7-119
-------
Table 7-71. INCREMENTAL CAPITAL COSTS FOR NEW FACILITIES
($000)
Control
Plant Option
A Powder (spray)
Waterborne
70% High solids
Incinerator & RACT coating
65% High solids
B Powder (spray)
Waterborne
70% High solids
Incinerator & RACT coating
65% High solids
C Powder (spray)
Waterborne
70% High solids
Incinerator & RACT coating
65% High solids
D Powder (spray)
Waterborne
70% High solids
Incinerator & RACT coating
65% High solids
E Powder (spray)
Waterborne
70% High solids
65% High solids
F Powder (spray)
Waterborne
70% High solids
65% High solids
G Powder (fid. bed)
Electrodeposition
Incinerator & RACT coating
Waterborne (convent.)
Increments
SIPa
240
678
0
130
0
417
1,044
0
130
0
83
203
0
110
0
84
208
0
no
0
29
31
0
0
32
67
0
0
(110)
2,416
110
0
relative to:
Uncontrolled
240
678
0
130
0
417
1,044
130
0
83
203
110
0
84
208
0
IT f\
10
0
29
*31
ol
32
en
D/
0
633
3,159
853
743
7-120
-------
Table 7-71. INCREMENTAL CAPITAL COSTS FOR NEW FACILITIES
($000)
(continued)
Control
Plant Option
H Powder (fluidized bed)
Electrodeposition
Incinerator & RACT coating
Waterborne (convent.)
I Powder (fluidized bed)
Electrodeposition
Waterborne (convent.)
J Waterborne
Increments
SIP
(20)
914
110
0
(25)
171
0
0
relative to:
Uncontrolled
127
1,061
257
147
34
230
59
59
aParentheses indicate decrease from baseline case.
7-121
-------
Table 7-72. INCREMENTAL CAPITAL COSTS FOR MODIFIED/RECONSTRUCTED FACILITIES
($000)
Increments relative to:
Plant
Control
Option
SIP
Uncontrolled
Powder (spray)
Waterborne
70% High solids
Incinerator & RACT coating
65% High solids
Powder (spray)
Waterborne
70% High solids
Incinerator & RACT coating
65% High solids
Powder (spray)
Waterborne
70% High solids
Incinerator & RACT coating
65% High solids
Powder (spray)
Waterborne
70% High solids
Incinerator & RACT coating
65% High solids
Powder(spray)
Waterborne
70% High solids
65% High solids
Powder(spray)
Waterborne
70% High solids
65% High solids
Powder (fid.bed)
Electrodeposition
Incinerator & RACT coating
Waterborne (convent.)
750
707
0
130
0
1,325
1,110
0
130
0
250
215
0
110
0
260
222
0
110
0
90
57
0
0
100
72
0
0
1,040
2,626
130
0
750
707
180
310
180
1,325
1,110
300
430
300
250
215
60
170
60
260
222
60
170
60
90
57
5
5
100
72
5
5
1,040
2,626
873
743
7-122
-------
Table 7-72. INCREMENTAL CAPITAL COSTS FOR MODIFIED/RECONSTRUCTED FACILITIES
($000)
(continued)
Plant
Control
Option
Increments relative to:
SIP Uncontrolled
Powder (fluidized bed)
E1ect rodepos i t i on
Incinerator & RACT coating
Waterborne (convent.)
Powder (fluidized bed)
Electrodeposition
Waterborne (convent.)
Waterborne
210
904
110
0
90
211
0
0
210
904
257
147
90
211
59
59
7-123
-------
Table 7-73. CAPITAL AVAILABILITY IMPACT FOR NEW FACILITIES
Control
Plant Option
A Powder (spray)
Waterborne
70% High solids
Incinerator &
RACT coating
65% High solids
B Powder (spray)
Waterborne
70% High solids
Incinerator &
RACT coating
65% High solids
C Powder (spray)
Waterborne
70% High solids
Incinerator &
RACT coating
65% High solids
D Powder (spray)
Waterborne
70% High solids
Incinerator &
RACT coating
65% High solids
E Powder (spray)
Waterborne
70% High solids
65% High solids
F Powder (spray)
Waterborne
70% High solids
65% High solids
G Powder (fid. bed)
Electrodeposition
Incinerator &
RACT coating
Waterborne (convent.)
% Impact
SIP
SIC
2514
a
a
a
a
a
a
a
a
a
a
.92
2.24
b
1.21
b
.45
1.11
b
.58
b
5.54
5.93
b
b ,
1.48
3.10
b
b
a
a
a
a
relative to
baseline
SIC
2522
.42
1.19
b
.23
b
.18
.45
b
.06
b
.75
1.83
b
.99
b
.37
.91
b
.48
b
4.54
4.85
b
b
1.21
2.53
b
b
c
1.04
.05
b
SIC
2542
a
a
a
a
a
a
a
a
a
a
1.04
2.55
b
1.38
b
.51
1.26
b
.66
b
6.30
6.74
b
b
1.68
3.52
b
a
a
a
a
% Impact relative to
uncontrolled baseline
SIC
2514
a
a
a
a
a
a
a
a
a
a
.92
2.24
b
1.21
b
.45
1.11
b
.58
b
5.54
5.93
b
b
1.48
3.10
b
a
a
a
a
SIC
2522
.42
11 n
.1 9
b
.23
b
.18
A C
.45
b
.06
b
.75
1.83
b
.99
b
.37
.91
.48
b
4.54
4.85
b
b
1.21
2.53
k
D
.27
1.35
f\ —j
.37
*"> O
.32
ML
2542
a
a
a
a
a
a
a
a
a
a
1.04
2.55
10 r\
.38
.51
1.26
.66
b
6.30
6.74
1.68
3.52
K
U
a
a
a
a
(continued)
7-124
-------
Table 7-73. CAPITAL AVAILABILITY IMPACT FOR NEW FACILITIES
(continued)
H Powder (fid. bed)
Electrodeposition
Incinerator &
RACT coating
Waterborne (convent.)
I Powder (fid. bed)
Electrodeposition
Waterborne (convent.)
J Waterborne
% Impact relative to
SIP baseline
4.86
.58
3.98
.48
7.90 6.47
5.52
.66
8.98
% Impact relative to
uncontrolled baseline
Plant
Control
Option
SIC
2514
SIC
2522
SIC
2542
SIC
2514
SIC
2522
SIC
2542
.68
5.64
1.37
.78
1.57
10.63
2.73
.55
4.62
1.12
.64
1.29
8.70
2.23
2.73 2.23
.77
6.41
1.55
.89
1.79
12.08
3.10
3.10
^Plant is not associated with this SIC group.
No impact involved - capital cost unchanged from baseline case.
No impact involved - decrease in capital cost from baseline case.
7-125
-------
Table 7-74. CAPITAL AVAILABILITY IMPACT FOR MODIFIED/RECONSTRUCTED FACILITIES
Plant
A
B
C
D
E
F
G
Control
Option
Powder (spray)
Waterborne
70% High solids
Incinerator &
RACT coating
65% High solids
Powder (spray)
Waterborne
70% High solids
Incinerator &
RACT coating
65% High solids
Powder (spray)
Waterborne
70% High solids
Incinerator &
RACT coating
65% High solids
Powder (spray)
Waterborne
70% High solids
Incinerator &
RACT coating
65% High solids
Powder (spray)
Waterborne
70% High solids
65% High solids
Powder (spray)
Waterborne
70% High solids
65% High solids
Powder (fid. bed)
Electrodeposition
Incinerator &
RACT coating
Waterborne (convent.)
% Impact
SIP
SIC
2514
a
a
a
a
a
a
a
a
a
a
2.76
2.37
1.21
b
1.38
1.18
b
.58
b
17.21
10.90
b
b
4.62
3.33
b
b
a
a
a
a
relative to
baseline
SIC
2522
1.32
1.25
b
.23
b
.57
.48
b
.06
b
2.26
1.94
b
.99
b
1.13
.97
b
.48
b
14.08
8.92
b
b
3.78
2.72
b
b
.45
1.13
.06
b
SIC
2542
a
a
a
a
a
a
a
a
a
a
3.14
2.70
b.
1.38
b
1.57
1.34
b
.66
b
19.56
12.39
b
b
5.25
3.78
b
b
a
a
a
a
% Impact relative to
uncontrolled baseline
SIC
2514
a
a
a
a
a
a
a
a
a
a
2.76
2.37
.66
1.88
.66
1.38
1.18
.32
.90
.32
17.21
10.90
.96
.96
4.62
3.33
.23
.23
a
a
a
a
SIC
2522
1.32
1.25
.32
.55
.32
.57
.48
.13
.18
.13
2.26
1.94
.54
1.54
.54
1.13
.97
.26
.74
.26
14.08
8.92
.78
.78
3.78
2.72
.19
.19
.45
1.13
.37
.32
ML
2542
a
a
a
a
a
a
a
a
a
a
3.14
2.70
.76
2.13
.76
1.57
1.34
.36
1.03
.36
19.56
12.39
1.09
1.09
5.25
3.78
.26
.26
a
a
a
a
(continued)
7-126
-------
Table 7-74. CAPITAL AVAILABILITY IMPACT FOR MODIFIED/RECONSTRUCTED FACILITIES
(continued)
% Impact relative to
SIP baseline
Plant
H
I
J
Control
Option
Powder (fid. bed)
Electrodeposition
Incinerator &
RACT coating
Waterborne (convent.)
Powder (fid. bed)
Electrodeposition
Waterborne (convent.)
Waterborne
SIC
2514
1.12
4.81
.58
b
4.16
9.75
b
b
SIC
2522
.91
3.93
.48
b
3.40
7.98
b
b
SIC
2542
1.27
5.46
.66
b
4.73
11.08
b
b
% Impact relative to
uncontrolled baseline
SIC
2514
1.12
4.81
1.37
.78
4.16
9.75
2.73
2.73
SIC
2522
.91
3.43
1.12
.64
3.40
7.98
2.23
2.23
SIC
2542
1.27
5.46
1.55
.89
4.73
11.08
3.10
3.10
^Plant is not associated with this SIC group.
No impact involved - capital cost unchanged from baseline case.
7-127
-------
Table 7-75. CASH FLOW TO CURRENT MATURITIES
OF LONG-TERM DEBT ANALYSIS
Cash Flow From Model Plant of Table 7-69:
Net profits .79
+ Depreciation .51
= Net cash flow 1.30
* 2.2 (pre-control ratio
of cash flow to current
maturities of long-term
debt3 .59
2.0 (ratio
considered as
marginal) .65
.65 - .59
=10% increase
.59
aSource: Annual Statement Studies. Robert
Morris Associates, Phi la., PA.
7-128
-------
For the metal office furniture component (SIC 2522) chosen earlier in
the profit impact assessment as the least profitable of the four SIC groups
involved in this analysis, the Robert Morris Associates data shows the
ratio of cash flow to current maturities of long-term debt as 2.2:1. Table
7-75, which builds upon the discounted cash flow analysis presented in
Table 7-69, shows that a 10 percent increase in the current maturities of
long-term debt would reduce the ratio to 2:1. This percentage change in
capital requirements was chosen as a level of potentially major impact.
