&EPA
United States Office of Air Quality
Environmental Protection Planning and Standards
Agency Research Triangle Park NC 27711
Air
EPA-453/R-00-004 I/
September 1998
Preliminary Industry Characterization
Wood Building Products
Surface Coating
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EPA-453/R-00-004
Preliminary Industry Characterization:
Wood Building Products Surface Coating
Prepared by:
Midwest Research Institute
Crossroads Corporate Park
5520 Dillard Road, Suite 100
Gary, NC 27511-9232
^~ Prepared for:
<$- U. S. Environmental Protection Agency
^- Coatings and Consumer Products Group
-^ Emission Standards Division
Office of Air Quality Planning and Standards
Research Triangle Park, NC 27711
September 1998
U.S. Environmental Protection Agency
Jegien 5, Library (PL-12J)
West Jackson Boulevard, 12th Ffcfc*
IL 60604-3590
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TABLE OF CONTENTS
EXECUTIVE SUMMARY v
1.0 OVERVIEW OF INITIAL MACT DEVELOPMENT PHASE FOR THE WOOD ... 1-1
2.0 SUMMARY OF INITIAL MACT DEVELOPMENT PROCESS 2-1
2.1 Roundtable Meetings 2-1
2.2 Site Visits 2-2
2.3 Information Collection Request 2-3
3.0 WOOD BUILDING PRODUCTS SURFACE COATING SOURCE CATEGORY . . 3-1
3.1 Industry Profile : 3-1
3.2 Summary of Existing State/Federal Requirements 3-2
3.3 Applicability 3-4
3.4 Wood Building Products Coating Processes 3-7
3.4.1 Interior Paneling 3-12
3.4.2 Exterior Siding 3-13
3.4.3 Doors and Door Skins : 3-15
3.4.4 Tileboard 3-17
3.4.5 Flooring 3-17
3.4.6 Window Frames and Joinery 3-17
3.4.7 Shutters 3-17
3.4.8 Moulding and Trim 3-17
3.5 Emissions 3-18
3.6 Emission Control Techniques 3-20
4.0 NEXT STEPS IN THE MACT DEVELOPMENT PROCESS 4-1
Appendix A. List of Stakeholders and Regulatory Subgroup
Appendix B. List of Hazardous Air Pollutants
Appendix C. Glossary
in
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LIST OF FIGURES . .-
Pag.
Figure 3-1. Simplified curtain and roll coater diagrams 3-10
Figure 3-2. Simplified flow, vacuum, and pneumatic coater diagrams 3-11
Figure 3-3. Generic coating line schematic for prefinished interior lauan plywood paneling 3-14
Figure 3-4. Generic coating line schematic for prefinished doors 3-16
Figure 3-5. Generic coating line schematic for prefinished woodgrain mouldings 3-19
LIST OF TABLES
Page
TABLE 2-1. SITE VISITS TO WOOD BUILDING PRODUCTS SURFACE COATING
FACILITIES 2-3
TABLE 3-1. SIC CODES REPRESENTING THE WOOD BUILDING PRODUCTS
INDUSTRY 3-2
TABLE 3-2. WOOD BUILDING PRODUCTS FACILITIES BY STATE
TABLE 3-3. RECOMMENDED MACT LIMITS FROM THE CTG FOR THE
FACTORY SURFACE COATING OF FLATWOOD PANELING 3-4
TABLE 3-4. STATE REGULATIONS FOR THE SURFACE COATING OF WOOD
BUILDING PRODUCTS 3-5
TABLE 3-5. PRIMARY HAP EMITTED BY THE WOOD BUILDING PRODUCTS
INDUSTRY 3-2!
TABLE 3-6. PRIMARY VOC EMITTED BY THE WOOD BUILDING PRODUCTS
INDUSTRY 3-22
TABLE 3-7. HAP EMISSIONS BY SIC CODE 3-22
TABLE A-l. INDUSTRY STAKEHOLDERS A-l
TABLE A-2. REGULATORY SUBGROUP A-2
IV
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EXECUTIVE SUMMARY . ,-
Under Section 112(d) of the Clean Air Act (CAA), the U. S. Environmental Protection
Agency (EPA) is developing national emission standards for hazardous air pollutants (NESHAP)
for the wood building products surface coating source category. The EPA is required to publish
final emission standards for the wood building products surface coating source category by
November 15, 2000. For this source category, a national volatile organic compound (VOC) rule
or control technique guidelines (CTG) may also be developed under Section 183(e) of the CAA.
There is a possibility that case-by-case maximum achievable control technology (MACT)
determinations will be required under Section 112 (g) for newly constructed and/or reconstructed
major sources. The information summarized in this document is intended to provide preliminary
information that can be used by States that may have to make case-by-case MACT
determinations under Sections 112(g) or 112(j) of the CAA.
Section 1 of this document gives an overview of the initial MACT development phase for
this source category. Section 2 summarizes the issues raised and information gathering
techniques used in this process. A preliminary characterization of the wood building products
source category is given in Section 3. Section 3 also focuses on the source category's products,
types of coatings used, application methods, emissions, and emission control techniques.
Section 4 addresses recommendations for next steps in the MACT development process.
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1.0 OVERVIEW OF INITIAL MACT DEVELOPMENT PHASE
FOR THE WOOD BUILDING PRODUCTS
SURFACE COATING SOURCE CATEGORY
Under Section 112(d) of the Clean Air Act (CAA), the U. S. Environmental Protection
Agency (EPA) is developing national emission standards for hazardous air pollutants (NESHAP)
for the wood building products surface coating source category. The EPA is required to publish
final emission standards for the wood building products surface coating source category by
November 15, 2000. For this source category, a national volatile organic compound (VOC) rule
or control technique guidelines (CTG) may also be developed under Section 183(e) of the CAA
The CAA requires that the emission standards for new sources be no less stringent than
the emission control achieved in practice by the best controlled similar source. For existing
sources, the emission control can be less stringent than the emission control for new sources, but
it must'b,e no less stringent than the average emission limitation achieved by best performing
12 percent of existing sources (for which the EPA has emissions information). In categories or
subcategories with fewer than 30 sources, emission control for existing sources must be no les.-
stringent than the average emission limitation achieved by the best performing 5 sources The
NESHAP are commonly known as maximum achievable control technology (MACT) standard -
The MACT standards development for the wood building products surface coating
industry began with a Coating Regulations Workshop for representatives of EPA and interested
stakeholders in April 1997 and continues as a coordinated effort to promote consistency and jo:;••
resolution of issues common across nine coating source categories.1 The first phase was one in
1 The workshop covered eight categories: fabric printing, coating and dyeing; large
appliances; metal can; metal coil; metal furniture; miscellaneous metal parts; plastic parts: ami
wood building products. The automobile and light duty truck surface coating project was started
subsequently.
1-1
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which EPA gathered readily available information about the industry with the help of
representatives from the regulated industry, State and local air pollution agencies, small business
assistance providers, and environmental groups. The goals of the first phase were to either fully
or partially:
1. Understand the coating processes;
2. Identify typical emission points and the relative emissions from each;
3. Identify the range(s) of emission reduction techniques and their effectiveness;
4. Make an initial determination of the scope of each category;
5. Determine the relationships and overlaps among the source categories;
6. Locate as many facilities as possible, particularly major sources;
7. Identify and involve representatives from each industry segment;
8. Complete informational site visits;
9. Identify issues and data needs and develop a plan for addressing them;
10. Develop questionnaire(s) for additional data gathering; and
11. Document results of the first phase of regulatory development for each source
category.
The associations that participated in the stakeholder process were American Plywood
Association (APA), Composite Panel Association (CPA), National Wood Window and Do6r
Association (NWWDA), Hardwood Plywood and Veneer Association (HPVA), American Forest
and Paper Association (AFPA), National Wood Flooring Association (NWFA), National Oak
Flooring Association (NOFA), Architectural Woodworking Institute (AWI), American
Hardboard Association (AHA), Manufactured Housing Institute (MHI), Wood Moulding and
Millwork Producers Association (WMMPA), Laminating Materials Association (LMA),
Adhesives and Sealants Council, National Paint and Coatings Association (NPCA), and the
Chemical Manufacturers Association (CMA) Solvents Council. The States that participated in
the process were Florida, Oklahoma, Oregon, and Washington. Appendix A contains a complete
list of participants.
