Urui«o S tat as
Ertvronmsntai Proiacson
Offlca at Ak QuaWy
Planning and Standard*
    Tri«ng<« Pwn NC 27711
EPA-453/R-96-007
April 1996
 Air
Guideline Series

Control of Volatile
Organic Compound
Emissions from
Wood Furniture
Manufacturing Operations
                          LJ

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               Guideline  Series

Control of Volatile Organic Compound
    Emissions from Wood Furniture
        Manufacturing  Operations
                 Emission Standards Division
                U.S. Environmental Protection Agency
                Region 5, Library (PL-12J)
                77 West Jackson Boulevard, 12th Floor
                Chicago, IL  60604-3590
              U. S. Environmental Protection Agency
                 Office of Air and Radiation
            Office of Air Quality Planning and Standards
               Research Triangle Park, NC 27711

                     April 1996

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                         GUIDELINE SERIES

     The guideline series of reports is issued by the Office of
Air Quality Planning and Standards  (OAQPS) to provide information
to State and local air pollution control agencies.  Mention of
trade names or commercial products is not intended to constitute
endorsement or recommendation for use.  Reports published in this
series will be available - as supplies permit - from the Library
Services Office (MD-35, U. S. Environmental Protection Agency,
Research Triangle Park, North Carolina 27711, or for a nominal
fee,  from the National Technical Information Service, 5285 Port
Royal Road, Springfield, Virginia 22161.
                               11

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                        TABLE OF CONTENTS
1.0  INTRODUCTION	     1-1
     1.1  THE REGULATORY NEGOTIATION PROCESS   	     1-2
     1.2  DEVELOPMENT OF THE CTG THROUGH REGULATORY
          NEGOTIATION	     1-3

2.0  INDUSTRY DESCRIPTION 	     2-1
     2.1  INDUSTRY STRUCTURE  	     2-1
     2.2  FINISHING PROCESS 	     2-9
          2.2.1  Finish Application Methods 	    2-11
          2.2.2  Finishing Materials  	    2-14
          2.2.3  Finishing Sequences  	    2-18
     2.3  EMISSION SOURCES  	    2-19
          2.3.1  Industry Source Definition 	    2-19
          2.3.2  Emission Sources 	    2-21
          2.3.3  VOC Emission Summary	    2-26
     2.4  EXISTING REGULATIONS  	    2-28
          2.4.1  Introduction	    2-28
          2.4.2  Summary of Existing Regulations  ....    2-30
     2.5  REFERENCES FOR CHAPTER 2	    2-37

3.0  EMISSION CONTROL TECHNIQUES  	     3-1
     3.1  ADD-ON CONTROL DEVICES  	     3-1
          3.1.1  Combustion Control Devices 	     3-2
          3.1.2  Recovery Devices 	    3-12
          3.1.3  Methods of Minimizing Control Costs--
                 Volume  Reduction 	    3-24
          3.1.4  Total Enclosure of the Finishing Line   .    3-30
     3.2  LOWER VOC FINISHES	    3-32
          3.2.1 Use of Lower VOC Finishing Materials  .   .    3-33
          3.2.2  Applicability of Lower-VOC Finishes to
                 Wood Furniture  Finishing Operations  .   .    3-44
          3.2.3  Advantages and  Disadvantages of Lower
                 VOC Finishes	    3-49
     3.3  EMERGING/SPECIALIZED TECHNOLOGIES 	    '3-52
          3.3.1  Mobile  Zone Spray Booth	    3-53
          3.3.3  Biof iltration	    3-54
     3.4  POLLUTION PREVENTION  	    3-57
          3.4.2  Reduction in  Cleaning Material Usage .   .    3-61
     3.5  REFERENCES FOR CHAPTER 3	    3-65
                               111

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                  TABLE OF CONTENTS  (continued)
4.0  MODEL PLANTS AND EMISSIONS ESTIMATES  	      4-1
     4.1  MODEL PLANTS	      4-1
          4.1.1  Finish Application Method   	      4-5
          4.1.2  Finishing Sequence 	      4-5
          4.1.3  Model Plant Sizes  	      4-6
          4.1.4  Finish Parameters	•  .  .  .     4-10
     4.2  EMISSIONS ESTIMATES  	     4-12
          4.2.1  Emissions by  Finishing Step	     4-13
          4.2.2  Emissions by  Emission Point	     4-13
     4.3  REFERENCES FOR CHAPTER 4	     4-19

5.0  SELECTION OF RACT	      5-1
     5.1  BACKGROUND	      5-1
     5.2  SELECTION OF REFERENCE CONTROL TECHNOLOGIES  .  .      5-2
     5.3  SELECTION OF WORK PRACTICE STANDARDS   	      5-6
          5.3.1  Coating Operations 	      5-7
          5.3.2  Cleaning and Washoff Operations   ....     5-10
          5.3.3  General Work Practice Requirements  ...     5-14
     5.4  SELECTION OF COMPLIANCE PROVISIONS   	     5-15
     5.5  SMALL BUSINESS CONSIDERATIONS'	     5-16
     5.6  REFERENCES FOR CHAPTER 5	     5-18

6.0  COST, ENVIRONMENTAL, AND ENERGY IMPACTS   	      6-1
     6.1  COST OF THE RECOMMENDED RACT OPTIONS	      6-2
          6.1.1  Limitation on VOC Content of Coatings   .      6-2
          6.1.2  Application Equipment Requirements  ...      6-8
          6.1.3  Work Practice Standards	     6-10
     6.2  MODEL PLANT COSTS 	     6-11
     6.3  NATIONWIDE IMPACTS OF PRESUMPTIVE RACTS  ....     6-14
          6.3.1  Nationwide Emission Reductions  	     6-21
          6.3.2  Nationwide Costs 	     6-23
     6.4  ENVIRONMENTAL AND ENERGY IMPACTS   	     6-23
          6.4.1  Environmental Impacts	     6-23
          6.4.2  Energy Impacts	     6-26
          6.4.3  Other Environmental Impacts   	     6-26
     6.5  IMPACTS OF OTHER CONTROL OPTIONS   	     6-27
          6.5.1  Hybrid Waterborne  	     6-31
          6.5.2  Full Waterborne	     6-33
          6.5.3  Add-On Controls	     6-33
     6.6  REFERENCES FOR CHAPTER 6	     6-37
                                IV

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                  TABLE OF CONTENTS  (continued)

                                                              Page

7.0  RACT IMPLEMENTATION	      7-1
     7.1  INTRODUCTION	      7-1
     7.2  DEFINITIONS	      7-2
     7.3  APPLICABILITY	      7-2
     7.4  FORMAT OF STANDARDS	      7-4
     7.5  COMPLIANCE AND MONITORING PROVISIONS  	      7-7
          7.5.1  Compliance Provisions  	      7-7
          7.5.2  Monitoring Requirements  	      7-9
     7.6  REPORTING AND RECORDKEEPING .  .  .-	     7-13

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                          LIST OF FIGURES

                                                              Page

 Figure  3-1.   Thermal  incinerator--general case	      3-3

 Figure  3-2.   Regenerable-type thermal incinerator ....      3-6

 Figure  3-3.   Catalytic  incinerator  	     3-10

 Figure  3-4.   Typical  two-bed,  continuously operated
              fixed-bed  carbon adsorber system 	     3-16


                          LIST OF TABLES

                                                              Page

 TABLE 1-1.    WOOD FURNITURE NESHAP REGULATORY NEGOTIATION
              COMMITTEE  MEMBERSHIP 	      1-6

 TABLE 2-1.    WOOD FURNITURE INDUSTRY STRUCTURE  	      2-2

 TABLE 2-2.    WOOD FURNITURE SIC  CATEGORIES	      2-3

 TABLE 2-3.    WOOD FURNITURE FACILITIES BY EPA REGION  .  .      2-4

 TABLE 2-4.    1990 FDM 300 TOP  10 FURNITURE MANUFACTURERS       2-7

 TABLE 2-5.    FINISHING  MATERIALS USED IN THE  WOOD
              FURNITURE  INDUSTRY  	     2-14

 TABLE 2-6.    TYPICAL  FINISHING SEQUENCES  	     2-18

 TABLE 2-1.    WOOD FURNITURE INDUSTRY STRUCTURE BY
              FINISHING  SEQUENCE  	     2-19

 TABLE 2-8.    SPRAY BOOTH CHARACTERISTICS  	    '2-22

 TABLE 2 - 9.    SOLVENT CONSUMPTION IN  PAINTS  AND
              COATINGS ORIGINAL EQUIPMENT MANUFACTURERS
              (OEM), 1989	     2-27

 TABLE 2-10.  WOOD FURNITURE INDUSTRY SOLVENT
             USAGE--1989	     2-28

TABLE 2-11.  REGULATORY SUMMARY--WOOD  FURNITURE COATING  .     2-30

TABLE 2-12.  VOC CONTENT LIMITATIONS--WOOD  FURNITURE
             FINISHING	     2-36
                                VI

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TABLE  3-1
                    LIST OF TABLES  (continued)
LOWER-VOC FINISH ALTERNATIVES--FINISH
SUPPLIERS' COMPARISON OF FINISH PROPERTIES  .
                                                              Page
                                                              3-51
TABLE  3-2.   WORK  PRACTICE  REQUIREMENTS  --  PRESUMPTIVE
             RACT	     3-58

TABLE  3-3.   COMMERCIALLY AVAILABLE SPRAY GUN WASHING
             UNITS	     3-62

TABLE  3-4.   LOW-VOLATILITY ALTERNATIVE  SOLVENTS   ....     3-63

TABLE  4-1.   CHARACTERISTICS  OF MODEL  PLANT CATEGORIES  .      4-3

TABLE  4-2.   'MODEL PLANT DESCRIPTIONS  	      4-4

TABLE  4 - 3.   RANGES  OF VOC  USAGE AND EMPLOYMENT DATA FOR
             MODEL PLANTS	      4-7

TABLE  4-4.   FINISHING  MATERIAL CHARACTERISTICS   ....      4-9

TABLE  4-5.   RELATIVE PERCENTAGE OF VOC  EMISSIONS  ....     4-12

TABLE  4-6.   MODEL PLANT SUMMARY--UNCONTROLLED VOC
             EMISSION RATES,  tons/yr  	     4-13

TABLE  4-7.   EMISSIONS DISTRIBUTION, tons/yr  	     4-15

TABLE  4-8.   EMISSIONS DISTRIBUTION, tons/yr  	     4-19

TABLE  5 -1.   REFERENCE CONTROL TECHNOLOGIES TO MEET  RACT      5 - 3

TABLE  5-2.   WORK  PRACTICE  STANDARDS TO MEET RACT  ....      5-8

TABLE  6-1.   COST  BY MODEL  PLANT FOR PLANTS CONVERTING
             TO HIGHER SOLIDS SEALER AND TOPCOAT   ....     6-15

TABLE  6 - 2.   COST  BY MODEL  PLANT FOR PLANTS CONVERTING TO
             WATERBORNE TOPCOATS   	     6-16

TABLE  6 - 3.   MODEL PLANT CONTROL COSTS FOR  PRESUMPTIVE
             RACT	     6-17

TABLE  6-4.   DISTRIBUTION OF WOOD FURNITURE PLANTS
             IN NONATTAINMENT AREAS  BY MODEL PLANT   ...     6-18

TABLE  6-5.   BASELINE AND CONTROLLED VOC EMISSIONS   ...     6-22

TABLE  6-6.   NATIONWIDE CONTROL COSTS FOR PRESUMPTIVE
             RACT	     6-24


                               vii

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                    LIST OF TABLES  (continued)
TABLE 6-7.


TABLE 6 - 8.

TABLE 6-9.

TABLE 6-10.


TABLE 6-11.


TABLE 6 -12.
ENERGY USE ASSOCIATED WITH WATERBORNE
TOPCOATS  	
INDUSTRY REPORT MODEL PLANTS  .

EARLIER DRAFT CTG MODEL PLANTS
EMISSION REDUCTIONS AND COST EFFECTIVENESS
OF HYBRID WATERBORNE COATING SYSTEM   .  .  .

EMISSION REDUCTIONS AND COST EFFECTIVENESS
OF FULL WATERBORNE COATING SYSTEM  ....

EMISSION REDUCTIONS AND COST EFFECTIVENESS
OF ADD-ON CONTROL DEVICES  	
6-26

6-29

6-30


6-32


6-34


6-35
                              VI11

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                         1.0   INTRODUCTION

      The  Clean Air Act Amendments  (CAAA) of  1990  require  that
 State implementation plans  (SIP's)  for  certain  ozone
 nonattainment  areas be revised  to  require  the implementation of
 reasonably available control  technology (RACT)  for control of
 volatile  organic compound  (VOC) emissions  from  sources for which
 EPA has already published  Control  Techniques Guidelines  (CTG's)
 or for which the U. S. Environmental Protection Agency (EPA) will
 publish a CTG  between the date  of  enactment of  the amendments and
 the date an area achieves attainment status.  Section 172(c)(l)
 requires nonattainment area SIP's  to provide, at  a minimum, for
 "such reductions in emissions from existing sources in the area
 as may be obtained through the  adoption, at a minimum, of
 reasonably available control  technology  ..."  As  a starting point
 for ensuring that these SIP's provide for  the required emission
 reduction, EPA in the notice at 44  FR 53761  (September 17, 1979}
 defines RACT as:  "The lowest emission limitation that a
 particular source is capable of meeting by the  application of
 control technology that is reasonably available considering
 technological  and economic feasibility."  The EPA has elaborated
 in subsequent  notices on how States and EPA should apply the RACT
 requirements (see 51 FR 43814, December 1989; and 53 FR 45103,
November 8,  1988} .
     The CTG's are intended to provide State and local air
pollution authorities with an information base for proceeding
with their own analyses of RACT to meet statutory requirements.
The CTG's review current  knowledge and data concerning the
technology and costs of various emission control techniques.
Each CTG contains  a "presumptive norm"  for RACT for a specific
                               1-1

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squrce category, based on EPA's evaluation of the capabilities
and problems specific to that category.  Where applicable, EPA
recommends that States adopt requirements consistent with the
presumptive norm.  However, the presumptive norm is only a
recommendation.  States may choose to develop their own RACT
requirements on a case-by-case basis, considering the economic
and technical circumstances of an individual source.  It should
be noted that no laws or regulations preclude States from
requiring more control than recommended as the presumptive norm
for RACT.  A particular State, for example, may need a more
stringent level of control in order to meet the ozone standard or
to reduce emissions of a specific toxic air pollutant.
     This CTG is 1 of at least 11 CTG's that EPA was required to
publish within 3 years of enactment of the CAA cimendments.  It
addresses RACT for control of VOC emissions from wood furniture
coating and cleaning operations.
     Unlike traditional development of CTG's for which a
determination of RACT involves the identification and extensive
analyses of a list of options, the determination of presumptive
RACT for the wood furniture industry was negoticited under the
Federal Advisory Committee Act with members of industry,
environmental groups, States,  and local agencies.   Included in
this chapter is a brief description of the regulatory negotiation
process,  a discussion of the process that led to the decision to
negotiate presumptive RACT,  and a brief discussion of the
regulatory negotiation process for the wood furniture industry.
1.1  THE REGULATORY NEGOTIATION PROCESS
     In a regulatory negotiation,  a well-balanced group
representing the industry to be regulated,  public interest
groups, state and local governments,  and the EPA form a federally
chartered advisory committee to negotiate the requirements of a
rule.   A neutral facilitator is used to convene the committee and
to manage its meetings.   In a regulatory negotiation,  decisions
are made by consensus,  not by majority vote.   Consensus is
defined by the committee prior to the start of its deliberations,
                               1-2

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 however,  it is generally defined as an agreement by all parties
 that they can live with the provisions of the rule.
      There are several advantages to the regulatory negotiation
 process.   The process allows the interested,  affected parties a
 more direct input  into the drafting of the regulation,  thus
 ensuring  that the  rule is more sensitive to the needs and
 restrictions of all parties.  The regulatory negotiation
 committee can draw on the diverse experience and creative skills
 of  the  committee members to address problems encountered in
 crafting  the regulation.   The group together may be able to
 propose solutions  to difficult problems that no one member could
 have thought of on his/her own.
 1.2   DEVELOPMENT OF THE CTG THROUGH REGULATORY NEGOTIATION
      In the fall of 1989,  EPA began developing the  CTG  for the
 wood furniture industry.   The EPA sent out surveys  to wood
 furniture manufacturers,  wood furniture coating suppliers,
 application equipment  vendors,  and manufacturers of add-on
 controls.   They also visited several wood furniture manufacturing
 plants.   The information  collected from these efforts was used to
 develop a draft  CTG.   Drafts of  Chapters  1 through  4 of  the CTG
 were  released in October  of  1991 and the  status of  the  CTG and
 the  basis for selecting the  RACT options  were presented  at a
 meeting of  the  National Air  Pollution Control Techniques Advisory
 Committee (NAPCTAC)  in November  of  1991.   A determination of  RACT
 was  not made by  EPA at  this  point  in time.
      In the  spring  of  1991,  the  industry  began preparation of its
 own  report  that  evaluated VOC emissions control  technologies  for
 the wood  furniture  and  cabinet industries.  The  report was
 prepared  by  an  independent contractor and was sponsored  by  the
 American  Furniture  Manufacturers Association,  the Business  and
 Institutional Furniture Manufacturers  Association,  the Kitchen
 Cabinet Manufacturers Association, and the National  Paint  and
 Coatings Association.  The report evaluated the  technical
 feasibility and the costs of  control  technologies for reducing
VOC emissions from  the industry.  An  extensive analysis  of  the
 economic  impacts of the control technologies  was also included  as
                               1-3

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a part  of  the  report.  The  report did not present a
recommendation for RACT.
     As the  draft CTG and the  industry report were being
completed, EPA also began work on a national emission standard
for hazardous  air pollutants  (NESHAP) for the wood furniture
industry.  Title III of the Clean Air Act Amendments of 1990 gave
EPA the authority to establish national standards to reduce air
toxics  from  sources that emit  such pollutants.  Section 112(b) of
the CAAA included a list of hazardous air pollutants (HAP) that
were to be regulated by NESHAP.  Because the wood furniture
manufacturing  industry is a source of many of these pollutants,
it was  included on the list of source categories for which a
NESHAP  was to  be developed.  By the time the draft CTG and the
industry report were released, EPA had already begun gathering
information  to be used in the development of a NESHAP for the
industry.
     In January of 1992, EPA met with industry representatives to
discuss  the  industry report and the status of the CTG and NESHAP.
The industry expressed their concern that the requirements of the
CTG and the  NESHAP might not be consistent with each other.
Because  the  development of  the CTG was ahead of the NESHAP, the
industry was concerned that they would invest in one set of
technologies to address the CTG requirements and then have to
invest  later in different technologies for the NESHAP.   In
response to  their concerns,  EPA presented industry with the
option  of determining both the presumptive norm for RACT and the
requirements of the NESHAP using a consensus-building approach.
The EPA indicated that this approach could consist of continued
informal meetings between EPA and the industry or it could
consist  of a formal regulatory negotiation in which the industry,
the EPA, and other interested parties form a Federal Advisory
Committee with  the goal of reaching agreement on both the
presumptive norm for RACT and the requirements of the NESHAP.
     In April of 1992,  the industry informed EPA that they wished
to explore the  option of using a regulatory negotiation approach
to develop the  CTG and the NESHAP for the wood furniture
                               1-4

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 industry.   The EPA agreed to pursue the possibility of using a
 regulatory negotiation approach to develop the CTG and the
 NESHAP.  During the winter of 1992/1993,  EPA met with
 representatives of the industry,  trade associations,  coating
 suppliers,  States,  and environmental groups to discuss issues,
 share information,  and assess whether a regulatory negotiation
 would be appropriate for the industry.  Two exploratory meetings
 were  held  for these purposes.  After the exploratory meetings,
 three public meetings were held in the spring and early summer of
 1993  to  continue to discuss issues associated with regulatory
 development.   After publishing in the Federal Register on
 June  23, 1993,  a notice of establishment  of the regulatory
 negotiation committee (58 FR 34011),  the  first official
 regulatory  negotiation meeting was held in July 1993.   The
 Committee included  representatives from industry,  including  small
 business, States, environmental and public health groups,  and an
 EPA representative.   Table l presents the list of committee
 members  and their affiliations.
      Formal meetings  and  informal  workshops were held over the
 next  several months  to identify and resolve the many  issues
 associated  with  determining the presumptive norm for  RACT for the
 wood  furniture manufacturing industry.  The Federal Advisory
 Commitee reached consensus  on a framework and principles  in
 November 1994.   The U.  S.  Environmental Protection Agency is
 responsible for  issuing the CTG, and  has  agreed to use  the
 agreed-upon framework  and principles  as the basis  for  the CTG.
     The wood furniture industry is described in Chapter  2 and
 emission control  techniques  are discussed in Chapter 3.   The
 development of model plants  and the associated emission estimates
are described in Chapter 4.   A detailed discussion of  the
 requirements of the presumptive norm  for  RACT that were agreed
upon by the Committee  is included  in  Chapter  5,  while Chapter 6
presents the environmental and  cost impacts  of  those
recruirernents.
                               1-5

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     TABLE 1.   WOOD FURNITURE NESHAP REGULATORY NEGOTIATION
                       COMMITTEE MEMBERSHIP
Members
Freeman Allen
Terry Blacka
Jack Burgess
Gerry Currier
William Deal
John DeVido
William Dorris
Jack Edwardson
Paul Eisele
Jon Heinrich
Gary Hunt
Alan Klimek
John Lingelbach
Brian Morton
Peter Nicholson
Susan Perry
Andy Riedell
'David Rothermel
William Sale
Mike Soots
Richard Titus
Janet Vail
Stephen willcox
Susan Wildau
John Zeltsman
Affiliations
Sierra Club
PA Department of Environmental Resources
Pridgen Cabinet Works (Small Business)
AKZO Coatings
Bernhardt Furniture Company (Office Furniture)
Aqualon (Resins)
Lilly Industries (Coatings)
U. S. Environmental Protection Agency
MASCO Corporation
Wl Department of Natural Resources
NC Office of Waste Reduction
NC Department of Environment, Health", and Natural
Resources
Facilitator
NC Environmental Defense Fund
Rohm and Haas (Resins) .
Business and Institutional Furniture Manufacturers
Association
PPG Industries (Coatings)
Stylecraft Corporation (Small Business)
Broyhill Furniture (Residential Furniture)
Kincaid Furniture (Residential Furniture)
Kitchen Cabinet Manufacturers Association
Vest MI Environmental Action Council
American Lung Association of NC
Facilitator
Architectural Woodwork Institute (Small Business)
aLeft the State of Pennsylvania in December 1993 and is now with Rettew
 Associates in Lancaster,  Pennsylvania.
                                1-6

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                    2.0   INDUSTRY DESCRIPTION

2.1  INDUSTRY STRUCTURE
     The structure of the wood furniture industry is presented in
Table 2-I.1"3  There are  10 Standard Industrial Classification
 (SIC) codes which cover what was analyzed for the development of
the Control Techniques Guideline for the "wood furniture*
industry.  The 10 SIC codes include Wood Kitchen Cabinets; Wood
Household Furniture (except upholstered); Wood Household
Furniture (upholstered);  Wood Television, Radios, Phonograph, and
Sewing Machine Cabinets;  Household Furniture Not Classified
Elsewhere; Wood Office Furniture; Public Building and Related
Furniture; Wood Office and Store Fixtures; Furniture and Fixtures
Not Elsewhere Classified; and Custom Kitchen Cabinets.  A more
detailed description of the products included in these industries
is provided in Table 2-1.  Three of the SIC codes, 2519, 2531,
and 2599, include the manufacture of nonwood products.  However,
the CTG will apply only to those products manufactured of wood
and wood products (including particle board, reed, rattan,
wicker,  etc.)   One of the SIC codes, 5712, was not included in
the draft CTG.   This SIC  code includes primarily furniture and
cabinet retailers.  However, one commenter on the NESHAP
indicated that this SIC code also includes manufacturing of
custom cabinets.   Custom  cabinet manufacturers operating under
SIC code 5712  will be subject to this CTG, but due to the limited
data that EPA has for these facilities, the impact of the
presumptive RACT requirements on these facilities is not included
in this  document.   They are also not included in the tables in
this chapter that present information on the distribution of wood
furniture manufacturing facilities.
                               2-1

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      Table 2-2 presents the relative number of facilities in each
 of the nine SIC codes (based on the 1987 Census data).1"3
 Facilities in SIC codes that manufacture furniture that  can be
 labeled as wood household or residential constitute approximately
 34 percent of the total and are concentrated in western  North
 Carolina;  wood kitchen cabinet manufacturers represent about
 29 percent of the total and are concentrated in Pennsylvania and
 the Midwest.   Facilities in SIC codes that manufacture products
 that can be labeled as business or office furniture represent
 24 percent of furniture manufacturing facilities and these
 facilities are concentrated in Michigan.4  The number of wood
 furniture  manufacturing facilities by EPA region is presented in
 Table 2-3.  The largest number of facilities,  2,721,  are  located-
 in Region  IV,  which includes the southeast States;  Region IX,
 which includes California,  has 2,007  facilities.1"3
      As  shown in Table 2-1,  the wood  furniture industry  is
 comprised  primarily of small plants;  86  percent of  the facilities
 have  fewer than 50  employees.   In comparison,  large facilities
 constitute  only 3 percent  of all wood furniture facilities.   Wood
 furniture  facilities  with  more than 20 employees  are  concentrated
 in North Carolina and California.4  Small  facilities  are usually
 batch operations, are not  generally automated,  and  have  a
 comparatively  low level  of  inhouse  technical  expertise.   Large
 facilities  are  usually highly automated,  continuous operations.
      Furniture  Design and Manufacturing magazine  ranks the top
 300 wood furniture  plants every  year  by  total  annual  sales
 (referred  to as  the FDM  300).5   The 1990  FDM  300  overall  ranking
 assigns Steelcase No.  1, Masco No.  2, Interco  No. 3,  and Herman
 Miller No.   4.   (The 1991 ranking placed Herman Miller as  No.  3
 and Interco as No.  4).  The  1990 FDM  300 also  ranks the  top
 10 companies in  three  categories of wood furniture, including
 residential, office/institutional, and kitchen cabinet furniture
manufacturers.  These  companies, and  their corresponding  annual
 sales, are  presented  in Table 2-4  (the 1991 ranking was not
broken down by industry segment and is therefore not presented).
Masco Corporation, which manufactures both household/residential
                               2-3

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           TABLE 2-2.  WOOD FURNITURE SIC CATEGORIES
                                                    1-3
SIC
code
2434
2511
2512
2517
2519
2521
2531
2541
2599
Industry
Wood kitchen cabinets
Wood household furniture, except
upholstered
Wood household furniture, upholstered
Wood television, radios, phonograph, and
sewing machine cabinets
Household furniture, not elsewhere
classified
Wood office furniture
Public building and related furniture
Wood office and store fixtures,
partitions, shelving, and lockers
Furniture and fixtures, not elsewhere
classified
Percentage
of total
facilitiesa
29
23
9
b
b
5
4
15
13
  aBased on 12,671 establishments for the nine SIC codes.
        than 1 percent.
furniture and kitchen cabinets, is the parent company of many
well-known companies including Merillat Industries, Henredon
Furniture Industries, Fieldstone Cabinetry, and Universal
Furniture.  Interco Corporation, which makes
household/residential furniture, includes Broyhill Furniture,
Ethan Allen, and The Lane Company, among others.  Of kitchen
cabinet manufacturers,  Merillat is believed to control the
largest portion of the market, approximately 10 percent.6'7  No
single company is believed to control more than 5 to 6 percent of
the household/residential furniture market.^
     The "wood furniture industry" is commonly grouped as
household/residential furniture, office/business furniture, and
kitchen cabinet furniture.  Facilities that produce these types
of furniture may be grouped together throughout the discussion in
this chapter.  These are intended to be general labels that
provide basic information about a facility's final product and
that identify the use and destination of the final product; the
                               2-4

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TABLE 2-3.  WOOD FURNITURE FACILITIES BY EPA REGION
                                                   1-3

Reqion I
Connecticut
Maine
Massachusetts
New Hampshire
Rhode Island
Vermont
Region II
New Jersey
New York
Reaion III
Maryland
Pennsylvania
Virginia
West Virginia
Reaion IV
Alabama
Florida
Georgia
Kentucky
Mississippi
North Carolina
South Carolina
Tennessee
Reqion V
Illinois
Indiana
Michigan
Minnesota
Ohio
Wisconsin

Reqion VI
Arkansas
Louisiana
New Mexico
Oklahoma
Texas

Total
facilitiesa
147
20
272
52
11
31
533
447
748
1,195
141
448
229
10
.828
203
868
318
98
167
690
79
298
2,721
351
313
283
219
325
232
1,723
117
23
72
34
468
714
Facilities with
20 employees or
more
35
7
72
14
5
13
146
65
1,195
1,260
30
149
81
2
262
69
134
82
31
90
353
24
123
906
104
131
91
49
81
69
525
44
3
8
11
135
201
                         2-5

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                   TABLE 2-3.   (continued)


Reqion VII
Iowa
Kansas
Missouri
Nebraska
Reqion VIII
Colorado
North Dakota
South Dakota
Utah
Reqion IX
Arizona
California
Nevada
Reqion X
Idaho
Oregon
Washington

Total
facilities5
53
52
166
28
299
156
18
10
91
~275
190
1,789
28
2,007
25
178
259
462
Facilities with
20 employees or
more
25
20
52
9
106
26
5
2
28
61
42
527
6
575
2
31
48
81
aNo data available for States not listed.
 information for the following SIC codes:
 2517,  2519, 2521, 2531,  and 2541.
Includes
2434,  2511, 2512,
                             2-6

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    TABLE  2-4.   1990 FDM  300 TOP 10  FURNITURE MANUFACTURERS5


Market
Residential











Kitchen cabinet









Office/institutional











Rank
1
2
3
4
5

6
7
8

9
10
1
2
3
4
5
6
7
8
9
10
1
2
3
4
5
6
7
8
9
10


Name
Masco Corp.
Interco
Ohio Mattress Co.
La-Z-Boy Chair Co.
Bassett Furniture, Industries,
Inc.
Ladd Furniture
Simmons OSA
Thomasville Furniture Industries,
Inc.
Mohasco Corp.
Klaussner Furniture Industries
Masco Corp.
Triangle Pacific Corp.
WCI Cabinet Group
American Woodmark Corp.
Aristokraft
KraftMaid Cabinetry, Inc.
Wood-Mode Cabinetry
Rivera Cabinets
HomeCrest Inc.
The St. Charles Companies
Steelcase, Inc.
Herman Miller, Inc.
Haworth, Inc.
HON Industries, Inc.
Kimball International, Inc.
Knoll International
Allsteel, Inc.
Virco Manufacturing Corp .
Westinghouse Furniture Systems
Shelby William Industries, Inc.
Annual
sales ,
million $
l,200a
I,l00b
700b
553b
466b

450b c
425b
417a

400a
250b
300a
185b =• -
180b
160b
>130b
<100b c
85a
80b
60a
58a
l,800b
793b
>500b
500a c
475b
275a c
220b c
183a
170b
169b
fBased on 1988 sales data.
'-teased on 1989 annual sales data.
cEstimated.
                                2-7

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generalizations are not  intended as descriptive classifications
  i
of the manufacturing process.  For example, manufacturers within
the household/residential group may use a variety of different
raw materials and manufacturing methods.  Differences would be
apparent in finish application methods, finishing sequences,
types of wood or wood product used, and types of finishes used.
The household/residential, office/business, and kitchen cabinet
groupings are qualitative descriptions and were not used in
categorizing the industry for control technique analysis.
     There are many different grades and styles of furniture.
The three grades of furniture are often described by the industry
as high-end, medium-end, and low-end.  Generally, high-end
furniture is constructed of" solid wood and wood veneers and has
the wood grain showing through the finish.  The finishing process
includes multiple finishing steps and is labor intensive.  Low-
end furniture, on the other hand, is often made of medium density
fiberboard (MDF)  with some plastic components and some natural
wood.   Also, the piece often has either a colored or printed wood
grain finish,  and the finishing process is less labor intensive.
Medium-end furniture may be made of some combination of MDF and
solid wood and may or may not show the natural wood grain.  The
cost of higher end furniture is more expensive due to the quality
of materials used and the slow,  labor intensive production
process.4
     For the same production level (or the same number of
furniture pieces),  the VOC emissions are greater for high-end
furniture compared with those emitted from lower end furniture.
The manufacture of high-end furniture often entails a series of
finishing steps,  up to 15 steps with multiple applications of
some finishing steps,  while low-end furniture involves fewer
finishing steps (in some instances as few as one).   More
finishing steps are performed for each piece of higher end
furniture than for low-end furniture,  and therefore more VOC
solvent is used.   The difference in VOC emissions between plants
with the same  production levels makes it difficult to predict
emissions from a particular plant based on production.4  Though
                               2-8