A review of the data in Table 7-73 and 7-74 reveals that, in the case
of shelving plants, Plant E is the only one subject to major impact. The
impacts are associated with the waterborne options and if powder is applied
at a film thickness of 6.35 x I0"3cm (2.5 mil). For chairs, Plant I (small
dip-coating plant) is subject to major impact under the electrodeposition
option. Again, the presence of differential impact is apparent. For
example, if Plant I is compared with its larger counterparts, Plant G and
H, it can be seen that the magnitudes of the impacts drop off considerably
with increasing plant size. For the new facility/uncontrolled baseline
combination, the impact of the electrodeposition option on Plant I (under
SIC 2542) is 12.08 percent. The corresponding impact for Plant H (medium)
is 6.41 percent. (The largest dip-coating plant, Plant G, is only associated
with SIC 2522). Thus, as far as the use of electrodeposition is concerned,
Plant I would suffer a disadvantage relative to its larger competitor,
Plant H.
7.4.4.5 Differential Impact Analysis. Based on the results obtained
in the analyses of profit reduction and capital availability, another
analysis was performed to assess differentials in impacts between the
smallest and largest plants producing the same product for each of the
control options. In virtually all cases, for both profit reduction and
capital availability, the impact for the smallest plant is greater than the
impact for the largest plant. In several cases, the differences in impacts
are large. For example, in comparing Plant I (small dip-coating plant)
with Plant G (large dip-coating plant) for the electrodeposition option,
the following types of differences are found for the modified/reconstructed
facilities - SIP baseline combination:
7-129
-------
Profit reduction:
Plant I: 17.29 percent
Plant G: 1.88 percent
Difference 15.41 percent
Capital availability:
Plant I: 7.98 percent
Plant G: 1.13 percent
Difference 6.85 percent
These differences underscore the fact that Plant I is clearly disadvantaged
relative to its larger dip-coating competitors. As pointed out earlier,
Plant I is subject to major profit impacts for powder and electrodeposition,
and major capital availability impacts for electrodeposition. Waterborne
is the only control option available to Plant I which is not connected with
some form of major impact.
7.4.5 Industry Compliance Costs
The preceding discussion has focused upon the impact of the NSPS
regulations at the level of the individual plant. In this section, results
from the plant-level analysis are utilized as a basis for assessing the
potential incremental annualized cost which the metal furniture industry as
a whole may have to bear.
In order to provide an estimate of the range over which industrywide
compliance costs might vary, cost calculations were carried out for four of
the various combinations of control options that might be employed. The
combinations are shown in Table 7-76. For example, under Combination #1,
70 percent high solids would be used for all spray-coating operations
(plant types A-F), waterborne for all dip-coating operations (plant types
G, H, and I), and waterborne, again, for flow-coating operations (plant
type J).
The estimates of the industrywide compliance costs associated with the
four combinations of control options were based upon the projected numbers
of new and replacement coating lines, as presented in Section 7.1.5.3. The
7-130
-------
projections in Section 7.1.5.3 call for the total number of new and
replacement lines to reach 1,963 by the end of the 1980-85 period. This
total is divided between 771 new facilities and 1,192 replacements of
existing facilities.
Based on the discussion in Chapter 6, it was assumed that both the new
and the replacement lines would be distributed on the basis of 85 percent
being spray-coating lines, 10 percent being dip-coating lines, and 5 percent
being flow-coating lines. The estimated numbers of lines in each
coating-method category are as follows:
New Lines Replacement Lines
Spray 655 1,013
Dip 77 119
Flow 39 60
771 1,192
For the numbers of new and replacement lines in the spray-and dip-coating
categories, it was assumed that 25 percent of the lines would be accounted
for by large plants, 50 percent by medium-sized plants, and the remaining
25 percent by small plants. For the flow-coating category, all of the
lines are accounted for by one type of plant of small size (Plant J). This
distribution is given in Table 7-77.
In order to facilitate calculations of cost for coating lines in the
spray-coating category, it was necessary to select three plant types from
among the six spray plants (Plants A-F), as being representative of large,
medium, and small spray-coating operations. It will be recalled that
within the spray-coating category, there are two model plants for each size
classification (A & B, large; C & D, medium; and E & F, small). Cost data
for the pairs of plant types were compared, and the differences were found
to be small enough to permit the use of three plant types as the bases for
the calculating compliance costs for the spray-coating category. The three
plant types chosen were A, D, and E. For the dip-coating category, plant
types G, H, and I were used as the bases for calculating compliance costs
for large, medium, and small operations, respectively. For the flow-coating
category, plant type J was used as the basis for cost calculations.
7-131
-------
OJ
ro
Table 7-76. REPRESENTATIVE COMBINATIONS OF CONTROL OPTIONS
COVERING THE TEN TYPES OF MODEL PLANTS
Plant
type
A
B
C
D
E
F
G
H
I
J
Application
method Size
Spray
Spray
Spray
Spray
Spray
Spray
Dip
Dip
Dip
Flow
Large
Large
Medium
Medium
Small
Small
Large
Medium
Small
Small
rnntml options employed in combinations below
Combination #1
70% High solids
70% High solids
70% High solids
70% High solids
70% High solids
70% High solids
Conventional
waterborne
Conventional
waterborne
Conventional
waterborne
Waterborne
Combination #2
Powder
Powder
Powder
Powder
Powder
Powder
Electrodeposition
Electrodeposition
Electrodeposition
Waterborne
Combination #3
Incinerator &
RACT coating
Incinerator &
RACT coating
Incinerator &
RACT coating
Incinerator &
RACT coating
Waterborne
Waterborne
Conventional
waterborne
Conventional
waterborne
Conventional
waterborne
Waterborne
Combination #4
70% High solids,
powder, & wHerbornea
70% High solids,
powder, & waterbornea
70% High solids,
powder, & waterbornea
70% High solids,
powder, & waterbornea
70% High solids,
powder, & waterborne3
70% High solids,
powder, & waterbornea
Conventional waterborne
Conventional waterborne
Conventional waterborne
Waterborne
aThe three control options are assumed to be equally represented.
-------
Table 7-77. DISTRIBUTION
OF LINES IN COATING-METHOD CATEGORIES
BY SIZE OF PLANT INVOLVED
Coating method
Spray
Dip
Flow
Plant size
Large
Medium
Small
Large
Medium
Smal 1
Small
Number of
New3
164
328
164
19
39
19
39
lines in 1985
Replacement3
253
507
253
30
60
30
60
Due to rounding error, numbers for new spray lines and replacement dip
lines do not add up exactly to 655 and 119, respectively.
7-133
-------
For each of the above plant types (i.e., A, D, E, G, H, I, and J), the
amount of surface area coated annually per line was determined (based on
data obtained from Chapter 5). These figures were then multiplied by the
numbers of lines corresponding to the different coating method/plant size
combinations (as shown in Table 7-77). The results of the calculations are
given in Table 7-78.
The cost data used for extrapolation of the industrywide compliance
costs are given in Tables 7-79 and 7-80, or Tables E-9 and E-10 (see
Appendix E). The incremental costs presented in the tables are per thousand
square meters coated. The data were obtained from Section 7.2. Only
incremental costs relative to the SIP baseline are considered.
To obtain the total compliance costs for the four combinations of
control options, the above costs were multiplied by the corresponding
figures on surface area coated (as given in Table 7-78). The results are
as follows:
From Tables 7-78, From Tables 7-78, E-9,
7-79 and 7-80 and E-10 of Appendix E
Combination #1: ($14.7 million) ($18 million)
Combination #2: $126 million ($1.7 million)
Combination #3: $17.6 million $17 million
Combination #4: $54.8 million $11 million
At $126 million, Combination #2 is by far the most costly of the four, and
exceeds by $26 million the threshold for a Significant Action Analysis (as
articulated in Executive Order 12044). However, this value ($126 million)
is based on powder being applied at 6.35 x 10~3cm (2.5 mil). This value
changes to a savings of nearly $2 million (see Appendix E) if powder is
applied at 3.81 x I0"3cm (1.5 mil). Combination #1 would involve a savings
of nearly $15 million.
The four combinations of control options were compared in terms of
their cost effectiveness, using the emission estimates for the model plants
presented in Chapter 5. For each of the coating method/plant size combina-
tions examined, emissions at the SIP level were calculated and summed to
7-134
-------
Table 7-78. SURFACE AREA
COATED PER YEAR BY PROJECTED
NEW AND REPLACEMENT LINES
Coating method Plant size
Spray Large
Medium
Small
Dip Large
Medium
Small
Flow Small
? i
Surface area coated per year (m x 10 )
New lines
109,333
127,920
7,380
7,600
15,210
855
1,755
270,053
Replacement lines
168,667
197,730
11,385
12,000
23,400
1,350
2,700
417,232
Industrywide total: 687,285,000 m2
7-135
-------
Table 7-79. INCREMENTAL ANNUALIZED CONTROL COST
PER THOUSAND SQUARE METERS COATED
NEW FACILITIES - SIP BASELINE
(in dollars)
Plant
A
D
E
G
H
I
J
70% High
solidsc
(21)
(29)
0
b
b
b
b
Conventional
waterborne
75
106
200
9
10
0
0
n j d
Powder
184
144
267
a
a
a
b
EDP
b
b
b
84
110
733
b
Incinerator &
RACT coating
9
32
b
a
a
b
b
aNot considered for this plant under the four combinations of
.control options being examined.
Control option does not apply to this plant.
^Parentheses indicate savings from baseline.
dThese incremental annualized control costs are based on a film
thickness of 6.35 x lQ-3cm (2.5 mil). However, the incremental
annualized control costs are reduced significantly if powder is
applied at a film thickness of 3.81 x 10-3cm (1.5 mil). This
data is presented in Appendix E.
7-136
-------
Table 7-80. INCREMENTAL ANNUALIZED CONTROL COST
PER THOUSAND SQUARE METERS COATED
MODIFIED/RECONSTRUCTED FACILITIES - SIP BASELINE
(in dollars)
70% High Conventional Incinerator &
Plant solidsc waterborne Powder" EDP RACT coating
A
D
E
G
H
I
J
(22)
(28)
0
b
b
b
b
76
110
267
9
10
0
0
205
185
489
a
a
a
b
b
b
b
94
169
889
b
8
31
b
a
a
b
b
aNot considered for this plant under the four combinations of
•control options being examined.
Control option does not apply to this plant.
^Parentheses indicate savings from baseline.
These incremental annual!zed control costs are based on a film
thickness of 6.35 x lQ-3cm (2.5 mil). However, the incremental
annualized control costs are reduced significantly if powder is
applied at a film thickness of 3.81 x 10-3cm (1.5 mil). This
data is presented in Appendix E.