The information summarized in this document is intended to provide preliminary
information that can be used by States that may have to make case-by-case MACT
determinations under Sections 112(g) or 112(j) of the CAA. The initial phase of the regulatory
1-2
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development focused primarily on the characterization of the wood building products industn .
coating application methods, types, and emissions. This document summarizes that phase of rule
development.
This document includes a description of the emission control technologies EPA identified
that are currently used in practice by the industry and that could serve as the basis of MACT.
Within the short time-frame allotted for this initial phase, however, only limited data were
collected. The information summarized in this document was collected prior to July 15, 199b
Additional information will be collected and considered before the wood building products
standards are promulgated.
During the next phase, EPA will continue to build on the knowledge gained to date and
proceed with more focused investigation and data analyses. We will also continue our efforts u
coordinate cross-cutting issues. We will continue to identify technical and policy issues that
need to be addressed in the rule making and enlist the help of the stakeholders in resolving those
issues.
1-3
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2.0 SUMMARY OF INITIAL MACT DEVELOPMENT PROCESS
2.1 ROUNDTABLE MEETINGS
The first phase of development of the NESHAP for Wood Building Products Surface
Coating began on April 8 and 9, 1997 with a workshop held by the Coatings and Consumer
Products Group (CCPG) of the Emission Standards Division (ESD) in Research Triangle Park,
North Carolina. The workshop presented information on the standards development process. As
part of the workshop, EPA held breakout sessions with representatives of each of the eight source
categories that the CCPG plans to regulate, including one for the wood building products source
category.
At this workshop and subsequent roundtable meeting a number of industry stakeholders
were identified. Appendix A contains a list of industry stakeholder or regulatory groups that
have attended roundtable meetings.
During the April 8 and 9, 1997 meeting EPA and stakeholders identified and discussed
four major issues:
1. Potential for overlap with the wood furniture, paper and other web coating, printing
and publishing, and particleboard/plywood manufacturing NESHAP.
2. Overlap with other non-EPA standards/requirements (OSHA requirements and wood
product certification requirements). The OSHA issue is based on industry concerns that as
capture efficiency requirements are tightened, worker exposure issues under OSHA may come
into play. Less air flow means that workers may be exposed to higher concentrations of
chemicals. Many of the products manufactured by the industry are subject to requirements
related to fire and weather resistance. Changing the coatings these facilities use can have an
impact on their wood product certification requirements for resistance to fire and weather.
3. The group developed a preliminary list of trade associations that should be involved in
the standards development process. Included on this list are the following associations:
2-1
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American Plywood Association (APA), National Particleboard Association (NPA), American
Forest and Paper Association (AFPA), National Paint and Coatings Association (NPCA).
Hardwood Plywood and Veneer Association (HPVA).
4. The group also raised three issues directly related to rule development. These
included economic impact (for example, the combined impact on one facility of multiple
standards), flexibility, and recordkeeping.
At the June 5,1997, roundtable, the EPA gave a presentation on the MACT partnership
approach, potential definitions for wood building products surface coating MACT, information
collected to date on the wood building products industry, additional data needed by the EPA to
develop PMACT and MACT, and potential mechanisms for collecting the data. Major issues
raised at the June 5 meeting were: the applicability of the wood building products surface coating
MACT standard and the identification of other potential stakeholders.
A regulatory subgroup meeting was held on June 10,1997. The discussion focused on
the role of the regulatory subgroup, issues raised in stakeholder meetings, and how the regulator-
subgroup could assist in data gathering activities. At this meeting, several States offered to help
set up site visits and gather permit information.
A second industry roundtable meeting was held on August 12,1997. The primary
purpose of the meeting was to present draft definitions to the stakeholders for comment. Otlv
discussion items included future data collection activities, such as site visits and an information
collection request (ICR) for the industry that will be used to establish the MACT floor
The next meeting was held on May 20, 1998 to discuss stakeholders comments on the
draft wood building products ICR and list of recipients. A major issue raised at this stakeholder
meeting was the addition of a group of small businesses questionnaire recipients.
2.2 SITE VISITS
The EPA representatives participated in multiple site visits to wood building products
surface coating facilities to collect information on the industry. These visits focused on
collecting general facility information and information on the finishing processes, emission
sources, and the types of coatings used. As of June 1998, visits have been made to 11 facilities
The principal products and type of coating applicator or operation of each facility visited arc
given in Table 2-1.
2-2
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TABLE 2-1.. SITE VISITS TO WOOD BUILDING PRODUCTS SURFACE
COATING FACILITIES
Product
Coating supplier
Hardboard siding
Laminate flooring
Miscellaneous wood products
Prefmished doors, millwork, and mouldings
Prefmished doors and mouldings
Prefinished door and window trim
Prefinished doors, windows, and
miscellaneous wood products
Prefinished interior wall paneling
Prefinished medium density fiberboard
mouldings
Primed cementitious and cedar siding
Coating methods
N/A
DRC, RRC, curtain coater
DRC (adhesive)
DRC, HVLP, airless spray guns
AAA, airless spray guns, spraybooths
HVLP, airless spray guns, dip tank,
spraybooths
Flow coaters, rotogravure cylinder
HVLP, spraybooths
AAA, DRC, airless spray guns, rotogravure
cylinder
Flow coaters
Flood coater
DRC = Direct roll coater
RRC = Reverse roll coater
HVLP = High volume low pressure spray gun
AAA = Air assisted airless spray gun
Future site visits will be made to a manufactured home production (manufacturing)
facility that performs on-site surface coating of wood building products and to facilities using
ultra-violet (UV) and electron beam (EB) coating/curing technologies for coating wood building
products. *
2.3 INFORMATION COLLECTION REQUEST
On May 20, 1998, a roundtable meeting was held among interested parties to obtain
feedback on a recent CCPG decision to look at alternative ways to collect the information needed
for regulatory development. The census approach would involve more than 1,500 ICR mail-outs
and responses with all the associated effort and logistical problems involving confidential
business information (CBI) and incomplete responses. For information-gathering purposes, the
CCPG elected to divide the wood building products industry into five industry segments based
2-3
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on primary products (manufactured home; millwork, panel and reconstituted wood products;
windows and doors; architectural/specialty millwork and miscellaneous; and small businesses
The fifth segment designated as "small business" facilities was added in an attempt to
receive additional/representative input from small businesses across the industry. Additional
steps may be taken to analyze this regulation's effect on small businesses. A draft of the ICR
survey and a list of possible industry recipients of each segment was circulated to the
stakeholders for comment.
Of the current listing of more than 1,500 companies/facilities that comprise the wood
building products industry, nine parent companies in each of the five segments were selected to
receive the ICR. Location of the companies, number of employees, reported TRI emissions, and
number of facilities were considered in obtaining a representative cross-section of each of the
segments. Approximately 300 facilities will be surveyed from only 45 ICR mailings (each parent
company is to send the ICR to each of its facilities that performs wood building products coating
operations).
On June 12, 1998, the Agency distributed the questionnaires to the five segments of the
wood building products industry to gather general facility information, as well as information on
the coating operations, coating types, HAP emissions, and emission controls employed. Data
obtained in response to these questionnaires will be used in the development of MACT for this
source category.
To date, the EPA, with assistance from State regulatory agencies, has collected
background information for the wood building products surface coating source category from the
Aerometric Information Retrieval System (AIRS), Source Test Information Retrieval System
(STIRS), and Toxic Chemical Release Inventory (TRI) data bases; the Census of Manufactures,
and State regulations and permit information. The gathered information is summarized in thus
document and will be used for the development of MACT. Additional information will be
collected and considered before emission standards for wood building products surface coating
operations are proposed.
2-4
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3.0 WOOD BUILDING PRODUCTS SURFACE COATING
SOURCE CATEGORY
3.1 INDUSTRY PROFILE
The wood building products coating source category includes facilities engaged in the
surface coating of flooring, shingles, awnings, doors, mantels, shutters, mouldings
hardwood/softwood plywood panels, arches, trusses, manufactured homes, hardboard,
particleboard, reconstituted wood panels, wall tile, wallboard, and cementitious board. These
facilities apply a protective, decorative, or functional layer (i.e., paints, stains, sealers, topcoats,
basecoats, primers, enamels, inks, laminates) to the wooden substrate before final sale to
distributors. The original source category designation was "surface coating of flatwood
paneling." After meetings with industry stakeholders, the EPA learned that interior paneling
products are no longer manufactured in large quantities in the United States and that there are
other wood surface coating operations with HAP emissions that are not addressed in current or
future regulations. Therefore, the EPA decided to revise the scope to cover the surface coating of
wood building products.