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 the low-,  medium-,  and high-end furniture designations  are used
 frequently by the  industry,  they are qualitative descriptions and
 therefore  were not used in categorizing the industry.
 2.2  FINISHING PROCESS
      The finishing process used in the wood furniture industry
 consists of some combination of finish application,  sanding and
 rubbing, and drying in ovens  and/or flashoff areas.  Finishing
 application techniques include  spray application and flatline
 finishing  techniques and in some instances,  hand application
 techniques.   Wood  furniture finishing basically consists of
 applications of a  series of  color coats (stains,  toners, etc.)
 and clear  coats  (washcoat,  sealer,  topcoat,  etc.).   The furniture
 piece may  be sanded, rubbed,  or polished and may-pass through
 drying ovens or flashoff areas.
      In the  wood furniture finishing process,  the finishes
 applied penetrate the  wood and  become an integral part  of  the
 final product.  The  finishes  enhance the qualities and  the  look
 of  the wood,  especially  for high-end furniture.   Many different
 types of wood, fiberboard, and  particleboard are  used,  and
 finishes react differently with each;  a finishing step  in a
 finishing  sequence must  be compatible not only  with  the wood
 substrate  but also with  the successive finishing  steps.   In the
 wood  furniture industry, each type  of  finish used for a
 particular step within a finishing  sequence  is  unique in color,
 solids content, VOC content, and  carrier solvent; successive
 finishes must be formulated as part  of  a complimentary  finishing
 system.  A single limit on VOC level applicable to all  finishes
 is difficult to require given the uniqueness  of each finish type
within a finishing sequence.4
     Geographic location and seasonal  changes affect the
 finishing material  formulation used.   Finishes  required for use
 in dry,  cool climates are different from finishes necessary for
hot, humid climates.  Often times, the necessary finish
formulation may change seasonally within a single plant.  The VOC
content and composition is adjusted to account for changes  in the
                               2-9

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 drying  time and  the overall ease of application of each  finish in
 relation  to ambient temperature and the humidity.4
     Some furniture facilities may operate more than one 8-hour
 shift per day.   Finishing operations, however, usually only occur
 during  the day shift.  In some facilities, the finishing area is
 in a separate room, apart from the woodworking operations.  In
 others, finishing occurs in a separate area within the same room
 as woodworking activities.  The finishing process is often labor
 intensive, especially for some types of furniture manufacturing
 processes.
     In small facilities the furniture is sometimes moved between
 stations  manually.  In most facilities, however, the furniture is
 moved mechanically along the finishing line; the furniture may be
 moved by  in-floor tow lines, overhead monorails, or by conveyor
 belt (mostly for flatline finishing).  Tow-lines are chains or
 cables mounted in or on the floor,  which move a pallet along the
 finishing  line.  The pallets can rotate and can be automatically
 disengaged from and reengaged to the tow-line to allow pauses, as
 needed.   Some facilities move the furniture on pallets that are
 hung from overhead chain conveyors.   Belt, roller,  and slat
 conveyors are also used.   Many facilities use a combination of
 these methods to transport the furniture along the finishing
 line.
     Wood furniture can either be finished and then assembled, or
 assembled and then finished.  In Europe,  most furniture  design is
 such that the individual components  that make up a piece tend to
 be flatter and more uniform than those used in furniture
manufactured in the United States.   For this reason,  furniture in
 Europe  is often finished before assembly.   Furniture manufactured
 in the United States,  however,  is generally made up of
 irregularly shaped,  nonflat components,  and most United  States -
made furniture is assembled and then finished (this is true
mostly for household/residential and office/business).   The
exception is kitchen cabinets that are manufactured in the United
States,  which are frequently finished before assembly.
                              2-10

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      The application methods, the types of finishes,  and the
 finishing sequences used in wood finishing are discussed in the
 following sections.
 2.2.1  Finish Application Methods
      There are various finish application techniques  used in the
 wood furniture industry.   The two principal methods used are
 flatline finishing and spray application.  Flatline finishing is
 used to finish pieces that are generally flat.   For nonflat
 pieces,  preassembled pieces,  or pieces with many recesses,  this
 application method is generally not used.  Brushing and dipping
 are feasible application methods in these instances,  but spray
 application is the most prevalent method used to finish nonflat
 parts.   In the wood furniture industry,  spray application -
 accounts for 87 percent of finish application whereas flatline
 finishing accounts for 13 percent.9
      2.2.1.1  Flatline Application.   If  components  are finished
 before assembly and are flat  or relatively flat,  "flatline"
 simple finishing processes can be used.   In flatline  finishing,
 the  furniture  pieces are  transported by  conveyor and  are finished
 by spray finishing,  roll  coating,  curtain coating,  or dip
         *  q
 coating.  >y  The industry denotes  these  as  "continuous  coaters"
 because  the  excess  coating (that  which does  not  remain  on the
 part) is constantly recirculated  to  the  coating  reservoir and
 then reused.   Fifty-five  percent  of  flatline  finishing  is
 performed by dip coating;  roll  and curtain coating  each account
 for  14 percent.9  It  is not known  how the remaining flatline
 finishing  is performed.   (Subsequent references to  flatline
 finishing  in this discussion will  refer  to roll-, curtain-, or
 dip-type  coating of furniture pieces.)
     Roll  coating involves the  transfer of finish to a  flat piece
 by a roller or series of rollers.  Curtain coating involves
passing a  flat piece through a cascade, or curtain,  of  finishing
material.  In dip coating, the piece is finished by passing
through a container  (vat)  of finishing material and by submerging
or partially submerging and withdrawing the piece.
                              2-11

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      2.2.1.2   Spray Application.   Since  the majority of wood
 furniture manufactured in the United States consists of nonflat
 pieces,  finishes  are usually spray-applied.  The spray
 technologies  that can be  used include  conventional air, airless,
 air-assisted  airless (AAA), electrostatic, the UNICARB® spray
 system,  and high-volume low-pressure  (HVLP).
      The conventional air spray technique uses compressed air  (at
 pressures greater than 10 pounds per square inch at the point  of
 atomization)  to atomize the finishing  materials as they are being
 sprayed.  Airless spraying involves atomizing the finish by
 forcing  it through a small opening at  high pressure.  The liquid
 coating  is not mixed with air before exiting the nozzle.  Air-
 assisted airless  spray uses an airless spray unit with a
 compressed air jet  to finalize breakup and help shape the spray
 pattern  of the finish material.
      Electrostatic  finishing has long  been used in the
 metalworking  and  automobile industries specifically to finish
 metal products.   In  the wood furniture industry,  electrostatic
 spraying has  had  somewhat  limited use, mostly by cabinet and
 chair manufacturers.   Finishing is performed by spraying
 negatively-charged  finish  particles onto grounded wood products.
 If the wood piece has  a sufficient moisture content to make it
 conductive, it can be  electrostatically sprayed without
 pretreatment.  However, some wood must be pretreated to make it
 conductive so that it  will draw the negatively charged finish to
 its surface.  Some of  these pretreatments can be mixed with water
 to act as a carrier;  some  pretreatment materials,  however, may
 contain VOC.
     The UNICARB® system  is a patented system for spray finishing
 developed by Union Carbide.  A finishing material normally
 contains both coalescing  (slow-evaporating)  and diluent (fast-
 evaporating) solvents.  The UNICARB® technology replaces the
 diluent solvents  from  the  finish mixture with liquid carbon
 dioxide  (C02).  The C02/coalescing solvent finish mixture is used
 to finish the wood furniture products with an airless spray gun.
When the finish leaves the spray nozzle,  the carbon dioxide in
                              2-12

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 the mixture immediately flashes;  the paint,  which still  contains
 coalescing solvents,  continues enroute to the piece.   The
 deposited paint  then  flows and cures in the  conventional way.
      High-volume low-pressure spraying involves the use  of  a high
 volume  of air delivered at an effectively low pressure to atomize
 a finish into a  pattern of low-speed particles.   The use of low
 pressure can result in decreased  overspray,  which translates into
 less finish usage and thus,  less  VOC emissions.   Not all HVLP
 systems are alike.  The most important distinction is  between  the
 two basic air supply  designs.   One  type of HVLP system converts
 80 to 100 pounds per  square inch  (lb/in.2) shop air to 10 lb/in.
 or lower.   The other  type  of HVLP system uses a turbine  generator
 to supply high volumes of  air at  low pressure?
      According to a turbine-based HVLP system vendor,  the
 turbine-based units can offer several advantages.1^1 Some turbine
 units supply  a heated air  stream.   In some instances,  this  heated
 air can improve  coating flowability and speed drying.  However,
 the airstream temperature  is not  always controllable,  and
 depending  on  the  finishing material  characteristics and
 environmental  conditions,  the  heated air stream is  not always
 desirable.  Because the  turbine units do not  use plant air,  the
 HVLP  systems  are not  affected  if  the existing shop  air lines are
 not working at full capacity.  The turbine units can be  designed
 to  supply  air at a certain pressure,  usually  around 10 lb/in.2.
 With  these turbine units,  it is not  possible  to achieve  pressures
 greater  than  the design pressure  (which is low).  By limiting the
 available pressure,  emissions  can be minimized.  The nonturbine
 HVLP systems convert  shop air  at  80  to  100 lb/in.2  to the lower
pressure required by  the HVLP  gun.   Because the shop air  is
 available at pressures exceeding 10  lb/in.2,   enforcing a
 10  lb/in.2 limit can be difficult.
     Disadvantages to the turbine HVLP units have also been
 identified.11  In some instances,  turbine systems offer
insufficient pressure  to provide effective atomization with
higher viscosity materials.  If less than 10 lb/in.2 is supplied
to the HVLP gun,  poor  atomization may result unless the finish is
                               2-13

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 cut with  solvents  to  lower  the viscosity.  A disadvantage of HVLP
 systems in  general is that  the HVLP  systems  are  reportedly not
 always able to apply  finishes as quickly as  the  other spray
 techniques.  However,  an air assisted airless HVLP gun has been
 developed.   The air pressure is limited to 10 lb/in.2, but
 reportedly  the use of higher fluid pressures enables the guns to
 supply finishes at rates comparable  to airless and air assisted
 airless spraying.12
 2.2.2  Finishing Materials
     The  wood furniture finish is applied in a series of steps.
 There is  great variety in the number, type,  and  order of
 finishing steps that  are applied.  Different types of the seven
 different finishes described "below are available, including
 conventional low-solids lacquers and relatively  higher-solids
 conversion  finishes,  polyurethane finishes,  and  unsaturated
 polyester/unsaturated polyacrylate (UPE/UPA)  finishing materials.
 The types of wood  furniture finishes used in the; U.S., Europe,
 and Japan are presented in Table 2-5.13
        TABLE 2-5.
FINISHING MATERIALS USED IN THE WOOD
  FURNITURE INDUSTRY13
Region
USA
Europe
Japan
Percent
Lacquers
75
29
32
Conversion
finishes
15
17
17
Polyurethane
finishes
4
32
30
UPE/UPA
f inishesa
6
22
20
  aUnsaturated polyester/unsaturated polyacrylate finishes.

     In the United States, lacquers  (mostly nitrocellulose-based)
are used by approximately 75 percent of the wood furniture
industry (commonly household/residential furniture).
Nitrocellulose lacquers have been used in the wood furniture
industry for many years; they are easy to use  (forgiving), .quick
drying, easy to repair, and familiar.  Approximately 15 percent
of the wood furniture industry uses conversion finishing
materials  (mostly acid-catalyzed finishes).14  To date,
                               2-14

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 polyurethane and unsaturated polyester and unsaturated
 polyacrylate finishing materials have seen limited use in the
 U.S.
      In Europe,  lacquers are not used as  extensively  as
 polyurethane finishes,  as seen in Table 2-5.   Approximately
 32  percent of the wood furniture industry in  Europe uses
 polyurethane finishing materials,  29  percent  uses  lacquers,
 22  percent uses  unsaturated polyester/unsaturated  polyacrylate
 finishes,  and 17 percent uses urea or melamine resin-based
 conversion finishes.   The breakdown of finish usage is similar  in
 Japan.^  The lacquers used by the European wood furniture
 industry are used primarily by the residential wood furniture
 manufacturers.   The kitchen cabinet industry  in Europe-uses  two-
 component  polyurethane systems and unsaturated polyester/
 polyacrylate systems  to a wider extent than the European
 furniture  industry because they require additional chemical  and
 mechanical  resistance.   Acid-curing conversion finishes are  also
 used by  the European  kitchen cabinet  industry,  but their  use is
 decreasing  (possibly  over concern  with the  associated
 formaldehyde emissions).14
     The basic steps  in wood furniture finishing (in
 generally-used order) and their purposes are  as follows:
     1.  Stain.15'25  Adds  initial  color,  evens out color and
 accents the natural wood grain.  Stains usually have a very  low
 solids content (less  than 5  percent by volume).  Includes
 nongrain raising  (NCR)  stains  such  as  equalizers,  prestains,  sap
 stains, and body stains;  no-wipe stains and toners.  Nongrain
 raising stains are dye-type  stains  that are intended to give
 clarity and depth to  the wood  finish.   Dye-type stains consist  of
 dyes that are dissolved  in methanol.   The dye  is completely
 dissolved in the methanol, so  it does  not contribute to the
 solids build on the furniture.  No-wipe stains  are pigmented
 stains that are sprayed on and not wiped that  contain a small
amount of oil, pigment, and solvent.  No-wipe  stains are  used to
accent the wood grain, provide color uniformity, and provide  for
color retention.
                               2-15

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     Toner  is  a  type  of  stain that evens out  the  color of.  the
 initial application of stain.  Toners contain higher solids than
 initial stains.  Toners  contain nitrocellulose or vinyl binders,
 dissolved in solvent.  Toners are not wiped,  and  are often
 pigmented.
     2.  Washcoat.15'25  Low-solids  (usually  2 to 13 percent by
 volume) finishing material used to assist in  filling or color
 uniformity, to aid in adhesion, and partially seal the wood from
 subsequent  staining operations.  Washcoat also prepares the wood
 surface for sanding after stain application.  Some facilities buy
 sealer in bulk,  and dilute their sealer to make washcoat.  There
 are three main types  of washcoat materials:   standard
 nitrocellulose, viriyl or modified vinyl types, and vinyl-
 modified/conversion types.  Advantages of nitrocellulose
 washcoats include quick drying, easy sanding, and clarity.  Vinyl
 and vinyl-modified washcoats consist of.nitrocellulose and vinyl
 and provide better toughness and adhesion than pure
 nitrocellulose washcoats; however, some clarity is sacrificed.
 The "conversion" or precatalyzed-type washcoats also provide good
 adhesion and toughness, and are good for open pore woods.
 Because they react in place,  they are impervious  to solvents
 contained in subsequently applied sealers and topcoats.
     3.  Glaze/filler.15'25  Usually highly-pigmented wiping
 stains that contain oil and are used in finishing furniture where
 open pore woods such as oak and mahogany are used.  Sometimes,
 relatively  closed-pore woods such as cherry are also filled.
 Glazes and  fillers are usually supplied as heavily pigmented,
 high-solids, low-VOC materials,  which are reduced on the job.   As
 supplied,  the solids contents of glazes and fillers are  in the
 75 percent  solids by volume range.  Once reduced,  the solids
 contents usually range from 10 to 45 percent by volume.   Glazes
 and fillers are usually spray applied,  then wiped into the wood.
     4.  Sealer.15'25  Usually a nitrocellulose-based lacquer.
Vinyl or vinyl-modified sealers and catalyzed sealers (including
 acid-cured alkyd amino vinyl sealers) are also available, and
provide advantages similar to those of their washcoat
                              2-16

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 counterparts.   Primary purposes  of  sealers  are to provide
 adhesion,  enable sanding,  to increase build,  and to seal the  wood
 and establish  a foundation for artistic  enhancement.   Solids
 contents  typically  range  from 10 to 30 percent by volume.
      5.   Highlight.15"25   Color  coat that is  applied sparingly to
 accent and give character to the wood.   Includes shading and
 padding stains as well as spatter.   Highlight is usually manually
 applied using  brushes,  sponges,  or  rags.  Distressing of
 furniture to obtain a  desired finish could  also be done at this
 point in  the finishing sequence.  Solids contents vary from less
 than 1 to 49 percent solids  by volume.  Generally low solids
 contents  (less than five  percent  by volume).
      6.   Topcoat.15'25 A clear  coat whose  function is to protect
 the color coats,  enhance  the beauty of the  furniture,  and provide
 a durable  final  finish.   Typical  solids contents range from 13 to
 30  percent  solids by volume.   There are four  categories of
 topcoats:   standard nitrocellulose  topcoats,  acrylic  topcoats,
 catalyzed  topcoats, and conversion  varnishes.   The advantages of
 nitrocellulose  lacquers are  that  they provide the best clarity,
 pick  up little dirt, dry quickly, and are easy to wipe off and
 repair.  Acrylic lacquers  are  used  over white or pastel finishes
 as  protection  from  common  household products.   They can also be
 applied over nitrocellulose  topcoats  for color retention.  The
 clarity of  acrylic  lacquers  is not  as good as the nitrocellulose
 lacquers.
      Catalyzed topcoats, like  catalyzed sealers,  are  available in
 one-  and two-pack form.  The one-pack coatings  are precatalyzed
 and contain nitrocellulose resins and a smaller percentage of
 urea  resin.  Because only a  small amount of catalyst  is added, it
 can take up to 3 to 4 weeks  after application until the coating
 is completely cured, although  it dries to the touch much sooner.
The shelf life of precatalyzed coatings is more than  6 months.
     The two-pack coatings consist of two packs,  one  contains
urea or melamine-based resins, and the other  contains  the
catalyst.   The two components must be mixed before use.  More
catalyst is added to two-pack catalyzed coatings, so  cure time is
                               2-17

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 short  (on the order of  minutes  or  hours).  Two-pack catalyzed
 coatings  have a limited "pot  life" after mixing  (from 1 day to
 more than a  week).
     Conversion varnishes  do  not dry as quickly as nitrocellulose
 topcoats,  and are difficult to  spot repair, with washoff also
 being difficult or  impossible.  Acid-cured alkyd amino conversion
 varnishes are used  extensively  by  the kitchen cabinet
 manufacturing industry.  Conversion varnishes, like 2-pack
 coatings,  have a limited pot  life.
 2.2.3  Finishing Sequences
     The  finishing  sequence for wood furniture finishing
 operations includes various finish application steps, as well as
 intermediate  sanding, -rubbing,  and polishing and drying steps.
 Drying of  the furniture  piece is performed between finishing
 steps by  flashoff (ambient drying with or without forced air)
 and/or oven drying.  Finishing  sequences vary considerably from
 plant to plant,  with some  manufacturers using more or less steps
 than other manufacturers.  The  finishing sequence varies based on
 a number of factors, including  the piece that is being finished,
 the desired finish  quality, and the finish application method.
The finishing  sequences  provided are intended to be
 representative  of operations in the wood furniture industry.
This section  discusses three typical finishing sequences:  short
 spray finishing  sequence;  long spray finishing sequence; and
roll,  curtain, and  dip finishing sequence.   A summary of the
various finishing sequences is presented in Table 2-6.
     A wide range of wood  furniture products may be finished
using the  same  finishing sequences; for this reason,  multiple
segments of the  industry may have the same finishing sequence.
 In addition,   the same type of furniture may be finished using
different  types  of  finishing sequences.  For example,  some
residential furniture,  SIC code 2511,  may be finished using the
short spray finishing sequence and some may be finished using a
 long spray finishing sequence.
     2.2.3.1  Short Spray Finishing Sequence.4  As seen in
Table 2-6, a typical finishing sequence for short spray finishing
                              2-18

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             TABLE 2-6.  TYPICAL FINISHING SEQUENCES4
Short spray finishing
Sap/equalizing stain
Air dry
Prestain toner/penetrating stain
Air dry
Sealer
Air dry
Oven
Sand
Topcoat
Air dry
Oven









Long spray finishing
Sap/equalizing stain
Air dry
Prestain toner/penetrating stain
Air dry
Washcoat
Air dry
Sand
Glaze/filler
Wipe
Air dry
Oven
Sealer
Air dry
Oven
Sand
Highlight
Air dry
Topcoat
Air dry
Oven
Roll, curtain and dip finishing
Stain
Air dry
Sealer
Air dry
Oven
Sand
Topcoat
Air dry
Oven







""



involves spray application of stain,  (e.g., equalizing stain
followed by a toner) sealer, and topcoat.  Wood furniture
facilities that finish products by short spray finishing
sequences occur in nearly all of the industry's SIC codes, as
seen in Table 2-7.
     2.2.3.2  Long Spray Finishing Sequence.4  A representative
long spray finishing sequence consists of spray application of
multiple stains,  followed by washcoat, glaze/filler, sealer,
highlight, and topcoat.  Facilities that finish furniture with a
long spray finishing sequence can be in market segments
represented by the five SIC codes seen in Table 2-7.
     2.2.3.3  Roll.  Curtain.  Dip Finishing Sequence.4  Use of the
roll, curtain,  and dip finishing sequence also occurs in six SIC
code industries,  as  listed in Table 2-7.  A typical finishing
sequence for roll,  curtain,  and dip finishing includes
application of  stain,  sealer,  and topcoat.
                              2-19

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   * TABLE 2-7.   WOOD FURNITURE INDUSTRY STRUCTURE BY FINISHING
                            SEQUENCE4
Finishing sequence
Short spray finishing sequence
Long spray finishing sequence
Roll finishing sequence
SIC
2434
2511
2512
2519
2521
2531
2541
2599
2511
2517
2519
2521
2531
2434
2517
2521
2531
2541
2599
codes
- Kitchen Cabinets
- Residential Furniture
- Upholstered
- Furniture , n . e . c .
- Office Furniture
- Public Building Furniture
- Store Fixtures
- Furniture and Fixtures, n.e.c.
- Residential Furniture
- Radio, Television Cabinets
- Furniture, n.e.c.
- Office Furniture
- Public Building Furniture
- Kitchen Cabinets
- Radio, Television Cabinets
- Office Furniture
- Public Building Furniture
- Store Fixtures
- Furniture and Fixtures, n.e.c.
2.3  EMISSION SOURCES
2.3.1  Industry Source Definition
     The CTG for wood furniture finishing and cleaning operations
will apply to the 10 SIC codes for the wood furniture industry
that were identified in Table 2-I.1"3  In addition to these
10 SIC codes that were included in the CTG analysis,  a State may,
in developing their own rule, include other processes that they
believe are best described as a wood furniture finishing
operation.
     Three of the applicable SIC codes,  2519,  2531,  and 2599 ^
involve operations associated with nonwood products.   The
SIC Code 2519 includes household furniture not classified
elsewhere; SIC Code 2531 includes public building and related
furniture; SIC Code 2599 includes furniture and fixtures not
elsewhere classified.  It is important to note that  the CTG only
covers the wood furniture finishing operations associated with
those SIC codes.  For example, SIC code 2531 includes facilities
manufacturing seats for automobiles and buses.  These facilities
will not be covered by the CTG.  The CTG for wood finishing
operations does apply to finishing rattan and wicker.  The VOC
                               2-20

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 emissions from a wood furniture manufacturing facility resulting
 from operations other than finishing,  cleaning,  and washoff are
 not covered by the CTG for wood furniture coating.   For example,
 if  a wood furniture manufacturing facility is involved in gluing
 operations,  the CTG would not apply to VOC emissions from the
 gluing operations.
 2.3.2  ^mission Sources
      The  following discussions apply to the majority of finishing
 operations,  in which separate areas such as spray booths and
 ovens have separate ventilation.   There are many potential VOC
 emission  sources in a wood furniture manufacturing  facility.
 However,  four  primary VOC emission sources are associated with
 wood furniture finishing  operations.   These sources  include spray
 booths, flashoff areas, ovens,  cleaning operations,  and washoff
 operations.  An additional,  although comparatively minor,  source
 of  VOC emissions is  the actual  finished product.  These sources
 are further  discussed below.
      1.   Spray booths.  In the  wood furniture industry,  finishing
 materials  are  usually applied in  booths;  various types  of  spray
 application  equipment  are  used  for spray  finishing techniques  and
 various types  of  roller,  curtain,  and  dip coating application
 equipment  are  used for flatline finishing techniques.   (Booths
 for both  spray  finishing  techniques and flatline finishing
 techniques will  be generally  referred  to  as "spray booths"  in
 this discussion.)  The  booths are  commonly maintained at ambient
 conditions.  The spray  booth  type,  size,  exhaust flowrate,  and
particulate  control methods may vary widely within the wood
 furniture  industry.  The types of booths  that are used in  the
wood furniture  industry include manual  and automatic spray
booths.  The average size booth within  the industry is 2.5  meters
 (m)  high,  5.2 m wide, and 3.0m deep (8.1 feet [ft]  high,  17 ft
wide, and 9.9 ft deep).  The spray booth exhaust rates range from
42.5 cubic meters per minute  (m3/min) to 2,160 m^/min
 (1,500 standard cubic feet per minute  [scfmj to 76,300 scfm) ;  the
average exhaust rate is 527 m3/min  (18,600 scfm).  Table 2-8
shows the  average spray booth characteristics for the overall
                               2-21

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 industry  and  for various  segments of the industry.  Particulate
 control of overspray  is commonly achieved with either dry filters
 or water  curtains.

             TABLE 2-8.  SPRAY BOOTH CHARACTERISTICS9
Industry Segment
Manual booths
Automatic booths
Short spray finishing
Long spray finishing
Roll, curtain, dip finishing
Overall industry
Average dimensions,
m (ft)
2.4x5.8x3.0 (8.0x19x3.9)
3.0x2.6x3.7 (10x8.5x12)
2.5x5.8x3.0 (8.3x19x10)
2.3x4.6x2.8 (7.7x15x9.2)
1.5x3.4x1.9 (5.0x11x6.2)
2.5x5.2x3.0 (8.1x17x9.9)
Average exhaust,
m /min (ecfm)
609 (21,500)
66.3 (2,340)
583 (20,600)
629 (22,200)
453 (16,000)
527 (18,600)
     The majority of spray booths are operated using manual
finishing techniques; approximately 84 percent are operated by
manually finishing products and 16 percent apply finishes with
automatic finishing methods.9  Automatic spray booths are often
smaller in size than manual spray booths, and exhaust rates from
automatic spray booths are significantly lower than those from
manual booths.  Average dimensions for manual finishing booths
are 2.4 m by 5.8 m by 3.0 m (8.0 ft by 19 ft by 9.9 ft),  compared
with 3.0 m by 2.6 m by 3.7 m  (10 ft by 8.5 ft by 12 ft) for
booths with automatic spraying operations.  The average booth
exhaust from manual finishing operations is 609 m3/min
(21,500 scfm) and the average exhaust from booths with automatic
finishing operations is 66.3 m3/min (2,340 scfm).
     Booth dimensions for short spray finishing and long spray
finishing sequences are similar, as shown in Table 2-8.  The
average dimensions of booths used for the roll, curtain,  and dip
finishing sequence are smaller than those used for short and long
spraying.  The exhaust for the short spraying sequence is
583 m3/min (20,600 scfm)  and for the long spraying sequence is
629 m3/min (22,200 scfm).   The exhaust flowrate for the roll,
curtain, and dip finishing sequence is 453 nr/min (16,000 scfm),
somewhat lower than for short and long spraying sequences.
                               2-22

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      Spray booth characteristics may depend on whether  the
 components are finished and then assembled or are  assembled then
 finished.   The spray booths used to finish furniture  products
 that  are  first assembled and then finished are mostly open,
 i.e.,  all  sides are  open except the backside.   The booth design
 is  open to accommodate  entrance and exit  of larger pieces.   In
 segments  of the industry where manufacturers finish components
 before assembly,  the booths are generally fully enclosed except
 for slots  in the sides  of the booth.  The unassembled pieces are
 much  smaller than assembled components, so the pieces can  enter
 and exit  the booths  on  conveyors through  these slots.
     Many  spray booths  are equipped with  dry filters, typically a
 paper  material,  to control particulates.   In the past, water
 curtains had been used  to control particulates.  However,  since
 the spent  water had  to  be disposed as a hazardous  waste,
 hazardous  waste disposal  costs had to be  considered.  As these
 costs  increased,  the  cost effectiveness of  water curtain
 filtration decreased.   Therefore,  most new  and modified spray
 booths  in  the wood furniture  industry that  use filters are
 equipped with dry filters.  However, some water-wash  spray booths
 are still  in use.
     2.  Flashoff areas.   Flashoff  areas,  where solvent is
 allowed to volatilize from the  finished piece, are located either
 between spray booths or between a  spray booth  and an  oven.  These
 areas are used  to allow solvent evaporation and partial curing
 prior to final  cure in the  oven or, in some instances, are used
 in lieu of an oven.   Some  flashoff areas have  forced air
 circulation and are referred to as  forced-flashoff areas.   Most
 flashoff areas do not have a separate exhaust.  A portion of the
 emissions from a flashoff area located in between a booth and an
 oven will be exhausted through the booth and oven;  the amount
 exhausted through the booth and oven depends on the total length
 of the flashoff area.  The length of flashoff areas varies
significantly by facility, and even within a facility.  A
flashoff area that is not followed by an oven is often longer
than one that is located in between a booth and an oven.
                               2-23

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     3.  Ovens.  Ovens are used between some finishing steps to
cure the finish prior to the next step in the finishing sequence.
Many types of ovens are used in the wood furniture industry.
Most are steam heated using either a wood- or coal-fired boiler;
others are gas-fired.  Turbulators and high velocity ovens are
frequently used.  Infrared (IR) or ultraviolet (UV)  ovens are
also used, but their use in the wood furniture industry is
limited at this time.  The parameters for the ovens can also vary
considerably.  Oven temperatures can range from less than 32.2°
to 19l°C (90.0° to 375°F) depending on the type of finishing
material used, the piece being finished, and the oven residence
time; the average temperature for ovens is 58.9°C (138°F).
Residence time ranges from l to 60 min, with an average of
13 min.  The exhaust rate from ovens also varies and can range
between 21.2 and 552 m3/min (750 and 19,500 ft3/min).   The
average exhaust rate from ovens in the wood furniture industry is
133 m3/min (4,690 scfm).9
     4.  Cleaning,  dilution,  and washoff operations.26  As
discussed previously, solventborne nitrocellulose lacquers are
the predominant type of finishing materials used by the wood
furniture industry today.  The resins in such finishes are
relatively "difficult" to dissolve,  so a high-solvency-rated
solvent must be used in their formulation.  Similarly, thinning
of these finishing materials requires the use of the same solvent
or one with equivalent solvency.  This solvent is generically
referred to as "lacquer thinner."  The current standard practice
is to use lacquer thinner for both incidental thinning of
premixed finishes and for cleaning and washoff.   Advantages of
the lacquer thinner include its compatibility with the finishing
materials and the ease with which it removes cured nitrocellulose
lacquers.
     In wood finishing operations, industrial solvents are used
predominantly for cleaning application equipment.  In addition to
application equipment cleaning, cleaning solvent can also be used
to clean out piping, clean booths and rails, strip cured finishes
from wood parts or machinery,  and periodically clean centralized
                               2-24

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 finishing material storage  and distribution  (pump  room)
 equipment.   They are also used to  strip  finishes from finished
 pieces  that do not meet  specifications.   This  process is  called
 washoff,  and it represents  a  significant portion of  cleaning
 solvent usage by the industry.  Although a major use of cleaning
 solvents  in some finishing  industries, surface preparation does
 not  require solvents in  the case of wood furniture finishing.
      Application equipment  must be cleaned every time there  is a
 color change,  every time there is  a change in  finishing material
 type (for smaller operations  with  limited equipment  and few
 booths),  and usually before the equipment is to be idled  for a
 period  of time (e.g., at the  end of the  day).  For spray  finish
 application; equipment cleaned with solvents includes spray  guns,
 feed lines,  and finish reservoirs  (where applicable).  In the
 case of roll,  curtain, and  dip coating operations, the rollers,
 spray bar nozzles,  and finish material containers  must be cleaned
 periodically to maintain application quality as well  as to change
 colors.
      Spray  guns have  traditionally been  cleaned by sending pure
 or reused solvent  through the gun  and atomizing the solvent  into
 the  booth ventilation system.   Recognizing that this  results in
 excessive emissions of solvent, some operators cut off the
 atomizing air  to the  spray  gun  and pump  the cleaning  solvent
 through the  gun into a container.  This  procedure  can be  followed
 provided  the gun is the  type that  does not depend  on  the  flow  of
 the  atomizing  air  to pump the finish (or cleaning  solvent)
 through the mechanism.  Alternately,  the  cleaning procedure may
 involve soaking the entire gun  in  solvent in a wash tank  or
 bucket.    This  guards against the possibility that  small amounts
 of finishing material inadvertently missed during the cleaning
will cure and  clog the small orifices of the gun.   Cleaning
 solvent is often reused within a facility and eventually  recycled
 in-house  or sent out for recycling/disposal.
     Generally, spray booth cleaning does not require significant
amounts  of solvent.  Usually,  a strippable coating is applied to
the spray booth walls so that when solids buildup reaches a
                               2-25