7-137
-------
yield a total for the projected 1,963 new and replacement lines. Similarlyv
total emissions associated with each of the four combinations of control
options were also calculated. The results are as follows:
Data Chapter 7 Appendix E Data
Combination Total Emissions (kg/year) (kg/year)
SIP level 53,089,870 58,603,389
#1 33,104,807 36,647,286
#2 2,825,595 1,806,853
#3 36,647,988 39,648,887
#4 21,531,082 20,693,304
The reductions in emissions from the SIP level are: 19,985,063 kg/year for
Combination #1; 50,264,275 kg/year for Combination #2; 16,441,882 kg/year
for Combination #3; and 31,558,788 kg/year for Combination #4. When these
figures are divided into the corresponding industrywide incremental annualized
costs, the following incremental costs per kilogram of emission reduction
are obtained:
Chapter 7 Appendix E Data
Combination #1: ($ .74) ($-82)
Combination #2: $2.52 ($.03)
Combination #3: $1.07 $.90
Combination #4: $1.74 $.29
7.5 AGGREGATE ECONOMIC IMPACT ASSESSMENT
The purpose of this section is to analyze the macroeconomic and
socio-economic effects of the proposed NSPS, and to determine whether they
trigger the criteria for a Regulatory (Significant Action) Analysis. These
criteria, as established by Executive Order 12044, are as follows:
• Additional annualized costs of compliance that, including capital
charge (interest and depreciation), will total $100 million (i)
within any one of the first five years of implementation (normally
in the fifth year for NSPS), or (ii) if applicable, within any
7-138
-------
calendar year up to the date by which the law requires attainment
of the relevant pollution standard.
• Total additional cost of production of any major industry product
or service will exceed 5 percent of the selling price of the
product.
• Net national energy consumption will increase by the equivalent
of 25,000 barrels of oil per day.
t Additional annual demand will increase or annual supply will
decrease by more than 3 percent for any of the following materials
by the attainment date, if applicable, or within five years of
implementation: plate steel, tubular steel, stainless steel,
scrap steel, aluminum, copper, manganese, magnesium, zinc, ethylene,
ethylene glycol, liquified petroleum gasses, ammonia, urea,
plastics, synthetic rubber, or pulp.
7.5.1 Industry Structure and Concentration Effects
As shown in Section 7.4, for any given control option, the magnitude
of impacts tends to vary inversely with the size of the plant; i.e., differen-
tial impact is present. Given a situation involving a full pass-through of
costs, the resulting price increases would be smaller for large plants than
for smaller plants. As pointed out in Section 7.4.2, the extent to which a
firm can pass through incremental costs to the consumer is affected in part
by the price elasticity of demand for the firm's product. If the demand
for the firms's product is inelastic, a firm may be able to pass through
incremental costs to the consumer. The extent to which this is possible,
however, would depend upon intra-industry competitive factors. Locational
considerations would be most important in this regard. If the demand for
the firm's product tends to be elastic, the potential for cost pass-through
is reduced. In this latter type of situation, the competitive disadvantage
of small plants relative to large plants would tend to be accentuated.
Over the long run, this increased disadvantage could lead to greater concen-
trations within the industry. Such a trend towards increased concentration
would be encouraged more by some of the control options than by others.
7.5.2 Employment Effects
It is not anticipated that the proposed NSPS will have a major impact
upon employment within the metal furniture industry. At most, the number
7-139
-------
of plants which would be forced to close as a result of the NSPS would be
very small. Also, it is not expected that the standard would result in the
curtailment of new construction in many cases.
7.5.3 Balance of Trade Effects
The proposed NPSP is not expected to have a measurable impact on the
balance of trade. Exports account for only a very small share of the metal
furniture industry's total value of shipments. Moreover, as pointed out in
Section 7.1.4, imports are not an important factor in the metal furniture
market.
7.5.4 Inflationary Impact
The potential inflationary impacts of the control options were determined
as follows:
Incremental Annualized Control Cost Per Shelf or Chair x 1QO
Retail List Price Per Shelf or Chair
The calculation yields the percentage by which retail list price would
increase if the incremental control cost per shelf or chair were wholly
passed on to the consumer. For shelves, a retail list price of $38.33 was
used; for chairs, $52.50. (The derivation of these prices is discussed in
Section 7.4.4.1.) Impacts for the shelving plants are presented in Table 7-81,
and for the chair plants in Table 7-82. The incremental annualized control
costs used in calculating the impacts were obtained from Tables 7-57 to
7-64.
In no case is there a potential increase of more than 5 percent (one
of the criteria in Executive Order 12044 for determination of major economic
impacts).
7.5.5 Energy Impact
Energy consumption estimates for each model plant control option
combination are presented in Chapters 5 and 6 of this document. These
estimates are given in terms of joules. Energy savings resulting from the
use of less solvent are factored in the data.
For the purpose of this analysis, the estimates for each model plant
were reduced to the amount of consumption per line per day. The number of
7-140
-------
days used in the calculation was 365. The data were then converted to
incremental form relative to both SIP and uncontrolled baselines. In turn,
these data, expressed in joules, were converted to equivalent barrels of
crude oil by multiplying each amount by a factor of 1.63 (derived by assuming
1 BTU = 1055 joules, and 1 barrel = 5,800,000 BTU).
The results of this procedure are presented in Tables 7-83 and 7-84.
In the case of the data calculated from the uncontrolled baseline, there
are no situations involving incremental energy consumption. Energy savings
are evidenced in all situations. With regard to the data calculated from
the SIP baseline, the results are mixed. In the case of the high solids
options (70 percent and 65 percent), there is no change in energy consumption
from the baseline. For the conventional waterborne option, however, there
are increments ranging from 0.08 to 0.15 barrel per day. For waterborne
with electrodeposition, incremental consumption ranges from 0.10 to 0.21 barrel
per day. The powder option involves energy savings in all cases. For
thermal incineration with RACT coating, incremental consumption ranges from
0.03 barrel per day to 0.23 barrel per day.
With respect to energy consumption, Executive Order 12044 defines a
major impact as one involving an increase in net energy consumption by the
equivalent of 25,000 barrels of oil per day. To determine whether the NSPS
would result in such an impact, a form of "worst case" analysis was performed.
In the procedure described above, it was determined that the largest incre-
mental consumption of energy would be equivalent to 0.23 barrel of crude
oil per day. In Section 7.1, the total number of affected facilities
(coating lines) was projected to reach 1,963 by the end of the 1980-85
period. If this figure is multiplied by 0.23, the result is an incremental
consumption figure of 451 barrels per day. This is far below the 25,000-barrel
threshold level, and, in reality, the figure would more likely be somewhat
lower, and perhaps even negative. The conclusion is therefore that the
NSPS will not have a major energy impact.
7.5.6 Industrywide Compliance Cost
The subject of industrywide incremental annualized control costs was
presented in Section 7.4.5. Of the four combinations of control options
discussed, Combination #2 (involving powder, electrodepostion, and waterborne)
7-141
-------
Table 7-81. INFLATION IMPACT
SHELVING PLANTSa
Inflation Impact %
Modified/
Control
Plant Option
A Powder (spray)
Waterborne
70% High solids
Incinerator &
RACT coating
65% High solids
C Powder (spray)
Waterborne
70% High solids
Incinerator &
RACT coating
65% High solids
E Powder (spray)
Waterborne
70% High solids
65% High solids
New
SIP
.47
.18
c
.03
c
.50
.21
c
.08
c
.70
.52
c
c
Facilities
Uncontrolled
.44
.16
c
c
c
.47
.16
c
.05
c
.52
.34
c
c
Reconstructed
facilities
SIP Uncontrolled
.55
.21
c
.03
c
.63
.21
c
.08
c
1.28
.70
c
c
^Impacts calculated on the basis of a retail list price of $38.33
The inflation impact changes significantly for the powder (spray)
based on data presented in
°No impact involved.
Appendix
E.
.50
If
6
c
c
C'
.57
T C\
.18
c
.08
c
1.10
.52
c
c
per shelf.
option
7-142
-------
Table 7-82. INFLATION IMPACT
CHAIR PLANTSa
Inflation Impact %
Control
Plant Option
B Powder (spray)
Waterborne
70% High solids
Incinerator &
RACT coating
65% High solids
D Powder (spray)
Waterborne
70% High solids
Incinerator &
RACT coating
65% High solids
F Powder (spray)
Waterborne
70% High solids
65% High solids
G Powder (fluidized bed)
Electrodeposition
Incinerator &
RACT coating
Waterborne (convent.)
New
SIP
.10
.08
c
.01
c
.19
.13
c
.04
c
.13
.23
c
c
.11
.06
.01
.01
Facilities
Uncontrolled
.08
.06
c
c
c
.17
.11
c
.02
c
.11
.19
c
c
.13
.08
.02
.02
Modified/
Reconstructed facilities
SIP
.11
.08
c
.01
c
.23
.13
c
.04
c
.30
.25
c
c
.13
.06
.01
.01
Uncontrolled
.10
.06
c
d
c
.21
.11
c
.04
c
.29
.23
c
c
.13
.06
.03
.03
7-143
-------
Table 7-82. INFLATION IMPACT
CHAIR PLANTS3
(continued)
Inflation Impact %
Modified/
Control
Plant Option
H Powder (fluidized bed)
Electrodeposition
Incinerator &
RACT coating
Waterborne (convent.)
I Powder (fluidized bed)
Electrodeposition
Waterborne (convent.)
J Waterborne
New
SIP
.04
.13
.04
.02
.25
.46
c
c
Facilities
Uncontrolled
.10
.19
.08
.06
.40
.61
.13
.13
Reconstructed
facilities
SIP Uncontrolled
.11
.21
.02
.02
.55
.55
c
c
.11
.21
.08
.04
.53
.55
1 O
. lo
.13
^Impacts calculated on the basis of a retail list price of $52.50 per chair.
bThe inflation impact changes significantly for the powder (spray) option
based on data presented in Appendix E.
SNO impact involved.
QLess than .01%.
7-144
-------
Table 7-83. INCREMENTAL ENERGY USE PER LINE PER DAY SIP BASELINE
I
en
Plant
A
B
C
D
E
F
G
H
I
J
High
Joules'3
0
0
0
0
0
0
d
d
d
d
Solidsa
Barrels
0
0
0
0
0
0
d
d
d
d
Conventional
waterborne
Joules^
.09
.08
.09
.09
.05
.05
0
0
0
0
Barrels
.15
.13
.15
.15
.08
.08
0
0
0
0
Waterborne
with EDP
Joules^
d
d
d
d
d
d
.11
.06
.13
d
Barrels
d
d
d
d
d
d
.18
.10
.21
d
Thermal i
PowderC and RACT
Joulesb
(.27)
(.27)
(.20)
(.20)
(.17)
(.17)
(.27)
(.20)
(.17)
d
Barrels Joulesb
(.44) .10
(.44) .05
(.33) .07
(.33) .07
(.28) d
(.28) d
(.44) .02
(.33) .14
(.28) d
d d
ncinerator
coating
Barrels
16
08
11
11
d
d
.03
.23
d
d
aRefers to both 65% and 70% high solids coatings.
t>Units multiplied by TO™.
cParentheses indicate savings from baseline case.
^Control option does not apply to this plant.