Table 3-1 lists the SIC codes that include facilities manufacturing wood building
products, the SIC code descriptions, and the total number of facilities included in each SIC code
based on the 1992 Census of Manufactures. Each SIC code includes facilities which do not have
surface coating operations and only manufacture the substrate (e.g., particleboard or plywood).
The census does not distinguish between manufacturers of unfinished and prefmished substrate.
The listed SIC codes also include manufacturers of other products that are not considered wood
building products. Many facilities in Table 3-1 will not be covered under this standard; however,
the SIC codes and census data do serve as starting points for conducting analyses of potentially
3-1
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TABLE 3-1. SIC CODES REPRESENTING THE WOOD BUILDING
PRODUCTS INDUSTRY2
SIC Code
2426
2429
2431
2435
2436
2439
2451
2452
2493
Description
Hardwood dimension and flooring
mills
Special product sawmills, NEC
Millwork
Hardwood veneer and plywood
Softwood veneer and plywood
Structural wood members, NEC
Mobile homes
Prefabricated wood buildings and
components
Reconstituted wood products
Representative products
Hardwood and parquet flooring
Wood shingles
Awnings, doors, garage doors,
mantels, shutters, mouldings
Hardwood plywood panels,
prefinished hardwood plywood
Softwood plywood panels
Arches, trusses
Mobile buildings, classrooms,
homes
Prefabricated floors, panels for
prefabricated buildings
Hardboard, particleboard,
reconstituted wood panels, wall
tile, wallboard
Total facilities
&2i
192
3,155
31 S |
201
895
2SO
655
285
Some SIC codes include facilities that do not perform surface coating operations and facilities that do
manufacture wood building products or are not major sources of HAP.
noi
affected sources. In addition, not all of the facilities in these SIC codes are major sources of
HAP.
Wood building products manufacturing facilities are located throughout the country The
States with the largest number of facilities are North Carolina, California, Oregon, and
Pennsylvania. Table 3-2 lists the number of facilities in each State for the SIC codes of imeresi
The data presented in the table are based on the 1992 Census of Manufactures. Again, not all o'
these facilities are major sources of HAP.
3.2 SUMMARY OF EXISTING STATE/FEDERAL REQUIREMENTS
There are currently no Federal regulations that limit either VOC or HAP emissions iron1.
the wood building products industry. The EPA did publish a CTG for some segments of the
flatwood paneling industry in 1978. Table 3-3 summarizes the emission limits included in the
CTG.
3-2
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TABLE 3-2. WOOD BUILDING PRODUCTS FACILITIES BY STATE**
Region State
Region I CT
ME
MA
NH
RI
VT
Region II NJ
NY
Region III DE
MD
PA
VA
WV
Region IV AL
FL
GA
KY
MS
NC
SC
TN
Region V IL
IN
Ml
MN
OH
WI
No. of
facilities
54
52
80
42
17
38
283
74
259
333
9
65
318
182
39
613
157
321
215
90
141
459
84
176
1,643
190
188
214
117
193
215
1,117
Facilities
with 20 or
more
employees
3
23
18
11
1
15
71
20
68
88
3
29
125
86
23
266
84
113
86
38
58
215
45
74
713 •
52
132
89
58
80
102
513
Region State
Region VI
AK
LA
NM
OK
TX
Region VII IA
KS
MO
NE
Region VIII CO
MT
ND
SD
UT
WY
Region IX AZ
CA
NV
Region X ID
OR
WA
Total
No. of
facilities
112
51
29
37
273
502
34
45
135
27
241
89
35
8
10
54
4
200
119
695
26
840
62
287
315
664
6,436
*
Facilities
with 20 or
more
employees
47
27
8
9
95
186
13
16
38
9
76
21
13
2
4
11
2
53
46
218
11
275
32
170
89
291
2,532
1 No data available for States not listed. Includes information for the following SIC codes: 2426, 2429, 2431, 2435,
2436, 2439, 2451, 2452, 2493.
b Some SIC codes include facilities that do not perform surface coating operations and facilities that do not
manufacture wood building products or are not major sources of HAP.
3-3
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TABLE 3-3. .RECOMMENDED MACT LIMITS FROM THE CTG FOR THE
FACTORY SURFACE COATING OF FLATWOOD PANELING
Product
Printed interior panels
Natural finish hardwood
Class n hardboard panel
Emission rate limit,
lbVOC/l,OOOft2
6.0
12
10
Equivalent coating limit.
Ib VOC/gal-water
2.5
3.3
2.8
Most States have developed regulations that are based on the 1978 CTG. However, both
California's Bay Area Air Quality Management District (BAAQMD) and Wisconsin have
expanded their regulations to include products not covered under the CTG. The BAAQMD
regulation limits the VOC content of all adhesives and coatings used for flat wood paneling and
for all other flat wood stock including door skins, baseboards, and tileboard. Wisconsin limits
the VOC content of the coatings used for finishing wood doors and molded wood parts and the
VOC content of the adhesives used for these products and the products covered under the
original CTG. A summary of existing State regulations that differ from the CTG is provided in
Table 3-4.
3.3 APPLICABILITY
Several applicability and overlap issues were identified early in the rule developmen;
process. Industry members expressed concern about overlap with the printing and publishing.
wood furniture manufacturing (surface coating), and plywood and particleboard NESHAP At
some facilities, numerous products are coated on the same line; panels used as both furniture and
building components are often finished on the same line with the same coatings. The EPA
intends for this NESHAP to cover surface coating of wood building products, not components
that are intended for use in furniture manufacture. Printing (i.e., of a simulated wood grain) on
wood building products will also likely be addressed by this NESHAP. The wood building
products NESHAP will not cover the manufacturing of the actual wooden substrate (e.g.,
plywood). The manufacturing of the substrate will likely be addressed under emission standards
such as those being developed for plywood and particleboard manufacturing operations
3-4
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Applicability to laminated products and products not finished on a flat line-has also been
raised as an issue by stakeholders. Some gluing and laminating operations will likely be covered
by this rule. For purposes of this rule, laminated products are considered wood building products
to which a protective, decorative, or functional layer has been bonded. Products that are
produced by bonding layers to the substrate as part of the substrate manufacturing process (e.g.,
plywood manufacture) are not considered laminated products for purposes of this rule, and will
likely be addressed under the emission standards being developed for particleboard and plywood
manufacturing operations.
3.4 WOOD BUILDING PRODUCTS COATING PROCESSES
The finishing processes and types of coatings used in the wood building products industry
vary by product type. Some facilities manufacture numerous products, while some manufacture
only panels that are then sold to other companies for final processing. The number of coatings a
product receives is determined by its end use. Substrates that are finished again after field
installation (e.g., wood siding) are typically only primed and sold to distributors after which
building contractors or homeowners apply architectural coatings which are formulated for
consumer use. High end products (e.g., wall paneling and millwork) receive numerous coatings.
Types of coatings used in the wood building products industry include fillers, sealers,
groove coats, primers, stains, basecoats, inks, and topcoats. Fillers are used to fill pores, voids,
and cracks in the wood and to provide a smooth surface. Sealers seal off substances in the wood
that may affect subsequent finishes and also protect the wood from moisture. Groove coats cover
grooves cut into panels and assure the grooves are compatible with the final surface color.
Primers are used to protect the wood from moisture and provide a good surface for further
coating applications. Stains are non-protective coatings that color the wood surface without
obscuring the grain. Basecoats provide color and hide substrate characteristics. Inks are used to
print decorative designs on printed panels or produce a simulated wood grain. Pigmented
(enamels) and clear topcoats provide protection, durability, and gloss.
Typical coating application methods include spraying, roll coating, rotogravure cylinder,
curtain coating, flow coating, pneumatic (air knife) coating, brush coating, vacuum coating, and
dip coating. Each of these methods is discussed below.
3-7
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In spray coating, a handheld or automatic spray gun is used to apply the coating. The
guns are typically used in a spray booth. Air is constantly pulled into and vented from the booth
to keep levels of volatile compounds low. Spray coating is often used to coat non-flat pieces.