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 certain limit,  the  strippable  coating  together with the solids
 can be  removed, minimizing  the need  for solvents.16' 27
 Similarly,  the  spray  booth  exhaust filters are disposed of as
 solid waste when  they become clogged with coating solids.  The
 use of  cleaning solvents  for removal of finish overspray and
 drips is a  minor  use.
     In regard  to the use of industrial solvents for finishing
 material dilution,  the majority of facilities do not dilute
 finishing materials in-house;  finishes are ready to use as
 purchased.   However,  in some instances, finishes are diluted to
 decrease their viscosity  and improve their sprayability and
 performance.  Various factors  are considered in determining how
"much dilution is  required,  i.e., the dilution ratio.  In some
 instances,  the dilution ratio  remains constant, regardless of
 conditions,  while in  other  instances, the extent of dilution is
 dependent on seasonal conditions such as temperature and humidity
 and  may  also vary according to the material being diluted.  For
 example, a  facility may dilute sealers but not topcoat.  The VOC
 contents of  finishes  presented in Chapter 4.0 represent finishing
materials as they are applied; any dilution has been taken into
account.
     5.   Final Wood Product.   In addition to the above major
emission sources  for wood furniture  finishing operations,  the
 finished dried furniture may be a minor emission source.  The
finished piece may  have small quantities of solvent that
eventually volatilize.  However,  the amount of VOC emissions 'from
this source  are expected to be very minor,  most likely
representing less than 1 percent of  the total VOC emissions.28
2.3.3  VOC Emission Summary
     The annual consumption of solvents by paint and coating
industries has been estimated by SRI International for the
National Paint and Coatings Association,  Inc. (NPCA).2^  A
summary of the estimated solvent consumption for the various
paint and coating industries is provided in Table 2-9.   Because
the solvents used in wood furniture finishing operations do not
typically react with or become part of the finished product,  the
                               2-26

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    TABLE 2-9.  SOLVENT CONSUMPTION IN PAINTS AND COATINGS
         ORIGINAL EQUIPMENT MANUFACTURER^  (OEM), 1989
                     (Million of pounds)
Market
Solvent
consump t iona
Original Equipment Manufacturers (OEM)
Wood furniture and fixtures
Wood flat stock
Metal furniture and fixtures
Containers and closures
Sheet, strip, and coil
Major appliances
Other appliances
Automotive
Trucks and buses
Railroad
Other transportation
Machinery and equipment
Electrical, insulation
Paper, foil, and film
Other products finishes
OEM total
Architectural total
Special purpose total
Thinner and miscellaneous total
PAINT and COATINGS TOTAL
270
6
85
191
71
41
23
131
33
7
13
159
59
40
256
1,398
614
659
1,682
4,349
aOf the 256 million pounds of solvent consumed by the Other
 Product Finishes market,  250 million pounds are considered
 VOC's.  Similarly, of the 659 million pounds consumed by the
 Special Purpose market,  638 million pounds are considered
 VOC's, and of the 1,682  million pounds consumed in Thinner'
 and Miscellaneous coatings, 1,659 million pounds are
 considered VOC's.
                             2-27

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assumption has been made that solvent consumption is
approximately equal to solvent emissions.  Furthermore, because
the majority of the solvents consumed by the wood furniture
industry are considered VOC's, solvent usage is approximately
equal to VOC emissions.  While this assumption provides a
reasonable estimate of overall industry VOC emissions, it is
still important to note that there are some coatings used by the
wood furniture industry which form VOC's as reaction by-products
from a curing process that involves a chemical reaction (as
opposed to only by solvent evaporation).  In addition, there are
some coatings in which not all of the VOC's contained in the
coating evaporates; some of the VOC's may chemically react to
form the dry film.  Both polyester and some ultraviolet (UV)
coatings used by the wood furniture industry contain styrene
monomer, which reacts to form the coating.  Some of the styrene
is emitted during the application and curing of the coating.  As
indicated in this table,  the wood furniture and fixture industry
consumes more solvent than any other industry listed.  Other
industries that consume large amounts of solvent include the
containers and closures,  automotive, and machinery and equipment
industries.
     The breakdown of solvent usage by the wood furniture
industry is provided in Table 2-10.  As  indicated in this table,
the most frequently used solvent is toluene,  followed by xylenes,
alcohols,  ketones, and acetates.29
2.4  EXISTING REGULATIONS
2.4.1  Introduction
     The review of existing VOC regulations for wood furniture
finishing is helpful in defining potential control strategies and
their effectiveness.  The bulk of the research into existing wood
furniture regulations was done in 1990,  and revisions were made
based on the latest available revised versions of the
regulations,  as of January 1995.   This list of regulations should
not be considered an exhaustive list of  all State and local wood
furniture regulations.   Nine areas identified as having existing
regulations (as of January 1994)  are Illinois,  Indiana,
                              2-28

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    TABLE 2-10.  WOOD  FURNITURE INDUSTRY SOLVENT USAGE--198929
                       (Millions of pounds)
Solvent
Aliphatic hydrocarbons
Toluene
Xylenes
Other aromatics
Butyl alcohol
Ethyl alcohol
Isopropyl alcohol
Other alcohols
Acetone
Methyl ethyl ketone
Methyl isobutyl ketone
Ethyl acetate
Butyl acetates
Other ketones and esters
Glycol ethers and ether esters
TOTAL
Wood furniture
8.6
71.5
40.4
9.2
27.5
27.7
15.4
2.0
3.0
15.0
19.8
7.8
14.3
2.8
4.7
270
Massachusetts, New Jersey,  the New York  City Metropolitan  area,
Pennsylvania, and California's Bay Area, South  Coast, and  San
Diego County Air Pollution  Control Districts.   Each regulation
applies to furnishings made of solid wood, wood composition, wood
material, and/or simulated  wood material.  The  Massachusetts, New
York City, San Diego, Bay Area, and South Coast regulations also
apply to the coating of wood products.   Exemptions include
musical instruments, refinishing, replacement,  and custom
furniture operations for the Bay Area regulation, flat wood
panels for the Massachusetts regulation, and classic guitars
until January 1, 1996, and  refinishing,  replacement, and custom
furniture operations until  July l, 1996  for the South Coast
regulation.  The regulations use various strategies to limit VOC
emissions from wood furniture finishing  operations.  These
strategies include requiring the use of  certain application
methods,  such as airless,  air-assisted airless,  HVLP,  and
electrostatic spraying,  as well as roller coating, dipping, and
brushing.   Other regulations require the use of lower-VOC content
                              2-29

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or nonphotochemically  reactive finish materials or the use of
add-on controls such as incinerators and carbon adsorbers.  Some
of the regulations allow combinations of the above strategies to
achieve compliance.
2.4.2  Summary of Existing Regulations30"41
     The key features  of the nine existing wood furniture
finishing regulations  are summarized in Table 2-11.  The
regulations generally  apply to both existing and new facilities.
     All of the nine regulations contain applicability criteria
in terms of finishing  material use or VOC emission cutoffs.  The
applicability criteria used in the San Diego, New Jersey, Bay
Area, and South Coast  regulations is in terms of amount of
finishing material used on a per hour, per day, or per year
basis.  Potential and/or actual VOC emissions resulting from wood
furniture finishing operations are used to determine
applicability in the Illinois, Indiana,  Massachusetts,  New York,
and Pennsylvania regulations.  It is difficult to compare the
applicability criteria of the regulations since the bases vary.
Converting finishing material use to emissions, or vice versa,
would require several assumptions regarding VOC content of
finishes,  operating hours,  etc.
     All of the regulations,  except New York City's,  contain
restrictions concerning allowable finish application method
requirements.   The regulations generally specify application
methods chat are believed to achieve greater transfer
efficiencies than air or airless spray.   If an application method
has a higher transfer efficiency, less finishing material will be
needed and thus,  VOC emissions will be lower.  Initially, some of
the regulations provided transfer efficiencies for a variety of
application methods.   However, because the transfer efficiency of
an application method can vary based on many factors,  including
the size and shape of the piece being coated, and because there
is no EPA-accepted method of measuring transfer efficiency, the
lists of transfer efficiencies were removed from most of the
regulations.
                               2-30

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     Of the areas addressing specific application methods,
airless and air-assisted airless spraying are allowed under all
but San Diego's regulation, provided certain criteria are met.
Electrostatic spraying is allowed under all the regulations.
Roller coating, brushing, wiping, and dipping are acceptable
under all the regulations.  (Pennsylvania's regulation does not
specify wiping.)  High-volume low-pressure spraying is specified
as an allowable method under all of the California areas'
regulations, in Illinois' regulation, and in Pennsylvania's
regulation.  It was not specified as an allowable method under
the other area regulations because in the past it has not been
used widely in wood furniture coating operations.  The
Massachusetts regulation does not indicate specific allowable
coating application methods that may be used.
     Repair coating operations are allowed less-stringent
application method and transfer efficiency (T/E)  requirements
under Illinois', Indiana's, and Pennsylvania's regulations.  An
exemption for coatings used in small amounts is contained in the
Illinois,  Indiana,  and Massachusetts regulations.  The San Diego,
Bay Area,  and South Coast regulations also contain cleanup
operation restrictions to limit VOC emissions.
     Alternative compliance methods are allowed under all the
regulations except Pennsylvania's.   Each alternative compliance
program works differently and can be quite complex.  Under the
alternative compliance plans,  add-on controls can be used, in
conjunction with or instead of required application methods and
coatings.
     The baseline level to be used for calculating equivalent
emissions for alternative compliance plans varies for the
regulations.  Under the Illinois regulation,  the emissions
resulting from the use of an application method with a transfer
efficiency of 65 percent for all operations (except repair coats,
which require a 30 percent transfer efficiency),  and the use of
complying coatings throughout the facility, represent baseline
emissions.  Massachusetts'  and San Diego's baselines are the same
as Illinois' except that there is no repair coat exemption.  New
                              2-34

-------
 Jersey's  baseline  definition  is  similar  to those  for San Diego
 and  Illinois.   Baseline under Indiana's  regulation is represented
 by use  of required application methods for all  coating
 operations.  Baseline emissions  under the Bay Area regulation are
 those that result  from the use of airless spraying for all
 coating operations, assuming  that compliant coatings are used.
 The  South Coast regulation defines baseline emissions as those
 resulting from  the use of compliant coatings  (required as of
 January 1, 1989) for all coating operations, applied at a
 transfer  efficiency of 65 percent.  South Coast's regulation,
 however,  does not  allow credit for any emission reductions
 resulting from  the use of an  application method with a transfer
 efficiency greater than 65 percent.  This emissions reduction
 credit  was excluded because transfer efficiency is difficult  to
measure and thus,  resulting emissions reductions would be
difficult  to quantify.  Baseline emissions for  New York City  are
those that would result from  the use of coatings with VOC
contents  specified in the regulation.
     Table 2-12 presents the VOC content limitations associated
with the  eight regulations that contain such restrictions.  San
Diego,  Bay Area, and South Coast all have a phased approach.
Under the San Diego regulation, one set of VOC-content limits
applied through January 1,  1995,  when  more stringent limits
became effective.   There are four different phases to Bay Area's
regulation and three phases to South Coast's regulations.
                              2-35

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2.5  REFERENCES  FOR  CHAPTER 2

  l.  U.S. Department of  Commerce,  Bureau  of  the  Census,  1987
     Census  of Manufacturers,  Industry  Series  MC87-I-24B,
     January 1990.

  2.  U.S. Department of  Commerce,  Bureau  of  the  Census,  1987
     Census  of Manufacturers,  Industry  Series  MC87-I-25A,
     March 1990.

  3.  U.S. Department of  Commerce,  Bureau  of  the  Census,  1987
     Census  of Manufacturers,  Industry  Series  MC87-I-25B,
     April 1990.

  4.  ENSR Consulting and Engineering.   An Evaluation of  VOC
     Emissions Control Technologies for the  Wood Furniture and
     Cabinet Industries.  Sponsored by  American  Furniture
     Manufacturers Association, Business  and Institutional
     Furniture Manufacturers Association, Kitchen Cabinet
     Manufacturers Association, and National Paint and Coatings
     Association.  January  1992.

  5.  Chazin,  M., editor.  The  FDM  300.  Furniture Design and
     Manufacturing.   February  1990.  pp.-  20-158.

  6.  Telecon.  Caldwell, M.J.  Midwest  Research  Institute, with
     Titus,  R., Kitchen  Cabinet Manufacturers  Association.
     June 18, 1990.  Discussion of the  cabinet industry.

  7.  Telecon.  Smith, L., Midwest Research Institute, with
     Taylor,  R., American Woodmark Corporation.  June 18, 1990.
     Discussion of American Woodmark's  facilities.

  8.  Telecon.  Caldwell,  M.J.,  Midwest  Research  Institute, with
     Runyan,  L., American Furniture Manufacturers Association.
     November 29, 1990.  Discussion of  furniture market.

  9.  Memorandum.  Rasor,  S., MRI, to Strum,  M. , EPA/ESD/CPB.•
     Summary of Responses to the Information Collection Request
     for the Wood Furniture Industry.   January 28,  1994.

10.  Survey  response and attachments from Can-Am Engineered
     Products, Inc.,  to Caldwell, M.,  Midwest Research Institute
     March 15, 1990.   Response to information  request.

11.  The DeVilbiss Company.   HVLP:   High-Volume Low-Pressure.
     Brochure.  Toledo, OH.   Publication No.  F-817-A.  1989,
     14 pp.

12.  Contact Report,   Caldwell, M.  J.,  Midwest Research
     Institute,  with Kish,  S.,  Graco,  Inc.  August 12,  1991.
     Discussion of spray systems and their use with waterborne
     coatings.

                               2-37

-------
13.  Riberi, B.,  "UV-curable Unsaturated Polyester Systems for
  •   the  Industrial Finishing of Furniture."  Paint & Coatings
     Industry, Vol. 6, No. 7, October 1990.

14.  Telecon, Caldwell, M.J., Midwest Research Institute, with
     Riberi, B., Mobay Corporation.  August 27, 1990.
     Clarification of information provided on Section 114
     information request response.

15.  Survey response from PPG Industries, Inc., to Farmer, J.,
     EPA/ESD.  May 8, 1990.  Response to Section 114 information
     request.

16.  Survey response and attachments from Reliance Universal,
     Inc., Division of Akzo Coatings, to Farmer, J.,  EPA/ESD.
     May  11, 1990.  Response to Section 114 information request.

17.  Survey response and attachments from The Lilly Company to to
     Farmer, J., EPA/ESD.  May 14, 1990.  Response to Section 114
     information request.

18.  Survey response and attachments from The Valspar Corporation
     to Farmer, J., EPA/ESD.  May 10, 1990.  Response to
     Section 114 information request.

19.  Survey response and attachments from Guardsman Products,
     Inc., to Farmer,  J., EPA/ESD.  May 10, 1990.   Response to
     Section 114 information request.

20.  Survey response and attachments from Amity Quality
     Restoration Systems, Inc.,  to Farmer,  J.,  EPA/ESD.   May 13,
     1990.  Response to Section 114 information request.

21.  Schrantz,  J., editor.   EPA Glossary.  Industrial Finishing.
     August 1989.  pp.  45-59.

22.  Telecon.   Caldwell, M.  J.,  Midwest Research Institute, with
     Tucker, R.,  Guardsman Products,  Inc.  January 29,  1991.  '
     Discussion of wood furniture finishing sequences and other
     aspects of the wood furniture industry.

23.  Memorandum.   Christie,  S.,  Midwest Research Institute, to
     Catlett,  K., EPA/ESD/CPB.   Summary of  Wood Finishing Seminar
     conducted in Grand Rapids,  Michigan, from March  4-5, 1991.
     March 12,  1991.   (Presentation by J. Kelbel,  Guardsman
     products.)   pp.  8-12.

24.  Domsey, S.   Woodworker's guide to conventional finishes.
     Furniture Design and Manufacturing.  January 1988.
     pp. 54-57.

25.  Chemcraft Sadolin International, Inc.   Wood Finishes
     Brochure.   Walkertown,  North Carolina.


                              2-38

-------
26.  Memorandum.  Christie, S., Midwest Research Institute, to
     Catlett, K., EPA/ESD/CPB.  Preliminary Assessment of
     Industrial  Solvent Use in Wood Furniture Coating Operations.
     January 28, 1991.

27.  Alternative Control Techniques--Control of Volative Organic
     Compound Emissions from Industrial Cleaning Solvents.
     February 1994.  EPA-453/R-94-014.

28.  H. Van Noordwyk, Acurex Corp.  Reducing Emissions From the
     Wood Furniture Industry with Waterbome Coatings.  Prepared
     for the Environmental Protection Agency.  EPA-600/2-80-160.
     July 1980.

29.  SRI International.  The U.S. Paint Industry Data Base.
     Prepared for The National Paint and Coatings Association,
     September 1990.

30.  Memorandum from Caldwell, M. J.,- Midwest Research Institute,
     to Catlett, K., EPA/ESD/CPB.  Summary of Existing
     Regulations.  March 6, 1990.

31.  Telecon.  Christie, S.,  Midwest Research Institute,  with
     D. Belik,  Bay Area Air Quality Management District.
     January 24, 1991.  Wood Coatings Regulation.

32.  Telecon.  Beall, C.,  Midwest Research Institute, with
     C. Lee,  Bay Area Air Quality Management District.
     December 13, 1991.  Wood Coatings Regulation.

33.  Telecon.  Beall, C.,  Midwest Research Institute, with
     J. Ross, Illinois Environmental Protection Agency.
     December 17, 1991.  Wood Furniture Rule.

34.  Telecon.  Beall, C.,  Midwest Research Institute, with
     T. Jones,  Indiana Department of Environmental  Management.
     December 18, 1991.  Wood Furniture and Cabinet Coating Rule.

35.  Telecon.  Beall, C.,  Midwest Research Institute, with
     G. Walker,  New Jersey Department of Environmental
     Protection.  December 11,  1991.   Wood Furniture Coating
     Regulation.

36.  Telecon.  Beall, C.,  Midwest Research Institute, with
     K. Heiss,  San Diego County Air Pollution Control District.
     December 13, 1991. -San  Diego Wood Products Coating  rule.

37.  Telecon.  Christie,  S.,  Midwest Research Institute,  with
     R. Oja,  South Coast Air  Quality Management District.
     November 2  and 6,  1990.   Transfer Efficiency Test Protocol
     Development Program.
                              2-39

-------
38.  Telecon.  Beall, C., Midwest Research Institute, with
     M. Price, South Coast Air Quality Management District.
     December 11, 1991.  Wood Furniture Coating Regulation.

39.  Telecon.  Beall, C., Midwest Research Institute, with
     D. Ono, South Coast Air Quality Management District.
     December 11, 1991.  Implementation of the Wood Furniture
     Coating Regulation.

40.  Telecon.  Beall, C., Midwest Research Institute, with
     A. Latif, South Coast Air Quality Management District.
     January 7,  1992.  Spray Gun Cleaning Requirements for Wood
     Furniture Coating Operations.

41.  Telecons.  Caldwell, M.J. with Illinois Environmental
     Protection Agency, Indiana Department of Environmental
     Management,  South Coast Air Quality Management Division, Bay
     Area Air Quality Management Division, San Diego Air Quality
     Management Division.  October 25,  1994.  Changes to Wobd
     Furniture Regulations.
                              2-40

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                 3.0  EMISSION CONTROL TECHNIQUES

      This  chapter  discusses  volatile  organic  compound  (VOC)
 emission control techniques  that  could potentially be used for
 wood furniture  finishing  and cleanup  operations.  The control
 techniques addressed  in this chapter  have been divided  into four
 categories:  add-on control  devices,  lower VOC coatings, emerging
 technologies, and  pollution  prevention.
 3.1   ADD-ON CONTROL DEVICES
      Add-on control devices  are addressed within two categories:
 combustion control devices and recovery devices.  Combustion
 control devices are defined  as those  devices  used to destroy the
 contaminants, converting  them primarily to carbon dioxide  (C02)
 and water.  The combustion control devices evaluated within  this
 section include•thermal incineration  with recuperative and
 regenerative heat  recovery and catalytic incineration.
      Recovery devices are used to collect VOC's prior to their
 final disposition,  which may  include  VOC recovery, destruction,
 or disposal.  One recovery device that is addressed in this
 section is  carbon adsorption  in conjunction with regeneration of
 the carbon bed by steam or hot air.   In either scenario, the
VOC's may be recovered or disposed of following regeneration.
Another system discussed is a proprietary system that uses
oxidant-ozone counterflow wet scrubbing and granular-activated
carbon adsorption with cold oxidation regeneration.   Also within
the recovery devices section, information regarding carbon
adsorption with final destruction of VOC's by incineration is
provided.
     Following the  discussion of add-on control devices, wood
furniture finishing line modifications that could be implemented
                               3-1

-------
in conjunction with add-on controls are described.  The finishing
line modifications discussed include those that would reduce the
volume of air sent to the control device and/or improve the
efficiency of capturing the VOC's to be sent to the control
devices.  Specific finishing line modifications identified in
this section include recirculation of spray booth exhaust and
conversion of the finishing room into a total enclosure.  The
feasibility of applying these methods to wood furniture finishing
operations is also addressed.
3.1.1  Combustion Control Devices
     Combustion is a rapid,  high-temperature, gas-phase reaction
in which VOC's are oxidized to C02, water,  sulfur oxides  (SOX),
and nitrogen oxides (NOX).  If combustion is not complete,
partial oxidation products,  which may be as undesirable as the
initial VOC's, could be released.  In order to avoid such
occurrences,  excess air (above the stoichiometric requirement) is
used.  More complete process descriptions are provided below for
each type of combustion control device.1
     In addition to the process descriptions, control device
efficiency and the applicability of the control device to wood
furniture finishing operations are discussed for each of the
combustion control devices identified in this section.
     3.1.1.1  Thermal Incineration.
     3.1.1.1.1  Thermal incineration process description.
Thermal incineration is a process by which waste gas is brought
to adequate temperature,  and held at that temperature for a
sufficient residence time for the organic compounds in the waste
gas to oxidize.2  The constituents of the waste streams generated
by wood furniture finishing  operations will be converted to C02
and water in the presence of heat and sufficient oxygen.
     A schematic diagram of  a typical thermal incineration unit
is provided in Figure 3-1.   Primary components of the thermal
incineration unit include a  fan,  a heat recovery device, the
combustion chamber,  and the  exhaust stack.   The heat recovery
device is used to preheat the incoming waste stream so that less
auxiliary fuel is required in the combustion chamber.   This type
                               3-2

-------
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                       3-3

-------
of heat  recovery  is known as primary heat recovery and can
generally be described as either  recuperative or regenerative.
If the exhaust stream is of sufficient temperature and/or heating
value so that little or no auxiliary fuel is needed, heat
recovery may not  be cost effective and thus may not be
implemented.  However, when auxiliary fuel is required, heat
recovery can be used to minimize  energy costs.  Each type of heat
recovery is discussed in more detail in Section 3.1.1.1.3.
     In  order for the thermal incinerator to achieve the desired
destruction efficiency, certain key parameters must be
controlled.  These parameters include the combustion airflow
rate, the waste stream flow rate, auxiliary fuel requirements,
residence time, combustion chamber operating temperature, and the
degree of turbulence between the  air and combustible materials.
Residence time is the time required for the initiation and
completion of the oxidation reactions.  Operating temperature is
a function of the residence time, the oxygen concentration, the
type and concentration of the contaminant involved,  the type and
amount of auxiliary fuel,  and the degree of mixing.   The
destruction efficiency for a particular contaminant is a function
of the operating temperature and  residence time at that
temperature.  A temperature above 816°C (1500°F)  will destroy
most organic vapors and aerosols.  Turbulence,  or the
mechanically induced mixing of oxygen and combustible material,
can be increased by the use of refractory baffles and orifices to
force adequate mixing in the combustion chamber.   Alternatively,
mixing can be enhanced by the use of over-fire air,  the injection
of air into the combustion zone at a high velocity,  or'by a
forced air draft.3
     3.1.1.1.2  Standard operating conditions.   Thermal
incinerators generally operate at a temperature ranging between
650° and 870°C (1200° and 1600°F) and require a minimum residence
time of 0.3 seconds in the combustion zone.4  Most thermal units
are designed to provide no more than 1 second of residence time
to the waste gas in the combustion chambers.5  Thermal
incinerators can be designed to control flow rates in excess of
                               3-4

-------
 2,832 cubic meters per minute (m3/min)  (100,000 cubic feet per
 minute [ft3/min]).  The VOC concentration of  waste streams
 controlled via thermal incineration can be from the part per
 million (ppm)  range to 25 percent of the lower explosive limit
 (LEL).   The VOC concentrations typically cannot exceed 25 percent
 LEL for safety and insurance reasons.
      3.1.1.1.3  Heat recovery.  Heat recovery is a method of
 reducing energy consumption of the incinerator or some other
 process operation.  Primary heat  recovery describes the process of
 preheating the incoming waste stream to the incinerator by
 transferring heat  from the incinerator  exhaust so that less
 auxiliary fuel is  required in the combustion  chamber.   Secondary
 heat "recovery refers to the exchange of heat  in the exhaust
 leaving the primary heat recovery device to some other medium
 that  is used in plant processes.
      Primary heat  recovery can be accomplished using recuperative
 or  regenerative devices.   The waste  gas preheater shown in
 Figure  3-1  could be a recuperative heat exchanger.   As  shown in
 this  figure, a heat exchanger is  used to transfer heat  to the
 incoming  waste stream from the incinerator  exhaust  stream.   In a
 recuperative heat  exchanger,  heating of the incoming  stream by
 the incinerator effluent  is  a continuous, steady-state  process.
 Types of  heat  exchangers  that  are typically used  for  recuperative
 heat recovery  include  plate-to-plate and  shell-and-tube.   The
 type of heat exchanger that  is chosen is  based  on the waste  gas
 flow rate,  the desired heat  exchange efficiency,  the  temperature
 of the  incinerator  exhaust stream (used for preheat), and
 economics.   Recuperative  heat  exchangers  can recover  70 percent
 of the  energy  in the  incinerator  exhaust  gas,  thereby reducing
 fuel, the primary operating  cost,  by 70 percent.6
     An incinerator employing  regenerative heat recovery is
presented in Figure 3-2.  Figure  3-2 illustrates a two-chamber
design  in which process exhaust air is purified in a conventional
combustion chamber but uses  two beds of ceramic material to
recover thermal energy.  The process exhaust passes through a bed
of ceramic heat sink material that was left hot at the end of a
                               3-5

-------
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Figure 3-2.   Regenerable-type thermal incinerator.



                         3-6

-------
 preceding cycle.   As the air passes over the ceramic,  it  extracts
 heat  from the bed.  This leaves the ceramic  bed cool at the  end
 of  the  cycle and  raises the air temperature  to near the desired
 thermal destruction temperature (combustion  chamber temperature).
 Additional heat to achieve the destruction temperature is
 obtained by firing natural gas,  propane,  or  fuel oil into the
 combustion chamber.   The airstream leaving the combustion chamber
 passes  through the other ceramic bed, which  was left cool during
 the preceding cycle.   The ceramic  bed absorbs  the heat from  the
 airstream,  leaving the ceramic bed hot at the  end of this cycle
 and the exit airstream relatively  cool.
      The inlet and discharge airstreams  are  reversed,  so  that the
 ceramic beds absorb and reject heat from the airstream on a
 cyclical basis.
      When the cycle reverses and the ceramic bed at the inlet
 becomes the  bed at the outlet,  there is  still  some contaminated
 air left in  the ceramic bed chamber.  In  order to attain  the
 maximum overall destruction efficiency from  a  regenerative
 thermal  incinerator,  it is  necessary to displace the volume of
 contaminated air  in  the inlet  heat  sink chamber into the
 combustion chamber before  extracting the  high-temperature
 combustion air through it.   A  system designed  to "purge"  the
 chamber  is provided  in a three-chamber design.   In this system
 the same  type  of  absorption/rejection of  heat  occurs,  but  the
 third chamber  allows  time between inlet and discharge cycles to
purge each chamber at  the  end  of an  inlet cycle.
     Regenerative heat  recovery systems can recover 95 percent of
the energy in  the  incinerator  exhaust gas, with  a comparable
reduction in  fuel, the major operating cost.6
     3.1.1.1.4  Thermal incinerator  efficiency.  Studies indicate
that a well designed and operated commercial incinerator can
achieve at least a 98 percent destruction efficiency (or an
outlet concentration of 20 ppm) of organics.   This destruction
efficiency corresponds to incinerators that are operated at 871°C
 (1600°F) with a nominal residence time of 0.75 second.7
                               3-7

-------
      3.1.1.1.5   Applicability  to  wood  furniture  finishing  exhaust
 streams.   Thermal  incinerators can be  used  to  control waste
 streams  containing various organic compounds and thus are
 technically  feasible  for  controlling emissions from wood
 finishing  operations.  The compounds typically contained in wood
 furniture  finishing exhaust streams  {aromatic  hydrocarbons,
 ketones, acetates, and alcohols)  are also present in exhaust
 streams  from other industries  and have been demonstrated to be
 readily  converted  to  innocuous compounds using thermal
 incineration technology.  Based on information gathered from the
 surveys  sent to  industry, thermal incineration is being used to
 control VOC  emissions in  the kitchen cabinet and business
 furniture manufacturing segments.
     The exhaust stream from conventional wood furniture
 finishing operations  is characterized  as a  dilute concentration
 of VOC in a  high-volume airflow".  The  costs associated with
 control of a dilute air stream can be  very  high  due to
 supplemental fuel  requirements.   (Details regarding costs  are
 provided in  Chapter 5).  However, incorporating  heat recovery
 into the thermal incineration  design can minimize supplemental
 fuel requirements  and associated  costs.  The quantity of process
 exhaust  (e.g.,  airflow)  from wood furniture finishing operations
 can be reduced by  recirculating the exhaust from spray booths, as
 discussed in Section 3.1.3,  or by reducing airflow through the
 use of air curtains.
     3.1.1.2  Catalytic Incineration.
     3.1.1.2.1  Catalytic incineration process description.
 Catalytic incineration is comparable to thermal  incineration in
 that VOC's are heated to a temperature sufficient for oxidation
 to occur.  However, with catalytic incineration,  the temperature
 required for oxidation is considerably lower than that required
 for thermal  incineration because a catalyst is used to promote
 oxidation of contaminants.8  The catalyst is imposed on a  large
 surface containing many active sites on which  the catalytic
 reaction occurs.  Platinum is the most widely used catalyst;
palladium is also commonly used.^  Because the metals used as
                               3-8

-------
 catalysts  are  expensive,  only  a  thin  film  is applied to  the
 supporting substrate.   A commonly  used  supporting substrate  is
 ceramic.
      Figure 3-3  is  a  schematic of  a typical catalytic
 incineration system.  As indicated in this figure, components of
 the  system include  a  fan,  a preheat burner, a combustion mixing
 chamber, a catalyst chamber, a waste  gas preheater  (recuperative
 heat recovery  device),  secondary heat recovery, and a stack.  The
 preheat burner is used  to heat the incoming waste stream to  the
 required oxidation  temperature,  usually between 149° and 482°C
 (300° and  900°F) for  catalytic incineration.1^1  The mixing
 chamber is used  to  thoroughly  mix  the hot combustion products
 from the preheat burner with the exhaust waste stream.   This
 ensures that the stream sent to  the catalyst bed is of uniform
 temperature.   The combustion reaction then takes place at the
 catalyst bed.  The  catalyst bed  may be a fixed bed or a  fluidized
 bed  consisting of individual pellets  enclosed in a screened unit.
 The  recuperative heat recovery device (if incorporated)  is a
 shell-and-tube or plate-to-plate heat exchanger.  A heat recovery
 device is  used if supplemental fuel requirements are expected to
 be high.10
     Many  parameters affect the  performance of a catalytic
 incineration system.  The primary  factors include operating
 temperature, space velocity (inverse  of residence time),  VOC
 concentration  and species, and catalyst type and susceptibility
 to contaminants.10  The optimum  operating temperature depends on
 the  type of catalyst,  as well as the  concentration and type of
VOC's.  Space velocity  is defined as  the volume of gas entering
 the  catalyst bed divided by the volume of the catalyst bed.
Space velocity depends on operating temperature.  However,  in
general,  as space velocity increases,  destruction efficiency
decreases.10  The amount and type of VOC determine the heating
value of the waste stream and thus the amount of supplemental
fuel required to maintain the desired operating temperature.
     The type of catalyst that is used is determined by the VOC
compounds in the waste stream.   Particulates and catalyst poisons
                               3-9

-------
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                  3-10