-------
Table 7-84. INCREMENTAL ENERGY USE PER LINE PER DAY UNCONTROLLED BASELINE
Hinh Snlidsa.C
Plant
A
B
C
D
E
F
G
H
I
J
Joulesb Barrels
(.56)
(.56)
(.40)
(.40)
(.37)
(.37)
d
d
d
d
(.91)
(.91)
(.65)
(.65)
(.60)
(.60)
d
d
d
d
Conventional
waterborne0
Joulesb
(.47)
(.47)
(.37)
(.37)
(.31)
(.31)
(.53)
(.39)
(.33)
(.33)
Barrels
(.77)
(.77)
(.60)
(.60)
(.51)
(.51)
(.86)
(.64)
(.54)
(.54)
Water borne
with EDPC
Joulesb
d
d
d
d
d
d
(.42)
(.33)
(.21)
d
Barrels
d
d
d
d
d
d
(.68)
(.54)
(.34)
d
I. i i
Thermal incinerator
Powder0 and RACT coating0
Joulesb
(.83)
(.83)
(.60)
(.60)
(.54)
(.54)
(.80)
(.59)
(.50)
d
Barrels Joulesb
(1.35)
(1.35)
(.98)
(.98)
(.88)
(.88)
(1.30)
(.96)
(.82)
d
(.45)
(.51)
(.33)
(.33)
d
d
(.52)
(.25)
d
d
Barrels
(.73)
(.83)
(.54)
(.54)
d
d
(.85)
(.41)
d
d
^Refers to both 65% and 70% high solids coatings
bunits multiplied by 10™.
cparentheses indicate savings from baseline case.
dControl option does not apply to this plant.
-------
would have a cost exceeding the $100 million threshold for a Significant
Action Analysis. However, this is based on powder (spray) applied at a
film thickness of 6.35 x 10~ cm, (2.5 mil), Combination #2 could result in
a savings of nearly $2 million if powder is applied at 3.81 x 10~3cm (1.5 mil).
Details of these costs are presented in Appendix E.
7-147
-------
REFERENCES FOR CHAPTER 7
1. Steven D. Channer, Executive Director of the Business and
Institutional Furniture Manufacturers Association (BIFMA), meet-
ing with Lynn Fugii and Abigail Mumy, JACA Corp., June 27, 1979.
2. "BIFMA Statistics, year ended December, 1977." Grand Rapids,
Michigan, BIFMA, May 10, 1978.
3. "Market Statistics for November, 1978." Grand Rapids, Michigan,
BIFMA, January 18, 1979.
4. U.S. Exports of Domestic Merchandise, SIC Based, 1977. Department
of Commerce (Washington, D.C.).
5. Predicasts Report 143. Cleveland, Ohio, Predicasts, Inc., September
26, 1977.
6. Wall Street Transcript, P. 52898, December 25, 1979. Household
Furniture Industry: An Economic, Marketing and Financial Study.
Morton Research Corp., Merrick, New York, 1978.
7. Michael Sherman, Director of Economic and Market Research, National
Association of Furniture Manufacturers, meeting with Abigail Mumy,
JACA Corp., July 12, 1979.
8. Oge, M. T. Trip Report—Angel Steel Company, Plainwell, Michigan,
Springborne Laboratories, Enfield, Connecticut. Trip Report 103.
April 5, 1976.
9. "Powder Coating a Good Investment," Proceedings of NPCA Chemical
Coatings Conference, Cincinnati, Ohio. April, 1976.
10. Telecon. Houser, J., TRW Environmental Engineering Division,
Redondo Beach, California, with T. Elliot, Hirt Combustion Engin-
eers. April 10, 1979. Cost and fuel requirements for thermal
incinerators.
11. Telecon. Houser, J., TRW Environmental Engineering Division,
Redondo Beach, California, with R. Gilbert, C-E Air Preheater.
April 10, 1979. Cost and fuel requirements for thermal incin-
erators.
12. Telecon. Houser, J., TRW Environmental Engineering Division,
Redondo Beach, California, with B. Ferraro, John Zink Company.
April 10, 1979. Cost and fuel requirements for thermal inciner-
ators.
7-149
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13. Letter from Wargel, W., George Koch Sons, Inc., Evansville,
Indiana, to A. Nunn, TRW Environmental Engineering Division,
Durham, North Carolina. May 17, 1979. Coating line cost esti-
mate.
14. Letter from Wargel, W., George Koch Sons, Inc., Evansville,
Indiana, to A. Nunn, TRW Environmental Engineering Division,
Durham, North Carolina. June 8, 1979. Electrodeposition
coating line cost estimates.
15. Letter from Freimuth, B., Graco Inc., Franklin Park, Illinois,
to D. Anderson, TRW Environmental Engineering Division, Durham,
North Carolina. May 7, 1979. Coating equipment costs.
16. Letter from Masterson, D., Arvid C. Walberg and Co., Downers
Grove, Illinois, to L. Lawrence, TRW Environmental Engineering
Division, Durham, North Carolina. March 9, 1979. Coating
equipment costs.
17. Nunn, A. B. and D. L. Anderson. Trip Report—Ransburg Electro-
static Equipment, Indianapolis, Indiana, TRW Environmental
Engineering Division, Durham, North Carolina. April 24-25, 1979.
18. Letter from Aronow, A. Sinclair Paints, Los Angeles, California,
to L. Carter, TRW Environmental Engineering Division, Durham, North
Carolina. March 20, 1979. Coating material costs.
19. Telecon. Carter, L., TRW Environmental Engineering Division,
Durham, North Carolina, with J. Spaulding, Chemical Coatings
Corporation, Pico Rivera, California. March 8, 1979. Coating
material costs.
20. Telecon. Carter, L., TRW Environmental Engineering Division,
Durham, North Carolina, with L. Nunamaker, E. I. Dupont, Inc.,
Wilmington, Delaware. March 9, 1979. Coating material costs.
21. Gallagher, V. Trip Report—Blacksmith Shop (Selrite Corpora-
tion), Division of U.S. Furniture Industries, High Point, North
Carolina, U.S. EPA/ESED, Durham, North Carolina. March 8, 1976.
22. Letter from LeBras, L. R. , PPG, Inc., to W. H. Halley, Springborne
Laboratories, Enfield, Connecticut. September 16, 1977. High
solids coatings.
23. Telecon. Halley, W. H., Springborne Laboratories, Enfield,
Connecticut, with B. Kirkpatrick, Lilly Industrial Coatings.
August 26, 1977. High solids coatings.
24. U.S. Department of Commerce. Bureau of the Census. County Business
Patterns, 1976. Washington, D.C. U.S. Government Printing Office.
1978.
7-150
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25. Telecon. Harris, John, Industry and Trade Administration,
U.S. Department of Commerce, with Abigail Mumy, JACA Corp.
July 19, 1979. Demand elasticities for metal furniture.
26. Refer to Table 7-1.
27. Refer to Table 7-3.
28. General Services Administration. Schedule 71, A & B,
Library Furniture - Wood and Metal.
29. "BIFMA Statistics, Third Quarter Ended September 30, 1978 "
Grand Rapids, Michigan, BIFMA, December 8, 1978.
7-151
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APPENDIX A
A.I LITERATURE REVIEW
The literature reviewed for this standard includes previous EPA
in-house reports, EPA-funded contractor reports, published literature, and
reports from industry and other private sources. Specifically, the review
included the following:
Date
August 11-20, 1975
September 26, 1975
April 21-23, 1976
August 23, 1977
August 25, 1977
April 1978
Literature Reviewed
Springborn Laboratories (SL)
conducted an equipment survey
to review coating equipment
contacting manufacturers
by telephone.
Office of Management and Budget
approved the EPA questionnaire
for distribution in the industrial
finishing industry.
SL attended Chemical Coatings
Conference in Cincinnati, Ohio.
SL conducted a telephone survey
with resin suppliers discussing
the present status of high solids
coating for metal furniture.
SL conducted a telephone survey with
resin suppliers discussing present
status of powder coatinqs and
waterborne coatings for metal
furniture.
SL submitted a draft copy of a
Study to Support New Source
Performance Standard for Surface
Coating of Metal Furniture
(EPA-450/3-78-008) to EPA.
A-l
-------
November 25, 1978
January 15, 1979
January-March 1979
February 1979
March 1979
March-May 1979
May 1979
May 1979
June 1979
January-June 1979
October 12, 1979
TRW starts work on converting
EPA-450/3-78-008 into a Background
Information Document (BID).
TRW takes a trip to SL to collect
data base used for writing the draft
of EPA-450/3-79-008.
TRW conducted a telephone survey of
state and local agencies to obtain
regulations and information covering
the surface coating of metal furniture.
TRW received an AEROS computer printout
from EPA covering SIC codes 2514,
2522, 2531, and 2542.
TRW received data contained in computer
printout for metal furniture industries
in Texas. Data obtained from Texas
Air Control Board.
TRW conducted a telephone survey of
equipment vendors and paint suppliers
for cost data.
TRW received cost data for model plant
coating lines from George Koch Sons, Inc.
TRW received cost data for some of the
model plant coating lines from Graco, Inc.
TRW received data from Gordon E. Cole,
GCA, concerning cure volatiles from
powder coatings. Data also contained
powder coating thicknesses that are
achievable on an auto coating line.
TRW reviewed and reduced collected data.
TRW received Sections 7.4 and 7.5 of
the economics chapter from JACA.
A.2 EMISSION SOURCE TESTING
No performance testing was done during the project. This issue was
decided early in the project. It was assumed that all of the VOC's in
coatings are emitted, thereby allowing easy material balance calculations.
Example calculations for VOC emissions are presented in Section 3.3 of the
BID.
A-2
-------
A.3 PLANT AND EQUIPMENT VENDOR VISITS
Plant trips were taken to observe different coating formulations being
applied to metal furniture parts. Trips were taken to observe new types of
equipment vendor application equipment being marketed that allow higher
transfer efficiencies.
Plant, Equipment Vendor, or
Other Related Trips
SL visited Electrostatic Equipment
Corp., to discuss the status of
powder coatings and the ionized
air coating process.
SL visited Nordson Corp. and
Interrad Corp. to discuss the
status of powder coatings and
powder coating equipment.
SL visited Simmons Co., Munster,
Indiana, to observe the electro-
static coating of metal drawers
with high solids coatings.
SL visited Lyon Metal Products,
Inc., Aurora, Illinois, to observe
organic solvent base coating of
metal furniture.
SL visited Virco Manufacturing
Corp., Gardena, California, to
observe powder coating of tubular
furniture. Also, witnessed at
this plant was the operation of a
thermal incinerator on the bake
oven.
SL visited Steel case Company,
Grand Rapids, Michigan, to observe
powder coating of office metal
furniture parts.
SL visited Goodman Brothers Manu-
facturing Company, Philadelphia,
Pennsylvania, to observe powder
coating of metal furniture hospital
beds.
Date
August 18, 1975
August 22, 1975
January 14, 1976
February 3, 1976
February 11, 1979
February 24, 1976
February 25, 1976
A-3
-------
Date
February 25, 1976
March 8, 1976
March 9, 1979
March 23, 1976
April 21-23, 1976
September 26, 1976
January 15, 1979
February 2, 1979
February 2, 1979
Plant, Equipment Vendor, or
Other Related Trips
SL visited Bunting Company,
Philadelphia, Pennsylvania, to
observe powder coating of outdoor
metal furniture.
SL visited U.S. Furniture Industries,
Highpoint, North Carolina, to
observe powder coating of metal
furniture.
SL visited Angel Steel Co., Plainwell,
Michigan, to observe electrodeposition
coating of metal furniture.
SL visited Herman Miller, Inc.,
Zeeland, Michigan, to observe powder
coating of office metal furniture.
SL attended a Chemical Coatings
Conference in Cincinnati, Ohio.
SL visited George Koch & Sons, Inc.,
Evansville, Indiana, to review
available finishing technology.
SL visited other facilities
involved in surface coating.
However, the above list were
the only facilities that are
involved in surface coating of
metal furniture.