Spray technologies used include conventional air, airless, air-assisted airless, electrostatic, and
high-volume low-pressure (HVLP). Conventional air spray uses compressed air to atomize the
finishing materials. Airless spraying involves atomizing the finish by forcing it through a small
opening at high pressure. Air-assisted airless spray uses an airless spray unit with a compressed
air jet to finalize breakup and help shape the spray pattern of the finish material. Electrostatic
finishing is performed by spraying negatively charged finish particles onto grounded wood
products. High-volume low-pressure spraying involves the use of a high volume of air delivered
at an effectively low pressure to atomize a finish into a pattern of low-speed particles, which
typically results in less overspray.
A curtain coating applicator uses a metered slit (shown in Figure 1) or weir to create a
free falling film of coating that the wooden substrate passes through. Coating pump speed, weir
or metered slit coating reservoir head, and conveyer belt speed all control the amount of coating
applied. Excess coating is collected in a reservoir and returned to the coating head. Curtain
coating is typically used when a relatively thick coat is required. The rate of panel movement
and the controlled uniform flow of the film of coating determines the coating thickness
Roll coating is a process in which cylindrical rollers apply a limited amount of coating to
the wood substrate. There are four types of roH coalers: direct roll (rolls in same direction as
product), reverse roll (rolls in opposite direction of product), differential roll (has two cylinder;
that move at different speeds), and sock (has a fabric sock over the roll to produce a textured
finish). In a roll coater, a rubber covered coating roll and a smooth, chrome-plated doctor roll
create a reservoir that holds the coating material. The material is held in this reservoir bs
adjustable end seals at the ends of the rolls. The doctor roll meters the coating material onto the
surface of the coating roll. A feed roll or conveyor belt holds the stock in contact with the
coating roll and helps drive it through the machine. A simplified schematic of both a direct rol
coater and a reverse roll coater is presented in Figure 1. A rotogravure cylinder is similar to tin
direct roll coater, only the cylinder is etched and coated with ink to apply a pattern such »s a
3-8
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simulated wood grain onto the substrate. Roll coating is suitable for the application of coatings
when a low-build finish is sufficient.
Flow coaters use nozzles and low pressure to create a wet film of coating that the wood
substrate passes through. Excess coating is collected in a reservoir and returned to the nozzle
heads. A simplified schematic of a flow coater is presented in Figure 2. Pneumatic (air knife)
coaters flood a panel with coating similarly to flow coaters and then remove the excess by
exposing the panel to pressurized air. The excess is collected in a reservoir and recycled back to
the coater. Brush coaters flood a panel with coating similarly to flow coaters and then use
brushes to remove the excess. The excess is collected in a reservoir and recycled back to the
coater. A vacuum coater pulls paint up from a reservoir, creating a wall of paint. The wooden
substrate passes through paint and receives a coating. Excess paint is vacuumed off the substrate.
Paint thickness is controlled by vacuum and the conveyor speed. Vacuum coaters can be used in
coating application that require all side of a substrate to be coated at one time. A simplified
schematic of a vacuum coater is presented in Figure 2.
Dip coating is a process in which the piece is dipped into a vat of coating, and the excess
is allowed to run off. Dip coaters can be used on multi-dimensional pieces and/or non-typical
part configurations.
A typical coating line moves between 100 to 400 feet/minute. The industry currently uses
primarily waterborne and UV-cured coatings, although some products (i.e., tileboard, fire
resistant paneling) still require solventborne coatings to provide good water, weather, and fire
resistance. Quick drying time is another reason why manufacturers use solventborne coatings,
especially when fast line speeds are used. The product's coating needs to be dry, hard, and cool
prior to packaging, otherwise the products have the potential to stick together when stacked,
causing defects or reject material. This problem is sometimes referred to as "blocking."
Following is a brief description of the primary products manufactured by the industry and the
finishing process used for each product.
3-9
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Curtain
Coater '
Panel movement
on a conveyer
Coating
Recycle Back
to
Pressure Head
Direct
Roll
Coater
Panel movement
on a conveyer
Coating
'Plicator
Drive Roll
Reverse
Roll
Coater
Coating
Applicator
Doctor Blade
Reverse Roll
Panel movement
on a conveyer
t>
Drive Roll +4 J
Figure 3-1. Simplified curtain and roll coater diagrams.
3-10
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Flow
Coater.
Panel
Movement
Coating
Recycle Back
to
Nozzle
Vacuum
Coater
Panel
Movement
Vacuum —
Recycle to
Paint Trough
Coating
Pneumatic or
Brush
Coater
Non-8'omizing Fan
Spray
Panel Movement
on Conveyer
Air Knife
or
Rotating Brush
L
Recycle Back
to
Nozzle
Figure 3-2. Simplified flow, vacuum, and pneumatic coater diagrams.
3-11
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3.4.1 Interior Paneling , .-
The 1978 CTG developed by the EPA covered surface coating of interior paneling onh.
Since the CTG was published, the use of interior paneling has decreased dramatically. One
coating supplier to the industry estimates that the production of traditional interior paneling has
decreased 75 percent over the last two decades due to the increased popularity of wallpaper and
use of dry wall. Most interior paneling manufactured today is manufactured outside of the
United States. However, there is still limited production in the United States. There are three
primary types of interior paneling: paper laminated, printed, and natural finish. The finishing
processes for each type are discussed below.
3.4.1.1 Paper Laminated Paneling. These panels are laminated with a decorative paper
Polyvinyl acetate (PVA) is the primary adhesive used for laminating, but urea-formaldehyde
resins and contact adhesives are also used for limited applications. Grooves are often cut in the
panel after lamination and then usually sprayed with waterbased pigmented coating. The
overspray is then ordinarily cleaned up with low solids waterbased clear coating which is applied
by rollcoaters. A protective waterbome topcoat is typically applied with a roll coater over some
paper laminated panels.
3.4.1.2 Printed Interior Paneling. A typical coating process for printed interior panels
includes filler, basecoat, ink, and topcoat. Groove coats are also used for finishing the grooves
cut in the paneling. The filler is typically a waterbome or UV coating that is applied using
reverse roll coating. After the filler is applied, a basecoat is applied, typically with a direct roll
coater. The basecoats are also primarily waterbome coatings. The inks are applied with a rubbei
offset gravure printer. Several ink colors may be applied to reproduce the'appearance of \\ ood >;
other substrates such as marble or textured cloth. One or two coats of a clear protective topcoat
are then applied with a direct roll coater. Both waterbome and UV-cured topcoats arc used
3.4.1.3 Natural Finish Interior Paneling. Stains, toners, sealers, and topcoats may all be
used to produce the final finish. A pigmented groove coat is also applied to the panel grooves.
Stains give the wood a uniform color. The stains are applied with a direct roll coater. A toner
may then be applied with a direct roll coater to seal the stain. Filler is then applied using a
reverse roll coater. The sealer, which is applied after the filler, protects the wood from nun slut
and provides a smooth base for the topcoat. Finally, one or more topcoats is applied with a direct
3-12
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roll coater or a curtain coater. The topcoat may be waterborne or UV-cured, although the other
finishes are typically Waterborne.
Figure 3 shows a generic coating process diagram for prefmished interior lauan paneling.
A sander smooths and cleans the substrate to ensure a suitable surface for coating adhesion. A
reverse roll coater applies filler to the paneling. Grooves are cut into the panels. Spray guns
apply a groove coat. The panels are sanded again before a direct roll coater applies a basecoat.
If needed, a second basecoat is applied. Ovens then cure the basecoat. An artificial wood grain
is printed onto the panel by a rotogravure cylinder. The panels then receive a topcoat from a
direct roll coater. Finally, the panels are oven dried, cooled, and packaged for storage and
shipment.
3.4.2 Exterior Siding
Exterior siding was not covered under the 1978 CTG. Exterior siding may be made of a
solid wood such as cedar, of hardboard or waferboard, or of a relatively new product known as
cementitious board. Siding made of solid wood is typically finished in the field, although some
finishing is done in the factory on a limited basis. Hardboard siding is typically primed in the
factory, usually with waterborne coatings; a final coating is applied in the field using consumer
architectural paint. Waferboard siding utilizes a coated paper overlay with a waterborne primer.