-------
 in the waste stream can affect the efficiency of  the  catalyst and
 its lifetime.   Some materials that are considered catalyst
 poisons include heavy metals (mercury,  lead,  iron,  etc.),
 silicon,  sulfur,  halogens,  organic solids,  and inert
 particulates.10  Particulates and poisons  reduce  the  activity of
 the catalyst site,  minimizing sites available for the oxidation
 reaction.   These materials  can also mask,  plug, or coat  the
 catalyst  surface,  thereby eliminating  available catalyst sites.
      3.1.1.2.2   Standard operating conditions.  The catalyst  bed
 in catalytic incinerators generally operates  at temperatures
 ranging between 149°  and 482°C (300° and 900°F),  with
 temperatures rarely exceeding 538°C (1000°F).   The  contact time
 required between the  contaminant  and the catalyst so  that
 complete oxidation  occurs is normally  0.3  second.   The excess air
 requirements for catalytic  incineration units  are usually  only
 1  to  2  percent  higher than  the stoichiometric  requirements.**'11
 Catalytic  incinerators  can  be designed  to  control waste  gas flow
 rates up to about 1,416  m3/min (50,000  ft3/min).  The VOC  content
 of  the  waste stream may  be  in the part-per-million  range up to
 25  percent  LEL.
      3.1.1.2.3  Catalytic incinerator efficiency.  A well
 operated and maintained  catalytic incineration unit can  achieve
 destruction efficiencies  of  98 percent, comparable  to thermal
 incineration units.   The  destruction efficiency would decrease in
 the presence of the catalyst  poisons and particulates described
 above.12
     3.1.1.2.4  Applicability to  wood furniture finishing
 operations.  Factors  to consider  in determining if catalytic
 incineration is suitable  for  controlling VOC emissions from wood
 furniture finishing operations include the waste gas flow  rate,
 the concentration of  contaminants, and the presence of catalyst
poisons and particulates.  Catalytic incineration units  can be
designed to  control the high-volume, low-concentration waste
streams from wood furniture finishing operations.   As with
thermal incineration units,  heat recovery and volume reduction
techniques are necessary to decrease the size of the unit
                               3-11

-------
 required and associated capital and operating costs.  Particulate
 matter  in the waste  stream would have to be removed using
 filtration to prevent  fouling  of the catalyst bed.   (This
 filtration would be  in addition to the dry filters-already used
 on  the  majority of existing spray booths.)  In general, catalyst
 poisons would not be present in the waste stream from wood
 furniture finishing  operations unless large quantities of
 halogenated materials  are  used  (for example, halogenated cleaning
 materials)  and their emissions controlled through the catalytic
 incinerator.   Based  on information obtained during the regulatory
 negotiation effort,  there  is presently at least one business
 furniture manufacturer using a fluidized-bed catalytic
 incinerator to control  VOC emissions.
     A  potential concern associated with using catalytic
 incineration is the  variability of the wood finishing waste gas
 flow rate and  VOC concentration.  A constant gas flow rate and
 concentration  is recommended for optimal operation.  The VOC's
 contained in the exhaust flow from wood furniture coating
 operations  vary in composition and concentration,  depending upon
 which spray booths are  being used and which coatings are being
 sprayed,  as  well as  the on/off nature of the spraying operation
 itself  as pieces pass through the booth.   One vendor felt that
 any application that involves many different types of pollutants
 or particulates,  or  the potential for change in the types of
pollutants  could significantly decrease the catalyst life.13"19
 3.1.2  Recovery Devices
     Volatile  organic compounds in a waste gas stream can be
 collected through adsorption of the contaminants onto a porous
bed.  The contaminants  can then be recovered,  if desired,  by
 desorption  of  the bed with steam or hot air.   After desorption,
 or regeneration,  contaminants can be condensed and recovered or
disposed of.  Alternatively, after regeneration by hot air,
 contaminants can be sent to an incinerator for destruction.   This
section discusses the use of activated carbon adsorption systems
 followed by steam and hot air regeneration,  carbon adsorption in
                               3-12

-------
 conjunction with incineration,  and activated carbon adsorption
 used in conjunction with oxidant/ozone  wet  scrubbing.
      The efficiency of carbon adsorption systems and their
 applicability for controlling emissions from wood  furniture
 finishing operations are also discussed below.
      3.1.2.1  Carbon Adsorption.
      3.1.2.1.1  Carbon adsorption  process description.  The
 carbon  adsorption process used  to  control VOC emissions from
 waste gas streams can be subdivided into two sequential
 processes.   The  first process involves  the  adsorption cycle, in
 which the waste  gas stream is passed over the adsorbent bed for
 contaminant removal.   The second process involves  regeneration of
 the  adsorbent bed,  in which contaminants are removed using a
 small volume of  steam or hot  air,  so that the carbon can be
 reused  for contaminant removal.
     Adsorption  is  the capture  and retention of a  contaminant
 (adsorbate)  from the  gas  phase  by  an adsorbing solid (adsorbent).
 The  four  types of adsorbents  most  typically  used are activated
 carbon, aluminum oxides,  silica gels, and molecular sieves.
 Activated  carbon is the most  widely  used adsorbent for air
 pollution  control and is  the  only  type of adsorbent discussed in
              9 n
 this section.  u  Both the  internal and external surfaces of the
 carbon are  used  as adsorption sites.  Diffusion mechanisms
 control the  transfer  of the adsorbate from the gas phase to the
 external surface of the carbon,  from the external surface  of the
 carbon to  internal pores, and finally to an active site in the
pores.  Adsorption depends on a mass transfer gradient  from the
gas phase to  the surface.  Van der Waals forces attract the
adsorbate to  the carbon.  Because adsorption is an exothermic
process, some method of heat removal from the carbon may be
necessary, depending on the amount of contaminant being removed
from the gas phase.
     Regeneration is the process of desorbing the contaminants
from the carbon.   Regeneration of the carbon bed is usually
initiated prior to "breakthrough."   Breakthrough,  as the name
implies, is that point in the  adsorption cycle at which the
                              3-13

-------
 carbon  bed approaches saturation  and  the concentration of
 organics  in the effluent  stream begins  to increase dramatically.
 If  the  carbon bed is  not  regenerated, the concentration of VOC's
 in  the  effluent will  continue  to  increase until it is equal to
 that of the inlet;  i.e.,  the carbon is  saturated.22  Regeneration
 can be  accomplished by reversing  the  conditions that are
 favorable to adsorption--by increasing  the temperature and/or
 reducing  the system pressure.   The ease of regeneration depends
 on  the  magnitude of the forces holding  the VOC's to the surface
 of  the  carbon.   The most  common method  of regeneration is steam
 stripping.   Low-pressure, superheated steam is introduced into
 the carbon.   The steam releases heat  as it cools; this heat is
 then available  for  adsorbate vaporization.  Another regeneration
method  is the use of  hot, inert gas or  hot air.  With either
 steam or  hot air regeneration,  the desorbing agent flows through
 the bed in the  direction  opposite to  the waste stream.  This
desorption scheme allows  the exit end of the carbon to remain
contaminant - free.
     In a regeneration process, some  adsorbate, known as the
 "heel," may  remain  in the carbon after  regeneration.   The actual
capacity  of  the  carbon is referred to as the working capacity and
is equal  to  the  total  capacity  of the carbon less the capacity
                  O o
taken by  the heel.
     Adsorption units  that are  commonly used to remove
contaminant  from  waste gas streams include the following:
     1.   Fixed or rotating regenerable  carbon beds;
     2.   Disposable/rechargeable carbon canisters;
     3.   Traveling bed carbon adsorbers;
     4.   Fluid bed carbon adsorbers;  and
     5.   Chromatographic baghouses.
Of the  five  adsorption systems  listed above,  the first two are
most commonly used for air pollution control.   The
disposable/rechargeable canisters are used for controlling low
flow rates  (less  than  3 m^/min  (100 ft^/min)  and would not be
used to control the high-volume flow rates typical of wood
furniture  finishing operations.  Only the fixed-bed,  regenerable
                               3-14

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 carbon adsorption system is discussed in this  section.24   Carbon
 adsorption systems that use a rotating bed  are addressed  in
 Section 3.1.2.2  and in Chapter 5.
      A fixed-bed,  regenerable carbon  adsorption system is
 presented in Figure 3-4.   The components of the carbon adsorption
 system include:
      1.   A fan  (to convey the waste gas into the carbon beds);
      2.   At least  two  fixed-bed carbon adsorption vessels;
      3.   A stack for the  treated waste gas  outlet;
      4.   A steam valve for introducing desorbing steam;
      5.   A condenser for  the steam/contaminant desorbed stream;
 and
      6.   A decanter for separating the VOC  condensate  and water.
 In the system depicted in Figure 3-4,  one carbon vessel is  being
 used  for  adsorption while the other is being regenerated.   Both
 vessels will  alternate in the adsorption and regeneration modes.
 The steam is  used  to regenerate a vessel  and is  then sent  to a
 condenser.  The  condensate is a water/VOC mixture.  The decanter
 can be used to separate the  condensate  into a  water stream  and a
 condensate stream.   Depending on its measured  toxicity, the water
 may be treated or  discharged to the sewer.   The  condensed
 organics  can  be  recycled  (if  usable),   used  as  a  fuel,  or disposed
 of.
      In lieu  of using  steam  for regeneration,  hot air  or a hot
 inert  gas could be  employed.  After regeneration, the desorbing
 stream would  then  consist  of  an air or gas  stream with a high VOC
 concentration.  This air or gas stream could then be sent to an
 incinerator for final destruction of VOC's.   A carbon
 adsorption/incineration system is discussed  in detail in
 Section 3.1.2.2.
     Several  factors affect the amount of material that can be
adsorbed onto the carbon bed.  These factors include type and
concentration of  contaminants in the waste gas, system
temperature, system pressure, humidity of waste gas,  and
residence time.22
                              3-15

-------
                 (DRYING/COOLING AIR)
          WASTE GAS
        (FROM SOURCE)
         PRYING/
       COOLING AIR)
                        STEAi
                                                  OUT
                                                        IN
                                            -   voc
                                            CONDENSATE   I"
                                            (TOSTORAGE7*H'
                                            PROCESSING)
                                         OUTLET
                                          GAS
                                                         WATER
                                                      (TO TREATMENT/
                                                         SEWER)
                                                    (TO STACK)
Figure 3-4.
Typical two-bed,  continuously operated  fixed-bed
       carbon adsorber system.
                                  3-16

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      The type and concentration of contaminants in the waste
 stream determine the adsorption capacity of the carbon.
 Adsorption capacity is defined as the pounds of material  adsorbed
 per pound of carbon.  In general,  adsorption capacity increases
 with a compound's molecular weight or boiling point,  provided all
 other parameters remain constant.   There is also a relationship
 between concentration and the carbon adsorption capacity.  As
 concentration decreases,  so does the carbon capacity.   However,
 the capacity does not decrease proportionately with the
 concentration decrease.   Therefore,  carbon  capacity still  exists
                                            OO
 at  very low pollutant concentration levels.  ^
      Operating temperature also affects  adsorption.   Adsorption
 efficiency decreases with increasing temperature.   At elevated
 temperatures,  the vapor pressure of the  contaminants  will
 increase,  reversing the mass transfer gradient.   Contaminants
 would then be more likely to be desorbed back into the gas phase
 than  to be retained on the carbon.   At lower temperatures, the
 vapor pressures  are lower,  favoring retention of  the  contaminants
 by  the carbon.25
      The  system  pressure  also influences the adsorption
 effectiveness.   Increases in the gas  phase pressure promote more
 effective  and rapid mass  transfer  of  the contaminants  from the
 gas phase  to  the carbon.   Therefore,  the probability  that the
 contaminants  will  be captured is increased.25
      The  relative  humidity or moisture content of  the  gas phase
 affects  the adsorption efficiency.  Although water vapor is not
 preferentially adsorbed over the contaminants, the presence of
 water vapor in the  gas phase has been demonstrated to  have a
 detrimental effect  on the  adsorption  capacity of the carbon.
 However,  the  effect  of humidity  or moisture  in the gas phase  is
 insignificant for VOC concentrations  greater than 1,000 ppm and
 during  the initial  startup of the adsorption cycle  (the carbon is
 drier).   Indeed, some moisture content in the gas phase can be
beneficial.   For instance, when high  concentrations of
 contaminants with high heats of adsorption are present, the
 temperature of the carbon bed may rise considerably during
                               3-17

-------
 adsorption due  to the exothermic  nature of the process.  The
                                                    9 *)
 presence  of water may minimize  the  temperature rise.
     Residence  time has  a minor effect on the adsorption
 efficiency.   The  contaminants require sufficient contact time
 with the  active sites of the carbon to allow enough time for mass
 transfer  to occur.  This is especially true if there are many
 molecules (high-concentration streams) competing for the same
 sites.  Residence, or contact,  time of the contaminants with the
 active sites can  be increased by  using larger carbon beds, but
 then the  pressure drop across the system increases, resulting in
 increased operating costs.25
     3.1.2.1.2  Standard operating  conditions.  Fixed-bed carbon
 adsorption units  have been sized  to handle flow rates ranging
 from several  hundred  to  several hundred thousand ft3/min.  There
 is no obvious practical  limit to  flowrate because multibed
 systems operate with  multiple beds  in simultaneous adsorption
 cycles.   The  VOC  concentrations of  the waste streams controlled
 by carbon adsorption  units can range from the part per billion
 level to  as  high  as 20 percent of the LEL.   Adsorption systems
 typically operate at  ambient pressure and temperatures ranging
 between 25° and 40°C  (77° and 104°F),24
     3.1.2.1.3  Carbon adsorption efficiency.   Carbon adsorption
 recovery  efficiencies of 95 percent and greater have been
 demonstrated  to be achievable in well designed and well operated
units.26"28  The performance of the carbon adsorption unit is
negatively affected by elevated temperature,  low pressure,  high
 humidity,   etc. as previously discussed.
     3.1.2.1.4  Applicability to wood furniture finishing exhaust
 streams.   Wood furniture finishing exhaust  streams are
 characterized as high-volume,  low-concentration exhaust streams.
Typical contaminants may include but are not limited to aromatic
hydrocarbons, ketones, acetates, and alcohols.   Exhaust streams
are usually at ambient temperature and pressure.   Relative
humidity  of the streams varies depending on the process and
location  of the plant.
                               3-18

-------
     Based  on  the  characterization of  the wood  furniture  exhaust
 streams,  carbon adsorption would be  technically feasible  to
 control  the VOC emissions  from finishing operations.  As  with the
 other add-on control options,  air volume reduction techniques
 should be explored to decrease capital and operating costs.
 Also, particulate  control  is  important to prevent fouling of the
 carbon bed.  If a  specific plant is  concerned with the relative
 humidity of the waste stream,  dehumidification  options such as
 refrigeration  should be evaluated.   The contaminants that are
 typical  of  wood furniture  finishing  process exhaust (aromatic
 hydrocarbons,  ketones, acetates, and alcohols)  can be adsorbed to
 an activated carbon bed.   Some alcohols, such as methanol, are
 not adsorbed as readily as the other contaminants.  Carbon
 adsorption  vendors  indicated  that a  carbon adsorption system
 designed  for an exhaust stream containing methanol would  probably
 be more expensive.29-31  Ketones exothermically polymerize on the
 carbon bed.  A system designed for ketones must ensure the
 airflow  through the bed is  sufficient to remove the heat  of
 reaction  so that the bed temperature is not significantly
 affected.   Humidity can help keep bed temperatures low.
 Nonetheless, special operating  conditions and provisions  to
 suppress  bed fires may be  required when ketones are present.
 Plant-specific studies would be necessary to determine the
 capacity  of carbon required and the recommended regeneration
 cycle.31'32
     Based  on discussions with  several add-on control  vendors,  it
was determined that carbon adsorption followed by steam
 regeneration (and subsequent condensation of the solvent)  is not
an appropriate technology for controlling VOC emissions from wood
 furniture finishing operations.  Carbon adsorption followed by
 condensation is best suited for applications involving only a few
different solvents, and there are many different solvents
contained in the variety of coatings used by the wood  furniture
industry.18'33   Condensing and distilling many different solvents
is complicated, and the purity of such distilled solvents limits
their use.  Because the condensate from a carbon adsorption/
                               3-19