TRW visited SL, Enfield, Connecticut,
to obtain the data base for
EPA-450/3-78-006, Draft.
TRW visited EPA, Ohio, to obtain
data for metal furniture facilities
in Ohio.
TRW attended the South Coast Air
Quality Management District meeting
to obtain information covering
proposed regulations for surface
coating of metal furniture.
A-4
-------
Date
March 26-27, 1979
April 18, 1979
April 24-25, 1979
Plant, Equipment Vendor, or
Other Related Trips
TRW visited Steel case, Inc.,
Grand Rapids, Michigan, to obtain
information concerning coating
lines, and various air pollution
control techniques employed at
the plant.
TRW visited Delwood Furniture Corp.,
Irondale, Alabama, to observe water-
borne coating of metal furniture tables.
TRW visited Ransburg Electrostatic
Equipment, Indianapolis, Indiana,
to obtain information for high
solids coatings and electrostatic
spraying equipment.
A.4 MEETINGS WITH INDUSTRY
Date
February 15, 1979
March 1979
January 30, 1980
Meeting
TRW attended meeting with Mr. E. W.
Pete Drum of Ransburg Electrostatic
Equipment to discuss electrostatic
spraying equipment.
TRW attended meeting with Mr. Wayne
Travis of Graco, Inc. to discuss
the costs of electrostatic spraying
equipment.
Meeting with Ron Farrell, Dr. Alexander
Ramig, and K. J. Mclnerney of Glidden
Coatings and Resins to discuss powder
coating costs and technical developments
in the area of powder coatings.
A.5 REPORTS AND REVIEW PROCESS
Date
July 15, 1976
August 23, 1976
Report or Review Process
SL submitted first interim report
on Air Pollution Control Engineering
and Cost Study to EPA.
SL submitted second interim
report on Air Pollution Control
Engineering and Cost Study to
EPA.
A-5
-------
Date
May 19, 1977
June 14, 1977
December 1977
April 1978
April 5-6, 1978
October 10, 1979
March 9, 1979
May 31, 1979
June 18, 1979
July 31, 1979
October 10, 1979
October 31, 1979
Report or Review Process
SL attended a meeting with EPA,
Research Triangle Park, North
Carolina to discuss all surface
coating projects.
SL received authorization from EPA
to continue and complete the study
to support a New Source Performance
Standard (NSPS) for surface coating
of metal furniture.
EPA issued EPA-450/2-77-032 (OAQPS
No. 1.2-086) Control of Volatile
Organic Emissions from Existing
Stationary Sources, Volume III:
Surface Coating of Metal Furniture.
EPA issued EPA-450/3-78-006,
Study to Support New Source Performance
Standards for Surface Coating of Metal
Furniture.
SL and EPA attended a National Air
Pollution Control Techniques Advisory
Committee (NAPCTAC) meeting to
support the proposed standard.
TRW began work on the project.
TRW finalized model plants and
regulatory alternatives.
TRW attended initial meeting with EPA
to obtain concurrence for selected
model plants and regulatory alternatives.
TRW submitted to EPA a complete cost
analysis.
TRW and EPA decide upon basis for
a standard.
TRW received draft copies of
Sections 7.4 and 7.5 from JACA
Corporation.
TRW submitted to EPA draft copies of
the Background Information Document
(BID), and preamble and regulation
for the EPA Working Group mail out.
A-6
-------
Date
December 21, 1979
January 11, 1980
January 29, 1980
February 27, 1980
Report or Review Process
TRW submitted to EPA draft copies of
the Background Information Document (BID),
preamble and regulation for the EPA
Steering Committee mail out.
TRW briefed the EPA Steering Committee
on the proposed NSPS.
TRW submitted to EPA draft copies of
the BID, preamble and regulation for the
NAPCTAC mail out.
TRW gave a NAPCTAC presentation.
A-7
-------
APPENDIX B
INDEX TO ENVIRONMENTAL IMPACT CONSIDERATIONS
Agency Guidelines for
Preparing Regulatory Action
Environmental Impact
Statements 39 FR 37419
Location Within the
Background Information
Document (BID)
1. Statutory basis for proposed
standards
The statutory basis for the
proposed standard is summarized
in Chapter 1.
Relationship to other regulatory The various relationships between
agency actions. the proposed standard and other
regulatory agency actions are
summarized in Chapter 1, Section 1.2.
Industry affected by the
proposed standards.
Specific processes affected
by the standard.
Availability of control
technology
Existing regulations
A discussion of the industries
affected by the standard is pre-
sented in Chapter 2, Section 2.1.
Also, details covering the
"business/economic" nature of the
industry is presented in Chapter 7,
Section 7.1 (and subsections).
The specific processes and facilities
affected by the proposed standard are
described in Chapter 2, Section 2.2.
Model plants for these processes
appear in Chapter 5, Section 5.1
(and subsections).
Information on the availability of
control technology is given in
Chapter 3. The regulatory alternatives
selected from the control technologies
are shown in Chapter 5, Section 5.2
(and subsections).
A discussion of existing regulations
on the industry to be affected by the
standard is included in Chapter 2
Section 2.3.
B-l
-------
Agency Guidelines for
Preparing Regulatory Action
Environmental Impact
Statements 39 FR 37419
2. Alternatives to the proposed
action
Environmental Impacts
Costs
Location Within the
Background Information
Document (BID)
3. Environmental impact of
proposed action
Air Pollution
Water Pollution
Solid Waste Disposal
Energy
4. Economic impact of proposed
action
Environmental effects of not
implementing the standard are
discussed in Chapter 6.
The costs of alternative control
techniques are discussed in
Chapter 7, Sections 7.2, 7.3, and
7.4.
The air pollution impact of the
proposed standard is discussed in
Chapter 6, Section 6.1.
The water pollution impact of the
proposed standard is discussed in
Chapter 6, Section 6.2.
The solid waste disposal impact of
the proposed standard is discussed in
Chapter 6, Section 6.3.
The energy impact of the proposed
standard is discussed in Chapter 6,
Section 6.4.
The economic impact of the proposed
standard on costs is discussed
in Chapter 7.
B-2
-------
APPENDIX C
EMISSION SOURCE TEST DATA
No emission testing was done during this project, It is well
documented in the technical literature that all of the organic volatile
portion of coatings is emitted to the atmosphere. As a result, it is
assumed for emission estimates that material balance calculations for
volatile organic compounds (VOC) are acceptable.
C-l
-------
APPENDIX D. EMISSION MEASUREMENT AND CONTINUOUS MONITORING
D.I EMISSION MEASUREMENT METHODS
A. Emission Testing
No emission measurement tests were conducted by the Environmental
Protection Agency (EPA) for this source category. The volatile organic
compound (VOC) emissions from this coating industry are similar to the
emissions from automobile and light duty truck surface coating opera-
tions as well as other surface coating operations. Several test methods
can be used for measuring VOC emissions from surface coating operations.1
These include:
1. Total Gaseous Non-Methane Organic (TGNMO) Analysis, i.e.,
oxidation/reduction of organics with Flame lonization Detection.
2. Direct Flame lonization Analysis (DFIA).
3. Gas Chromatographic Separation/Flame lonization Detection
(GC/FID).
Table D-l lists advantages and disadvantages of these procedures.
For determination of VOC emissions, the need for identification and
quantification of individual species is not necessary. Therefore,
although useful in some cases, the GC/FID procedure was not considered
as the best approach for measuring VOC emissions from surface coating
operations. The other methods listed above yield a single result with-
out identification of individual species present. The first two methods
listed above were investigated during the study conducted for automobile
and light duty truck surface coating operations. In the TGNMO method,
the sample is manually collected in a sampling train consisting of a
condensate trap and evacuated cylinder. The sampling train is returned
to the laboratory where the entire organic contents of the condensate
D-l
-------
Table D-l. ADVANTAGES AND DISADVANTAGES OF EACH EMISSION MEASUREMENT METHOD
Emission measurement
method
Advantage
Disadvantage
1.
Total Gaseous Nonmethane Organic
(TGNMO)
a
ro
2.
Direct Flame lonization Analysis
(DFIA)
3. Gas Chromatography/Flame
lonization Detector (GC/FID)
A. Has been successfully
employed in determining
compliance by Los Angeles
Air Pollution Control
District.
B. Is considered to be the
most accurate of sampling
methods for measuring
total carbon from sources
of unknown organics.
A. Has also been employed
to determine compliance
with state and local
regulations.
B. Costs less than TGNMO.
A. Identifies individual
species.
A. Most costly.
Not as accurate as
TGNMO for measuring
unknown compounds.
A. Expensive and complex.
-------
trap are oxidized to carbon dioxide, reduced to methane and quantitatively
measured by a Flame lonization Detector (FID). The non-methane organics
collected in the tank (after chromatographic separation from carbon
monoxide, carbon dioxide, and methane) are similarly oxidized to carbon
dioxide, reduced to methane and quantitatively measured by a FID. The
results are reported as total gaseous non-methane organics as carbon
(ppm or mass basis). The advantage of this procedure is that because of
the oxidation/reduction procedure, all organics in the sample are
measured by the FID as methane, consequently, any variation in response
to the FID to different organic species is eliminated.
The DFIA procedure involves directly measuring the effluent stream
with a FID. VOC emission results are yielded in terms of the FID cali-
bration gas (ppm or mass basis). Because FIDs have different response
factors for various organic compounds, the accuracy of the results
depends on the calibration gas chosen and the species of compounds in
the effluent.
During the automotive coating study, a test was conducted on a
gas-fired incinerator controlling the effluent from an automotive bake
2
oven. The results of this test indicated that the concentrations
obtained from the DFIA technique were lower than the concentrations
obtained by the TGNMO procedure; especially at the incinerator outlet.
B. Coatings Testing
Although no metal furniture coatings were tested, the recommended
test procedure based on the results from automotive coatings would be
Method 24, Determination of Volatile Organic Matter, Water Content,
3
Density, Volume Solids, and Weight Solids of Surface Coatings. This
procedure uses ASTM methods to measure the coating density, the mass of
volatile material per mass of coatings, the volume of solid material per
volume of coatings, and the mass of water per mass of coating. The
results from the different methods can be obtained to calculate the mass
of volatile organic material per volume of coating solids as applied.
The cost of analyzing a coating sample in triplicate using this
procedure would be approximately $250.
D-3
-------
Alternatively, the VOC content can be determined from the manufacturer's
formulation data by calculation.
D.2 PERFORMANCE TEST METHODS
A. Emission Testing
Reference Method 25, Determination of Total Gaseous Nonmethane
Organic Emissions as Carbon, is recommended as the performance test
method for concentration measurement. This method is recommended as the
reference test method because the problem of variation in response of a
FID to different organic species is eliminated. This is accomplished by
reducing all organic compounds to methane prior to measurement by the
FID. Since the FID in the reference method measures all the non-methane
organics as methane, all carbon atoms give an equal response. There-
fore, Reference Method 25 is recommended as the performance test method
for industrial surface coating operations since the effluent stream
usually contains a mixture of various unknown organic species.
The recommended procedure for determining the mass of VOC (as
carbon) in the incinerator system vents uses a combination of several
standard methods. EPA Reference Method 1 is used to select the sampling
site; Reference Method 2 measures the volumetric flow rate in the vent;
and Methods 3 and 4 measure the molecular weight and moisture content to
adjust the volumetric flow to dry standard conditions. The VOC concen-
tration in the vent is measured by Reference Method 25. The results
from these methods are combined to give the mass of VOC (as carbon) in
the vent.