Cementitious board, which consists of approximately 10 to 30 percent wood fiber and 70 to
90 percent cement, has been used extensively in Europe, and is growing in popularity in the
United States. Several companies are in the process of opening, or have recently opened,.new
facilities to produce cementitious board for use in the United States. Some industry
representatives and end users state that cementitious board has several advantages over hardboard
in that it is more moisture resistant, termite resistant, and fire resistant than hardboard. As with
hardboard siding, cementitious board is typically primed in the factory with the final coating
applied in the field. However, some board is sold unfinished or prefinished. Both the primers
and topcoats are typically either waterborne or UV cured.
3-13
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3.4.3 Doors and Door Skins f ,-
Door and door skin manufacturing are substantially differentiated processes in practice.
Doors are made by applying adhesive to a core and frame, and then pressing a doorskin on either
side of the core and frame. Such an operation is not usually done at the doorskin manufacturing
location. The door factory may do some finishing of doorskins and or doors and frames. These
finishes are generally waterbased, but smaller operations may use solvent based finishes.
Door skins are produced on high speed finishing lines using low VOC and HAP coatings.
The predominant market for door skins are the door manufacturers themselves, who use them in
their own manufacturing processes. The following paragraphs are generic descriptions and
typical coating applications for different door products.'
3.4.3.1 Solid Wood Doors. Solid wood doors are typically constructed from multi-layers
of veneer or flat pieces of wood over a wooden core. These doors are usually finished by a spray
application of stain, sealer, and topcoat using solvent, waterborne, or UV coatings.
3.4.3.2 Hollow Core Doors. Hollow core doors are constructed'by flat pieces of veneer
or plywood built into a hollow wood frame.
3.4.3.2.1 Plywood Veneer Doors. The typical surface coating processes for plywood
veneer doors include spray or direct roll coat of stain, sealer, and topcoat using solvent,
waterborne, or UV coatings.
3.4.3.2.2 Flat Composite Doors. Typical coating process steps for flat composite doors
are seal, fill, basecoat, ink, topcoat via spray or direct roll coat application. Ink is printed.
Coatings may be solventborne or waterborne.
3.4.3.2.3 Molded Doors. Molded doors are usually primed and pr'efinished using
waterborne or UV-curable coatings.
Figure 4 displays generic coating process diagrams for molded and smooth-face doors. A
sander smooths and cleans the substrate to ensure a suitable surface for coating adhesion. A
reverse roll coater applies filler to the doors. The doors are sanded again before a direct roll
coater applies a stain. Ovens dry the stain. Then the doors receive a topcoat from a direct roll
coater. Finally, the topcoat is UV cured, cooled, and packaged for storage and shipment.
3-15
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3.4.4 Tileboard . ,-
Tileboard is a type of Class I hardboard. Tileboard is a wood product that resembles tile.
It is used as a splashboard around sinks and tubs. While most hardboard is finished with
waterborne primers and topcoats, tileboard is finished with solventborne coatings because
waterbome coatings do not provide the required moisture resistance. Emissions from the
solventborne coatings are often controlled with a thermal oxidizer.
3.4.5 Flooring
Hardwood flooring is cut and grooved, and then is typically finished in 8 foot by 12 foot
strips. The industry uses both waterbome and solventborne stains and primarily UV-cured
topcoats. Coatings are typically applied with a roll coater. Laminate flooring is becoming
increasingly popular in the United States. Adhesives (typically urea formaldehyde or melamine
formaldehyde) are used to apply a paper backing to one side of a-thin piece of particle board and
a decorative laminate to the other side. The adhesive is usually applied with a roll coater.
Alternatively, the decorative laminate and backing paper may be applied to the particle board
using pressure and high temperatures. The flooring usually is then cut to size and given tongue
and groove edges.
3.4.6 Window Frames and Joinery
Window frames and joinery are typically finished with either flow coaters or spray guns.
Both waterborne and solventborne coatings are used. Solventborne coatings are required for
some products, particularly those with a long warranty, because they are more durable and
provide better protection than the waterborne coatings. Some products are also dipped in a water
repellant/preservative treatment (usually consisting of wax, mineral spirits, etc.) before finishing.
3.4.7 Shutters
Shutters are usually roll, spray, or dip coated with a protective and/or decorative coating.
Waterborne coatings are typically used for finishing.
3.4.8 Moulding and Trim
These are decorative or ornamental wood products that are used around doors and
windows. Exterior use of these products is growing. The products are typically spray-coated or
flow coated with waterborne or solventborne coatings. Additionally, factories which are
finishing wood moulding and trim products may also be finishing a considerable amount of
3-17
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plastic mouldings and trim. The surface finishes for plastic usually require a coating which is
more technically difficult to use and apply than for coatings used for wood substrates.
Figure 5 represents a generic coating process for high end woodgrain millwork. The
substrate is cut to the size and milled to the shape of the final product. A sander smooths and
cleans the substrate to ensure a suitable surface for coating adhesion. A flow coater applies a
basecoat. Ovens dry the coating. If needed, a second basecoat is applied. A rotogravure cylinder
applies a wood grain ink. The millwork receives a topcoat from a curtain coater. Finally, the
millwork is oven dried, cooled, and packaged for storage.
Other products and finishing lines can incorporate any number of combinations of
coaters, sanders, ovens, etc. The combination typically depends upon uses of the final product.
3.5 EMISSIONS
The primary source of emissions associated with surface coating operations at wood
building products manufacturing facilities is the finishing process. The emissions result from the
application and subsequent evaporation of the solvents in the finishing materials. Other source>
of emissions are:
1. Storage of finishing materials. Emissions can result from the filling and cleaning of
storage media. If containers are not kept closed, evaporation of the finishing materials may also
occur. Some surface coating applicators that use waterborne coatings must operate with open top
paint reservoirs to dissipate the foam created in the coating and recycling process.
2. Gluing operations (e.g., laminating). The adhesives used in gluing operations typical!)
contain formaldehyde and may be a significant source of emissions. Laminating may be
considered part of the finishing process for purposes of this rulemaking.
3. Mixing operations. Facilities that thin their coatings or have other mixing operation-
will have emissions from evaporation of the solvent in the mixing materials.
4. Cleaning operations. Most cleaning operations use water or mechanical devices.
However, cleaning solvents that are used to remove coatings from coating applicators and othei
equipment are a source of emissions.
5. Repair/rework. Most repair and reworking involves the substrate being sent down the
regular finishing line to be finished. However, solvent used in repair or rework of pieces with
finishing defects is a source of emissions.
3-18
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Based on the 1.994 and 1995 emissions data from EPA's Toxic Release, Inventory' (TRI)
System data base, methanol, formaldehyde, xylene, toluene, and methyl ethyl ketone (MEK) arc
the primary HAP emitted by the industry. Tables 3-5 and 3-6 present the primary HAP and
VOC, respectively, emitted by facilities included in the SIC codes of interest as reponed in the
1994 TRI data base. Table 3-7 lists total HAP/VOC emissions by SIC code.
Several of the HAP listed in Table 3-5 and VOC listed in Table 3-6 are not emitted from
the finishing of wood building products or associated emission sources (e.g., cleaning and
gluing). Many are likely emitted from the substrate manufacturing process(es) or other processes
at the facility; these emissions can include acetaldehyde, hydrochloric acid, and chlorine
In addition, some of the other HAP listed are emitted from both the finishing process and
the substrate manufacturing process, so the total emissions reported are likely higher than actual
emissions from the finishing process and associated emission sources. These HAP include
methanol, formaldehyde, and phenol. Unfortunately, the TRI data base does not provide
sufficient information to apportion the emissions to a particular process.
3.6 EMISSION CONTROL TECHNIQUES
The most prevalent form of emission control for the wood building products surface
coating source category is the use of low-VOC or low-HAP coatings, such as waterbome or
UV-cured coatings. Solventborne coatings are typically only used in applications where watei
fire, or weather resistance is an issue. In addition, solventborne coatings typically hax e quick
drying times. This allows facilities to operate coating lines much faster and dedicate less flooi
space to curing/drying, and prevents incomplete drying of products that could subsequently suck
together in shipment. Much effort has been put into developing coating materials for the \\ oo,;
finishing industry that contain fewer HAP and VOC.
3-20
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TABLE 3-5. PRIMARY HAP EMITTED BY THE WOOD.