-------
condensation  system would most likely still be a mixture of
solvents,  it  would  not  be suitable for reuse in the coatings.  It
could potentially be used as a fuel onsite, but because waste-
wood boilers  are usually present at wood furniture facilities and
an abundant supply  of wood waste is available, the additional
fuel may not  be needed.  The market value of the fuel is not
expected to be significant.34  It would be necessary, therefore,
in some instances,  to dispose of the condensate, which could be
costly.  For  these  reasons, carbon adsorption followed by steam
regeneration  was not analyzed further.
     3.1.2.2  Carbon Adsorption/Incineration.  As; discussed in
Section 3.1.2.1, carbon adsorption units that are used to remove
VOC's from waste gases  can be subsequently regenerated using
steam or hot  air.   In streams containing a variety of VOC,
solvent purification is not always cost effective.   Disposal
costs can  also be substantial.  When desorption is performed
using hot  air, an alternative final disposition is incineration.
There are  also systems  currently available that use synthetic
polymer adsorbents.   However, because carbon has been used
extensively as an adsorbent in the past,  in this section, the use
of incineration in  conjunction with carbon adsorption systems is
discussed.  The process description,  system efficiency estimates,
and an assessment of  the applicability of the system to wood
furniture  finishing  operations are provided below.
     3.1.2.2.1  Carbon adsorption/incineration process
description.  A carbon adsorption system in which the desorption
stream is  sent to an  incinerator operates on the principles of
adsorption and combustion,  which have previously been discussed.
Basic system  components, include the following:
     1.  System fan to convey the waste stream to the carbon
adsorber;
     2.  Carbon adsorption unit for collecting contaminants;
     3.  Inlet air  fan for air to be used in regeneration;
     4.  Heat exchangers for preheating air for regeneration and
prior to introduction to the incinerator;
     5.  Carbon adsorption unit being regenerated;
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      6.   Thermal or catalytic incinerator for VOC destruction;
 and
      7.   Exhaust stack for treated (incinerated)  exhaust.
      During system operation,  the process exhaust stream is
 directed through the carbon adsorption bed,  the  contaminants  are
 collected on the carbon,  and the treated stream  is exhausted  out
 a stack.  Prior to breakthrough of the carbon, the gas  flow is
 switched to a fresh carbon adsorption bed and the used  bed is
 regenerated.   Some designs incorporate a rotary  wheel,  which
 contains the adsorbent.   The wheel constantly rotates,  so  that  at
 any time half the adsorbent is adsorbing and half is being
 regenerated.   In the fixed-bed and rotary designs,  ambient air  is
 directed through a heat exchanger to  be preheated (by the
 incinerator exhaust)  to a temperature sufficient  for
 regeneration.   The heated air  is used to desorb  contaminants  from
 the carbon bed.   The desorption air is sent  through another heat
 exchanger to  be further heated and then introduced into the
 incinerator where the contaminants are destroyed.   The
 incinerator exhaust  is directed through the  two heat exchangers;
 heat  from the  incinerator exhaust  preheats the outside  air and
 the stream sent  to the incinerator.
      With the  carbon adsorption/incineration  system, contaminants
 from a volume  of  waste gas  are  first  collected on the carbon  bed.
 A much smaller volume of  air  (approximately one-tenth the
 original  volume)  is  used  for regeneration and sent  to the
 incinerator.   The  incinerator used for VOC destruction  is  much
 smaller  than the unit that  would have  been required for  the
 initial waste  gas  volume.   Also, the waste stream sent  to  the
 incinerator has a  higher  heating value,  so that less auxiliary
 fuel may  be required.  Finally, with incineration, the VOC's  are
destroyed.  With carbon adsorption alone, proper disposal  of  the
water/VOC stream must  be  considered.
     3.1.2.2.2  Standard  operating conditions.  The standard
operating  conditions  that were  identified for carbon adsorption
units also  apply in this  case.  The carbon adsorption/
incineration systems  can handle a broad range of  flow rates and
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VOC concentrations  and are especially suited to weaker streams at
100 ppm VOC and below where conventional systems are most
expensive to operate.
      3.1.2.2.3   Carbon adsorption/incinerator efficiency.  A
well-designed,  -operated,  and  -maintained carbon adsorption/
incineration system can achieve an overall destruction efficiency
of  97 percent.   Higher efficiencies have also been reported.27'35
      3.1.2.2.4   Applicability  to wood furniture finishing exhaust
streams.   As discussed previously, carbon adsorption and
incineration are technically feasible technologies for the
control of the  contaminants present in wood furniture finishing
exhaust streams.  The  use  of these two technologies together is
also technically feasible.   The technology is especially well-
suited  to  applications like the wood furniture industry,  which
has  high-volume, low-concentration exhaust streams with many
different  solvents present.  This technology is currently being
used to control  VOC  emissions  in the business furniture
manufacturing industry segment.
      3.1.2.3  Enhanced Carbon Treatment System.   Terr-Aqua Enviro
Systems  has  developed  an air pollution control system that is
referred to  as an ultraviolet  (UV)-oxidation air pollution
control  system.  Depending  on the contaminants involved and the
sources, the specific  system designs include aqueous-phase
scrubbing and activated carbon adsorption.   Oxidant generated on-
site, as required,  is  used  to neutralize captured organics on a
continuous basis.  The resultant exit streams (air and water,  as
applicable)  contain  only carbon dioxide and water.  °
      3.1.2.3.1  Enhanced carbon treatment process description.
The UV-oxidation technology uses UV light plus ozone and  other
oxygen-based oxidants  to create smog and complete the process of
oxidation.  Some of  the specific equipment designs and process
techniques are proprietary and the subject of patent
applications.  Basic system components include:
      1.   Two-stage prefilter to remove particulate;
     2.   Photolytic reactor, which uses UV light and oxidant to
begin destruction of the VOC's;
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      3.   Aqua reactor,  where the exhaust  is  scrubbed with
 ozonated water and soluble VOC's collect  in  the water;
      4.   Water recycling tank,  where  the  VOC's are  removed from
 the  water;
      5.   Carbon adsorber units,  which remove the  remaining VOC's
 from the airstream;  and,
      6.   Activated oxygen generators.
      Operation of  the system can be described as  follows.   A
 typical  system collects the exhaust from  paint booths, ovens,
 etc.  and ducts it  to the system where  a two-stage prefilter
 collects particulate from the airflow.  From there  the air passes
 through  the photolytic  reactor,  where  it  is  exposed to tuned
 frequency UV  light and  injected with  oxidant.  At this point in
 the  process,  the molecular structure  of the  VOC's is starting to
 break down.   Next,  the  effluent stream is scrubbed  with ozonated
 water in the  aqua  reactor.   Many of the VOC's are water soluble
 and  will  collect in  the water.   The water is then heavily
 oxidized in the  water recycle tank for an extended  period  of
 time, which completes the  oxidation of the VOC's  to carbon
 dioxide  and water.   The process  water  is  then recycled back to
 the  aqua  reactor.
      After the aqua  reactor,  the  effluent air stream goes  through
 a coalescer, which removes micron-level water droplets and wetted
 particulate entrained in the  airstream.  The air  then goes  into
 one  of two  {or more) carbon beds  where the remaining organic
 material  is removed.  These beds  are alternated every 24 hours,
 or as required.  One bed stays on-line to collect VOC's while the
 other bed is sealed and fed oxidant to regenerate the carbon.
 This  regeneration  is the last step of converting the remaining
 VOC's to carbon dioxide and water.36~^9
      3.1.2.3.2  Standard operating conditions.   The standard
 operating conditions that were identified for carbon adsorption
 units also apply in this case.  Critical components in the  UV-
oxidation system design are modular in design,  thereby
accommodating various airflow requirements,  from a few
 1,000 ft3/min to as large as necessary.  The  largest Terr-Aqua
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UV-oxidation system in  operation  is designed to control
approximately 2,549 m3/min  (90,000 ft3/min).  The UV-oxidation
systems  are  well  suited for  streams that contain multiple
solvents;  unlike  a  conventional steam-regenerated adsorption
system,  it does not generate a mix of solvents requiring
disposal.  No secondary wastes are created.36"3^'
     3.1.2.3.3 Enhanced carbon treatment efficiency.  A wel 1
maintained UV-oxidation system can achieve removal and
destruction  efficiencies in  the 95 to 99 percent range.37
     3.1.2.3.4 Applicability to wood furniture finishing exhaust
streams.   The UV-oxidation air pollution control system is a
feasible control  technology  for the control of VOC's.  Three
Terr-Aqua  UV-oxidation  systems have been installed at aircraft
painting facilities operated by General Dynamics;  the first
system was installed in 1986.  As of January 1995, there is only
one installation  at a furniture plant.  A Terr-Aqua system
designed to  handle  90,000 scfm of exhaust began operating at a
large residential furniture  plant in November 1991.40/41
3.1.3  Methods of Minimizing Control Costs--Volume Reduction
     3.1.3.1   Recirculation.  As previously discussed, exhaust
streams from wood furniture  finishing operations are generally
high-volume  and low-concentration streams.   In wood finishing
operations,  volume  reduction techniques should be  explored for
three reasons, each of  which has merit to the plant  owner for
economic reasons:   (1)   to reduce air flow sent to  an add-on
control, (2)  to concentrate  the air stream to be sent to the add-
on control device,  and/or (3) to reduce makeup air requirements.
     First,  prior to buying  add-on controls,  any reduction in the
exhaust air volume  from spray operations allows the  purchase of a
smaller control unit.   Second,  the exhaust  stream would be more
concentrated  with the potential for savings in the auxiliary fuel
required.  (Thus, both  capital and operating costs associated
with the add-on control device could potentially be  reduced.)
Third,  reduced exhaust  air volume reduces makeup air
requirements;  the energy required for heating and  cooling the air
would decrease, as would the overall energy cost.  This section
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 discusses recirculation of spray booth exhaust as a volume
 reduction technique.   Spray booth design modifications and the
 applicability of recirculation to wood furniture finishing
 operations are also addressed in this section.
      Recirculation is used as a volume reduction technique to
 reduce the volume of  makeup air required in a spray booth and/or
 the volume of air sent to an add-on control device.   In
 recirculation,  part of the discharge air from the spray booth is
 recycled.   The remaining air is exhausted to the atmosphere or to
 an add-on control device.   Makeup air is supplied at the rate at
 which air is  exhausted to the atmosphere (or control device)  from
 the booth.
      The  amount of air that can be recirculated is limited by the
 maximum VOC concentration allowed in the booth.   In a manned
 spray booth,  the VOC  concentration in the booth must remain below
 the permissible exposure level (PEL).   The Occupational  Safety
 and Health Administration (OSHA)  allows the use of recirculation
 in manned  booths,  provided the VOC concentration does not exceed
 the PEL.   According to OSHA representatives,  the VOC
 concentration must be  measured as  soon as recirculation  is
 implemented.  The VOC  concentration must be measured again  if  a
 process modification occurs that  could initiate  a change  in spray
 booth operations.43'43
      The OSHA standard governing  spray booths  was  based on  an  old
 National Fire Protection Association (NFPA)  standard.  (NFPA
 No.  33-1969 is  cited in OSHA regulations).   The  NFPA standard  was
 revised in  1990,  but the revised NFPA  standard has not been
 formally incorporated  into  the  OSHA regulations.   The  current
 version of NFPA No. 33  (1990) allows spray booth recirculation if
 the air is continuously monitored and  automatic  shutdowns are
 provided.44  Though OSHA currently  allows the use  of recircula-
 tion, as described above, the revised NFPA code  has not been
 formally incorporated  into  the  OSHA regulations.
      In an automatic spray booth, the VOC concentration in  the
booth must be less than 25 percent  of  the LEL, pursuant to
 insurance company requirements.  The NFPA requires an LEL monitor
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 if the VOC  concentration is expected to exceed 20 percent of the
 LEL.45  The OSHA representative indicated that most spray booths
 are equipped with alarms that are activated if the VOC
 concentration exceeds 25 percent of the LEL.42
     Recirculation may only be feasible if the design of the
 spray booths that are currently used in finishing operations is
 modified.   The following subsection briefly describes the types
 of booths currently used in the wood furniture industry and
 discusses how those booths may need to be modified to incorporate
 recirculation.
     3.1.3.2  Spray Booth Design Modifications.  Paint spray
 booths currently used by wood furniture manufacturers vary
 according to the coating application method used,, as discussed in
 Chapter 2.  Booths in which coatings are applied manually are the
 most common.  They are mostly open and require large volumes of
 ventilating air.  Booths in which coatings are applied using
 automatic equipment are also used,  and these booths are usually
more enclosed.   In order to incorporate recirculation, the design
 of the more open booths would need to be modified.  The same
booth modifications could be performed for both manual and
automatic coating operations,  with either spray application or
 flat line finishing.
     As was discussed in Chapter 2,  a typical manual spray booth
 is 2.4 m (8.0 ft)  high,  5.8 m (19 ft)  wide,  and 3.0 m (9.9 ft)
deep,  with three open sides.   An example of such a booth is
depicted in Figures 2-1 and 2-2.   The coatings may be applied
manually by a worker using spray guns.   The booth is ventilated
by a side draft such that the air moves past the worker,  over the
piece,  and through filters to remove overspray and is exhausted
 out the booth stack to the atmosphere.   Typically, dry filters
 are used,  although some water wash booths are still used.
     The OSHA regulations concerning spray finishing operations
 state that the total air volume exhausted through a spray booth,
at a minimum,  shall be such as to dilute solvent vapor to at
 least 25 percent of the LEL of the solvent being sprayed.  The
 regulation also provides a table indicating the minimum required
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 velocities into spray booths,  as a function of the type of spray
 operation (manual or automatic)  and spray application method
 (electrostatic or nonelectrostatic).   For manual spray operations
 using air-operated guns,  a minimum design airflow velocity of
 30  meters per minute (m/min)  (100 feet per minute [ft/min])  is
 recommended,  though velocities in the range of 23 to  38 m/min
 (75 to 125 ft/min)  are in compliance.46  Based on an  average
 ventilating air rate of 609 m3/min (21,500 scfm)  and  a filter
 cross-sectional area of 14.1 m2  (152  ft2)  (2.4 m x 5.8 m [8.0 ft
 x 19 ft]),  the average side draft velocity for manual spray
 booths is 43.0 m/min (141 ft/min).
      Both manual and automatic spray  booths could be  enclosed by
 minimizing the openings for the  piece to  enter and exit to the
 greatest  extent possible.   The limiting factor will be the size
 of  the largest piece being finished and the space required for
 the conveying system (hooks, pallets,  etc.).   The auto industry
 minimizes  the openings by using  masks or  silhouettes  that  mount
 in  the booth  opening to accommodate differently sized and  shaped
 pieces.  Also,  the  front  of the  booth,  where the  worker stands,
 could potentially be further enclosed.  To meet OSHA
 requirements,  the minimum air  velocity must be maintained  across
 the entire  length of the  booth in which the worker could
 potentially operate.   By minimizing the opening in the  front of
 the booth,  the  ductwork required for  recirculation could be
 installed.  The extent  of  volume reduction is  a function of  the
 extent  to which the  booth  openings can be  minimized while
maintaining the minimum required velocity  across  the worker.
      3.1.3.3  Classic  Systems' CamBooth.47  Classic Systems  is a
 company that  has  since  gone out  of business that  developed a
unique design called the CamBooth spray booth,  herein referred to
as  CamBooth.  Although  the  company apparently  is  no longer
operating, the  CamBooth technology is  described in this  section
to  demonstrate  the types of modifications  that  can be made to a
spray booth to  incorporate recirculation.   The  company indicated
the CamBooth can reduce the volume of exhaust air by
approximately 80 percent compared to a  conventional spray booth.
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 The' basic  design of  the  CamBooth  involves the use of air
   *
 curtains;  the  worker stands  outside  of the booth and sprays
 through  the  air  curtain.  The air curtain provides a barrier
 between  the  worker and the solvent emissions inside the booth
 resulting  from spraying  coating on the piece.
     The CamBooth booth  can  be designed to be from 2.4 to 7.3 m
 (8  to 24 ft) long.   The  booth features downdraft design with
 filters  located  on the floor of the  booth to control the
 overspray.   The  face velocity across the filters is between
 38  and 61  meters  per minute  (125  and 200 feet per minute).  The
 total exhaust  rate from  the  Cambooth is from 71 to 170 m3/min
 (2,500 to  6,000  scfm) , depending  on  the length.  The CamBooth
 spray booth  operates at  a slight  negative pressure; the makeup
 air flow is  less  than the exhaust  rate.  According to Classic
 Systems, the air  curtains minimize dirt problems typically
 associated with operating at negative pressure.
     The booth design can also include an adjacent,  enclosed
 flash tunnel.  As with the spray booth, air curtains separate the
 air  inside the flash area from the outside air.  The design is
 such that  if an abatement device  is used,  the exhaust from the
 flash tunnel can be  sent to the control device.  Because the
 exhaust  rate from the CamBooth is  so much lower than conventional
 booths,   the  reduction in makeup air  requirements decreases makeup
 air heating  and cooling costs.   Also, because the volume of air
 exhausted  from the booth is low,  the capital and operating costs
 of an add-on control  device are reduced.
     Advantages of the CamBooth spray booth include the reduced
makeup air requirements,  the low exhaust volume, and the air
 curtain design.  The  low exhaust volume reduces the capital and
 operating  cost of an  add-on control device.   The air curtain
 design separates the  worker from the VOC emissions.   Thus,  the
VOC concentrations inside the booth can exceed the normal
permissible exposure  limit (PEL).   Therefore,  if an add-on
 control device were used in conjunction with the CamBooth,  a more
 concentrated stream could be sent to the control device,
resulting  in lower auxiliary fuel requirements in the case of an
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 incinerator,  or greater adsorbent capacity in the case of an
 adsorber.
      A disadvantage of the CamBooth,  is that in some instances it
 unacceptably  limits the worker's access to the piece.   A
 demonstration of the CamBooth spray booth was provided at a large
 household/residential furniture manufacturer.   The furniture
 manufacturer  felt that the CamBooth spray booth was not
 applicable for finishing large three-dimensional pieces.   During
 the  demonstration,  the spray operator reportedly broke the air
 curtain (stuck his head through the curtain)  in order  to reach
 the  back side of the three-dimensional part.48  Training of the
 worker may eliminate such problems.   If worker training is not
 sufficient, it may be possible to modify the design -of the
 CamBooth to eliminate this problem.
      3.1.3.4   Applicability to Wood Furniture  Finishing
 Operations.   Both automatic and manual application booths in the
 wood  furniture finishing industry utilize  spray booth
 recirculation.45'49   Recirculation is  also used in other
 industries  performing surface  coating  operations involving manual
 and automatic  equipment.50"-'4   Studies have  also been  conducted
 by EPA to ascertain  the  feasibility and safety of
 recirculation.56'56   Those studies  conclude  that recirculation
 can safely  and effectively be  used  in  paint  spray  booths.   Based
 on the use  of  recirculation by furniture manufacturers  and on  the
 studies  conducted to date,  the incorporation of  recirculation
 appears  feasible  for all  segments of wood  finishing, with
 appropriate booth modification.
     An existing spray booth can, in some  instances, be modified
 to incorporate  the use of  recirculation.  However, if an  existing
booth is modified, undesirable  rolling  turbulence may be  created,
 resulting in finish  quality  problems.57  The majority of  the
spray booth vendors  contacted  recommended replacing the existing
booths with new booths that  incorporate recirculation into  the
original design.54'58"60
     The potential impact of incorporating spray booth
recirculation  on the insurance premiums for a facility was
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examined.  A representative of a company that insures plants in
the wood furniture industry said that there is no simple answer
to the question of what would happen to insurance premiums if a
manufacturer began using a spray booth with air recirculation.
The insurance representative said that the premiums for a
facility are determined by an analysis of the entire plant, not
just a given area.  The representative said that some additional
safety precautions, such as installation of an LEL monitor and
possibly sprinklers within the booth, could be required if spray
booth recirculation is used.  Decisions regarding requirements
and premiums are site-specific,  according to the insurance
representative.
     Some office and cabinet manufacturers have modified the '
spray booth designs in their facilities in order to incorporate
recirculation.45  In addition to the facilities already using
modified spray booths, some spray booth vendors have designed
spray booths that utilize smaller volumes of air.  These booths
may or may not incorporate recirculation. 3'°3  These booths have
been and are being tested in facilities that surface-coat and are
discussed in further detail in Section 3.3.
     As of May 1992,  Classic Systems' CamBooth was being used in
production at one facility, is being installed at two additional
facilities,  and was being tested by several others.   The CamBooth
was being used at a coating manufacturing facility.   The CamBooth
was installed in April 1992 and is used for spraying test
coatings developed by the coating manufacturer.
3.1.4  Total Enclosure of the Finishing Line
     The overall control efficiency of an add-on control system
is the product of the capture efficiency of the system and the
control device destruction efficiency.  Therefore, to achieve the
highest overall  control, the capture efficiency must be
maximized.   Capture efficiency is defined as the fraction of all
VOC's generated that are captured and sent to an add-on control
device.  Capture efficiency can be assumed to be 100 percent if
the source of VOC is totally enclosed (e.g., spray booth, flash
area,  etc.).  This section describes a total enclosure, provides
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 the  EPA criteria for verifying that an enclosure is  total,  and
 discusses  the applicability of total enclosures  for  wood
 furniture  finishing lines.
      3.1.4.1   Total Enclosure Description/Criteria.  A total
 enclosure  is  a structure  that completely  surrounds a source of
 emissions  such that all VOC emissions exhaust  through  a duct  to  a
 control device.
      The EPA  has developed  the following  criteria for  verifying
 if an enclosure  is  a total  enclosure.65
      1.  Any  natural draft  opening  (NDO)  is at least four
 equivalent opening  diameters from each VOC-emitting  point.  An
 NDO  is defined as any permanent opening in the enclosure that
 remains open  during operation of the"facility  and is-not'
 connected  to  a duct in which a fan  is installed;
      2.  The  total  area of  all NDO's does not  exceed 5  percent of
 the  surface area of the enclosure's  four walls,  floor,  and
 ceiling;
      3.  The  average facial  velocity (FV) of air  through all
 NDO's  is at least 3,600 meters per hour  (m/hr) (200  ft/min).   The
 direction  of  air through all NDO's is into the enclosure; and
      4.  All  access doors and windows whose areas are not
 included in No.  3,  above, are closed during routine  operation  of
 the process.
      Procedures  for determining  NDO's  and FV are provided in the
 EPA enabling  document, The Measurement Solution—Using a
 Temporary  Total  Enclosure for Capture  Efficiency Testing.65
      3.1.4.2  Applicability  to Wood  Furniture Finishing
 Operations.   A total enclosure may be  set up over an individual
 booth  or oven or over an entire  finishing line.  Alternatively,
 an entire  finishing  room may function as a total enclosure.
     Establishing a  total enclosure  for an individual
 booth/oven/flashoff area may be difficult given the current
method of wood furniture finishing.   The wet piece leaves the
booth, and the solvent in the  coating material flashes off in an
 open area prior to entering  the oven.  In some facilities,  the
 conveyor loops back and forth  to provide increased flash/dry
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time.  In many facilities, expansions have resulted in very
little unused space.  Therefore, space constraints in the
finishing area may prohibit enclosing portions of the finishing
line or the finishing line in its entirety.  One solution may be
to have the entire finishing room function as a total enclosure.
     An entire finishing room could function as a total enclosure
if it meets the criteria,--i.e., all booths and ovens were
exhausted to a VOC control device and there were no other exhaust
points from the room.  The room would have to be maintained at a
slight negative pressure; the volume of makeup air supplied under
pressure must be less than the volume of air exhausted.  Open
windows and doors would be considered NDO's.  A total enclosure
must be designed to maintain VOC levels below OSHA limits in all
areas of the plant.
3.2  LOWER VOC FINISHES
     Volatile organic compound emissions from wood furniture
finishing operations can be reduced by using coating materials
that contain fewer VOC's.  Currently in wood furniture finishing
operations,  VOC emissions result from the application and
subsequent evaporation of finishing materials.   Efforts have been
made to develop and introduce finishing materials for the wood
furniture industry that contain fewer VOC's.  The EPA has
published a report on current and emerging technologies that can
reduce VOC emissions from the coating industry.b6  The lower VOC
coatings that are currently available or reportedly will be
available in the near future are discussed in this section,  and
the VOC reductions that these materials offer are identified.
The types of finishing operations for which these coatings could
potentially be used are also discussed.   Finally,  the advantages
and disadvantages of these lower VOC finishing materials are
identified.
3.2.1 Use of Lower VOC Finishing Materials
     The finishing material descriptions provided in this section
include the finish formulation,  the VOC content of the finish,
percent solids by weight, and some general finish
characteristics.   By comparing the VOC content of the
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 conventional finish material currently used by the wood furniture
 industry with the VOC content of the lower VOC finishes,  and
 assuming the same quantity of solids is applied (except for
 nonfi1m-forming low-solids finishes),  an estimate of  potential
 VOC emission reductions associated with each finish is  provided.
 Alternative finishing systems in which some of the steps  involve
 lower VOC finishes are presented for the different model  plants
 in Chapter 5.   Waterborne and higher solids coatings, the lower
 VOC finishes focused on for the model  plants,  are discussed in
 this section.
      The VOC emission reductions identified in this chapter have
 been calculated based on the switch from nitrocellulose-based
 finishes to the new finishing system.   Because the new  finishing
 systems  are model  plant-specific,  the  VOC emission reductions
 presented in Chapter 6 are more likely to represent actual plant
 emission reductions than the VOC emission reductions presented in
 this  chapter.
      The types  of  finishing materials  currently used for  wood
 furniture finishing in general  have been identified in  Chapter 2.
 Finishing materials include stain,  washcoat, glaze/filler,
 sealer,  highlight,  and topcoat.  The sealers and  topcoats,  or
 lacquers,  constitute  the majority  (approximately  65 percent) of
 finishing materials used.   The  lacquers  are clear  coats and, in
 the conventional formulations,  are  nitrocellulose  products.  The
 stain materials are alcohol-based and  do not contain
 nitrocellulose.  While  lower VOC finishes have  been developed  for
 nearly all  finish types, the most commonly used lower VOC
 finishes  are those  for  the  clear coat  steps.  Thus, the focus  of
 this  section is on  the  clear coats.  Therefore, when conventional
 nitrocellulose coatings are discussed, only the lacquers  (clear
 coats) are actually being considered.  Lower-VOC stain materials,
which reduce the VOC content by replacing some of the alcohol
with water, are also being used by  the industry.
     Lower VOC coatings that could  replace the traditional
nitrocellulose products include waterborne and higher solids
coatings.  Higher solids coatings include catalyzed, ultraviolet
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 (UV)  - curable, polyester, polyurethane, and those modified for
 the UNICARB® and VOC Control® coatings systems.  A description of
 the traditional nitrocellulose products and the lower VOC
 finishes are provided below.  In the following descriptions, the
 VOC contents are provided in:  (1) grams of VOC per liter of
 finishing material, less water, less negligibly photochemically
 reactive compounds  (g/L-water) (pounds of VOC per gallon of
 finishing material, less water, less negligibly photochemically
 reactive compounds  [Ib/gal-water]) and (2) grams of VOC per gram
 of solids used  (g/g solids)  (pounds of VOC per pound of solids
 used  [Ib/lb solids]).  The solids content is expressed as percent
 solids by weight.
     3.2.1.1  Nitrocellulose-Based Finishes.  Nitrocellulose-
 based finishes are the most widely used finishes in the wood
 finishing industry today.67  The primary components of these
 materials are cellulosic resins,  film-forming resins,
 plasticizers, and solvent.  Nitrocellulose is the cellulosic
 resin that is most widely used.  It is prepared by nitration of
 cellulose with nitric acid.68  The nitrocellulose serves as a
 binder in the finish material.  The film-forming resins are
 thermoplastic and are characterized by their low resistance to
 heat and solvents.  The plasticizers contained in the finishes
 can be esters or oils.  Solvents are selected depending on
 required application,  manner of drying,  and other conditions.
 Some solvents,  such as acetone and ethyl acetate;,  are included in
 the formulation due to their high evaporation reite because they
 serve to shorten the flashoff time.  Other solvents,  such as
 esters and glycol ethers, serve as active solvents to dissolve
 the nitrocellulose.  Finally, solvents such as butyl  acetate and
 xylene are selected for their low evaporation rate to prevent
premature drying and the associated problems of bubbling and
blistering.69'70
     Nitrocellulose-based finishes are nonconvertible finishes.
That is,  film formation and drying occur via solvent  evaporation;
no chemical reaction,  or curing,  takes place.  Nitrocellulose-
based finishes are categorized as fast-drying.  They  are
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 relatively easy to spray.   Because of the low solvent resistance
 of the thermoplastic resins and nitrocellulose in the
 formulation,  nitrocellulose finishes are easily dissolved,  and
 thus pieces finished with  nitrocellulose finishes are both easy
 to damage and relatively easy to repair.70'71  Their function is
 to give the pieces the desired aesthetics and to protect  the
 substrate.
      The average VOC content of nitrocellulose-based lacquers is
 approximately 727 g/L-water (6.1 Ib/gal-water)  and 4.0 g/g solids
 (4.0 Ib/lb solids).   The solids content  of nitrocellulose-based
 lacquers is approximately  20 percent by  weight.72"77
      3.2.1.2   Waterborne Finishes.   Waterborne finishes are
 finishes in which water is the main solvent or dispersing
 agent.78  There are  distinct differences  between the various
 waterborne  formulations that are available.   Based on the types
 of  polymers used in  the formulation,  waterborne finishes  may be
 water  emulsions,  solutions,  or colloidal  dispersions.78"80   The
 various  polymers determine the cured film properties of the
 finish.   However,  there is one common feature:   each type employs
 water  as the major solvent or carrying liquid for  polymers.7^"80
     Waterborne finishes formulated with  water-emulsion polymers
 are true emulsions;  the polymers  are discrete water-insoluble
 spherical particles  of  high molecular weight  uniformly  dispersed
 in  water.   Waterborne  finishes  that  are considered  solutions  are
 formulated  with copolymers (referred to as water-reducible
 polymers  in some  industry  publications) that  are formed in  a
 polymerization  reaction occurring in  a water-miscible solvent
 such as  alcohol.  The polymers  have polar groups that allow
 water-reducibility and, thus,  true solutions  of polymers  in
 water.  Waterborne finishes  known as  colloidal dispersions
 contain  colloidal dispersion polymers  (referred to as water-
 soluble polymers in some industry publications).  These polymers
 are materials in which particles of a medium molecular weight
 (not as high as the emulsion polymers) are dispersed in water.
The colloidal dispersion polymers have polar groups, thus
allowing some degree of solubility.  The colloidal dispersion
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 formulations  are not  true  solutions but are also not true
 emulsions  because  there  is some degree of 'solubility of the
 polymers in the solvent.80
     Each  type of  waterbome finish, like all finishes, exhibits
 different  film properties  depending on the type of polymer in the
 formulation.  The  water-emulsion formulations are of a higher
 molecular  weight and  therefore offer advantages in the areas of
 durability and chemical  and stain resistance.79'80  Water-
 reducible  formulations offer high gloss, clarity, and good
 application properties.  However, their film is not as durable as
 that of the water-emulsions, and the viscosity and properties of
 the finishes  are very dependent on molecular weight.79  The
 water-soluble formulations exhibit properties of the water-
 emulsion and  water-reducible formulations.  The water-soluble
 finishes offer high gloss  and good application properties and are
                                               *7 Q
 also durable  and chemical- and stain-resistant.
     Waterborne finishes can be formulated for air/force drying
 or for baking, depending on the binders in the formu-
 lation.72'79'81  Waterborne finishes may cure in the same manner
 as the solventborne finishes.  Curing occurs through oxidative or
 thermosetting cross-linking reactions.   Waterborne finishes may
 also cure via latex coalescence.79'81  Latex coalescence occurs
 when a polymer is dissolved in solvent,  then dispersed in water.
 Either the solvent or water then evaporates,  leaving a polymer
 dispersed in  solvent or water.   As the remaining liquid
 evaporates, the pressures force the polymer to coalesce.  No
 polymerization takes place; these are a special  form of
 nonconvertible finishes.
     The VOC  content of waterborne finishes varies substantially.
 Waterborne finishes are usually not free of VOC.   Cosolvents are
 added to allow adequate coalescence and film formation, as well
 as color penetration for pigmented materials.82   Based on the
 survey information, waterborne finishes have a VOC content of
approximately 328 g/L-water (2.7 Ib/gal-water.)   The VOC content
based on solids ranges from approximately 0.3 to 0.8 g/g solids
 (0.3 to 0.8 Ib/lb solids).  The average solids content of the
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 waterborne finishes in the surveys is 24 percent by
 weight.77'82"88  Based on the VOC content of nitrocellulose-based
 finishes,  the waterborne finishes represent 75 to 88 percent
 reduction in VOC emissions per weight of solids applied.
 However,  a plant's overall VOC emission reduction depends on the
 number of finishing steps for which waterborne finishes can be
 used.
      3.2.1.3  Higher Solids Finishes.   Higher solids finishes are
 common in various segments of the wood furniture industry.   The
 higher solids finishes consist of catalyzed,  ultraviolet  (UV) -
 curable,  polyurethane,  polyester,  those modified for the  UNICARB®
 system, and those in Akzo's VOC Control® system.   Based on
 equivalent solids applied,  the higher solids coating results in
 lower  VOC emissions than traditional finishes.   A description of
 the various higher solids finishes is  provided below.
     3.2.1.3.1  Catalyzed finishes.  The most common catalyzed
 finishes  used in the wood furniture  industry today are  the  acid-
 catalyzed  finishes.   The film-forming  resins contained  in these
 finishes are usually a  urea-formaldehyde or me1amine-formaldehyde
 prepolymer,  in admixture with an alkyd resin that  serves  as a
 plasticizer.   The catalysts that are used in these finishes vary.
 Common catalysts contained  in the  acid-catalyzed  finishes include
 sulfuric acid and p-toluenesulphonic acid.    Catalyzed finishes
 can be in  a one-pack or two-pack form.   The one-pack finishes are
 precatalyzed.   They  contain nitrocellulose  resins  and a smaller
 percentage of  the urea  resin.  Also, only a small  amount  of
 catalyst is  added.   Thus, cure time  is  long;  it is usually  3 to
 4 weeks until  full curing occurs.  Eventually,  the finishes will
 cure in the  container.   The  pot  life is  usually 2  to 3  months.77
 The two-pack finishes must be mixed  before  use.  The two-pack
 finishes are  formulated with urea or melamine resins.   More
 catalyst is  contained in these than  in  the  one-pack.  Thus,
 curing time  is  short.   The main  advantage of  the one-pack form  is
 that the user does not  have  to be concerned with weighing and
mixing constituents prior to application.  However, the two-pack
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products  are  considered to have superior properties as compared
to the one-pack products.71'72
     Catalyzed finishes are convertible finishes; film formation
occurs through curing  (polymerization) of the resins rather than
drying.72  The finish  is cured through a chemical reaction, the
rate of which is controlled by the amount of catalyst in the
finish.  Depending on  the coating formulation and the amount of
catalyst used, reaction by-products may include alcohol,
formaldehyde, and water.90  Acceptable catalyzed finishes yield a
cured film that is hard, tough, scratch- and impact-resistant,
and resists water, alcohol, and common household chemicals.71
     The VOC  content of the catalyzed clear coats used by the
industry today is approximately 547 g/L-water "(4.6 Ib/gal-water)
with solids content of 48 percent solids by weight.72"77'91  The
VOC content based on solids is l.l g/g solids (1.1 Ib/lb solids).
Based on the  VOC content of the nitrocellulose-based finishes,
the catalyzed finishes represent a 62 percent VOC emission
reduction per weight of solids applied.   Therefore,  a facility
would reduce  VOC emissions by 62 percent for each finishing step
that could be converted to catalyzed finishes.  However, as
previously stated for the waterborne finishes, cictual VOC
emission reductions for a particular facility are a function of
the number of steps for which catalyzed finishes can be used.
     Conversion varnishes are a type of catalyzed coating that
are used in the wood furniture industry.  Conversion varnishes do
not dry as quickly as nitrocellulose finishes, and are difficult
to repair.  Conversion varnishes,  like two-pack catalyzed
finishes, have a limited shelf life.
     The VOC  content of the conversion varnishes used by the
industry today is approximately 600 g/L-water (5.0 Ib/gal-water),
with a solids content of about 35 percent by weight.   The VOC
content based on solids is approximately 1.9 g/g solids
(1.9 Ib/lb solids).72"77'91  Based on the VOC content of
nitrocellulose-based finishes, conversion varnishes represent a
43 percent VOC emission reduction per weight of solids applied.
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 However,  the total emission reduction depends on the number of
 finishing steps that are switched to conversion varnishes.
      3.2.1.3.2   Ultraviolet-curable finishes.   Radiation curing
 is  a  technology that utilizes electromagnetic radiation energy to
 affect  chemical and physical change of organic finish materials
 by  the  formation of cross-linked polymer networks.88 One type of
 radiation used  is UV light.  The primary components  of  UV-curable
 finishes  are multifunctional polymers (acrylates,  acrylated
 oligomers),  monofunctional diluent monomers,  and the
 photoinitiators.   The photoinitiator absorbs  the UV  light and
                                                           ftp
 initiates free  radical polymerization,  the  curing process.00   The
 diluent serves  as a viscosity modifier for  the finish,  enabling
 the finish to be  applied to the  substrate.  It is similar to a
 solvent in this regard.   In traditional  UV  finishes,  however,
 most  of the  diluent also polymerizes and becomes part of  the
 coating film.80  However,  the diluent in the  finish  that  does  not
 reach the piece and,  thus,  is not  incorporated into  the  final
 film, is  emitted.
      Ultraviolet-curable finishes  are convertible  finishes; the
 curing  process  is  via polymerization.  The  curing  process for
 UV-curable finishes is very fast.   As the substrate  is exposed to
 UV radiation, the  photoinitiator absorbs  the light and initiates
 near-instant  polymerization.   Polymerization,  or  curing,  of the
 material  is  rapid,  providing a final  film that  is  stain-,
 scratch-,  and mar-resistant.71'^2   Because  the  curing is  so
 rapid,  finished pieces can  immediately be stacked.  Other
 properties of the  UV-cured  film include heat resistance,
 durability, and good  build.
     Ultraviolet-curable  finishes do  not  typically contribute
 substantial VOC emissions  (due to the polymerization process
 discussed above) and  often  are considered to contain up to
 100 percent solids  since  100 percent  of the components react to
 form the coating.   Some UV-curable  finishes are formulated such
 that some conventional solvent that volatilizes is added  along
with the diluent monomer.  The VOC content of these materials  is
approximately 458 g/L-water  (3.8 Ib/gal-water) and
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0.15 g/g solids  (0.15 Ib/lb solids); they are approximately
81? percent solids by weight.77'82"84'86"88  The UV-curable
finishes represent approximately an 83 percent reduction in VOC
emissions per weight of solids applied.  However, as previously
stated, these emission reductions depend on the number of
finishing steps used by a facility that switches from
nitrocellulose to UV-curable finishes.
     3.2.1.3.3  Polyester finishes.  Two types of polyester
finishes are available for use in the wood furniture finishing
industry.  The first type is the styrene-derived polyester.  This
type of polyester uses styrene as a solvent and reactant for
unsaturated alkyd resins contained in the finishes.  The styrene-
derived finishes contain a dryer, also known as an accelerator or
promoter, typically a heavy metal such as cobalt.  Curing can
occur through a catalytic reaction, or through exposure to UV
radiation.  To cure the finishes via a catalytic reaction, an
organic peroxide is added to serve as a catalyst.70  The styrene-
derived polyesters can be supplied in a two-pack or three-pack
form.  In the three-pack form,  the dryer and catalyst are added
by the user.   In the two-pack form, the dryer is already in the
                                             "71
finish formulation and the catalyst is added.
     The second type of polyester finishes is the acrylic
polyesters.  These finishes contain cross-linking acrylics and
solvents such as esters,  ketones, and aromatic hydrocarbons.
Some of the cross-linking acrylics are modified by styrene and
are considered special types of the styrene-derived polyesters.
As with the styrene-derived polyesters,  curing can occur via a
catalytic reaction by organic peroxides or through exposure to
radiant energy.70  The cured films of both types of polyester
finishes are characterized as high-build,  fast-drying,  durable,
and heat-,  chemical-,  and mechanical-resistant materials.71
     Polyester finishes are very difficult to repair once cured.
Therefore,  minimizing the amount of dirt in the finishing room is
critical to minimizing rejects.  Because of this, clean room
environments are strongly recommended for polyester finish
applications.82'83
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      The styrene-derived polyester finishes are typically
 100 percent solids.  The VOC's,  such as styrene,  which are
 present in the finish formulation, become part of the cured film.
 However,  a small portion of such materials may not cross-link and
 therefore may result in some VOC emissions.  The acrylic
 polyesters have a VOC content of approximately 402 g/L-water
 (3.4 Ib/gal-water)  and 0.21 g/g  solids (0.21 Ib/lb solids)  and a
 solids content of 80 percent by  weight.77'82'84'87  Based on the
 VOC content of nitrocellulose-based finishes,  polyester finishes
 represent approximately an 83 percent reduction in VOC emissions
 per weight of solids applied. However,  a facility is not likely
 to use polyester materials for all of its finishing steps.
 Therefore,  overall  emission reductions would be less.
      3.2.1.3.4  Polyurethane finishes.   Polyurethane finishes are
 formed through the  reaction of a polyhydric alcohol with an
 isocyanate cross-linking resin.   The isocyanates  in the
 formulation may include toluene  diisocyanate,  naphthalene
 diisocyanate,  or hexamethylene diisocyanate.   The polyhydric
 alcohol could be glycerol,  pentaerythritol,  or others.  °'^3
 There  are  three classifications  of polyurethane finishes
 depending  on the formulation or  cure process:   (1)  one-component
 products,  (2)  two-component products,  and (3)  moisture-cured
 materials.   The one-component and two-component products  are
 different  in their  formulations.   A one-component product  is a
 urethane alkyd,  which  contains no free  isocyanate.   The
 two-component  products are  the most common  and produce  a  finish
 by  cross-linking a  polyester resin with an  isocyanate.  The
 moisture-cured product is a special one- component  product,  based
 on  the way  the coating is cured,   as discussed  below.^3
     The two-component polyurethane finish products  are
 convertible  finishes;  film  formation occurs through
 polymerization.   The finish material  is cured  through a chemical
 reaction taking  place  between the  binders in the product and
 binders in the hardener.71   Film  formation of  one-component
 polyurethane finishes may occur through polymerization or through
moisture curing.  Moisture-cured  finishes are not  fully cured
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through polymerization.  However, they are not nonconvertible
finishes such as the nitrocellulose-based finishes described
above.  Final curing of the moisture-cured finishes occurs when
moisture in the environment reacts with free isocyanate groups to
form the dry film.  The curing rate of the moisture-cure finishes
cannot be controlled and can require several months for final
cure.70  The final cured film of all the different types of
polyurethane finishes is durable.  It is resistant to chemicals,
scratches, and abrasion.  Polyurethane products are characterized
as good for polishing, providing a high-gloss finish.71
     Polyurethane finishes, like polyester,  are difficult to
repair once they have cured.  Because the cured polyurethane film
is resistant to solvents, repairs involve mechanically removing
the cured coating through abrasion.   Due to the difficulty of
repair and the final finish achievable once repaired,
polyurethane coated pieces are rarely repaired extensively.
Therefore, it is critical to minimize the amount of dirt in the
finishing room.   If dirt gets on a wet nitrocellulose lacquer, it
can often be rubbed out after the lacquer has dried.   However,
polyurethane finishes are not rubbed;  it is not possible to
remove dirt from cured polyurethane finishes by rubbing.  For
this reason,  finish suppliers indicate a clean room environment
is highly desirable when applying polyurethane finishes.82'83
     The VOC content of the currently available polyurethane
finishes ranges  from about 239 to 792  g/L-water (2.0  to
6.6 Ib/gal-water)  and range from 0.25  to 2.33 g/g solids (0.25 to
2.33 Ib/lb solids).  The solids content of polyurethane finishes
                                           £ Q *7*7 ft"? R 4.
ranges between 30 and 80 percent by weight."'   '0<     As
compared to the  nitrocellulose-based finishes,  polyurethane
finishes represent from approximately a 27 to 92 percent
reduction in VOC emissions per weight  of solids applied.  A
facility would reduce VOC emissions  by this amount for each
finishing step that was converted to use polyurethane finishes
from using nitrocellulose-based finishes.   However, a facility's
overall VOC emission reduction would depend on the number of
finishing steps  for which polyurethane finishes could be used.
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      3.2.1.3.5  UNICARB® System Finishes.   The UNICARB® finishing
 system was developed by Union Carbide as a way to apply
 conventional finishes that minimizes the quantity of VOC-
 containing solvent required.   The general  concept behind the
 UNICARB® system is that some  of the solvent used for spraying the
 conventional clear coats is replaced by C02.   Thus, the UNICARB®
 system involves modified finishes and a somewhat modified
 application method,  as described in Chapter 2.   This section
 provides information regarding VOC content and solids  content of
 the finishes formulated for use with the UNICARB® system.
      The UNICARB®  finishes are specially formulated.   They
 contain polymers and high boiling-point solvents that  are  mixed
 with liquid C02 immediately prior to being sprayed.  As a  rule of
 thumb,  1 pound of  C02 "replaces"  1 pound of solvent in the
 conventional finishes.   The same  resins that  are used  in
 conventional (nitrocellulose-based)  finishes  are used  in the
 UNICARB® finishes.   UNICARB®  finishes are  spray-applied and  dried
 in  the  same manner as conventional (nitrocellulose-based)
 finishes.  -1
      The UNICARB®  finishes are  only available in clear coat
 formulations.   The VOC content  of  these formulations is
 approximately  643  g/L-water (5.4  Ib/gal-water)  and 1.4  g/g solids
 (1.4  Ib/lb  solids).   The  solids content of  the  UNICARB® finishes
 is  approximately 41  percent solids  by weight.77'82'84'85   The VOC
 content  of  the  UNICARB®  finishes  represents approximately  a
 48  percent  reduction in VOC emissions  per weight  of solids
 applied,  compared  to their traditional  nitrocellulose-based
 counterparts.   However, actual overall  VOC  emission reductions
 are a function  of  the number of finishing steps  for which
 UNICARB®  finishes  can be  used.
      3.2.1.3.6  VOC  Control® System.94  The VOC Control®
 finishing system was developed by Akzo  Nobel  Coatings,   Inc.   The
VOC Control® system  finishes are higher-solids
nitrocellulose-based sealers and topcoats.  The finishes are
heated and then applied using an application  system developed by
Graco.  The Graco system can be either  air assisted or  air
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assisted  airless,  and uses  "ultra-high" pressures to atomize the
higher-solids  finishes.
     The  higher  solids content of the VOC Control® system
finishes  allows,  in  some instances, for the user to eliminate
finishing steps;  by  applying more solids during each step, steps
can be eliminated.
     The  VOC content of the VOC Control® system sealers is less
than 1.9  g/g solids  (1.9 Ib/lb solids), and that of topcoats is
less than 1.8  g/g solids (1.8 Ib/lb solids).  The solids content
of the VOC Control®  finishes ranges from 30 to 50 percent by
weight.   As compared to conventional nitrocellulose-based
finishes,  VOC  Control® finishes represent about a 41 to
44 percent reduction in VOC emissions per weight of solids
applied.   A facility would reduce VOC emissions by this amount
for each  finishing step that was converted to VOC Control® system
finishes.  However,  a facility's overall. VOC emission reduction
would depend on the  number of finishing steps for which VOC
Control®  system finishes are used.
3.2.2  Applicability of Lower-VQC Finishes to Wood ^Furniture
       Finishing  Operations
     As previously mentioned, nitrocellulose-based finish
materials  are  extensively used in the wood furniture finishing
industry.  Attempts  are being made to reformulate finishing
materials, as  described above,  so that lower-VOC materials can be
used.  Some of the lower VOC coatings may not apply to all
aspects of the wood  finishing industry.  Therefore,  this section
identifies the industry segments able to use each of the lower
VOC finishes and  discusses the shortcomings of the finishes that
prevent their more widespread use.
     3.2.2.1  Waterborne Finishes.  Waterborne finishing
materials  are  currently being used by some furniture
manufacturers.   The potential exists for waterborne finishes to
be used by all segments of the wood finishing industry.   However,
the waterborne finishes currently available are better suited to
certain applications than others.   For example:
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      1.   Open-pore woods are considered easier to finish with
                                       09 o/
 waterborne finishes than filled pores;0"6'0
      2.   Darker woods sometimes appear cloudy when finished with
 waterborne finishes,  though the clarity has  improved over the
               QO
 last  10  years;°*
      3.   Waterborne finishes do not have the rubbability of
 nitrocellulose lacquers,  and the finish is therefore not as
 glossy where a glossy finish is required; and
      4.   Waterborne finishes may require a modified drying method
                                     ft 2  R ^
 (increased airflow and temperature). *'CJ
      Some facilities  may be able to use waterborne finishes for
 some  finishing steps  but not all.   According to finish material
 suppliers,  in certain applications  only solventborne stains and
 washcoat can be used  because of the problems of grain
 raising.82'88  Grain  raising is a swelling of  the fibers in the
 wood  due to the absorptance of  a liquid,  such  as water.   Grain
 raising  causes  the  surface  of the wood  to look and feel  rough.
 Waterborne  topcoats are  available and are used by many segments
                                Qp Q Q
 of the wood furniture industry.0^"00
      3.2.2.2  Catalyzed  Finishes.   Catalyzed finishes (primarily
 conversion  varnishes)  are currently used  by  kitchen  cabinet and
 office/business  furniture manufacturers because  of the durable
 finish that  these finishes  provide.  Catalyzed finishes  are also
 used  in  the manufacture of  knock-down furniture.71   However,
 catalyzed finishes are presently not used much in  the manufacture
 of traditional household/residential furniture because the
 catalyzed finishes do not provide the same appearance as  the
 nitrocellulose-based  finishes.  Technically,  catalyzed finishes
 could be applied to household/residential furniture and would
provide a more durable and  stain-resistant surface than the
 traditional nitrocellulose-based lacquers.  The  consumer  would
have to weigh the positive and negative aspects  of furniture
 finished with the two chemistries.  If, however, the purpose of
the changeover to catalyzed finishes is only VOC emission
reduction, other alternative finishes provide more substantial
emission reductions.
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      3.2.2.3  Ultraviolet-Curable Finishes.  Ultraviolet-curable
  i
finishes  are  currently used in various segments of the wood
finishing industry.  5  Ultraviolet-curable finishes can be
applied using spray  equipment, roll coaters, or curtain coaters.
Therefore,  the potential exists for UV-curable finishes to be
used  on case  goods as well as flat pieces, and progress in this
direction has been made and is discussed in Section 3.3.3.
However,  curing of three-dimensional pieces remains difficult
because all of the finish material must be exposed to the UV
radiation.  Problems arise in curing recessed surfaces that do
not get direct exposure to the radiation.83  Therefore, the
majority  of UV-curable finishes that are used in the wood
furniture  industry are on flat line operations (although some
chair finishing is being done using UV-curable finishes).^6  Many
studies are being conducted in the area of three-dimensional UV-
curing so  that UV-curable materials may .experience more
widespread use in the future.
     Ultraviolet-curable finishes are feasible and demonstrated
for finishing operations in which the pieces are flat, with no
significant carvings or recessed areas.  There are two types of
UV-curable finishes.  One type is applied via a curtain coater,
roll coater,  or similar flat line apparatus.  The UV-curable
finishes applied by these methods typically are almost
100 percent solids with a VOC content close to
zero.77'82"84'86*88  The other main type of UV-curable finishes
are applied using conventional spray application equipment.
     As discussed previously,  the VOC content,  percent solids,
and material  cost of the sprayable UV-curable finishes are
approximately the same as the VOC content percent solids,  and
cost of the polyester and polyurethane finishes.77'82"84'8^'88
The cost parameters that need to be considered in the conversion
are also the same.  However,  with UV-curable finishes, the
additional cost of UV ovens needs to be considered.   (Polyesters
and polyurethanes can be catalyzed with curing enhanced by
conventional ovens.)82"84'86  Because converting from sprayable
solventborne finishes to sprayable UV-curable finishes is
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 expected to be more expensive for a facility than converting to a
 pe/pu system,  and the associated emission reduction would be
 approximately the same, the use of sprayable UV-curable finishes
 was not analyzed further.
      3.2.2.4  polyester Finishes.   Polyester finishes  are similar
 to polyurethanes in their uses and their limitations.   The film
 properties of the polyester finishes are good;  they provide good
 build and good chemical-, mechanical-,  and heat resistance."
 Polyester finishes,  like polyurethane finishes,  require a clean
 room environment,  which can be very expensive and difficult to
 maintain;  have a short pot life;  and are difficult to  repair.71
      3.2.2.5  Polyurethane Finishes.   Polyurethane finishes are
 used in some segments of the wood finishing industry.
 Polyurethane materials can be spray-applied or  applied by curtain
 or roll  coat,  and  are cured in the conventional manner.
 Polyurethane finishes are characterized by a high-gloss  look,
 which may  not  be desirable to certain segments  of  the  wood
 furniture  industry.   Other limitations  that  may impair its
 widespread use include the need for a clean room environment, the
 short  pot  life (1  to  6 hours),  and the  difficulty  in repairing.71
      Polyurethane  finishes are  based  on polyisocyanates,  which
 are manufactured from diisocyanate monomers, which  link  to form
 the polyisocyanate chains.57'^8  A common misunderstanding
 regarding  the  manufacture and use  of  polyisocyanates is  in the
 use of monoisocyanates.   Monoisocyanates are very volatile and
 very  toxic.  However,  monoisocyanates are not used  in
 manufacturing  polyisocyanates nor  are they a byproduct of  the
 manufacturing  process.   '
     The level of worker  protection required when using  finishes
 containing polyisocyanates depends on the concentration  of
 polyisocyanates  in the air.  The OSHA regulations regarding
 respirators  state that air purifying respirators can be  safely
 used at concentrations up  to 10 times the threshold limit value.
Above this concentration, supplied air respirators must be
     Q 7
used.    A manufacturer of diisocyanates and polyisocyanates
 recommends using supplied-air respirators when using polyurethane
                               3-47