Three one-hour runs of Reference Method 25 are recommended for a
complete test, with Reference Methods 2, 3, and 4 being performed at
least twice during that period. Measurements at the inlet, outlet, and
fugitive emission vents should be performed simultaneously. Although
the actual testing time using Reference Method 25 is only 3 hours, the
total time required for one complete performance test is estimated at 8
hours, with an estimated overall cost of $4,000, plus $2,000 for each
fugitive vent measured. During the performance test, the process should
be operating normally. Because this is a short-term test, the enforce-
ment agency should consider the solvents and coatings being used and the
products being produced to ensure representativeness.
D-4
-------
B. Coating Analysis
Reference Method 24 is recommended as the reference method for
measuring the volatile content of metal furniture coatings.
D.3 MONITORING SYSTEMS AND DEVICES
The purpose of monitoring is to ensure that the emission control
system is being properly operated and maintained after the performance
test. One can either directly monitor the regulated pollutant, or
instead, monitor an operational parameter of the emission control
system. The aim is to select a relatively inexpensive and simple method
which will indicate that the facility is in continual compliance with
the standard.
For solvent recovery systems, the recommended monitoring test is
identical to the performance test. A solvent inventory record is main-
tained, and the control efficiency is calculated every month. Excluding
reporting costs, this monitoring procedure should not incur any additional
costs for the affected facility, because these process data are normally
recorded anyway, and the liquid meters were already installed for the
earlier performance test.
For incinerators, two monitoring approaches were considered:
(1) directly monitoring the VOC content of the inlet, outlet, and fugitive
vents so that the monitoring test would be similar to the performance
test; and (2) monitoring the operating temperature of the incinerator as
an indicator of compliance. The first alternative would require at
least two continuous hydrocarbon monitors with recorders, (about $4,000
each), and frequent calibration and maintenance. Instead, it is
recommended that a record be kept of the incinerator temperature. The
temperature level for indication of compliance should be related to the
average temperature measured during the performance test. The averaging
time for the temperature for monitoring purposes should be related to
the time period for the performance test, in this case 3 hours. Since a
temperature monitor is usually included as a standard feature for
incinerators, it is expected that this monitoring requirement will not
incur additional costs for the plant. The cost of purchasing and
installing an accurate temperature measurement device and recorder is
estimated at $1,000.
D-5
-------
REFERENCES FOR APPENDIX D
1 Guideline Series - Measurement of Volatile Organic Compounds.
Emission Measurement Branch, Emission Standards and Engineering
Division. EPA-450/2-78-041, OAQPS No. 1.2-115. EPA, Research
Triangle Park, North Carolina. October 1978.
2. Emission Test Report: Ford Motor Company, Pico Riveria, California,
ESED Report Number 78-ISC-l.
3. Determination of Volatile Organic Matter, Water Content, Density,
Volume Solids, and Weight Solids of Surface Coatings. Draft,
Emission Measurement Branch, Emission Standards and Engineering
Division, EPA, Research Triangle Park, North Carolina.
D-7
-------
APPENDIX E - REVISIONS TO ECONOMIC DATA
This appendix addresses issues concerning the technical content of
tha background ii. formation document (BID) for the surface coating of
metal furniture. The following issues have been raised by industry
representati ves:
1. For all calculations the powder film thicknesses can range from
81 >
1-6
2.03 to 3.81 x 10"3 cm (0.8 to 1.5 mil) instead of 6.35 x 10"3 cm
(2.5 mil).
2. New cost data for powder coatings were submitted by industry.
3. Other cost data and film thicknesses were submitted by industry
136
for other low organic solvent coatings (e.g., high solids and waterborne). ' '
4. The impact of solid waste generated from different low solvent
coatings was questioned by industry.
5. The industry expressed concern that spray booth ventilation
rates could decrease as solvent levels of RACT coatings are decreased.
These are the major issues concerning the quality of the BID. Each
issue is addressed separately in the following sections.
E.I ADDITIONAL COSTS AND ECONOMIC ANALYSIS
E.I.I Cost Analysis
This section covers Issues 1-3. Although Table E-l is similar to
Table 7-21 in the BID, the cost data contained in Table E-l have been
changed based upon data received from an industry representative. The
selected base year for cost calculations both in the BID and in this
appendix is 1978. The film coating thicknesses have also been changed
as shown below:
E-l
-------
Table E-l. MODEL PLANT ANNUAL CONTROL COST FACTORS
Operating
Electricity
Natural gas
Paint:
Conventional solvent-borne (35% solids)
High solids (60% to 70% solids)
60/40 Waterborne
80/20 Waterborne
Powder
Labor
Capital recovery factor assumptions
(Equipment life and interest rate):
Coating line equipment
Building
Add-on control equipment
Taxes, insurance, and G&A
Maintenance labor
Maintenance material
Overhead
2000 h/yr
$0.08/107 J ($0.03/KWh)
$1.89/109 J ($2.00/106 Btu)
$1.85/liter ($7.00/gallon)
$2.80/liter ($10.75/gallon)
$1.98/liter ($7.50/gallon)
$2.10/liter ($8.00/gallon)
$3.53/kg ($1.60/lb)
$6.70/manhour
15 years 10% interest
25 years at 10% interest
10 years at 10% interest
4% of total installed cost
10% of direct labor
1.5% of equipment cost
80% of direct labor cost
E-2
-------
Low organic Film thickness..
solvent coatings cm (mil)
Powder 3.81 x 10-3 ,, CA
(1.5)
High solids (60-70 percent solids) 3.05 x 10~3 (1.2)
Waterborne Unchanged
In addition, high solids coatings are applied at transfer efficiencies
as high or higher than are solvent-borne coatings. These transfer
efficiencies are based en -'^forraatien obtained *rc^> ~.r. V :!•.•; A-y representative.1
As a result of tha changes in film thickness and transfer efficiencies,
the emission estimates for powder and high solids coatings are not the
same for spray coating lines (Chapter 5). However, emission estimates
for only three of the Model Plants (A, D and E) are shown in this
appendix. This is because only three spray coating lines were employed
in Chapter 7 to determine total fifth-year annualized costs. The emission
estimates are shown in Table E-2.
Tables E-3 through E-10 show the results of these calculations for
Model Plants A, D, E, G, H, and I. The costs only changed for Model
Plants A, D and E.
E.I.2 Economic Analysis
The total fifth-year annualized costs for three regulatory alternatives
are listed below:
Total
annualized
Regulatory costs (savings),
alternatives Combination $ millions
11 1 (18)
IV 2 (1.7)
II 3 17
III 4 11
The regulatory alternatives and combinations are defined in Chapters 5 and
7, respectively, of the BID.
Based upon the analysis of the cost data, all of the low organic
solvent coatings are competitive. The maximum inflationary impact, as
discussed in Chapter 7, would still occur if Plant E applied powder
E-3
-------
Table E-2. EMISSION ESTIMATES FOR MODEL PLANTS
A, D AND E
Model
plant
Control
option
Emission
estimate
(kilograms)
Uncontrolled
SIPs (60% solids)
65% solids
SIPs + incineration
70% solids
Waterborne
Powder
Uncontrolled
SIPs (60% solids)
65% solids
SIPs + incineration
70% solids
Waterborne
Powder
Uncontrolled
SIPs (60% solids)
65% solids
70% solids
Waterborne
Powder
195,362
84,148
67,966
58,904
54,095
38,000
1,981
49,814
21,458
17,144
15,001
13,715
9,700
386
2,197
947
767
606
420
22
E-4
-------
Table E-3. CONTROL COSTS FOR MODEL PLANT A - LARGE SPRAY COATING
FACILITY FOR FLAT METAL FURNITURE SURFACES
A-l A-2
Control options
A-3 A-4 A-5 A-6
A-U
INSTALLED CAPITAL COSTS ($1000's)
Line(s)
Add-on control equipment
Building
Total capital costs
Annualized capital costs
Insurance, taxes, and G&A
Total annualized capital costs
OPERATING COSTS C$1000's/yr)
Direct labor
Maintenance labor
Overhead
Maintenance materials
Paint
Electricity
Natural gas
Total operating costs
$1810 $2041 $1570 $1570 $1570 $1570 $1570
2063
J8/3
444
155
b99
600
60
480
'£1
775
69
34
2270
4311
495
172
667
600
60
480
31
760
84
45
2063
3633
413
145
558
600
60
480
24
610
69
45
1JU
2063
3763
433
151
584
600
60
480
26
711
69
49
2063
3633
413
145
558
600
60
480
24
656
69
45
2063
3633
413
145
558
600
60
480
24
711
69
45
2063
3633
413
145
558
600
60
480
24
671
73
67
2045 2060 1888 1995 193T 1989
TOTAL ANNUALIZED COSTS ($1000's/yr) 2644 2727 2446 2579 2492 2547 2533
Cost (credit) per kilogram of emis-
sion reduction versus uncontrolled
Plant 0.6 1.2 (0.6) 0.3 (0.3) 0.1 N/Ab
Cost (credit) per kilogram of emis-
sion reduction versus base case 1.2 3.9 (3.4) 1.3 (3.4) N/A N/A
Cost per area covered
($/1000 m2)
661 682 612 645 623 637 633
aA-l
A-2
A-3
A-4
A-5
A-6
A-U
bN/A
Powder
Waterborne
70 percent high solids
Incinerator on base case
65 percent high solids
Base case—typical SIP
Uncontrolled plant.