BUILDING PRODUCTS INDUSTRY3
Pollutant
Methanol
Formaldehyde
Toluene
Xylene (Mixed Isomers)
Acetaldehyde
Methyl Ethyl Ketone
Hydrochloric Acid
Phenol
Chloroform
Methyl Isobutyl Ketone
Certain Glycol Ethers
Dichloromethane
Ethylbenzene
n-Hexane
Styrene
Ethylene Glycol
Cresol (Mixed Isomers)
Chlorine
Methyl Methacrylate
Chloromethane
1,1,1 -Trichloroethane
Dibutyl Phthalate
1 ,2,4-Trichlorobenzene
Diisocyanates
Tons emitted
7,069
1,881
1,261
906
853
635
424
301
227
163
122
106
98
56
52
39
38
22
13
13
10
9
8
5
a Based on 1994 TRI data.
3-21
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TABLE 3-6. PRIMARY VOC EMITTED BY THE WOOD
BUILDING PRODUCTS INDUSTRY3
Pollutant
Methanol
Formaldehyde
Toluene
Xylene (Mixed Isomers)
Acetaldehyde
Methyl Ethyl Ketone
Phenol
Chloroform
n-Butyl Alcohol
Methyl Isobutyl Ketone
Certain Glycol Ethers
Dichloromethane
Ethylbenzene
n-Hexane
Styrene
Ethylene Glycol
Tons emitted
7,069
1,881
1,261
906
853
635
301
227
171
163
122
106
98
56
52
39
'Based on 1994 TRI data.
TABLE 3-7. HAP EMISSIONS BY SIC CODE
SIC Code and Title
2426- Hardwood Dimension and Flooring Mills
2429 - Special Product Sawmills, NEC
2431-Millwork
2435 - Hardwood Veneer and Plywood
2436 - Softwood Veneer and Plywood
2439 - Structural Wood Members, NEC
2451 - Mobile Homes
2452 - Prefabricated Wood Buildings and Components
2493 - Reconstituted Wood Products
Total Annual HAP Emissions (tons y. ;
TRI 1994
388
1,520*
2,267
467
3,120
170
128
50
5,905
TRI 1995
- -
22 ;
: i >!
1 ,664
955
3,079
148
13u
32
8,704
3-22
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Waterborne coatings are coatings in which water is the main solvent or dispersing agent.
Each type of waterbofne coating exhibits different film properties depending on the type of
polymer in the formulation. Waterborne coatings are typically not free of VOC, but their use can
reduce VOC emissions by as much as 70 percent. However, disadvantages include grain raising,
increased drying time, and low gloss. Use of waterborne coatings also requires the facility to
convert to stainless steel lines and equipment. Some facilities may be able to use waterborne
coatings for some finishing steps, but not all. Higher solids coatings can also be used to reduce
HAP/VOC emissions. Based on equivalent solids applied, the higher solids coating results in
lower emissions than a traditional finish.
Radiation curing is a technology that utilizes electromagnetic radiation energy to affect
chemical and physical change of organic finish materials by the formation of cross-linked
polymer networks. One type of radiation used is UV light. The primary components of
UV-cured coatings are multifunctional polymers, monofunctional diluent monomers, and the
photoinitiators. A photoinitiator absorbs the UV light and initiates the curing process. The
diluent serves as a viscosity modifier for the finish and is similar to a traditional solvent in this
regard, but most of the diluent in UV finishes polymerizes and becomes part of the coating film.
Only the diluent in the coating that does not reach the piece is emitted. The curing process is
very fast (as little as one or two seconds), and provides a final film that is stain-, scratch-, and
mar-resistant. The UV-curable finishes are often considered to contain up to 100 percent solids
because 100 percent of the components reacts to form the coating. Due to the generally high
solids content of these types of coatings, high film thicknesses can be achieved with fewer coats
or process steps than with lower solids conventional coatings. Because curing requires "line of
sight" radiation, these types cf coatings are ideal as flat panel or component part finishes.
Add-on controls, such as incinerators, are not widespread in this industry. Thermal
incinerators can be used to control waste streams containing various organic compounds and thus
are technically feasible for controlling emissions from wood finishing operations. However, the
exhaust stream from most wood finishing operations is characterized as a dilute concentration of
VOC/HAP in a high-volume airflow. The costs associated with control of a dilute air stream can
be very high due to auxiliary fuel requirements.
Use of pollution prevention techniques is common in the coating industries. They are
3-23
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cost-effective means of reducing emissions from the coating process and also from cleaning
operations. Typical pollution prevention techniques/work practices for coating facilities include:
1. Use of low or no HAP/VOC coatings and/or cleanup solvents;
2. Use of more efficient spray equipment;
3. Use of nonspray alternatives;
4. Inventory control and material audits;
5. Process improvements to reduce waste/cross-media impacts;
6. Coating operator training;
7. Keeping storage containers covered or closed;
8. Recycling of cleaning solvent and finishing materials;
9. Proper coating preparation;
10. Direct delivery of coating to spray gun;
11. Use of heat (rather than thinner) to obtain the desired coating viscosity;
12. Proper care and maintenance of spray equipment.
13. Use of high transfer efficiency application and recovery equipment.
3-24
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4.0 NEXT STEPS IN THE MACT DEVELOPMENT PROCESS
Further information gathering efforts will include: analysis of data collected from the ICR
responses (October 1998); additional permit information and data collected from States (fall
1998); analysis of emission inventory data (fall 1998); additional site visits (August 1998); and
additional stakeholder meetings. The ICR data will aid in characterizing the types and
magnitudes of emission sources and HAP contents of coatings used at particular facilities for
specific products. These data will also aid in developing the scope of the regulation. State
permit information will provide information on the types of emission limits wood building
products coating facilities already have to meet. Data on surface coating emissions by 8-digit
Source Classification Code (SCC) will be collected for this source category. The additional site
visits will be targeted toward facilities using pollution prevention type measures (e.g.,
waterborne, UV, or EB coating technologies) and those in segments of the industry not yet
visited. The additional information collected will be used to develop the MACT floor and,
ultimately, the MACT standard for the surface coating of wood building products.
4-1
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APPENDIX A
LIST OF STAKEHOLDERS
-------
TABLE A-1. INDUSTRY STAKEHOLDERS
Name
Jim Berry
Kurt Bigbee
John Bradfield
Jack Burgess
Erich Burke
Allen Campbell
Gary Gramp
Michael Jonas
Rob Kaufmann
Edward Korczak
Brock Landry
Mike Luffy
Barbara Martin
Brad Miller
Mickey Moore
Jim Rabe
David Ritchey
Alex Ross
Jeff Twaddle
Paul Vasquez
Louis Wagner
Dave Walters
Frank Walters
Robert Weiglein
Tammy Wyles
George Carter
Mark Collatz
Madelyn Harding
Allen Irish
Bob Matejka
David Mazzocco
Bob Nelson
Carol Niemi
Sherry Stookey
Affiliation
Industry
Industry
Industry
Industry
Industry
Industry
Industry
Industry
Industry
Industry
Industry
Industry
Industry
Industry
Industry
Industry
Industry
Industry
Industry
Industry
Industry
Industry
Industry
Industry
Industry
Industry supplier
Industry supplier
Industry supplier
Industry supplier
Industry supplier
Industry supplier
Industry supplier
Industry supplier
Industry supplier
Organization
Berry Environmental
American Plywood Association
Composite Panel Association
Archetectural Woodworking Institute
ABTco Inc.
National Wood Window and Door Association
Hardwood Plywood and Veneer Association
Lozier Corporation
American Forest and Paper Association
National Wood Flooring Association
Venable, et al.
ABTco, Inc.
Building Systems Councils
BIFMA International
National Oak Flooring Association
Masonite
Architectural Woodworking Institute
Radtech
Secor International Incorporated
Georgia Pacific
American Hardboard Association
Chesapeake Hardwood Products
Manufactured Housing Institute
Wood Moulding and Millwork Producers Association
Georgia Pacific
Laminating Materials Association
Adhesives and Sealants Council
Sherwin-Williams
National Paint and Coatings Association
Akzo Nobel Coatings Inc.