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finishes unless sufficient air monitoring data have been
                                        Q *7 T 0 ^
collected to make an alternate decision.  'xu^  Further worker
protection  can be achieved by engineering controls, primarily
spray booth design and ventilation to keep the concentrations
below the exposure limits.^8  In all use of polyurethane
finishes, protection of eyes and skin should be ensured through
the use of  safety glasses and permeation-resistant gloves
                             q Q
(preferably of butyl rubber). °
     Based  on available information, it is possible to safely use
polyurethane finishes in wood furniture finishing operations.
Spray booths should be designed to minimize the concentration of
isocyanates.  Some level of respiratory protection should always
be worn; the exact type of protection depends on actual
measurement of isocyanate levels.  Eye and skin protection must
always be worn.
     3.2.2.6  UNICARB® Finishes.  As of.October 1994,  the
UNICARB® finishing system has been purchased by one
household/residential furniture manufacturer and is being used in
full production applying topcoat on a chair  line.   This line was
used to conduct an evaluation of product quality,  waste
reduction,  and economic issues for the UNICARB® system in a
May 1994 report.103  Testing has been conducted by a piano
manufacturer,  and a residential furniture manufeicturer that makes
occasional  furniture, though no purchase agreements with these
facilities have been reached.105'106
     The solids content of UNICARB® finishes is approximately
twice that of conventional solventborne finishes.   Therefore, in
some instances, a coating step can be eliminated if a facility
switches to UNICARB®.  For instance,  if a facility applies two
coats of topcoat using conventional finishes,  only one coat of
UNICARB® topcoat may be required.  Whether a finishing step can
be eliminated depends on the desired build and other site-
specific factors.
     In UNICARB® finishes,  the faster solvents are replaced with
supercritical C02-   Since the faster solvents are  no longer
present, drying time may increase.   The increase in drying time
                              3-48

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 required,  if any,  depends on the  exact  finish  formulation and
 site-specific conditions.
      3.2.2.7  VOC  Control® Finishes.  The VOC  Control®  finishing
 system is  being used by more than ten wood  furniture
 manufacturing facilities.  Akzo's Nobel's VOC  Control®  finishing
 system is  currently being used  in both  high- and  low-end
 furniture  manufacturing operations.   According to the Akzo Nobel
 Coatings representative,  the use  of the VOC Control® system by
 the  wood furniture industry is  growing  rapidly. 4
      Because the VOC Control® finishes  are  higher solids  finishes
 than their conventional counterparts, use of the  system can
 eliminate  finishing steps.   Therefore,  the  system offers  the  most
 advantages to an operation that currently applies several lacquer
 coats,  because some of  the applications can be eliminated.
 Conversely,  the system  would not  be as  adaptable  to an  operation
 that  had a limited number of finishing  steps because elimination
 of finishing steps may  not be practical. 4
      According to  the Akzo Nobel  Coatings representative,  due to
 the high solids  content of the  VOC Control® finishes, drying  time
                                Q 4
 may increase in some  instances. *  Any  potential  increase in
 drying  time  would  depend  on the site-specific  conditions  and  the
 exact finish formulation.
 3.2.3  Advantages  and Disadvantages of  Lower VOC  Finishes
      Each  type of  coating discussed in  this chapter has
 advantages and disadvantages  associated with its  use.  Based  on a
 survey of  wood furniture  finish suppliers,  Table  3-1 presents a
 comparison of  the  suppliers'  opinions concerning  the properties
                     DO  p Q
 of each finish type.  ^  °°   The  information provided includes  the
 finish properties  only.   The  ranking of finish properties  in
 Table 3-1  reflects  the  opinions of finish suppliers and probably
 represents desirable  qualities from the standpoint of finish
 suppliers and wood  furniture manufacturers.   The  importance of
 the various  qualities to a  consumer may be different.
     As indicated  in Table  3-1,  finish suppliers  feel that
advantages of nitrocellulose finishes, conventional as well as
higher solids, include  the appearance of the finish,  the  ease of
                              3-49

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                                               3-50

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 application and drying of  the finish, and  the ability  to  remove
 the finish and thus  repair deficiencies  in the  near-finished
 product.   According  to the survey  respondents,  a  disadvantage  of
 the nitrocellulose finish  is  its durability, which  is  not as good
 as  other  types of finish materials.
      The  nitrocellulose UNICARB® finishes  offer the same
 advantages and disadvantages.  An  additional disadvantage that
 may be associated with UNICARB® finishes is an  increase in the
 amount of drying time  required.  However,  any potential increase
 in  drying time may be  offset  by eliminating a finishing step.
 There may be a disadvantage associated with the UNICARB®  system
 because at present,  only one  manufacturer  makes the application
 system for the wood  furniture industry, and only  two finish
 manufacturers are presently formulating UNICARB®  finishes for  the
 wood furniture industry.
     According to survey respondents, advantages  of the
 waterborne finishes  include their  resistance to yellowing and  to
 extreme temperatures.   Also,  the waterborne finishes are
 satisfactory  in  terms  of the  finish quality, finish application
 and  cure,  and the ability  to wash  off/repair.   A  disadvantage  of
 the  waterborne  finishes  is  the difficulty  in applying  them using
 a fan or  curtain coater, due  to their inability to  hold together
 well.  Waterborne finishes  are more susceptible to breaks  in the
 fan  or curtain.  According  to one  finish supplier, adding
                                                    R9
 surfactants may minimize or eliminate this problem.  ^  Another
 disadvantage  that may be associated with waterborne finishes'is
 the  requirement for increased drying capacity, and the potential
 for grain  raising.
     As indicated in Table  3-1, the main advantages of the  UV-
 curable finishes are their durability,  their ability to be
applied by several  methods, and their resistance to chemicals,
temperature, and yellowing.  Disadvantages of these finishes to
the wood furniture  manufacturer include their inability to  wash
off/repair, the curing difficulties that may be associated  with
the finish, and the  limited experience  of the manufacturers with
the use of the finishes on case goods.
                               3-51

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      The advantages and disadvantages  of  the urea  or melamine
 catalyzed,  polyester,  and polyurethane finishes are similar to
 those of the UV-curable finishes.   However, the urea and melamine
 catalyzed,  polyester,  and polyurethane finishes offer additional
 advantages  in that  they are  satisfactory  for use on case goods
 and are  more easily cured.   Disadvantages of polyester and
 polyurethane finishes  to the furniture manufacturer include their
 being difficult  to  work with and repair,  the requirement for a
 clean room  environment,  and  the potential need for increased
 worker protection.
 3.3   EMERGING/SPECIALIZED TECHNOLOGIES
      Several technologies currently in the developmental stages
 could potentially apply to the wood furniture industry.  These
 technologies are in the areas of spray booth design, curing
 methods,  and add-on control  devices.   The spray booth design
 discussed in this section is the Mobile Zone design, which
 reduces  the  volume  of  air exhausted.   The curing method  discussed
 in this  section is  three-dimensional UV curing.  Developments in
 this  area would facilitate the use  of  UV-curable finishes on case
 goods.   Finally, biofiltration, an  add-on control  technology that
 is used  in other countries for both odor and VOC control, is
 discussed.
 3.3.1  Mobile Zone  Spray  Booth62'106'107' 115
     Mobile  Zone Associates  has developed a device which, when
 installed on a spray booth,  enables the worker(s)   to spray
 finishes  from a partially enclosed mobile work platform.  The
 worker stands inside a moving "cab," the movement of which  is
 controlled from inside  the cab by the worker.   Within the Mobile
 Zone cab, fresh ventilating  air passes across the painter from an
 open  "moving window" at his  or her  rear.  The remaining  section
 of the mobile work platform  is ventilated using recirculated air.
 The Mobile Zone design contrasts with a conventional spray  booth,
 in which  the entire length of the booth is supplied with fresh
ventilating  air.  Through the use of the moving window,   the
ventilating  air requirements for the worker are greatly  reduced.
The fresh makeup air requirements of the mobile zone are equal to
                               3-52

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 the flow through the window,  greatly reduced compared to
 conventional booths.  The reduction in makeup air requirements
 would reduce heating and cooling costs,  as  well  as capital and
 operating costs of an add-on  control device.
      The Mobile Zone system was  tested in a commercial job shop
 finishing operation that uses solvent-thinned paint.   The  testing
 involved finishing flat  panels.   The facility's  conventional
 spray booth was modified by the  addition of the  Mobile Zone.
 Design,  fabrication,  and installation of the mobile zone was
 conducted under an EPA Small  Business Innovation Research  (SBIR)
 grant.   The testing program indicated that  the Mobile Zone
 allowed  the company to reduce the spray  booth exhaust flow rate
 by  90  percent.
     The Mobile Zone is  considered an emerging technology  for
 several  reasons.   The Mobile  Zone system was  used commercially
 for a  short time by a metal working operation that  has since
 ceased finishing operations.   As  of February  1995,  the system  is
 not presently being used anywhere commercially.   Finally,  the
 Mobile Zone is  considered an  emerging technology  for  the wood
 furniture  industry because testing  thus  far has occurred on a
 overhead conveyor  line;  most  furniture manufacturers  employ
 pallet lines, which run  along  the ground.  Mobile Zone Associates
 indicated  that  it  thought the  system could be  used  on a pallet
 line.  However,  this  may  not be the  best application  for the
 system.
 3.3.2  Three-Dimensional Ultraviolet  Curing
     Ultraviolet-curable  finishes are frequently used by flat
 line furniture  finish operations.  The pieces are flat,  so  curing
 in a conventional UV-cure oven is straightforward.  Although
 UV-curable  finishes are also applied  to case goods  (nonflat
 pieces),  the UV curing process with such pieces is much more
 difficult.  In order  for a UV-curable finish to cure,   all finish
must be exposed to the UV light.   The lamps in the UV  oven must
be situated to ensure exposure to all areas of the case  goods,
 including recessed areas, carvings, etc.  The UV lamp  locations
would need to be set  for each type of case good depending on its
                               3-53

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 configuration.  Because  furniture manufacturers typically produce
 many different  types  of  case goods on a single line at any time,
 realignment  of  the UV lamps for each situation on such a line is
 not feasible.   However,  if a manufacturer produced a single piece
 continuously for a length of time, the lamps could be arranged
 for that  configuration.  Then another type of piece could be
 produced  for a  length of time, after the lamps were adjusted.
     Some three-dimensional UV ovens have been designed for
 specialized  applications.  Typically, these applications involve
 the consistent  finishing of one type of piece (i.e., one chair
 design).   In such applications, the UV lamp configuration does
 not require  realignment with the introduction of each piece.  For
 the majority of case  goods finishing operations, however, three-
 dimensional  UV  curing is considered an emerging technology.
 Finish suppliers, oven manufacturers, and furniture manufacturers
 continue  to  conduct research in this area.
 3.3.3  Biofiltration108'111
     Biofiltration is a control technology in which contaminated
 exhaust air  is  sent through a biofilter for contaminant removal.
 The biofilter consists of organic matter,  such as tree bark and
 compost,  the pores of which are filled with water.  In the water
 phase,  biologically active micro-organisms are present, partly
 free-floating in the  water and partly attached to the organic
 matter.
     The mechanism of the biochemical process consists of a
 combination  of adsorption,  absorption,  and biological
 degradation.  As the  exhaust air travels through the biofilter,
 pollutant removal from the gas phase occurs in two ways.   By Van
 der Waals forces, some pollutant molecules in the waste air are
 adsorbed by  the organic matter.  Some of these molecules transfer
 from the gas phase to the water phase by means of absorption.  To
maintain the adsorption and absorption capacity of the biofilter,
 the activity of the aerobic micro-organisms is necessary.  The
micro-organisms oxidize the contaminants to water, C02 and,
 depending on the contents of the exhaust stream,  NOX and SOX.
 The micro-organisms are sustained by the addition of moisture,
                               3-54

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 oxygen,  and nutrients in the exhaust stream.   The used nutrients
 are recycled;  once the micro-organisms die,  the living micro-
 organisms consume them to obtain the nutrients.  Eventually/
 however,  the filter material is exhausted.   In normal  operations,
 the biofilter beds usually last between 2 and 5 years.  When the
 bed is spent,  it can be disposed of readily,  e.g., used in
 agricultural applications.
      The micro-organisms used in a biofilter  are specific to the
 type(s)  of pollutants being controlled.  The  temperature  and
 humidity of the  biofilter must be precisely maintained to protect
 the micro-organisms and thus ensure proper pollutant removal.  If
 multiple pollutants are present in the exhaust stream,  several
 biofilters with  varying micro-organisms  may be required.   It is
 difficult to maintain a single biofilter with multiple  micro-
 organisms,  since the temperature and humidity requirements of  the
 different micro-organisms may differ.  These  pollutant-specific
 requirements make biofilters best suited to applications  with
 consistent exhaust streams  with relatively few types of
 pollutants.  The exhaust  streams from wood furniture finish
 operations vary  in volume and concentration and contain a wide
 variety of pollutants.
     Biofiltration is  a proven odor-control technology  that has
 long been used in sewage  treatment  facilities  and other
 industrial  processes.  Biofilters are  typically used to control
 small-volume exhaust streams.  Odor-control efficiencies  of
 95 percent  and greater have  been  reported for  biofiltration
 units.  In  some  installations, the odors being  controlled are
 caused by  the presence of VOC's in the exhaust  stream.
 Therefore,  the biofiltration technology could be expected to
 control VOC's as well as  odor.  However, data  concerning  the VOC
 control efficiency of biofilters are only now becoming available.
The relationship between  odor and/or VOC control efficiency and
pollutant concentration may not be linear.   Therefore,
conclusions regarding VOC control efficiency await closer review
of data now becoming available from foreign installations.
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     Biofliters have been developed by Bio Clean AB of Sweden and
 introduced  for use  in  the U.S. by Ahlquist & Hunters
 Technologies, Inc.  The Bio Clean filters have been in commercial
 use in Sweden since 1989 for applications such as odor removal
 from wastewater facilities and slaughterhouses and VOC removal
 from paint  manufacturing, various painting operations, and
 fiberglass  boat manufacturing.  Their filters cam achieve VOC
 removal efficiencies of better than 95 percent.
     Biofiltration  is  considered an emerging technology for
 controlling VOC emissions from wood furniture finishing
 operations.  Biofilters are recommended for small-volume exhaust
 streams with consistent concentrations of a few types of
 compounds.  Exhaust streams from furniture manufacturers are
 characterized as large-volume exhaust streams containing a wide
 variety of  VOC's of varying concentrations.  The large volume
 exhaust would require very large biofilters,  and the space
 requirements could  be substantial.  The wide variety of VOC's may
 require multiple beds with different micro-organisms.  Each bed
 would have  to be maintained at slightly different conditions.
 Another factor that could hamper the use of biofiltration in the
 wood furniture industry at this time is the limited VOC control
 efficiency  data that is currently available.
 3.4  POLLUTION PREVENTION
     Volatile organic compound emissions can also be reduced by
minimizing  the opportunity for evaporation of finishing and
 cleaning materials  as well as by minimizing the use of these
 materials.  A variety of work practices,  designed to minimize the
 use and evaporation of finishing and solvent materials,  are
 required by presumptive RACT,  and these requirements are
 discussed in Section 3.4.1.   Additional work practices that could
 be used to  further  reduce VOC emissions from finishing and
 cleaning operations, but are not required by presumptive RACT,
 are discussed in Section 3.4.2.
 3.4.1  Required Work Practices
     The work practices that are required as part of presumptive
 RACT are summarized in Table 3-2.  The practices listed in this
                              3-56

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 TABLE 3-2.  WORK PRACTICE REQUIREMENTS -- PRESUMPTIVE RACT


A. Finishing. Cleaning, and Washoff
       Covered storage of finishing, cleaning, and washoff
       materials.
       Inspection and maintenance program must be developed
       and implemented to minimize leaks  (monthly
       inspection frequency,  repairs within 15 days).
       Conventional air spray guns prohibited in most
       circumstances.

B. Cleaning and Washoff Operations
   Gun/line cleaning
       Cleaning solvent must be collected in a container
       that can be closed.
       Cleaning solvent containers must be closed when not
       in use.
   Spray booth cleaning
       Use of organic solvents for spray booth cleaning is
       prohibited except in limited circumstances
       (conveyors that carry pieces through booth and
       continuous coaters and their enclosures can continue
       to be cleaned with solvent, as- can the metal filters
       in spray booths,  1.0 gallon per booth limit to clean
       stained areas when replacing strippable spray booth
       coating).
   Furniture washoff
       Cover washoff tanks when not in use.
       Minimize dripping by tilting and/or rotating piece.
   General cleaning/washoff activities
       Cleaning and washoff accounting system
    — Log of quantity and type of solvent used for washoff
       and cleaning,  the number of pieces washed off,  and
       reason for washoff.
    — Record quantity of  spent solvent generated from each
       activity and its  ultimate fate.
    — Calculate  net cleaning and washoff solvent usage
       quantities,  accounting for disposal and recycling of
       spent solvent,  monthly.

C. General Work Practice Requirements
       Operator training program (train new employees  upon
       hiring and retrain  all employees annually)
       Implementation  Plan must be developed and maintained
       to demonstrate  compliance with work practice
       requirements.
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table must be followed by all facilities subject to RACT.  These
requirements are discussed in the following sections.
     3.4.1.1  General Requirements for Finishing^  Cleaning, and
Washoff.
     3.4.1.1.1  VOC storage.  Materials containing VOC are often
stored in containers that are left open, allowing the volatiles
to evaporate and be emitted through room ventilation to the
atmosphere.  The Work Practice Group agreed that a
straightforward, inexpensive method of reducing emissions from
VOC storage would be to cover all containers storing finishing,
cleaning, and washoff materials when not in use.
     3.4.1.1.2  VOC transfer.  In wood furniture plants,
finishing, cleaning, and washoff materials are pumped from
storage containers to spray guns through piping.  Because leaks
are likely to occur whenever materials are transferred, the Work
Group agreed that requiring sources to check this equipment for
leaks was reasonable.  To implement the leak inspection program,
sources will be required to develop and implement an Inspection
and Maintenance plan that requires the inspection of each piece
of equipment used to transfer or apply finishing materials and
solvents; a schedule for inspection;  reporting of the inspection
results and any repairs that were made to the equipment,  and the
timeframe between identifying the leak and performing repairs.
     The Work Practice Work Group agreed upon the concept of an
Inspection and Maintenance plan,  but never discussed what the
inspection frequency or repair response time should be.  The
Agency decided that a monthly inspection frequency is appropriate
to accomplish the goal of reducing leaks from transfer and
application equipment.  To ensure that action would be taken if
leaks were detected, repairs must be made within 15 calendar
days,  with a first attempt at repair made within 5 calendar days.
     3.4.1.1.3  Washoff operations.   Washoff is the practice of
removing coating from a piece of furniture.   The main reason for
washoff is because the finish does not meet company
specifications.   By washing off the finishes,  the substrate can
be refinished.  Washoff is typically accomplished by dipping the
                               3-58

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 furniture into a tank containing organic solvent;  the same
 solvents used for cleaning are usually used for washoff.
      To minimize the VOC emissions resulting from washoff
 operations,  the Work Practice Work Group decided on several
 required work practices.   As with finishing and other cleaning
 operations,  the work group agreed that covering washoff tanks
 when they are not in use would limit  emissions.   Also,  sources
 can minimize dripping by tilting and/or rotating the piece to
 drain as much solvent as possible.
      In general,  cleaning and washoff practices are not well
 documented by sources.   For example,  most sources  do not  know the
 quantity of  solvent  used for cleaning and washoff  operations,  how
 many pieces  are washed off,  and the fate of spent  solvent from
 cleaning and washoff operations.   The Work Practice Work  Group
 agreed that  one of the first steps in reducing  emissions  is to
 know the quantity of solvent used for the various  operations,  and
 therefore presumptive RACT requires all  facilities subject to
 RACT to implement a  cleaning and washoff  solvent accounting
 system.   Such an  accounting system will minimize solvent  usage
 and  will  enable a facility to analyze  their number of pieces
 washed off to improve their operation.  Under the  cleaning and
 washoff solvent accounting system,  sources  have  to (l)  maintain a
 log  of  the quantity  and type of  solvent used for washoff  and
 cleaning,  the number of pieces washed  off,  and the  reason for the
 washoff;  and  (2)  record the  quantity of spent solvent generated
 from each activity.   The  net cleaning  and washoff  solvent usage
 quantities, accounting for disposal and recycling  of spent
 solvent,  must  be  calculated  monthly, and copies  of  the  logs must
 be made available upon request.
      The  Work  Practice Work  Group and  the regulatory negotiation
 committee as a whole  agreed  that an accounting system should  be
 required. The  Committee believed that the accounting system would
 be an  important first step for facilities to develop a broad-
based, multimedia pollution  prevention plan.
     The  Committee believed  that once the accounting system is in
place, the burden of maintaining it would not be too great.
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Although implementation of a cleaning and washoff solvent
accounting system is expected to reduce VOC emissions, the
expected reduction in emissions has not been quantified, nor has
the associated cost.
     3.4.1.1.4  Improved finishing material application methods.
The most common method of applying finishing materials in the
wood furniture industry is through the use of spray guns.
Spraying of finishes can be very wasteful.  In some industries,
tests have shown that 80 percent or more of the finish directed
at a substrate is wasted and becomes a solid waste expense due to
disposal costs.  In certain applications, some spray guns can be
more efficient than others in that the quantity of finishing
material lost as overspray is less.  The amount of finishing
material that is saved through use of improved application
techniques varies considerably by facility and application.
Differences in the shape of the piece being finished,  airflow
rates,  line speed, and operator technique translate into
differences in the amount of overspray.   In recent years, the
concept of transfer efficiency (the amount of finish that ends up
on the piece,  as a percentage of the total finish used) has been
formally recognized and studied at great length.
     The regulatory negotiation committee agreed that  highly
efficient transfer methods are desirable, but also agreed that
the data supporting one type of application equipment  over
another were conflicting except in one instance;  almost all data
suggest that conventional air guns are the least efficient
transfer method.   Therefore,  presumptive RACT prohibits the use
of conventional air spray guns in most instances.
     The VOC emission reduction achieved through improved
application techniques is difficult to quantify.   A study
performed by Pacific Northwest Pollution Prevention Research
Center indicated that transfer efficiency is a function of both
                                                              119
operator experience and the type of gun (among other factors).
Based on this study,  it was estimated that alternative
application techniques reduce finish usage,  and thereby
emissions,  by approximately 10 percent.   The company has economic
                              3-60

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 motivation (although there is limited evidence that it has
 influenced industry in the past)  for maximizing transfer
 efficiency.   Costs associated with finishing material purchases,
 filter media disposal,  and other  waste disposal would decrease if
 improved application techniques were used.113  The high costs of
 toxic waste  disposal may ultimately provide the incentive for
 change.
 3.4.2  Reduction in Cleaning  Material Usage
      As discussed in Chapter  2, industrial  solvents are currently
 used in the  wood furniture industry for equipment  cleaning,  and
 to a lesser  extent,  spot repair,  rewetting,  and dilution of
 finish materials.   Some VOC-containing cleaners will most likely
 still be used for equipment cleaning even in facilities that
 switch to lower-VOC finishing materials.  There are a number of
 options  available to reduce the VOC emissions from cleaning
 material usage in the wood furniture industry.   These include
 work practice modifications,  use  of  alternative cleaning
 materials, and add-on capture and control devices.   Each of  these
 options  is discussed in the following paragraphs.
      3.4.2.1   Work Practice/Administrative Modifications.  From
 an  industry perspective,  the  lowest-impact approach to reducing
 VOC  emissions  resulting  from  cleaning material  use  is  to change
 work practices  to  minimize  the opportunities  for emissions.   No
 change in solvents  is involved, so no  compromise in cleaning
 efficacy  is required.  Emissions  of VOC from  cleaning  materials
 can  be limited by  restricting the movement of air across
 containers of  solvent and by limiting the amount of  solvent  that
 is intentionally exposed to air.   Thus, the use of  training and
 safety programs to inform employees of the dangers  and ecological
 risks and to  teach good work practices are required.   In
 addition, closed containers with soft-gasketed, spring-loaded
 closures for storing, transporting, and dispensing  cleaning
materials are essential.  Containers of cleaning materials
saturated with cleaning materials   (rags, towels, etc.) must be
closed tightly so that the solvent does not evaporate.   In turn,
these materials must be disposed  of in a way that does not result
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 in  evaporation of the solvents  (e.g., incineration).  To further
 reduce VOC emissions, small parts must be cleaned in a closed
 device to minimize evaporation.  Products are on the market that
 are specifically designed to clean spray guns without the need
 for spraying the solvent into the air (see Table 3-3).114"117
 One of these units, the Gun Washer/Recycler, made by Herkules
 Equipment Corporation, involves internal and external cleaning of
 the gun in an enclosed vessel.  External cleaning is accomplished
 by  soaking the gun in the solvent; internal cleaning is
 accomplished inside the enclosed vessel by pumping solvent
 through the gun.  The cleaning solvent collects in the vessel,
 the solids are allowed to settle out, and the solvent is then
 reused.  The Solvent Manager, made by Solvent Management, and the
 Lighthall unit, developed by Lighthall Enterprises,  allow just
 the cleaning solvent resulting from internal cleaning of the gun
 to  be captured in a removal cap as opposed to being sprayed into
 the air.  The captured solvent can then be reused.

          TABLE 3-3.   COMMERCIALLY AVAILABLE SPRAY GUN
                      WASHING UNITS114"117
Model
GW/R (Gun Washer Recycler)
The Solvent Manager
The Lighthall
Manufacturer
Herkules Equipment Corporation
8320 Goldie Street
Walled Lake, MI 48088-1298
Solvent Management
15 Normanhurst Avenue
Bournemouth BH8 9NN
U.K.
Lighthall Enterprises
934 Bay Street
Santa Cruz, CA 95060
     Another approach to changing work practices to limit
cleaning material VOC emissions is an administrative control used
successfully in the fiberglass-reinforced plastic industry.117
In accordance with the administrative control,  a limited amount
of cleaning material is issued to each worker during a shift.
                              3-62

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 This automatically limits the total  solvent  consumption  but  also
 requires  each worker to carefully monitor  solvent  use  so that  the
 required  cleaning is accomplished without  impairing product
 quality.
      Another method of  changing  work practices  to  limit  solvent
 VOC emissions is  the use of  a recordkeeping  system to  help
 management track  the use of  solvent  within a plant and ensure
 that used solvents are  properly  tracked  to disposal.
      3.4.2.2  Use of Alternative Cleaning  Materials.118'120  A
 second  approach to reducing  VOC  emissions  resulting from cleaning
 operations is to  use cleaning materials  that have  been
 reformulated to minimize or  eliminate the  solvent  content.   The
 VOC emissions may also  be reduced if less  volatile solvents  are
 used in lieu of the highly volatile materials used in  the lacquer
 thinners.   Because the  reformulated  cleaning material  is no
 longer  the same solvent that is  contained  in the finishes, the
 reformulation approach  may have  the disadvantage of requiring
 some process changes  to eliminate risks  of cross contamination of
 the  cleaning material with the finish material.  However, this
 approach  has an advantage in that no additional work practice
 modifications  need be incorporated to prevent evaporation.
 Volatile  organic  compound emissions are  inherently reduced if  the
 cleaning  material  has a lower VOC content  because  a high-boiling-
 point (low-volatility)  solvent that is exposed to  air movement
 will  evaporate very little,  A "slow-drying" solvent of  this type
 will  eventually evaporate  when exposed to  the air, as,  for
 example,  when  a thin film is left  on a wiped surface.   But casual
 activities,  such as pouring  or agitating the surface of  a wash
 basin of  solvent,  will  not result  in a high evaporation  rate.
 The  use of  reformulated solvents  for gun cleaning would  also
 result  in  lower emissions  than those resulting from use  of the
 finish  solvent, as  long as the used solvent is collected and
 contained.   However, use of a "slow-drying" solvent for gun
 cleaning may necessitate the use of a hot airstream that  is
directed through the gun for quicker drying.   Table 3-4
                               3-63

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summarizes some low-volatility alternative solvents that have
  i
only recently been widely marketed.