Not applicable
line(s)
E-5
-------
Table E-4. CONTROL COSTS FOR MODEL PLANT D - MEDIUM-SIZED SPRAY
COATING FACILITY FOR COMPLEX METAL FURNITURE SURFACES
D-l D-2
Control options
D-3 D-4 D-5 D-6
D-U
INSTALLED CAPITAL COSTS ($1000's)
Line(s)
Add-on control equipment
Building
Total capital costjL
Annualized capital costs
Insurance, taxes, and G&A
Total annualized capital costs
OPERATING COSTS ($1000's/yr)
Direct labor
Maintenance labor
Overhead
Maintenance materials
Paint
Electricity
Natural gas
Total operating costs
$644 $728 $560 $560 $560 $560 $560
— 110
402 552 402 402 402 402 402
1046 1170 "962" 1072 962 962 962
125 140 114 131 114 114 114
42 47 38 43 38 38 38
TB7 187 152" T7T TBT 152" T5T
150
15
120
10
95
9
8
150
15
120
11
198
10
11
150
15
120
8
158
9
11
150
15
120
10
185
9
12
150
15
120
8
171
9
11
150
15
120
8
185
9
11
L _ "I '
150
15
120
8
175
9
16
•- ' _
407 515 471 501 484 4"98 493
TOTAL ANNUALIZED COSTS ($1000/yr) 574 702 623 675 636 650 645
Cost (credit) per kilogram of emis-
sion reduction versus uncontrolled
plant
(1.4) 1.4 (0.6) 0.9 (0.3) 0.2 N/Ab
Cost (credit) per kilogram of emis-
sion reduction versus base case (3.6) 4.4 (3.5) 3.9 (3.3) N/A N/A
Cost per area covered
($/1000 m2)
736 900 799 865 815 833 827
Vi
D-2
D-3
D-4
D-5
D-6
D-U
bN/A
Powder
Waterborne
70 percent high solids
Incinerator on base case
65 percent high solids
Base case— typical SIP
Uncontrolled plant
Not applicable
line(s)
E-6
-------
Table E-5. CONTROL COSTS FOR MODEL PLANT E - SMALL SPRAY COATING
FACILITY FOR FLAT METAL FURNITURE SURFACES
E-l
Control options
E-2 E-3 E-4 E-5
OPERATING COSTS ($1000's/yr)
Direct labor
Maintenance labor
Overhead
Maintenance materials
Paint
Electricity
Natural gas
Total operating costs
92 97 93 93 96
Cost (credit) per kilogram of emis-
sion reduction versus uncontrolled
plant
E-U
INSTALLED CAPITAL COSTS ($1000' s)
Line(s)
Add-on control equipment
Building
Total capital costs
Annuali zed capital costs
Insurance, taxes, and G&A
Total annual i zed capital costs
$225
23
"248
32
10
42
$225
25
250
32
11
~43~
$196
23
219
28
9
37
$196
23
219
28
9
37
$196
23
219
28
9
37
$196
23
219
28
9
37
40
4
32
3
5
4
4
40
4
32
4
7
5
5
40
4
32
3
7
4
5
40
4
32
3
7
4
5
40
4
32
3
8
4
5
40
4
32
3
8
4
7
Cost per area covered
($/1000 m2)
98
TOTAL ANNUALIZED COSTS ($1000's/yr) 134 140 130 130 133 135
(0.5) 2.8 (3.1) (3.5) (1.6) N/Afc
Cost (credit) per kilogram of emis-
sion reduction versus base case 1.1 13.3 (8.8)(16.7) N/A N/A
2978 3111 2889 2889 2956 3000
E-l Powder
E-2 Waterborne
E-3 70 percent high solids
E-4 65 percent high solids
E-5 Base case—typical SIP
E-U Uncontrolled plant
3N/A Not applicable
E-7
-------
Table E- 6. PLANT A - CONTROL COSTS FOR MODIFICATION OR
RECONSTRUCTION OF SIP LEVEL FACILITIES
A-l
Control options
A-2 A-3 A-4
A-5
INSTALLED CAPITAL COSTS ($1000' s)
Line(s)
Add-on control equipment
Building
Total capital costs
Annual ized capital costs
Insurance, taxes, and G&A
Total annual ized capital costs
OPERATING COSTS (SAVINGS) ($1000' s)
Direct labor
Maintenance labor
Overhead
Maintenance materials
Paint
Electricity
Natural gas
Total operating costs
TOTAL ANNUALIZED COSTS (SAVINGS) ($1000'
Cost (savings) per area covered
($71000 m2)
aA-l Powder
A-2 Waterborne
A-3 70 percent high solids
A-4 Incinerator on base line(s)
A- 5 65 percent high solids.
$750
0
0
75B
99
30
125
0
0
0
11
64
0
<§§*
s) 182
46
$500
0
207
707
87
28
ITS
0
0
0
8
167
15
0
T50
305
76
0
0
0
0
0
0
B
0
0
0
0
$(101)
0
0
Tiory
(101)
(25)
0
$130
0
13U
20
5
25
0
0
0
2
0
0
5
7
30
8
0
0
0
0
0
0
U
0
0
0
0
$(55)
0
0
TB3T
(55)
(14)
E-8
-------
Table E-7. PLANT D - CONTROL COSTS FOR MODIFICATION OR
RECONSTRUCTION OF SIP LEVEL FACILITIES
Control options3
D-l D-2 D-3 D-4 D-5
INSTALLED CAPITAL COSTS ($1000' s)
Line(s)
Add-on control equipment
Building
Total capital costs
Annual i zed capital costs
Insurance, taxes, and G&A
Total annual ized capital costs
OPERATING COSTS (SAVINGS) ($1000 's)
Direct labor
Maintenance labor
Overhead
Maintenance materials
Paint
Electricity
Natural gas
Total operating costs
$260
0
0
260
34
10
44
0
0
0
4
(90)
0
(5)
T9TT
$182
0
40
222
28
9
37
0
0
0
3
44
2
0
49
0
0
0
0
0
0
0
0
o
0
o
$(27)
o
0
7277
0
$110
o
\J
no
±^\j
17
•L /
4
21
n
\j
n
\J
n
V
2
C.
0
o
V
1
3
0
0
n
\J
n
\j
n
\J
o
\J
n
w
n
\j
n
u
o
\j
o
$(14)
n
\j
o
7T4T
TOTAL ANNUALIZED COSTS (SAVINGS) ($1000's) (47) 86 (27) 24 (14)
Cost (savings) per area covered
($71000 m5) (60) HO (35) 31 (18)
D-l Powder
D-2 Waterborne
D-3 70 percent high solids
D-4 Incinerator on base case line(s)
D-5 65 percent high solids.
E-9
-------
Table E-8. PLANT E - CONTROL COSTS FOR MODIFICATION OR
RECONSTRUCTION OF SIP LEVEL FACILITIES
Control options
E-l E-2 E-3 E-4
INSTALLED CAPITAL COST ($1000' s)
Line(s)
Add-on control equipment
Building
Total capital costs
Annual ized capital costs
Insurance, taxes, and G&A
Total annual ized capital costs
OPERATING COSTS (SAVINGS) ($1000' s)
Direct labor
Maintenance labor
Overhead
Maintenance materials
Paint
Electricity
Natural gas
Total operating costs
TOTAL ANNUALIZED COSTS (SAVINGS) ($1000'
Cost (savings) per area covered
($71000 m2)
$90
0
0
90
11
4
15
0
0
0
1
(3)
0
(2)
T4T
s) 11
244
$55
0
2
57
7
2
9
0
0
0
1
1
1
0
3
12
267
0
0
0
0
0
0
0
0
0
0
0
$(1)
0
0
TIT
(i)
(22)
0
0
0
0
0
0
0
0
0
0
0
$(1)
0
0
TIT
(1)
(22)
E-l Powder
E-2 Waterborne
E-3 70 percent high solids
E-4 65 percent high solids.
E-10
-------
m
Table E-9. INCREMENTAL ANNUALIZED CONTROL COST (SAVINGS) PER THOUSAND SQUARE METERS
COATED AT NEW FACILITIES - SIP BASELINE
($1000's)
Plant
A
D
E
G
H
I
J
70%
High solids
$(25)
(34)
(67)
b
b
b
b
Conventional
waterborne
$45
67
155
9
10
0
0
Powder
$24
(97)
22
a
a
a
b
EDP
b
b
b
$84
110
733
b
Incinerator & RACT coating
$8
32
b
a
a
b
b
aNot considered for this plant under the three combinations of control options being examined.
Regulatory alternative does not apply to this plant.
cParentheses indicate savings from baseline.
-------
Table E-10. INCREMENTAL ANNUALIZED CONTROL COST PER THOUSAND SQUARE METERS
COATED AT MODIFIED/RECONSTRUCTED FACILITIES - SIP BASELINE
($1000's)
ro
Plant
A
D
E
G
H
I
J
70%
High solids
$(25)
(35)
(22)
b
b
b
b
Conventional
waterborne
$76
110
267
9
10
0
0
Powder
46
(60)
244
a
a
a
b
EDP
b
b
b
$94
169
889
b
Incinerator & KACT coating
$8
31
b
a
a
b
b
aNot considered for this plant under the three combinations of control options being examined.
bRegulatory alternative does not apply to this plant.
cParentheses indicate savings from baseline.
-------
Table E-ll. PROFIT IMPACT
MODEL PLANTS A, D AND E - NEW FACILITIES
SIP BASELINE
Control
Plant option
A Powder (spray)
(shelves) Waterborne
70% High solids
Incinerator &
RACT coating
65% High solids
D Powder (spray)
(chairs) Waterborne
70% High solids
Incinerator &
RACT coating
65% High solids
E Powder (spray)
(shelves) Waterborne
70% High solids
65% High solids
Incremental
annual i zed
control cost
($000)
97
180
(101)
32
(55)
(76)
52
(27)
25
(14)
1
7
(3)
(3)
# Shelves
coated
(000)
4000
4000
4000
4000
4000
780
780
780
780
780
45
45
45
45
Incremental
annual i zed
control cost
per shelf
coated3 ($)
.024
.045
(.02)
.008
(.014)
(-097)
.067
(.035)
.032
(.018)
.022
.156
(.067)
(.067)
Profit margin impacts
F.O.B. price
per shelf ($)
25.55
25.55
25.55
25.55
25.55
35.00
35.00
35.00
35.00
35.00
25.55
25.55
25.55
25.55
$
.09
.18
b
.03
b
b
.19
b
.09
b
.09
.61
b
b
?Parentheses indicated decrease from baseline case.
^lo negative impact on profit margin.
E-13
-------
Table E-12. PROFIT IMPACT
MODEL PLANTS A, D AND E - NEW FACILITIES
UNCONTROLLED BASELINE
Incremental
Plant
A
(shelves)
D
(chairs)
E
(shelves)
Incremental
annual i zed
Control control cost
option ($000)
Powder (spray)
Waterborne
70% High solids
Incinerator &
RACT coating
65% High solids
Powder (spray)
Waterborne
70% High solids
Incinerator &
RACT coating
65% High solids
Powder (spray)
Waterborne
70% High solids
65% High solids
111
194
(87)
46
(41)
(71)
57
(22)
30
( 9)
( D
5
ill
# Shelves
coated
(000)
4000
4000
4000
4000
4000
780
780
780
780
780
45
45
45
45
annual i zed
control cost Profit margin impact
per shelf F.O.B. price
coated3 ($) per shelf ($) %
.028
.049
(.022)
.012
(.010)
(.091)
.073
(.028)
.038
(.012)
(.022)
.111
(.111)
(.111)
25.55
25.55
25.55
25.55
25.55
35.00
35.00
35.00
35.00
35.00
25.55
25.55
25.55
25.55
.11
.20
b
.05
b
b
.21
b
.11
b
b
.43
b
b
"Parentheses indicate decrease from baseline case.
bHo negative impact on profit margin.
E-14
-------
Table E-13. PROFIT IMPACT
MODEL PLANTS A, D AND E - MODIFIED/RECONSTRUCTED FACILITIES
SIP BASELINE
Incremental
annuali zed
Control control cost
Plant option ($000)
A Powder (spray)
(shelves) Waterborne
70% High solids
Incinerator &
RACT coating
65% High solids
D Powder (spray)
(chairs) Waterborne
70% High solids
Incinerator &
RACT coating
65% High solids
E Powder (spray)
(shelves) Waterborne
70% High solids
65% High solids
182
305
(101)
30
(55)
(47)
86
(27)
24
(14)
11
12
( D
( 1)
1 Shelves
coated
(000)
4000
4000
4000
4000
4000
780
780
780
780
780
45
45
45
45
Incremental
annualized
control cost
per shelf
coated3 ($)
.046
.08
(.025)
.01
(.014)
(.060)
.110
(.02)
.031
(.018)
.24
.27
(.022)
(.022)
Profit marqin
F.O.B. price
per shelf ($)
25.55
25.55
25.55
25.55
25.55
35.00
35.00
35.00
35.00
35.00
25.55
25.55
25.55
25.55
impact
%
.18
31
• tJl
h
V
b
b
V)
• J£
K
\J
no
• \jy
b
.96
1 Ofi
A * W
K
u
b
^Parentheses indicate decrease from baseline case.