PPG
National Paint and Coatings Association
CMA Solvents Council
Lilly
A-l
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TABLE A-2. REGULATORY SUBGROUP
Name
Maggie Corbin
Jerry Ebersole
Gregg Lande
Venkata Panchakarla
Saba Tahmassebi
Affiliation
Local agency
State agency
State agency
State agency
State agency
Organization
Puget Sound APCA
Oregon DEQ
Oregon DEQ
Florida DEQ
Oklahoma DEQ/AQD
Phone Number and E-mail Address
(904)488-0114
(503) 229-6974
ebersole.jerry@deq.state.or.us
(503)229-6411
lande.gregg@deq.state.or,us
(904)488-0114
(405)702-4100
A-2
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APPENDIX B
LIST OF HAZARDOUS AIR POLLUTANTS
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List of Hazardous Air Pollutants
CAS No. Chemical name
CAS No. Chemical name
75070 Acetaldehyde 62737
60355 Acetamide 111422
75058 Acetonitrile 121697
98862 Acetophenone 64675
53963 2-Acetylaminofluorine 119904
107028 Acrolein 60117
79061 Acrylamide 119937
79107 Acrylic acid 79447
107131 Acrylonitrile 57147
107051 Allyl chloride 68122
92671 4-Aminobiphenyl 131113
62533 Aniline 77781
90040 o-Anisidine 534521
1332214 Asbestos 51285
71432 Benzene (including benzene from gasoline) 121142
92875 Benzidine 123911
98077 Benzotrichloride 122667
100447 Benzyl chloride 106898
92524 Biphenyl
117817 Bis(2-ethylhexyl)phthalate(DEHP) 106887
542881 Bis(chloromethyl)ether 140885
75252 Bromoform 100414
106990 1,3-Butadiene 51796
156627 Calcium cyanamide 75003
133062 Captan 106934
63252 Carbaryl 107062
75150 Carbon disulfide 107211
56235 Carbon tetrachloride 151564
463581 Carbonyl sulfide 75218
120809 Catechol 96457
133904 Chloramben 75343
57749 Chlordane 50000
7782505 Chlorine 76448
79118 Chloroacetic acid 118741
532274 2-Chloroacetophenone 87683
108907 Chlorobenzene 77474
510156 Chlorobenzilate 67721
67663 Chloroform 822060
107302 Chloromethyl methyl ether 680319
126998 Chloroprene 110543
1319773 Cresols/Cresylic acid (isomers and mixture) 302012
95487 o-Cresol 7647010
108394 m-Cresol 7664393
106445 p-Cresol 123319
98828 Cumene 78591
94757 2,4-D, salts and esters 58899
3547044 DDE 108316
334883 Diazomethane 67561
132649 Dibenzofiirans 72435
96128 l,2-Dibromo-3-chloropropane 74839
84742 Dibutylphthalate 74873
106467 l,4-Dicblorobenzene(p) 71556
91941 3,3-Dichlorobenzidene 78933
111444 Dichloroethyl ether (Bis(2-chloroethyl)ether)
542756 1,3-Dichloropropene
Dichlorvos
Diethanolamine
N,N-Diethyl aniline (N,N-Dimethylanilme)
Diethyl sulfate
3,3 -Dimethoxybenzidine
Dimethyl aminoazobenzene
3,3'-Dimethyl benzidine
Dimethyl carbamoyl chloride
1,1-Dimethyl hydrazine
Dimethyl formamide
Dimethyl phthalate
Dimethyl sulfate
4,6-Dinitro-o-cresol, and salts
2,4-Dinitrophenol
2,4-Dinitrotoluene
1,4-Dioxane (1,4-Diethyleneoxidc>
1,2-Diphenylhydrazine
Epichlorohydnn (1-Chloro-
2,3-epoxypropane)
1,2-Epoxybutane
Ethyl acrylate
Ethyl benzene
Ethyl carbamate (Urethanc;
Ethyl chloride (Chloroethanej
Ethylene dibromide (Dibromoethane)
Ethylene dichloride (1,2-Dichloroethane)
Ethylene glycol
Ethylene imine (Aziridme)
Ethylene oxide
Ethylene thiourea
Ethylidene dichloride (1,1-Dichloroethanci
Formaldehyde
Heptachlor
Hexachlorobenzene
Hexachlorobutadiene
HexachlorocyclopentadienL
Hexachloroethane
Hexamethylerie-l,6-diisoc\ana'i
Hexamethylphosphoramidc
Hexane
Hydrazine
Hydrochloric acid
Hydrogen fluoride (Hydrofluoric ac:di
Hydroquinone
Isophorone
Lindane (all isomers)
Maleic anhydride
Methanol
Methoxychlor
Methyl bromide (Bromomcthane)
Methyl chloride (Chloromethane i
Methyl chloroform (1,1,1-lnchlorot'thane)
Methyl ethyl ketone (2-Buta»onc
B-l
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List of Hazardous Air Pollutants (continued)
60344 Methyl hydrazine 78875
74884 Methyl iodide (lodomethane) 75569
108101 Methyl isobutyl ketone (Hexone) 75558
624839 Methyl isocyanate 91225
80626 Methyl methacrylate 106514
1634044 Methyl tert butyl ether 100425
101144 4,4-Methylenebis(2-chloroaniline) 96093
75092 Methylene chloride (Dichloromethane) 1746016
101688 Methylene diphenyl diisocyanate (MDI) 79345
101779 4,4'-Methylenedianiline 127184
91203 Naphthalene 7550450
98953 Nitrobenzene 108883
92933 4-Nitrobiphenyl 95807
100027 4-Nitrophenol 584849
79469 2-Nitropropane 95534
684935 N-Nitroso-N-methylurea 8001352
62759 N-Nitrosodimethylamine 120821
59892 N-Nitrosomorpholine 79005
56382 Parathion 79016
82688 Pentachloronitrobenzene (Quintobenzene) 95954
87865 Pentachlorophenol 88062
108952 Phenol 121448
106503 p-Phenylenediamine 1582098
75445 Phosgene 540841
7803512 Phosphine 108054
7723140 Phosphorus 593602
85449 Phthalic anhydride 75014
1336363 Polychlorinated biphenyls (Aroclors) 75354
1120714 1,3-Propanesultone 1330207
57578 beta-Propiolactone 95476
123386 Propionaldehyde 108383
114261 Propoxur(Baygon) 106423
Propylene dichloride (1,2-Dichloropropane)
Propylene oxide
1,2-Propylenimine (2-Methyl aziridine)
Quinoline
Quinone
Styrene
Styrene oxide
2,3,7,8-Tetrachlorodibenzo-p-dioxin
1,1,2,2-Tetrachloroethane
Tetrachloroethylene (Perchloroethylene)
Titanium tetrachloride
Toluene
2,4-Toluene diamine
2,4-Toluene diisocyanate
o-Toluidine
Toxaphene (chlorinated camphene)
1,2,4-Trichlorobenzene
1,1,2-Trichloroethane
Trichloroethylene
2,4,5 -Trichlorophenol
2,4,6-Trichlorophenol
Triethylamine
Trifluralin
2,2,4-Trimethylpentane
Vrnyl acetate
Vinyl bromide
Vinyl chloride
Vinylidene chloride (1,1 -Dichloroethylene)
Xylenes (isomers and mixture)
o-Xylenes
m-Xylenes
p-Xylenes
B-2
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. List of Hazardous Air Pollutants (continued)
CAS No. Chemical name
0 Antimony Compounds
0 Arsenic Compounds (inorganic including arsine)
0 Beryllium Compounds
0 Cadmium Compounds
0 Chromium Compounds
0 Cobalt Compounds
0 Coke Oven Emissions
0 Cyanide Compounds'
0 Glycol ethers2
0 Lead Compounds
0 Manganese Compounds
0 Mercury Compounds
0 Fine mineral fibers3
0 Nickel Compounds
0 Polycylic Organic Matter"
0 Radionuclides (including radon)5
0 Selenium Compounds
NOTE: For all listings above which contain the word "compounds" and for glycol ethers, the following applies:
Unless otherwise specified, these listings are defined as including any unique chemical substance that contains the
named chemical (i.e., antimony, arsenic, etc.) as part of that chemical's infrastructure.
1 X'CN where X = H' or any other group where a formal dissociation may occur. For example KCN or Ca(CN)-
2 Includes mono- and di-ethers of ethylene glycol, diethylene glycol, and triethylene glycol R-(OCH2CH2)n-OR'
where
n= 1, 2, or 3
R = alkyl or aryl groups
R' = R, H, or groups which, when removed, yield glycol ethers with the structure:
R-(OCH2CH)n-OH. Polymers are excluded from the glycol category.