      TABLE 3-4.   LOW-VOLATILITY ALTERNATIVE  SOLVENTS118"120
Compound
n-Methyl-2-
pyrrolidone
Dibasic
ester
Shipshape™
Propylene
glycol
ethers
Boiling
point, °C
202
N/A
N/A
120-242
Manufacturer
GAF
Arco
Chemical
DuPont
GAF
Arco
Chemical
Remarks
Low- toxicity replacement
for methylene chloride for
cleaning, stripping, and
degreasing
Substitute for acetone for
polyester resin cleanup
Substitute for acetone for
polyester resin cleanup
Solvents for waterbome and
high- solids coatings
  N/A = exact information not available


     Another type of alternative cleaning material is an aqueous,
detergent-type cleaner, which would result in very little VOC
emissions.  This type of cleaner is chemically incompatible with
the solventborne finishing systems currently used.  Thus, there
is the risk of cross contamination during activities such as gun
or paint-line cleaning.  However,  such a material may be
plausible for gun cleaning, in conjunction with drying of the
internal mechanisms of the gun,  by using a hot airstream to
eliminate residual cleaning materials.  Also,  there may be
opportunities in general cleaning operations where such aqueous
materials could be substituted.   Solvent cleaners are often used
more as a matter of convenience (because of availability) than
because of any rigid efficacy requirements in general cleaning
situations.
     These aqueous detergent-type cleaners may be compatible with
waterborne finish systems that are being developed in response to
more stringent regulations.  A related alternative general
cleaning process is the use of high-pressure water (water
blasting)  to remove cured or partially cured finishes from
                               3-64

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equipment.  The mechanism of cleaning is by abrasion, rather than
by chemical interaction, so that the technique would be limited
to spray booths and related application equipment.
     3.4.2.3  Add-On Control Devices.  A third approach to
reducing VOC emissions from cleaning operations is the use of
add-on controls, which first capture airborne VOC and then
recover or destroy it.  In some large operations this approach
may be feasible if cleaning operations were conducted in a
central location.  In this case, the proper hoods and ventilation
systems could be installed to capture the vapors and route them
to a control device.  Similarly, if the finishing line itself has
emission control devices installed, it may be possible to conduct
cleaning operations in the finishing booths with the ventilation
systems operating,  so that vapors from cleaning could be handled
by the same control devices that normally handle the finishing
emissions.
3.5  REFERENCES FOR CHAPTER 3
  1.   Bethea,  R. M.  Air Pollution Control Technology.   New
      York,  Van Nostrand Reinhold Company.   1978.   p. 395.
  2.   Brunner,  C.  R.   Hazardous Air Emissions from
      Incineration.  New York,  Chapman and Hall.   1985.
      p.  92.
  3.   Ref.  1,  pp.  401-402.
  4.   Ref.  1,  p.  405.
  5.   Prudent  Practices for Disposal of  Chemicals  from
      Laboratories.  National Academy Press.   Washington,
      D.C.   1983.
  6.   Seiwert,  J.J.  Regenerative Thermal  Oxidation for  VOC
      Control.   Smith Engineering Company.   Duarte,  CA.
      Presented at  Wood Finishing Seminar--Improving
      Quality  and Meeting  Compliance Regulations.
      Sponsored by  Key  Wood  and Wood Products and  Michigan
      State University.  Grand  Rapids.   March 5, 1991.
      27  pp.
  7.  Memorandum and  attachments from Farmer,  J. R.,  EPA,
      to  Distribution.   Thermal  Incinerator Performance  for
     NSPS.  August 22,  1980.   29  pp.
                              3-65

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 8.  Radian Corporation.  Catalytic Incineration for
     Control of VOC Emissions.  Park Ridge, NJ, Noyes
     Publications.  1985.  pp. 4-5.

 9.  Ref. 1, p. 421.

10.  Ref. 7, pp. 12-24.

11.  Ref. 1, p. 425.

12.  Telecon.  Caldwell, M. J. , Midwest Research
     Institute, with Minor, J., M & W Industries.
     June 20, 1991.  Catalytic incineration.

13.  Survey response and attachments from Smith Engineering
     Company to Wyatt, S., EPA/ESD.  May 16 and June 21, 1991.
     Response and follow-on information pertaining to add-on
     control survey.

14.  Telecon.  Caldwell, M.J., Midwest Research Institute, with
     Mcllwee, R., Smith Engineering Company.  June 25, 1991.
     Clarification of information provided in add-on survey
     response.

15.  Telecon.  Caldwell, M.J., Midwest Research Institute, with
     Mcllwee, R., Smith Engineering Company.  August 13, 1991.
     Destruction efficiency of thermal incineration systems.

16.  Survey response and attachments from M&W Industries, Inc.,
     to Wyatt, S.,  EPA/ESD.  June 13,  1991.  Response to add-on
     control survey.

17.  Telecon.  Caldwell, M.J., Midwest Research Institute, with
     Minor,  J., M&W Industries,  Inc.  June 20,  1991.
     Clarification of information provided in add-on survey
     response.

18.  Survey response and attachments from Met Pro Corporation to
     Wyatt,  S., EPA/ESD.  May 13,  1991.   Response and follow-on
     information pertaining to add-on control survey.

19.  Telecon.  Caldwell, M.J., Midwest Research Institute, with
     Kenson, Dr. R., Met Pro Corporation.   June 17,  1991.
     Clarification of information provided in add-on survey
     response.

20.  Ref. 1, pp. 375-376.

21.  Ref. 1, p. 366

22.  Calgon Corporation.  Introduction to Vapor Phase
     Adsorption Using Granular Activated Carbon,  pp. 11-1
     through 11-16.


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 23.  Ref.  1, pp.  382-387.

 24.  Ref.  5, pp.  4-1  through 4-44.

 25.  Ref.  I, pp.  380-382.

 26.  Crane, G.  Carbon Adsorption for VOC Control.  U. S.
     Environmental Protection Agency.  Research Triangle
     Park, NC.  January 1982.  p. 23.

 27.  Kenson, R.E.  Operating Results from KPR Systems for
     VOC Emission Control in Paint Spray Booths.  Met-Pro
     Corporation.  Harleysville, PA.  Presented at the CCA
     Surface Finish '88 Seminar and Exhibition.  Grand
     Rapids, MI.  May 18, 1988.  10 pp.

 28.  VIC Manufacturing.  Carbon Adsorption/Emission
     Control.  Minneapolis, MN.

 29.  Telecon.  Catlett, K., EPA/CPB, with Sengupta, P.,
     Vara  International.  December 16, 1991.  Control of
     alcohols using carbon adsorption.

 30.  Telecon.  Beall,  C., Midwest Research Institute, with
     Kenson, R.,  MetPro, Inc.  January 3, 1992.  Control
     of alcohols  using carbon adsorption.

 31.  Telecon.  Caldwell, M. J., Midwest Research
     Institute, with  Bhushan, D.,  Durr Industries.
     June  25, 1991.   Effect of alcohols and ketones on
     carbon adsorption performance.

 32.  Radian Corp.   Adsorption for control of VOC
     emissions:   Theory and full scale system performance.
     Prepared for U.   S. Environmental Protection Agency.
     EPA Contract No.  68-02-4378.   June 6,  1988.

 33.  Telecon.  Caldwell, M. J., Midwest Research Institute,  with
     Weissert,  M., Calgon Carbon Corporation.  June 25, 1991.
     Clarification of  information provided in add-on survey
     response.

 34.  Telecon.  Caldwell, M.  J., Midwest Research Institute,  with
     Blocki,  S.,  ABB  Flakt Alpha.   June 5,  1991.  Clarification
     of information provided in add-on survey response.

35.  Calgon Carbon Corporation.  CADRE VOC Control
     Process.  Pittsburgh,  PA.   1987.

36.  Brochure and attachments from Jackson,  T.,  Terr-Aqua Enviro
     Systems,  Inc.,  to Catlett, K.,  EPA/CPB.   Received
     February 14,  1992.   Information regarding Terr-Aqua's
     UV-oxidation system.


                             3-67

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37.  Shugarman, L.  Ultraviolet/Activated Oxygen  - A New Air
     Pollution Control Technology Comes of Age.  Terr-Aqua
     Enviro Systems, Inc.  Fontana, California.  Presented at
     the 84th Annual Meeting, Air and Waste Management
     Association, Vancouver, British Columbia.  June 16-21,
     1991.

38.  Telecon.  Caldwell, M. J., Midwest Research Institute, with
     Shugarmann, L., Terr-Aqua Enviro Systems, Inc.  June 20,
     1990.  Future installation of Terr-Aqua UV-oxidation system
     at a furniture plant in California.

39.  Telecon.  Caldwell, M. J., Midwest Research Institute, with
     Jackson, T., Terr-Aqua Enviro Systems,  Inc.  November 1,
     1990.  Status of Terr-Aqua installation at a furniture
     plant.

40.  Telecon.  Caldwell, M. J., Midwest Research Institute, with
     Jackson, T., Terr-Aqua Enviro Systems,  Inc.  April 22,
     1992.  Status of Terr-Aqua installation at a furniture
     plant.

41.  Telecon.  Parker,  A.,  Midwest Research Institute, with
     Jackson, T., Terr-Aqua Enviro Systems,  Inc.  January 31,
     1995.  Update on Terr-Aqua installations in the wood
     furniture industry.

42.  Telecon.  Christie, S.,  Midwest Research Institute,
     with Bodie, J.,  Occupational Safety and Health
     Administration.   March 18, 1991.   Recirculation.

43.  Telecon.  Christie, S.,  Midwest Research Institute, with
     Kanth,  S., Occupational Safety and Health Administration.
     April 16,  1991.   Recirculation.

44.  Memorandum.  Conray,  D. ,  EPA Region I,  to Catlett, K. ,
     EPA/CPB.  December 19, 1991.  Review of draft CTG -
     "Control of Volatile Organic Compound Emissions from Wood
     Furniture Finish Operations."

45.  Telecon.  Christie, S.,  Midwest Research Institute, with
     Bombay,  B.; Kraftmaid Cabinetry.   November 29, 1990.
     Recirculation.

46.  Occupational Health and Environmental Control.
     29 CFR 1910.94(c)(6)(i)  and (ii).   July 1,  1991.

47.  Telecon.  Christie, S.,  Midwest Research Institute,
     with Campbell,  C.,  Classic Air Systems.   June 12,
     1991.  Campbell Spray Booth.

48.  Letter.   Deal,  W.,  and Dorris,  W.,  Joint Industry
     Steering Committee, to Jordan,  B.,  EPA/ESD.


                             3-68

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     December  5,  1991.   Comments of the Joint Industry
     Steering  Committee  on  the NAPCTAC package and
     presentation.

49.  Telecon.   Christie, S., Midwest Research Institute, with
     J. Bauersox, Wood Mode, Inc.  November 15-16, 1990.
     Clarification  of survey response.

50.  Letter and attachments from Shepich, T.J., OSHA, to
     Wyatt, S., EPA/ESD.  January 16, 1990.
     Recirculation.

51.  Telecon.   Christie, S., Midwest Research Institute,
     with Gregory,  W., BMY Corporation.  February 26,
     1991.  Recirculation.

52.  Telecon.   Caldwell, M., Midwest Research Institute, with
     D. Bhushan, Durr Industries.  November 5, 1990.  Spray
     booth circular,

53.  Telecon.   Christie, S., Midwest Research Institute, with
     J. Minor,  M&W  Industries.  December 20, 1990.  Spray booth
     recirculating  with add-on control systems.
                                       f
54.  Telecon.   Christie, S., Midwest Research Institute, with
     Nowack, W., Industrial Technology Midwest.  February 26,
     1991.  Description and costs of recirculating spray booths.

55.  Norton, L. E., R. J. Bryan,  and D. P. Becvar.
     (Engineering-Science, Inc.).  Evaluation of a Paint
     Spray Booth Utilizing Air Recirculation.  Prepared
     for the U. S.  Environmental Protection Agency.
     Cincinnati.  Publication No. EPA-600/2-84-143.
     August, 1984.  67 pp.

56.  Ayer, J.  (Acurex Corporation).   Split-flow Exhaust
     Recirculation  for the Economic Control of VOC
     Emissions  from Paint Spray Booths.  Prepared for
     U. S. Environmental Protection Agency.  Research
     Triangle Park, NC.   Paper No.  90-104.3 for
     Presentation at the 83rd Annual Meeting of Air and
     Waste Management Association.   June 24-29,  1990.
     12 pp.

57.  Letter.  Runyan,  L., American Furniture Manufacturers
     Association,  to Catlett,  K.,  EPA/CPB.  January 14,
     1992.  Response to request for information dated
     January 14, 1992, regarding JISC comments on
     preliminary draft CTG.
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58.  Telecon.  Caldwell, M. J., Midwest Research
 '    Institute, with Taylor, R., Durr Industries, Inc.
     August 8, 1991.  Regenerative incinerator idling and
     recirculating spray booths.

59.  Telecon.  Caldwell, M. J., Midwest Research
     Institute, with Miller, D., George Koch Sons, Inc.
     August 7, 1991.  Clarification of information
     provided in add-on survey response.

60.  Telecon.  Caldwell, M.J., Midwest Research Institute,
     with Nowack, W.,  Industrial Technology Midwest.
     August 7, 1991.  Recirculating spray booths.

61.  Telecon.  Beall,  C.,  Midwest Research Institute,  with
     Febo, F., Allendale Insurance Company.  January 2 and
     3, 1991.  Impact of various control options on
     insurance premiums.

62.  Mobile Zone Associates.  Mobile Zone Spray Booth for
     Reduction of VOC Contaminated Air.   Prepared for
     U. S. Environmental Protection Agency.  Research
     Triangle Park,  NC.   Contract No.  68-D9-0122.
     April 12, 1990.  17 pp.

63.  Memorandum from Christie, S.,  Midwest Research
     Institute, to Catlett, K.,  EPA/ESD.  March 12,  1991.
     Summary of Wood Finishing Seminar-Improving Quality
     and Meeting Compliance Regulations.  Sponsored by
     Wood and Wood Products and Michigan State University.
     37 pp.

64.  Telecon.  Caldwell, M. J.,  Midwest  Research
     Institute, with Ellis, T.,  Classic  Air Systems.
     May 11,  1992.   Status of CamBooth.

65.  U. S. Environmental Protection Agency.  Enabling
     Document.  The  Measurement Solution--Using a
     Temporary Total Enclosure for Capture Efficiency
     Testing.  Publication No. EPA-450/4-9-020.  Final
     Draft.   August  1991.

66.  Battelle and Eastern  Research Group,  Inc.  Guide to Cleaner
     Technologies:   Organic Coating Replacements.  Prepared for
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     September 1994.  Publication No.  EPA/625/R-94/006.

67.  Beels,  G.J.   Industrial Finishing 1991 Market Study.
     Industrial Finishing.  December 1990.  pp. 22-25.

68.  SRI International.  U. S. Paint Industry Data Base.
     Prepared for the  National Paint and Finishes
                             3-70

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     Association.  Washington, D.C.  September 1990.
     227 pp.

69.  Winchester, C.M.  Waterborne Nitrocellulose Wood
     Lacquers with Lower VOC.  Aqualon Company.
     Wilmington, DE.  Presented at the Higher-Solids,
     Waterborne and Powder Finishes Symposium.
     February 6-8, 1991.  19 pp.

70.  Domsey, S.  Woodworker's Guide to Conventional
     Finishes.  Furniture Design & Manufacturing.
     January 1988.  pp. 54-57.

71.  Chemcraft Sadolin International Inc. Wood Finishes.
     Brochure.  Walkertown, NC.

72.  Survey response from PPG Industries, Inc., to
     Fanner J., EPA/ESD.  May 8, 1990.  Response to
     Section 114 information request.

73.  Survey response and attachments from Reliance
     Universal, Inc., Division of Akzo Finishes, to
     Farmer, J., EPA/ESD.  May 11, 1990.  Response to
     Section 114 information request.

74.  Survey response and attachments from The Lilly
     Company to Farmer, J., EPA/ESD.  May 14, 1990.
     Response to Section 114 information request.

75.  Survey response and attachments from The Valspar
     Corporation to Farmer, J., EPA/ESD.  May 10, 1990.
     Response to Section 114 information request.

76.  Survey response and attachments from Guardsman
     Products,  Inc.,  to Farmer, J.,  EPA/ESD.  May 10,
     1990.   Response to Section 114 information request.

77.  Memorandum.  Rasor,  S.,  Midwest Research Institute, to "Wood
     Furniture Project File.   Summary of Data from Wood
     Furniture Information Collection Request.  October 12,
     1994.

78.  Brantley,  M.  (E-Z-Go,  Division of Textron).  VOC
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     pp.  4-5.

79.  Ballaway,  B.   New Developments in Waterborne
     Finishes.   Industrial  Finishing.   December 1989.
     pp.  24-25.
                             3-71

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 80.  Detrick, G. F. and K. Kronberger.  Addressing the VOC
     Issue in Industrial Finishes.  American Paint and
     Finishes Journal.  September 11, 1989.  pp. 42-52.

 81.  Del Donno, T. A.  Waterborne Finishes Outlook Bright.
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 82.  Contact Report.  Caldwell, M. J., and Christie, S.,
     Midwest Research Institute, with Tucker, R. ,
     Guardsman Products, Inc.  March 28, 1991.  Lower-VOC
     finishes.

 83.  Contact Report.  Caldwell, M. J., and Christie, S.,
     Midwest Research Institute, with Reidell, A.,  PPG
     Industries.  March 21, 1991.  Lower-VOC finishes.

 84.  Survey response and attachments from Guardsman
     Products,  Inc., to Wyatt, S., EPA/ESD.  May 30, 1991.
     Response to finish suppliers questionnaire.

 85.  Survey response and attachments from the Lilly
     Company to Wyatt, S.,  EPA/ESD.   June 7,  1991.
     Response to finish suppliers questionnaire.

 86.  Survey response and attachments from PPG Industries,
     Inc.,  to Wyatt, S., EPA/ESD.  June 3,  1991.  Response
     to finish suppliers questionnaire.

 87.  Survey response and attachments from Sadolin,  Inc.,
     to Wyatt,  S.,  EPA/ESD.  May 24, 1991.   Response to
     finish suppliers questionnaire.

 88.  Survey response and attachments from the Valspar
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89.  Hornung,  J.  R. (Southern California Edison Company).  Test
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90.  Letter.   Fujimoto,  K., Consultant,  to J. Berry,  EPA/ESD.
     June 14,  1994.  Results of Method Analysis.

91.  Telecon.   Christie,  S.,  Midwest Research Institute,
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92.  Schmidt,  K.   UV Curing for Flatline and 3-D
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  93.   Bean,  J.  E.   Finishing Handbook.   London,  Sawell
       Publications.   1988.   p.  172.

  94.   Telecon.   Caldwell, M., Midwest Research Institute,  with
       G.  Currier,  Akzo Finishes,  Inc.  October 19,  1994.   Akzo's
       "VOC Control"  Systems.

  95.   Letter and attachments from Rechel,  C.  J.,  RadTech
       International,  to Edwardson,  J. A.  and  J.  Berry,  EPA/ESB.
       October 13,  1993.   Potential for reduction of emissions  by
       the use of UV  curable  finishing systems.

  96.   Loewenstein  Dip Continues.   Industrial  Finishing.
       69:14-15.  May 1993.

  97.   Telecon.   Beall,  C., Midwest Research Institute,  with
       0'Block,  S., Miles, Inc.  January 22, 1992.   Toxicity
       and safe  handling of isocyanates.

  98.   Mobay  Corporation.  Hexamethylene Diisocyanate Based
       Polyisocyanates -  Health  and Safety Information.
       Pittsburgh,  PA.   February 1991.   13  pp.

  99.   Telecon.   Beall,  C., Midwest Research Institute,  with
       0'Block,  S., Miles, Inc.  January 24, 1992.   The
       toxicity  of  the components  in polyurethane  finishes.

100.  Mobay  Corporation.  Some  Plain  Talk  About Safe Use of
       Polyurethane Finishes.  Pittsburgh,  PA.  4 pp.

101.  Mobay  Corporation.  Isocyanates-Questions and Answers
      About  Use  and Handling.   Pittsburgh, PA.  August
       1991.   26  pp.

102.  Mobay  Corporation.  Polyurethane  Finishes--
       Performance,  Quality,   Safety.   Pittsburgh, PA.  1989.
       12 pp.

103.  Heater, K. J., A. B. Parsons, and R. F. Olfenbuttel
       (Battelle Memorial Incorporated).  Project Summary:
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      U. S.  Environmental Protection Agency,  Washington, DC
      Publication No. EPA/600/SR-94/043.  May 1994.  3 pp.

104.  Telecon.  Caldwell, M.  J., Midwest Research
      Institute, with Morgan, R.,  Union Carbide.  April 23,
      1992.  Status of UNICARB® installations.

105.  Telecon.  Caldwell, M., Midwest Research Institute,  with
      T. West, Union Carbide.  October 24, 1994.  Status of
      UNICARB® in the Wood Furniture Industry.
                              3-73

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106.  Letter and attachments from Putsche, V., ENSR, to
      Christie, S., Midwest Research Institute.  April 18,
      1991.  Mobile Zone.

107.  Telecon.  Parker, A., Midwest Research Institute, with
      W. Brown, Mobile Zone Associates, February 13, 1995.
      Status of commercial installations for Mobile Zone System.

108.  K. I. Lipton, Inc.  Marketing Communication.  Gist-
      Brocades Yeast Plant Applies Biotechnology to Solve
      East Brunswick Odor Problem.  Doylestown, PA.

109.  Product Information.  Ahlquist & Munters Technologies, Inc
      Undated.  Discussing biofliters and commercial
      installations.

110.  Paul, P. G.  New Developments in Biofiltration.
      Comprimo Corporation.  Presented at the 22nd ACHEMA
      Exhibition--Congress.  Frankfurt.  June 5-11, 1988.
      8 pp.

111.  Leson,  G.  Biofiltration:  An Innovative Air
      Pollution Control Technology for yOC Emissions.
      Journal of the Air and Waste Management Association.
      11:1045-1054.  August 1991.

112.  Schecter, R.  N.,  and G. Hunt.  Case Summaries of
      Waste Reduction by Industries in the Southeast.
      July 1989.  p. 11.

113.  Transfer Efficiency and VOC Emissions of Spray Gun and
      Coating Technologies in Wood Finishing.  Pacific Northwest
      Pollution Prevention Research Center.  Seattle, WA.  1992.

114.  Herkules Equipment Corporation,  product brochure.
      Gun Washer and Recycler.   Form GWR-1086.  Canada.

115.  SRC,  product  brochure.   The Solvent Manager.
      Document SM/002.

116.  Lighthall Enterprises,  product brochure.  The
      Lighthall.  Santa Cruz, CA.  October 1987.

117.  Memorandum from Vaught, C., Midwest Research
      Institute, to Evans, L.,  EPA.  July 23, 1990.
      Industrial uses of cleanup materials--Industry uses
      investigation.

118.  Arco Chemical, product  brochure.   NMP data sheet.
      Newtown Square,  PA.   1990.
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119.   GAP advertisement.   Industrial Finishing,  p.  44
      November 1990.
120.   DuPont, product brochure.  High-boiling-point
      solvents.
                                3-75

-------

-------
             4.0  MODEL PLANTS AND  EMISSIONS  ESTIMATES

     This  chapter describes  the model plants selected  to
 characterize the wood  furniture industry, the corresponding
 emissions  estimates, and  the methodology used to determine these
 estimates.   The model  plants describe finishing operations and
 are intended to be representative  of existing facilities.  The
 majority of  the existing  facilities have no  VOC controls on  their
 finishing  operations;  therefore, model plants represent
 uncontrolled finishing operations.  The .model plants have been
 developed  to represent the wood furniture industry as  a  whole;
 they do not  necessarily represent  every possible facility.   The
 model plants  will be used to evaluate the environmental, cost,
 economic,  and energy impacts of control options on the affected
 sources.
     This  chapter describes  the model plants  in detail,  and
 presents the  methodology used to estimate model plant emissions.
 Model plants  are described in Section 4.1; overall categories,
 finish application methods,  finishing sequence, model plant
 sizes,  finish usage,  and finishing parameters are discussed.
 Emissions estimates are described  in Section  4.2,  and a  list of
 references is provided  in Section 4.3.
 4.1  MODEL PLANTS
     Development of the model plants has been based primarily on
 information from a study sponsored by the wood furniture industry
and data collected from responses to the Agency's information
collection request (ICR).1'^  The wood furniture industry's study
evaluates VOC control technologies applicable to wood furniture
finishing and estimates the costs of these controls.   The ICR was
sent by the Agency to wood furniture manufacturers in all
                               4-1

-------
segments of the  industry.  There are several key parameters that
must be considered in order to conceptualize the models to be
used.  The type  of finish application method, the finishing
sequence, and the size of the model plant are of primary
importance.
     Seventeen model plants have been developed to characterize
wood finishing operations.  The model plants are divided into
five main categories:  short spray finishing sequence; long spray
finishing sequence; roll, curtain, and dip coating (referred to
as roll); upholstered furniture manufacturing; and kitchen
cabinet manufacturing.  These categories are classified by
general finishing application technique; of the five categories,
four use spray application methods and one uses flatline
finishing application (roll, curtain, and dip coating).   Spray
application finishing is further classified as either short spray
or long spray finishing sequences.  Three of the categories,
short spray finishing sequence,  long spray finishing sequence,
and roll,  curtain, and dip finishing sequence,  represent plants
in multiple market segments or SIC codes.  Two of the categories,
manufacturing of upholstered furniture and kitchen cabinets, are
short spray sequences that are each specific to one single
industry or SIC code.  Table 4-1 identifies the SIC codes
represented in each of the five main categories.
     Each of the categories is further divided by size on the
basis of finish usage (extra small,  small,  medium,  and large),
except the category representing manufacturers of upholstered
furniture.   These facilities are typically small in terms of the
amount of finish used.
     The seventeen model plants that were developed based on the
five categories are described in Table 4-2.   Finish application
method,  finishing sequence,  and plant size are identified.   This
table also identifies other important model plant characteristics
such as the number of finishing steps,  the number of spray booths
per finishing line,  the  type of topcoats used,  and the number of
finishing lines for each model plant.  The following sections
                               4-2

-------
TABLE 4-1.  CHARACTERISTICS OF MODEL PLANT CATEGORIES
Model plant category
Short



Long



Roll



Upholstered
furniture
Kitchen cabinets



Model plant No.
la
1
2
3
4a
4
5
6
7a
7
8
9
10
lla
11
12
13
SIC codes/ furniture type
2511 -Residential Furniture
2519 -Furniture, n.e.c.
2521-Office Furniture
2531 -Public Building Furniture
2541 -Store Fixtures



2511 -Residential Furniture
2517 -Radio, Television Cabinets
2 5 19 -Furniture, n.e.c.
2521-Office Furniture
2531 -Public Building Furniture



2434 -Kitchen Cabinets
2517 -Radio, Television Cabinets
2521-Office Furniture
2531-Public Building Furniture
2541-Store Fixtures



2512 -Upholstered
2434 -Kitchen Cabinets



                        4-3

-------








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 describe the overall model plant categories,  the finishing
 sequences,  model plant sizes,  and coating parameters.   The
 rationale for the categorization is presented in the following
 sections.
 4.1.1  Finish Application Method
      The model plant categories are identified as either spray
 finishing application or roll  coating application operations.
 Four of the five categories of model plants spray apply finishes;
 one category of the model plants employs  flatline application
 methods (roll coat,  curtain coat,  or dip  coat).   Spray
 application finishing is assumed to be performed with
 conventional spray guns  using  compressed  air  to atomize finishes.
 Conventional spraying techniques are applicable to a wide range
 of  common finishing needs,  including the  finishing of  nonflat,
 irregularly shaped furniture pieces,  both before and after
 assembly.   Flatline finishing  use,  however, is  relatively limited
 because pieces  must be relatively flat for roll,  curtain,  and  dip
 coating methods to be used  most  effectively.  Wood furniture
 manufacturers  that finish the  components  and  then assemble the
 product may be  able  to use  roll,  curtain,  and dip coating methods
 only  for some  of  the components.   Furniture producers  that
 manufacture ready-to-assemble  furniture (with flat  components)
 can also use  flatline  finishing.
 4.1.2   Finishing  Sequence
      Finishing  sequences have  been  defined for both  flatline and
 spray type  application methods.  The  distinction  between  short
 and long  finishing sequences for spray application finishing
 operations  has been  made for the model plants because  the  use  of
 lower-VOC finishes may affect  the two types of spray finishing
 operations  differently.  No further categorizations are necessary
 for roll, curtain, and dip application methods.
     A  short finishing sequence is defined as one or two
applications of stain, followed by one application each of
sealer,  and topcoat.1  A long finishing sequence consists  of the
following finish application steps:  a total of two or more stain
applications, washcoat, glaze/filler,.sealer,  and highlight, and
                               4-5

-------
 three  topcoat applications.1  The finishing sequence for roll,
  >
 curtain,  and dip coating application consists of one application
 each of  stain, sealer, and topcoat  (three finishing steps).1
 Kitchen  cabinets, represented by model plants lla through  13, are
 also finished with a short finishing sequence.  (They are
 typically finished with a different type of sealer and topcoat so
 they are included in a separate category.)  Sanding and drying
 operations occur in between the finishing steps for each of the
 finishing sequences.
     The long finishing sequence requires two or more topcoat
 application steps, while the other categories require only one
 topcoat  application.  Extra small and small furniture finishing
 facilities are assumed to have one finishing line each and medium
 and large facilities are assumed to have two finishing lines.
 The number of spray booths for each finishing line is also
 provided in Table 4-2.
     The actual sequence used at a facility may very well differ
 from those described.  In these instances, the regulatory agency
 must evaluate the operation from the standpoint of the finishing
 sequence  used and the final finish requirements.
 4.1.3  Model Plant Sizes
     Model plant sizes and process parameters were developed
 based on  the model plants described in the furniture industry's
VOC control technology study.   Finish parameters,  including VOC
 content,   density,  solids content,  and relative usage rates, are
 based on  industry's model plants.1  The model plant types
 developed by the wood furniture industry in its study,  however,
 are specific to one size plant;  to ensure that this CTG's models
 represent all sizes within the industry,  the wood furniture
 industry's model plants 2,  8,  and 10 were scaled up or down,
 based on  total finishing material usage,  to create other sizes of
plants within a category.   In addition,  another model plant type
was developed and sized for roll coating.  See Table 4-3 for a
 summary  of the industry and earlier draft CTG model plants.
     4.1.3.1  Coating Usage.   Finishing matericil use for each of
 the model plants is presented in Table 4-2.1  Finish usage values
                               4-6

-------
TABLE 4-3.
SUMMARY OF INDUSTRY AND EARLIER DRAFT CTG
       MODEL PLANTS1'3
Model
plant
No.
NO. Of
employees
No. of finishing
steps
VOC emissions
from finishing,
Mg/yr
Industry model plants
1
2
3
4
5
6
7
8
9
10
11
12
10-238
250-455
284-484
120-217
325-389
140
800
105-212
159-225
123-549
108-215
258-375
10-14
<, - 10
Print <, « 9
Finish <, - 10
15 +
<, - 9
< , «= 6
Print - 8
Finish - 5
4
<, - 4
3
<, - 7
<, - 7
95
321
375
42
286
66
368
111
117
349
30
88
Earlier draft CTG model plants
1
2
3
4
5
6
7
8
9
10
11
<100
100-249
>249
<100
100-249
>249
<100
100-249
>249
100-249
>249
6
6
6
10
10
10
3
3
3
3
3
45
204
454
45
204
454
45
204
454
204
454
                         4-7

-------
 are  used  in  estimating VOC emissions and the costs of control
 options.
     4.1.3.2  VOC Usage.  The total VOC usage provided in
 Table 4-2  for the model plants includes- all VOC from finishing
 and  cleaning operations.  In general, VOC emissions from finishes
 are  based  on the VOC content of the finishes, which is measured
 using test Method 24.  For the majority of finishes that cure by
 the  evaporation of solvents from the film, all of the VOC is
 presumed to evaporate to the atmosphere:  i.e., VOC usage equals
 VOC  emissions.
     The VOC usage for finishing operations  (minus cleaning
 solvents)  was used to define the different sizes of model plants.
 Each size  model plant represents a range of usage within the
 industry.  Extra small plants use between 25 and 65 tons per year
 of VOC, small plants use between 65 and 160 tons per year, medium
 plants use between 160 and 325 tons per year, and large plants
 use  more than 325 tons per year.1'2  The range of VOC usage
 applicable for each model plant is shown in Table 4-4.
     Size  designations are based on VOC usage,  not finishing
 material usage.   The same volume of total finish usage provides
 differing  levels of VOC usage for the five categories of model
plants.  The combination of coating steps in the finishing
 sequence varies with each category (for example,  stain,  stain,
 sealer, and topcoat for the short spray sequence versus stain,
 sealer, and topcoat for roll,  curtain,  and dip coating),  and the
VOC usage  associated with the same quantity of total finish usage
 for each category would vary.   Another important factor that
accounts for the differing VOC usage levels is that the VOC
content of the finishing materials used for the same type of
 finishing  step (topcoat,  for instance)  varies from category to
category.
     Whether a plant with 100 tons per year of VOC usage from
finishing  operations is truly "small" in the sense of the level
of production is not important here.   The plant size designations
are made for the purpose of comparing plants with comparable
                               4-8