"Mo negative impact on profit margin.
E-15
-------
Table E-14. PROFIT IMPAIRMENT
MODEL PLANTS A, D AND E - NEW FACILITIES
SIP AND UNCONTROLLED BASELINES
Plant
A
(shelves)
D
(chairs)
E
(shelves)
Control
option
Powder (spray)
Waterborne
70% high solids
Incinerator & RACT
coating
65% high solids
Powder (spray)
Waterborne
70% high solids
Incinerator & RACT
coating
65% high solids
Powder (spray)
Waterborne
70% high solids
65% high solids
SIP
4.3%
a
a
a
a
a
b
4.42
b
2.09
b
2.09
14.19
b
b
% Imp
base!
4.8%
1.88
3./b
b
0.63
b
b
3.96
b
1.88
b
1.88
12.71
b
b
lairment at
me
5.6%
a
a
a
a
a
b
3.39
b
1.61
b
1.61
10.89
b
b
profit rates below
Uncontrol
4.3%
a
a
a
a
a
b
4.88
b
2.56
b
b
10.00
b
led base
4.8%
2.29
.17
1.04
b
4.38
2.29
b
8.96
b
line
5.6%
a
a
a
a
a
b
3.75
1.96
b
7.68
aProfit rate does not apply to this plant.
bNo profit impairment involved. Incremental annualized cost for this
control option is negative - i.e., there is a decrease in cost from
the baseline case.
E-16
-------
Table E-15. PROFIT IMPAIRMENT
MODEL PLANTS A, D AND E - MODIFIED/RECONSTRUCTED FACILITIES
SIP BASELINE
m -.«4-
r lant
A
(shelves)
D
(chairs)
E
(shelves)
a-K — ^T
-Profit rate
Mrt t-i»rt/^^^ -I- -J
•"
Control
option
Powder (spray)
Waterborne
70% high solids
Incinerator & RACT
coating
65% high solids
Powder (spray)
Waterborne
70% high solids
Incinerator & RACT
coating
65% high solids
Powder (spray)
Waterborne
70% high solids
65% high solids
does not apply to
% Impairment at
Sli
4.3%
a
a
a
a
a
b
7.44
b
2.09
b
22.33
24.65
b
b
this plant.
profit
P base!
4.8%
3.75
6.46
b
0.83
b
b
6.67
b
1.88
b
20.00
22.08
b
b
rates below
me
5.6%
a
a
a
a
a
b
5.71
b
1.61
b
17.14
18.93
b
b
No profit impairment involved. Incremental annual 1 zed cost for this control
option is negative - i.e., there is a decrease in cost from the baseline case,
E-17
-------
Table E-16. INFLATION IMPACT
FOR MODEL PLANTS A, D AND E
Inflation Impact %
Plant
A
(shelves)
D
(chairs)
E
(shelves)
Control
option
Powder (spray)
Waterborne
70% high solids
Incinerator &
RACT coating
65% high solids
Powder (spray)
Waterborne
70% high solids
Incinerator &
RACT coating
65% high solids
Powder (spray)
Waterborne
70% high solids
65% high solids
New
SIP
.06
.12
b
.02
b
b
.13
b
.06
b
.06
.41
b
b
Facilities
Uncontrolled
.07
.13
b
.03
b
b
.14
b
.07
b
b
.29
b
b
Modified/
Reconstructed
facilities
SIP
.12
.21
b
.03
b
b
.21
b
.06
b
.63
.70
b
b
Impacts calculated on the basis of retail list price of $38.33 per
bshelf, and $52.50 per chair.
No impacts involved.
E-18
-------
coatings at a thickness of 6.35 x 10"3 cm (2.5 mil). The worst-case impact
for Plant E is about 1.3 percent. However, if the coating thickness is
_2
changed to 3.81 x 10 cm (1.5 mil), the worst-case impact for Plant E is
the waterborne control option, Unde^ this control option, the wholesale
pi-ice increases by about 0.70 percent. Tables E-ll through E-16 show
additional information for profit impact, profit impairment, and inflation
impact employing the Different film thicknesses arid transfer efficiency
values. The only control option to change significantly is the powder
option, in a!"! cases for powder the -impacts indicated significant
improvement over Chapter 7 information.
E.2 SOLID WASTE DATA
This section covers Issue 4. Data reported in Table 6-7 of the BID
have been questioned by an industry representative. However, the
variability of the data presented in Table 6-7 is due to the assumed
transfer efficiencies for solvent-borne, high solids, and waterborne
coatings and to the powder utilization efficiencies and film thickness.
Regardless of how the transfer efficiencies are changed, the conclusion
of the solid waste impact reported in Chapter 6 remains unchanged.
E.3 SPRAY BOOTH VENTILATION RATES
Another industry representative has questioned calculated application
exhaust flow rates in areas that apply high solids and waterborne coatings,
stating that these flow rates are fixed by OSHA regulations.7 However,
as shown in the following excerpt, this OSHA regulation allows a range of
flow rates, and the second part of the regulation allows reduction of
flow rates because of quantity of "solids and nonflammables contained in
the finish":
"(6) Velocity and air flow requirements.
(i) Except where a spray booth has an adequate air replacement
system, the velocity of air into all openings of a spray booth shall
be not less than that specified in Table G-10 for the operating
conditions specified. An adequate air replacement system is one
which introduces replacement air upstream or above the object
being sprayed and is so designed that the velocity of air in
the booth cross section is not less than that specified in
Table G-10 when measured upstream or above the object being
sprayed.
E-19
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Table G-10—Minimum Maintained Velocities Into Spray Booths
Operating conditions for
objects completely inside
booth
Cross draft, f.p.m.
Air flow velocities, f.p.m.
Design
Range
Electrostatic and automatic Negligible.
airless operating con-
tained in booth without
operator.
Air-operated guns, manual or Up to 50.
automatic
, 50 large booth... 50-250
100 small booth... 75-125
100 large booth... 75-125
150 small booth... 125-175
Air-operated guns, manual or Up to 100 150 large booth... 125-175
automatic 200 small booth... 150-250
Notes:
(1) Attention is invited to the fact that the effectiveness of the spray
booth is dependent upon the relationship of the depth of the booth to its
height and width.
(2) Crossdrafts can be eliminated through proper design and such design
should be sought. Crossdrafts in excess of 100 fpm (feet per minute) should
not be permitted.
(3) Excessive air pressures result in loss of both efficiency and material
waste in addition to creating a backlash that may carry overspray and fumes
into adjacent work areas.
(4) Booths should be designed with velocities shown in the column headed
"Design". However, booths operating with velocities shown in the column
headed "Range" are in compliance with this standard.
(ii) In addition to the requirements in subdivision (i) of
this subparagraph the total air volume exhausted through a spray
booth shall be such as to dilute solvent vapor to at least
25 percent of the lower explosive limit of the solvent being
sprayed. An example of the method of calculating this volume is
given below . . . ."Note that the quantity of solvent will be
diminished by the quantity of solids and nonflammables contained
in the finish.
"To determine the volume of air in cubic feet necessary to
dilute the vapor from 1 gallon of solvent to 25 percent of the
lower explosive limit, apply the following formula:
E-20
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n., .. , 4(100-LEL)(cubic feet of vapor per gallon)
Dilution volume required per = -
gallon of solvent
Using toluene as the solvent.
(1) LEL of toluene ... is 1.4 percent.
(2) Cubic feet of vapor per gallon ... is 30.4 cubic feet per gallon
(3) Dilution volume required =
4 (100-1.4) 30.4 n „, .. . ^ „
5-4 8,564 cubic feet."
The reduced exhaust flow rates from the coating application area are
also supported by coating line designers contacted during the development
of the BID.
E-21
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REFERENCES FOR APPENDIX E
1. Ramig, Alexander. Rebuttal presentation concerning industrial surface
coating of metal furniture. Glidden Coatings and Resins Division.
Strongsville, Ohio. NAPCTAC meeting. Raleigh, North Carolina.
February 27, 1980.
2. Lissy, Gus. Rebuttal presentation concerning industrial surface
coating of metal furniture. Nordson Company. Amherst, Ohio. NAPCTAC
meeting. Raleigh, North Carolina. February 27, 1980.
3. Letter from Cole, G. E. , Dr., GCA Associates, Greenwich, Connecticut,
to D. R. Goodwin, U.S. Environmental Protection Agency, Research
Triangle Park, North Carolina. January 18, 1980. Draft - Surface
Coating of Metal Furniture - Background Information for Proposed
Standards.
4. Letter from Cole, G. E., Dr., GCA Associates, Greenwich, Connecticut,
to J. R. Farmer, U.S. Environmental Protection Agency, Research Triangle
Park, North Carolina. February 23, 1980. Concerning changes made to
the BID.
5. Letter from Rothschild, M. V., Reliance Powder Products, Inc., Tinley
Park, Illinois, to D. R. Goodwin, U.S. Environmental Protection Agency,
Research Triangle Park, North Carolina. February 26, 1980. Concerning
the draft BID.
6. Letter from Scattoloni, T. J., Armstrong Products Company, Warsaw,
Indiana, to D. R. Goodwin, U.S. Environmental Protection Agency,
Research Triangle Park, North Carolina. March 4, 1980. Concerning
the draft BID.
7. Speir, C. Rebuttal presentation concerning industrial surface coating
of metal furniture. Lyon Metal Products, Inc. Aurora, Illinois.
NAPCTAC meeting. Raleigh, North Carolina. February 27, 1980.
8. Occupational Safety and Health Administration. 29 CFR 1910.94.
Washington, D.C. U.S. Government Printing Office. 1979.
E-22
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO.
EPA-450/3-80-007a
4. TITLE AND SUBTITLE
Surface Coating of Metal Furniture - Background
Information for Proposed Standards
3. RECIPIENT'S ACCESSION NO.
5. REPORT DATE
1 QRf)
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Office of Air Quality Planning and Standards
U.S. Environmental Protection Agency
Research Triangle Park, NC 27711
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
DAA for Air Quality Planning and Standards
Office of Air, Noise, and Radiation
U.S. Environmental Protection Agency
Research Triangle Park, NC 27711
13. TYPE OF REPORT AND PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
EPA 200/04
15. SUPPLEMENTARY NOTES
Standards of performance to control emissions of volatile organic compounds
(VOC) from new, modified, and reconstructed metal furniture surface coating
facilities are being proposed under Section 111 of the Clean Air Act. This
document contains information on the background and authority, regulatory
alternatives considered, and environmental and economic impacts of the regulatory
alternatives.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS
COSATl Field/Group
Air Pollution
Metal Furniture
Pollution Control
Standards of Performance
Surface Coating Operations
Volatile Organic Compounds (VOC)
Air Pollution Control
13B
"EMEf
Unlimited
19. SECURITY CLASS (This Report)
Unclassified
21. NO. OF PAGES
20. SECURITY CLASS (This page)
Unclassified
22. PRICE
EPA Form 2220-1 (Rev. 4-77) PREVIOUS EDITION is OBSOLETE
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U.S. Environmental Protection Agency
Regwn 5.Library JPH» -_
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