3 Includes mineral fiber emissions from facilities manufacturing or processing glass, rock, or slag fibers (or other
mineral derived fibers) of average diameter 1 micrometer or less.
4 Includes organic compounds with more than one benzene ring, and which have a boiling point greater than ot
equal to 100°C.
5 A type of atom which spontaneously undergoes radioactive decay.
B-3
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APPENDIX C
GLOSSARY
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Glossary
Adhesive. A substance capable of holding materials together by surface attachment. Various
descriptive adjectives are used with the term adhesive to indicate certain characteristics: physical
(liquid adhesive, tape adhesive), chemical type (silicate adhesive, resin adhesive), materials
bonded (paper adhesive), and conditions of use (hot-set adhesive).
Airless and Air Assisted Airless Spray Guns. Spray gun technologies that are not
conventional air spray because the coating is not atomized by mixing it with compressed air.
Class I Hardboard. Hardboard that meets the specifications for Class I given by the standard
ANSI/AHA A135.4-1995 as approved by the American National Standards Institute. The
standard specifies requirements and test methods for water absorption, thickness swelling.
modulus of rupture, tensile strength, surface finish, dimensions, squareness, edge straightness.
and moisture content for five classes of hardboard. Class I hardboard is also known as tempered
hardboard.
Class II Hardboard. Hardboard that meets the specifications for Class II given by the standard
ANSI/AHA A135.4-1995 as approved by the American National Standards Institute. The
standard specifies requirements and test methods for water absorption, thickness swelling.
modulus of rupture, tensile strength, surface finish, dimensions, squareness, edge straightness.
and moisture content for five classes of hardboard. Class n hardboard is also known as standard
hardboard.
Coating. A protective, decorative, or functional film applied as a thin layer to a substrate or
surface and which cures to form a continuous solid film. This term applies to paints such as
lacquers or enamels, but also is used to refer to films applied to paper, plastics, or foil. Inks.
adhesives, and caulks are being treated as "coatings" for purposes of this rule development.
Coating Applicator. A unit operation for applying coatings to a wooden substrate (direct roll
coater, curtain coater, spray gun, etc.).
Coating Line. A unit operation necessary for producing a finished wood product (coating
applicator, sander, oven, etc.).
Coating Operation. Those activities in which a coating is applied to a substrate and is
subsequently air dried, cured in an oven, or cured by radiation.
Curtain Coater. A coating applicator that uses a weir or metered slit to create a free falling film
of coating that the wood substrate passes through.
Direct roll coater (DRC). A coating applicator that uses cylindrical rollers to apply coaDnus u
the wood substrate. The cylinders on a DRC rotate in the same direction as the wood substrate
movement.
C-l
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Finished (wood) product. Any wood building product to which a protective, decorative, or
functional layer has b.een applied. Materials used include, but are not limited to, paints, stains,
sealers, topcoats, basecoats, primers, enamels, inks, adhesives, and temporary protective
coatings.
Flow coaters. Coating applicators that uses nozzles and low pressure to create a film of coating
in which the wood substrate passes through.
HAP. Hazardous Air Pollutant. Any air pollutant listed in or pursuant to Section 112(b) of the
Clean Air Act. The current list of HAP is attached separately (see Appendix B).
High Volume Low Pressure (HVLP) Spray Equipment. Spray equipment that is used to
apply coating by means of a spray gun that operates at 10.0 psig of atomizing air pressure or less
at the air cap.
Laminated (Wood) Product. Any wood building product which a protective, decorative, or
functional layer has been bonded with an adhesive. Products that are produced by bonding layers
to the substrate as a part of the substrate manufacturing process are not considered laminated
products under this regulation.
Primer. The first layer and any subsequent layers of identically formulated coating applied to
the surface to be coated. Primers are typically used for corrosion prevention, protection from the
environment, functional fluid resistance, and adhesion of subsequent coatings. Primers that are
defined as specialty coatings are not included under this definition.
Process (Process Line). The aggregate of unit operations necessary for producing a product.
The emissions from a process include all sources of air emissions (e.g., storage, transfer,
handling, painting, and packaging).
Reverse Roll Coater (RRC). A coating applicator that uses cylindrical rollers to apply coatings
to the wood substrate. The cylinders on a RRC rotate against the movement of the wood
substrate.
Solvent. The liquid or blend of liquids used to dissolve or disperse the film-forming particles in
a coating and which evaporate during drying. A true solvent is a single liquid that can dissolve
the coating. Solvent is often used to describe turpentines, hydrocarbons, oxygenated compounds,
furans, nitroparaffins, and chlorinated solvents.
Solventborne. Coatings in which volatile organic compounds are the major solvent or
dispersant.
Spray gun. A device that atomizes a coating or other material and projects the particulates onto
a substrate.
C-2
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Thinning Solvent. Organic solvent used to thin coating material prior to application to the par
or product.
Topcoat. A coating that is applied over a primer on a part, product, or component for
appearance or protection. Topcoats are typically the last coat applied in a coating system.
Touch-up and Repair Operation. That portion of the coating operation that is the incidental
application of coating used to cover minor imperfections in the coating finish or to achieve
complete coverage. This definition includes out-of-sequence or out-of-cycle coating.
Unit Operation. An industrial operation, classified or grouped according to its function in an
operating environment (e.g., a paint mixing vessel, a spray booth, etc.).
VOC (Volatile Organic Compound). Any compound defined as VOC in 40 CFR 51.100(s).
This includes any organic compound other than those determined by the EPA to be an "exempt"
compound.
Waterborne coatings. Coatings in which water accounts for more than 5 weight percent of the
volatile portion.
Wood Building Product. Any finished or laminated wood product that is used in the
construction, either interior or exterior, of a residential, commercial, or institutional building.
C-3
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TECHNICAL REPORT DATA
(Please read Instructions on reverse before completing)
1. REPORT NO.
EPA-453/R-00-004
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
Preliminary Industry Characterization:
Wood Building Products Surface Coating
5. REPORT DATE
September 1998
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
Luis Lluberas, Coatings and Consumer Products Group (CCPG)
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.
68-D6-0012, TO No. 47
12. SPONSORING AGENCY NAME AND ADDRESS
Office of Air and Radiation
U. S. Environmental Protection Agency
Washington, D.C. 20460
13. TYPE OF REPORT AND PERIOD COVERED
14. SPONSORING AGENCY CODE
EPAyOAR/OAQPS/ESD/CCPG
15. SUPPLEMENTARY NOTES
16. ABSTRACT
National emission standards to control the emission of hazardous air pollutants (HAP) from the Wood
Building Products (Surface Coating) industry are being proposed under Section 112 of the Clean Air Act
(CAA). There is a possibility that case-by-case maximum achievable control technology (MACT)
determinations will be required under Section 112 (g) for newly constructed and/or reconstructed major
sources. The information summarized in this document is intended to provide preliminary information that
can be used by States that may have to make case-by-case MACT determinations under Sections 112(g) or
112(j) of the CAA. Section 1 of this document gives an overview of the initial MACT development phase
for this source category. Section 2 summarizes the issues raised and information gathering techniques used
in this process. A preliminary characterization of the wood building products source category is given in
Section 3. Section 3 also focuses on the source category's products, types of coatings used, application
methods, emissions, and emission control techniques. Section 4 addresses recommendations for next steps in
the MACT development process.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b. IDENTIFIERS/OPEN ENDED TERMS
c. COSATI Field/Group
surface coating, wood building products, air
pollution, NESHAP, hazardous air pollutant,
HAP, window, door, panel, reconstituted wood,
flooring, tileboard, doorskin, Class I hardboard,
laminate flooring
air pollution control
wood building product
manufacturing
stationary sources
18. DISTRIBUTION STATEMENT
Unlimited
19. SECURITY CLASS (Report)
Unclassified
21. NO. OF PAGES
48
20. SECURITY CLASS (Page)
Unclassified
22. PRICE
EPA Form 2220-1 (Rev. 4-77)
PREVIOUS EDITION IS OBSOLETE
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U.S. Environmental Protection Agency
Region 5, Library (PL-12J)
T? West Jackson Boulevard, 12th Flow
Chicago. II 60604-3590
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