-------
TABLE 4-4.
RANGES OF VOC USAGE AND EMPLOYMENT DATA FOR
          MODEL PLANTS
Model plant
category
Short
Long

Roll
Model Plant No.
la
1
2
3
4a
4
5
6
7a
Finishing VOC range,
tons
25-65
65-160
160-325
>325
25-65
65-160
160-325
>325
25-50
SIC Code
2511
2519
2521
2531
2541
2511
2519
2521
2531
2541
2511
2519
2521
2531
2541
2511
2519
2521
2531
2541
2511
2517
2519
2521
2531
2511
2517
2519
2521
2531
2511
2517
2519
2521
2531
2511
2517
2519
2521
2531
2534
2517
2521
2531
2541
Employee range
20-99
20-99
50-99
50-99
5O-99
100-249
100-249
100-499
100-249
1CKM99
250499
250-499
500-999
250-499
500-999
>500
>500
> 1,000
>500
> 1,000
20-99
20-99
20-99
50-99
50-99
100-249
100-249
100-249
100-499
100-249
250-499
250-499
250-499
500-999
250^99
>500
>500
>500
> 1,000
>500
20-49
20-99
50-99
50-99
50-99
                          4-9

-------
TABLE 4-4.  (continued)
Model plant
category
Roll (cont'd)











Upholstered
furniture
Kitchen
cabinets



Model Plant No.
7



8




9




10
lla

11
12
13
Finishing VOC range,
tons
50-150



150-300




>300




>25
25-50

50-100
100-250
>250
SIC Code
2534
•2517
2521
2531
2541
2534
2517
2521
2531
2541
2534
2517
2521
2531
2541
2512
2434

2534
2434
2434
Employee range
50-99
100-249
100-499
100-249
100-499
100-249
250-499
500-999
250-499
500-999
>250
>500
> 1,000
>500
> 1,000
> 100 to 250
20-49

50-99
100-249
>250
         4-10

-------
 emission reduction potential.   Actual plant emissions may lie
  i
 anywhere in the size ranges indicated.
      4.1.3.3  Cleaning Solvent Usage.  The usage of VOC solvents
 for cleaning operations is  provided in Table 4-2 for each model
 plant.   Based on information obtained from industry,  it was
 estimated that 10 percent of the total  volume of "coating
 materials" purchased is industrial  solvents used for cleaning
 purposes.2  Cleaning operations can occur  throughout the plant,
 but the  majority of cleaning operations associated  with wood
 furniture finishing operations occur in or near  the spray booths.
 Using an average cleaning material  VOC  content of 6.9 Ib VOC/gal,
 VOC usage resulting from cleaning operations were estimated  and
 are shown in Table 4-2.
      4.1.3.4  Number of Employees.   The number of employees  also
 varies with each size model  plant and encompasses a fairly wide
 range for some of  the sizes.   The range ,of  employees  varies  among
 SIC codes for a particular  size plant within a model  plant
 category.   It is important  to  remember  that model plant size is
 not specifically related to  the number  of employees;  employee
 numbers  are provided for later use  in nationwide  emission
 calculations in Chapter  6.   Extra small  plants have between  20
 and 99 employees,  small  plants have  between 50 and  499  employees,
 medium plants  employ  between 100  and 999 workers, and large
 plants employ greater than 500  workers.1'2   Employment
 information is  shown  in  Table  4-4 for each  SIC code for each
 sized model  plant.
 4.1.4  Finish  Parameters
      Finishing material  parameters have been identified for  each
 of  the five model plant  categories.    The finish parameters are
presented  in Table 4-5 for each  type  of  finishing material
 typically used by the model plant facilities.  The average VOC
content  (Ib VOC/gal and  Ib VOC/lb solids) and solids  content  for
the finishing materials used in each  of the model plant  catego-
ries including stain, toner  (a type of stain), washcoat,  filler/
glaze, sealer, highlight, and topcoat, are shown.1  The VOC
content refers to the volatile organic compound content,  in  grains
                               4-11

-------
TABLE 4-5
FINISHING  MATERIAL CHARACTERISTICS

Short
Long
Roll
Upholstered
furniture
Kitchen
cabinets
STAIN
VOC content, g/L Ob/gal)
VOC content, Ib/Ib solid
Solids content, % by weight
791 (6.6)
160
0.60
791 (6.6)
160
0.60
815 (6.8)
110
0.82
791 (6.6)
160
0.60
791 (6.6)
130
0.75
TONER (Another stain)
VOC content, g/L (lb/gal)
VOC content, Ib/lb solid
Solids content, % by weight
779 (6 .5)
17
5.7
779 (6.5)
17
5.5
NA
NA
NA
779 (6.5)
17
5.7
NA
NA
NA
WASHCOAT
VOC content, g/L (lb/g«l)
VOC content, Ib/lb solid
Solids content, % by weight
FILLER/GLAZE
VOC content, g/L (lb/gal)
VOC content, Ib/lb solid
Solids content, % by weight
NA
NA
NA
779 (6.5)
11
7.6
NA
NA
NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
479 (4.0)
1.0
50.9
NA
NA
NA
NA
NA
NA
NA
NA
NA
SEALER
VOC content, g/L (lb/gal)
VOC content, Ib/lb solid
Solids content, % by weight
731 (6.1)
4.6
17.9
731 (6.1)
4.7
17.6
623 (5.2)
2.0
33.1
731 (6.1)
4.6
17.9
671 (5.6)
3.4
23.0
HIGHLIGHT
VOC content, g/L (lb/gal)
VOC content, Ib/lb solid
Solids content, % by weight
NA
NA
NA
791 (6.6)
51
1.9
NA
NA
NA
NA
NA
NA
NA
NA
NA
TOPCOAT
VOC content, g/L Ob/gal)
VOC content, Ib/lb solid
Solids content, % by weight
719 (6.0)
3.6
21.9
719 (6.0)
3.8
20.9
599 (5.0)
1.7
36.6
719 (6.0)
3.6
21.9
599 (5.0)
1.9
35.0.
                     4-12

-------
 of  VOC per liter of coating less water and less  negligibly
 photochemically reactive compounds,  (g/L-water-exempt  compounds).
      The relative VOC emissions for  each model plant category are
 presented in Table 4-6.   The largest portion  of  relative
 emissions may result from a different finishing  step in the
 finishing sequence for each model plant category.  Stain
 application is the major contributor to emissions  for  both the
 roll,  curtain,  and dip coating and kitchen cabinet finishing
 categories,  at 39 percent and 38 percent,  respectively.  In the
 short finishing sequence,  sealer application, which accounts  for
 44  percent of emissions,  is the major contributor  to VOC
 emissions.   The VOC emissions attributable to the  application of
 topcoat  accounts for 37-percent of total VOC emissions for the
 long  finishing sequence.   For stain,  sealer, and topcoat,  the
 three most prevalent coating steps for the model plants, the
 relative emissions  remain within a fairly  small  range over the
                                        *
 five  categories.

         TABLE 4-6.  RELATIVE PERCENTAGE OF VOC EMISSIONS
Model plant
category
Stain
Toner
Washcoat
Filler/glaze
Sealer
Highlight
Topcoat
Short
19*
1
.
.
44
-
36
Long
26
3
8
1
16
9
37
Roll
39
-
.
.
25
-
36
Upholstered
19
1
.
-
44
-
37
Kitchen
cabinets
38
.
.
_
28 .
-
34
4.2  EMISSIONS ESTIMATES
     Total VOC coating emissions, broken down by finishing step
and by emission point, and cleaning solvent VOC emissions are
discussed in the following sections.
                              4-13

-------
 4.2.1  Emissions by  Finishing Step
     For all  of the  finishing materials used in defining the
 model plants, all of  the VOC contained in the cocitings is
 presumed to evaporate to the atmosphere.  Because the VOC
 contained  in  the coatings used in the furniture industry
 generally  does not become part of the finish during curing, this
 assumption is thought to be reasonable.  The VOC contents  in
 Table 4-5  were used  in conjunction with the total finish usage of
 each material for each model plant to determine the VOC emissions
 from each  finishing step.  The emission summary is presented in
 Table 4-7.  As can be seen in Table 4-7, the majority of the
 emissions  from furniture finishing operations for each model
 plant category are from stain, sealer, and topcoat application.
 4.2.2  Emissions by Emission Point
     Volatile organic compound emissions from finishing
 operations occur at three primary points in the finishing
 process:   the spray booths, the flashoff (air dry)  areas, and the
 ovens.  Volatile organic compound emissions also result from
 cleaning operations,   including equipment cleaning and general
 cleaning operations.   A comparatively small source of emissions
 is the finished piece, which may still contain small amounts of
 solvent that  eventually volatilize.  Total emissions from the
 finished piece (once  all finishing operations are completed) are
 expected to be less than 1 percent of the total VOC emissions.4
The magnitude and distribution of the VOC emissions from
 finishing and cleaning operations are discussed below.
     The relative distribution of VOC emissions among the spray
booths,  flashoff areas, and ovens varies among plants.   Finish
 formulation affects the emissions distribution.   For example,  if
a finish containing mostly low-boiling solvents is applied in a
spray booth,  the solvents will evaporate quickly,  and relatively
more emissions will occur in the booth and flashoff areas than
would occur if a finish with high-boiling solvents was  used.  The
distribution of emissions is also affected by the layout of the
finishing line and the finishing sequence used.   The relative
positions and design of the booths,  flashoff areas,  and ovens can
                              4-14

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4-15

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 affect  the  relative  emissions.  The  length of the flashoff area
 can also affect  the  emissions distribution.  Finishing sequences
 for typical furniture  facilities were described previously in
 Chapter 2.   Not  all  spray booths are followed by both an air dry
 (flashoff)  area  and  an oven; in many instances, there is only a
 flashoff area in between two spray booths, without an oven.  In
 such instances,  the  emissions would  be distributed just between
 the booth and flashoff areas.
     Although the distribution of VOC emissions among the booths,
 flashoff areas,  and  ovens varies with finish formulation and
 plant layout, overall  average emissions distributions have been
 developed based  on previous studies  and conversations with add-on
 control equipment suppliers.  These  emission distributions are
 discussed below.  The  actual VOC emissions from each emission
 point are also a function of the amount of VOC that is captured
 and exhausted to the atmosphere or an add-on control device.
 Therefore,  an estimate of the percentage of VOC that is exhausted
 is provided following  the emission distribution discussion.
     The study conducted by industry indicates that emissions
 from spray  booths represent from 84  to 97 percent of the total
VOC emissions.1'4"^  More or less emissions may occur in the
 spray booths depending on the properties of VOC solvents used for
 individual  finishing steps.  Because stains contain many low-
boiling solvents, relatively more emissions {95 to 97 percent)
were estimated to occur in the stain spray booth,  whereas the
sealer and  topcoat spray booth emissions were estimated to be
 84 to 87 percent of the total.   The study estimated that from
90 to 94 percent of washcoat emissions occur in the spray booth.-1
     Flashoff areas are located either between spray booths or
between a spray booth and an oven.   Some or all of the solvent
remaining on the recently sprayed piece evaporates in the
flashoff area.   Based on industry studies,  it was estimated that
in a booth,  flashoff, oven sequence,  between 3 and 11 percent of
the total VOC emissions are emitted in flashoff areas.   If the
flashoff area is not followed by an oven,  essentially all of the
remaining solvent is expected to evaporate in the flashoff area.
                              4-16

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 Thus,  in such instances,  flashoff emissions are expected to be
 approximately 5 to 16 percent of the total VOC emissions.1'4"6
      Ovens are sometimes  used to cure the finish prior to the
 next step in the finishing process.   Previous  studies  indicate
 that approximately 2 to 5 percent of the total VOC finishing
 emissions occur.in the oven.4"6  The ovens used by many furniture
 manufacturers that finish pre-assembled pieces are enclosed
 tunnels with open ends where the pieces enter  and exit the oven
 on a belt.
      In a typical furniture finishing room,  there are  no roof
 vents.   The only finishing room exhausts are those from the spray
 booths  and ovens.   The total exhaust often exceeds the makeup
 inflow  rate,  which results in the finishing room being maintained
 at a negative pressure relative to the outside.   Because the
 exhaust flowrates of the  spray booths are generally quite large,
 and because the flashoff  area is located either in between two
 booths  or in between a booth and an  oven,  the  majority of the
 flashoff  emissions are expected to be exhausted through the
 booths  and  ovens.   Even in an operation with a long flashoff
 area, most  of the  flashoff emissions are expected to eventually
 be exhausted through the  booths and/or ovens,  since they are
 generally the only forced exhaust  points.
     Since  the ovens are  mostly enclosed, most  of  the VOC
 emissions generated in the oven are  expected to be  exhausted from
 the oven  to  the  atmosphere.   Though  spray booths  are more open
 than ovens,  the  booths are the  only  (other than the ovens)  forced
 exhaust from the building and thus,  most of  the VOC emitted  in
 the booths  is  expected to be  exhausted  out the booth exhaust.
 Where the emissions  from  the  flashoff areas  is exhausted  depends
 on the  relative  locations  of  the booths and  ovens.  For purposes
 of  this CTG,  it  is  estimated  that approximately 90 percent of the
 total VOC emissions  released  in  the  spray booths, ovens,  and
 flashoff  areas combined are exhausted from the facility through
 the exhaust system, based on engineering judgement.
Approximately  10 percent of the total VOC emissions are estimated
                               4-17

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 to  leave  the  finishing area through openings such as doors and
 windows.
     The  majority of cleaning operations occur in or near the
 spray booths.  As discussed previously, cleaning solvent usage is
 10  percent of the total volume of "coating materials" purchased.
 The assumption is made that all VOC cleaning solvent used is
 emitted.
     The  distribution of finishing and cleaning solvent emissions
 is  presented in Table 4-8; finishing emissions are provided by
 coating type and emission point.  Table 4-8 presents the
 emissions that are exhausted through the booths and ovens, which,
 as  previously discussed, represents approximately 90 percent of
 the finishing emissions (minus cleaning solvents).  The other
 miscellaneous 10 percent of finishing emissions released through
 doors and windows are also shown.  This table provides a
 breakdown of emissions by finishing step for every size model
 plant in each of the five model plant categories.  Because it is
 assumed that staining operations involve just a spray booth and a
 flashoff area, with no oven,  stain emissions are distributed
 between the booth and flashoff areas.   Emissions from cleaning
 solvent operations,  10 percent of the total volume of "coating
materials" purchased, are also presented for each model plant.
                              4-18

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4.3  REFERENCES FOR CHAPTER 4

1.  ENSR Consulting and Engineering.  An Evaluation of VOC
    Emissions Control Technologies for the Wood Furniture and
    Cabinet Industries.  Prepared for the American Furniture
    Manufacturers Association, Business and Institutional
    Furniture Manufacturers Association, Kitchen Cabinet
    Manufacturers Association, and the National Paint and
    Coatings Association.  January 1992.

2.  Memorandum.  Rasor, S., MRI, to Strum, M. ,  EPA/ESD/CPB.
    Summary of Responses to the Information Collection Request
    for the Wood Furniture Industry.  January 28, 1994.

3.  Control of VOC Emissions from Wood Furniture; Coating
    Operations-Draft Chapters 1 through 5 of Control Techniques
    Guideline.  U. S. Environmental Protection Agency, Research
    Triangle Park, NC.  October 1991.

4.  H. Van Noordwyk, Acurex Corp.  Reducing Emissions from the
    Wood Furniture Industry with Waterborne Coatings.  Prepared
    for the Environmental Protection Agency.  EPA-600/2-80-160.
    July 1980.

5.  Telecon.  Christie, S., Midwest Research Institute, with
    Novak,  W., Industrial Technology Midwest.  February 26, 1991
    Spray booth recirculation and emissions.

6.  Telecon.  Caldwell, M.J.,  Midwest Research Institute, with
    Shugarman, L. , Terr-Aqua Enviro Systems.  F€±>ruary 28, 1991.
    Emissions distribution in wood furniture plants.

7.  Memorandum.  Christie,  S., Midwest Research Institute, to
    Catlett, K.,  EPA/ESD/CPB.   Preliminary Assessment of
    Industrial Solvent Use in Wood Furniture Coating Operations.
    January 28, 1991.
                              4-20

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                      5.0  SELECTION OF RACT

      This  chapter discusses  the selection of  reasonably available
 control  technology (RACT)  to control volatile organic compound
 (VOC)  emissions from wood furniture manufacturing operations.
 The  process through which RACT was  selected and the other
 regulatory activities that affected RACT  selection are discussed
 in Section 5.1.   The selection of specific guidelines such as  the
 reference  control technologies,  work practice standards,  and
 compliance provisions are discussed in Sections 5.2,  5.3,  and
 5.4,  respectively.   Finally,  small  business issues that were
 considered in  selecting RACT are identified in Section 5.5.
      As  is discussed further in Chapter 7, the RACT guidelines
 presented  in this document are simply  a framework for State and
 laocal  regulatory  agencies.   These agencies will promulgate the
 specific regulations that  sources will be  required to implement
 to meet RACT.   Possible ways  for agencies  to  codify RACT
 guidelines are  discussed  in  Chapter 7, and a  model rule  is
 presented  in Appendix B.
     The environmental and cost  impacts associated with  RACT are
 provided in Chapter  6, along  with the  impacts  associated with
 other alternatives that were  not selected  as RACT.
 5.1  BACKGROUND
     The determination of  RACT for  the wood furniture
manufacturing industry was concurrent  with a national emission
 standards  for hazardous air pollutants (NESHAP) that was also
developed  for the industry.  The final NESHAP  for the wood
 furniture  industry was promulgated  in December, 1995
 (60 CFR 62930).  The NESHAP will control emissions of hazardous
air pollutants  (HAP) listed in Section 112(b)  of the Clean Air
                               5-1

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Act, as required by Sections 112(c) and  (d) of the Act.  Control
of HAP is achieved by requiring major sources to implement
maximum achievable control technology (MACT).  Although the CTG
and the NESHAP pertain to controlling VOC's and HAP,
respectively, a source could potentially be affected by both.
For example, some of the HAP are also VOC's; a major source of
HAP that is located in a nonattainment area and that emits HAP
that are VOC's would have to comply with the NESHAP and, if it
emits above the CTG cutoff, would also have to comply with the
RACT imposed by the State regulatory agency.  In selecting RACT,
the EPA considered this potential overlap.
     As discussed in Chapter 1, both RACT and the requirements of
the NESHAP were selected" within the framework of a regulatory
negotiation.  In trying to reach an agreement on the presumptive
norm for RACT, the Committee looked at several factors.  In
particular, they focused on technologies that they deemed to be
reasonable for all segments of the wood furniture industry at the
present time.  In developing coating emission limitations, they
also considered the impact of the work practice standards.  After
much discussion, the Committee agreed upon a combination of
emission limitations and work practice standards they believed
represented RACT for the wood furniture industry.1
     The remaining sections of this chapter provide a summary of
RACT and discuss the rationale the Committee used in selecting
the requirements that form the basis for RACT.
5.2  SELECTION OF REFERENCE CONTROL TECHNOLOGIES
     The presumptive norm that forms the basis for RACT consists
of reference control technologies and work practice standards.
The selection of work practice standards is presented in
Section 5.3.  Through the regulatory negotiation process,  the
Committee decided that two reference control technologies should
form the basis of RACT.   These technologies are either
(l)  waterborne topcoats,  or (2) higher-solids sealers and
topcoats,  as identified in Table 5-1.   As indicated in this
table,  State agencies should apply RACT to sources located in
ozone nonattainment areas (except extreme nonattainment areas)
                               5-2

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 that  emit  or have the potential to emit  25  tons  per year
 (t6ns/yr)  or more of VOC's.   The RACT requirements  should be
 applied to sources in extreme nonattainment areas that  emit or
 have  the potential to emit 10 tons/yr or more  of VOC's.

     TABLE 5-1.  REFERENCE CONTROL TECHNOLOGIES TO MEET RACT*
Coating type
1. Topcoats; or
2 . Topcoats and sealers
sealer
topcoat
acid- cured alkyd amino vinyl
sealers
acid- cured alkyd amino conversion
varnish topcoats
Allowable VOC
content ,
kg VOC/kg solids
(Ib VOC/lb solids)
0.8
1.9
1.8
2.3
2.0
  aRACT requirements apply to all sources located in nonattain-
   ment areas (other than extreme areas)'that emit or have the
   potential to emit 25 tons/yr or more of VOC's.  Sources
   located in extreme areas must meet the RACT requirements if
   they emit or have the potential to emit 10 tons/yr or more
   of VOC's.
     Once the Committee decided that RACT should include the use
of waterborne topcoats or higher-solids sealers and topcoats, a
specific format for identifying allowable emissions from these
technologies had to be chosen.  In recommending a format for
RACT, the following factors were considered:
     1.  The format must accommodate multiple compliance
techniques for the various industry segments;
     2.  Given the large number of small businesses in this
source category, the format must ensure that the cost of
compliance is not excessive;
     3.  The format must ensure that an equivalent level of
control is achieved by all affected sources;
     4.  The format must facilitate enforcement by regulatory
agencies; and
                               5-3

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      5.   If  possible,  the  format  should be consistent with  the
 format selected  for  the MACT standards because a source could
 potentially  be subject to  both RACT and MACT.
      The  possible  formats  considered include:  (l) a limit  on
 emissions of VOC per kilogram  (pound) of coating solids;  (2) a
 percent reduction  format;  (3) a limit on emissions of VOC per
 liter (gallon) of  coating, less water; and (4) a limit on
 emissions of VOC per liter (gallon) of coating solids.  For all
 formats limiting VOC content, the VOC content should be
 calculated as applied  to account for in-house dilution of
 coatings  purchased from an outside source.
      The  format  selected by the Committee (and included in  the
model rule in Appendix B)  is a limit on the kilograms (pounds) of
VOC emitted  per  kilogram (pound) of coating solids (kg VOC/kg
solids [Ib VOC/lb  solids]).  Another possible format, percent
reduction, was not selected because several disadvantages to this
format were  identified.  Primarily, the percent reduction that
will  result  from implementing RACT will vary from facility  to
facility.  This  is especially the case when reformulated coatings
are used  in  lieu of  conventional add-on controls.  To implement a
global percent reduction format, baseline conditions at each
affected  source would have to be assessed.  At an uncontrolled
facility, this would not be a problem;  baseline conditions  would
be the current emission rate (although exactly which year
represents "typical" for baseline may not be straightforward)..
The percent  reduction would be applied to this uncontrolled rate
to calculate the controlled VOC emission rate reijuired by the
rules implementing RACT.   Problems with the percent reduction
format arise, however,  if a facility has implemented control
strategies prior to being subject to RACT.  If the same baseline
year is selected for both the uncontrolled and controlled
facility, the controlled facility would have to ultimately
control a greater quantity of VOC emissions than the uncontrolled
facility.  In some instances,  however,  a percent reduction  format
offers advantages.   For example, a percent reduction format
                               5-4

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 allows sources the flexibility to choose any control method
 feasible for their situation.
      A limit on the kilograms (pounds)  of VOC contained in a
 liter (gallon)  of coating (kg VOC/liter [Ib VOC/gal]),  less
 water,  was also considered.   -A similar format was considered for
 the MACT standard but was eliminated because it does not give
 ample credit to sources that substitute non-HAP VOC for HAP in
 their coatings.  Another format considered was one expressed as
 kg VOC/liter solids (Ib VOC/gal of solids) .   For both RACT and
 MACT,  however,, a disadvantage to this format is that there is no
 EPA test method currently available for accurately measuring the
 volume of solids in a coating.   As stated above,  consistency
 between MACT and RACT is desired and therefore neither  format (kg
 VOC/liter [Ib VOC/gal])  of coating or kg VOC/liter (Ib  VOC/gal)
 of solids was selected for RACT.
      Once the format of  kg VOC/kg solids (Ib VOC/lb solids)  was
 selected,  the actual emission limits associated with the coating
 technologies had to be selected.   Based on data presented by the
 industry,  the major suppliers of  wood furniture coatings who
 participated in the negotiation  supply  waterborne topcoats with
 VOC contents ranging from 0.3 to  0.8 kg VOC/kg solids (Ib VOC/lb
 solids).   Due to variations  in ambient  conditions,  additional
 solvent  is sometimes added to the waterborne coatings,  raising
 the VOC  content  of  the as-applied coatings.   The  committee
 therefore chose  0.8 kg VOC/kg solids (Ib VOC/lb solids)   as a
 reasonable VOC  limit for waterborne  topcoats.
     For  higher-solids sealers and topcoats,  the  Committee
 decided that different coating limits were appropriate  depending
 on  the type  of sealer and topcoat used  by a  facility.   As
 discussed in Chapter 2,  residential  furniture manufacturers
 typically use nitrocellulose  sealers and topcoats.  These
 conventional  coatings have a  solids  content  ranging from 15  to
 20 percent by weight.  Office furniture manufacturers typically
use acid-catalyzed  sealers and topcoats.  The solids  content  of
 these coatings ranges from 20 to  30 percent  solids.   Finally,
kitchen cabinet manufacturers typically use vinyl sealers  and
                               5-5

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 conversion varnishes  with  a  solids  content ranging from 25 to
 35  percent by  weight.
     The Committee decided that  there were no higher solids
 sealers and  topcoats  available to the entire wide range of
 finishing sequences that were readily usable by the existing
 processes and  met the performance specifications of the vinyl
 sealers and  conversion varnishes.   Therefore, they agreed on a
 limit of 2.3 kg VOC/kg solids  (Ib VOC/lb solids), as applied, for
 acid-cured alkyd amino vinyl sealers.  For acid-cured alkyd amino
 conversion varnishes, they agreed on a limit of 2.0 kg VOC/kg
 solids (Ib VOC/lb solids), as applied.  These values are roughly
 equivalent to  coatings with a solids content of 30 percent by
 weight.
     For all other sealers and topcoats, the Committee decided on
 limits of 1.9  kg VOC/kg solids (Ib VOC/lb solids) and 1.8 kg
 VOC/kg solids  (Ib VOC/lb solids), as applied, respectively.
 These values roughly correspond  to coatings with a solids content
 of  32 to 35 percent by weight.
 5.3  SELECTION OF WORK PRACTICE  STANDARDS
     In selecting RACT and the requirements for the NESHAP, the
 Committee recognized that  VOC and HAP emissions could be further
 reduced by implementing work practice standards.  The work
 practices selected for the proposed NESHAP and as part of RACT
 are basically  the same.  One difference is that there are
 additional work practices  in the NESHAP that are particularly
 concerned with the use of  specific materials due to their
 potential effects on health and  the environment.  The work
 practices that are included as part of RACT are concerned solely
 with reducing VOC's.
     The Committee believed that there were reasonable work
practices to reduce VOC emissions from both coating operations,
 cleaning operations,  and washoff operations.
 5.3.1  Coating Operations
     Specifically,  three areas in which VOC emissions from
 coating operations could be reduced through work practices were
 identified:   VOC storage,  VOC transfer,  and coating application.
                               5-6

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 Work practices for each of these areas are discussed below and
 summarized in Table 5-2.
      5.3.1.1  VOC Storage.  Materials containing VOC are often
 stored in containers that are left open,  allowing the VOC to
 evaporate and be emitted through room ventilation to the
 atmosphere.   A straightforward,  inexpensive method of reducing
 emissions from VOC storage would be to use normally closed
 containers,  that is,  to cover all VOC storage  containers when not
 in use.   This practice has already been implemented at some
 facilities.   In addition to reducing VOC  emissions to the
 atmosphere,  this work practice has the added benefit of reducing
 worker exposure to VOC and creating a cost savings by reducing
 evaporative  losses.
      5.3.1.2  VOC Transfer.   In  wood furniture coating
 operations,  coating is pumped from its storage container to the
 spray gun through piping.   The most likely locations for leaks to
 occur in  such a transfer system  are from  the pumps and at the
 coating application equipment juncture.   The Committee agreed
 that  requiring sources to check  these areas for  leaks  was
 reasonable.   To implement the leak inspection  program,  sources
 should develop an inspection and maintenance (I&M)  plan that
 requires  the inspection of  each  piece of  equipment  used to
 transfer  or  apply finishing  materials or  solvents.   The inspec-
 tion  may  be  a visual  inspection  only,  but  it must be conducted at
 a minimum frequency of  once  per  month, with repairs  to  leaking
 equipment  made within 15  calendar days unless new equipment must
 be ordered.   Also, the  plan  should identify the procedures to  be
 followed  in  the event  that a pump or  coating application
 equipment  malfunctioned such that a VOC release could occur.
      This  work practice includes  some minimum criteria  that are
 necessary  for  an  I&M program to be effective.   For example, the
 Committee  believed that a monthly inspection frequency would be
 appropriate  to  accomplish the goal of reducing leaks from pumps
 and coating  application equipment.  More frequent monitoring may
be burdensome;  smaller shops would not have the personnel to
perform the  inspections and  larger shops would be devoting a
                               5-7

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           TABLE 5-2.   WORK  PRACTICE  STANDARDS  TO MEET  RACT
Emission source
Work practice
Finishing operations
Transfer equipment leaks
Storage containers, including mixing
equipment
Application equipment
Develop written inspection and maintenance plan to address
and prevent leaks. The plan must identify a mmiminn
inspection frequency of 1 /month and procedures for
addressing malfunctions. Repairs to leaking equipment
must be made in IS days unless replacement equipment has
to be ordered.
When such containers are used for VOC or
VOC-containing materials, keep covered when not in use.
Discontinue use of conventional air spray guns.*
Cleaning operations
Gun/line cleaning
Spray booth cleaning
Washoff tanks/general cleaning
- Collect cleaning solvent into a closed container.
- Cover all containers associated with cleaning when not
in use.
- Use strippable spray booth coating with a VOC content
of no greater than 0.8 kg VOC/kg solids Ob VOC/lb
solids).
- Do not use solvents unless cleaning conveyors or metal
filters, or refurbishing the spray booth.
- Keep washoff tanks covered when not in use.
- Minimize dragout by tilting and/or rotating part to drain
as much solvent as possible and allowing sufficient dry
time.
- Maintain a log of the quantity and type of solvent used
for washoff and cleaning, as well as the quantity of
waste solvent shipped offsite, and the fate of this waste
(recycling or disposal).
- Maintain a log of the number of pieces washed off, and
the reason for the washoff.
Miscellaneous
Operator training
implementation plan
All operators shall be trained on proper application,
cleanup, and equipment use. A training program shall be
written and retained onsite.
Develop a plan to implement these work practice standards
and maintain onsite.
aConventional air guns will be allowed in the following instances:
  -  when they are used on conjunction with coatings that emit less than 1.0 kg 0°) VOC per kg (lb) of
    solids used;
  -  for touchup and repair under limited conditions;
  -  when spray is automated;
  -  when add-on controls are employed;
  -  if the cumulative application is less  than 5.0 percent of the total gallons of coating applied; or
  -  if the permitting agency determines  that it is economically or technically in feasible to use other
    application technologies.
                                            5-8

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 significant portion of time to monitoring the many pumps and
   t
 coating stations.   The monthly inspection frequency is further
 supported by other EPA regulatory actions.2  The leak detection
 and repair program identified in Subpart H of the hazardous
 organic NESHAP (HON)  (57 FR 62608)  also requires monthly
 inspection of pumps.   To ensure that action would be taken if
 leaks were detected,  the I&M plan should require that repairs be
 made within 15 calendar days,  with a first attempt at repair made
 within 5 calendar  days.   Again,  the EPA's decision is supported
 by previous regulatory action;  the HON and the NESHAP for coke
                                                        O "3
 oven batteries both require this same repair timeframe.  /J
      The I&M plan  must also somehow address equipment
 malfunctions.   In  the model rule in Appendix B,  this is
 accomplished by requiring that the I&M plan include a malfunction
 plan.   Such a plan has its basis in the startup,  shutdown,
 malfunction plan required by §  63.6(e)  of the General Provisions
 to 40 CFR Part 63.4  As  discussed in Chapter 7,  the State or
 local regulatory agency  may pursue a different method for
 addressing malfunctions,  as long as it  achieves  the same goal of
 requiring a facility  to  address  equipment malfunctions.
      5.3.1.3  Coating Application.   Another aspect of wood
 furniture coating  operations that was evaluated  was the  type of
 coating application equipment used.   There have  been numerous
 studies comparing  the transfer efficiency of  one  type of
 application equipment with that  of  another type.   Transfer
 efficiency is  the amount  of coating that  actually is  applied to  a
 surface compared to the  total amount  of coating used for the
 application process.   The higher the  transfer efficiency,  the
 less  coating that  is  used and the less  coating that  is lost  as
 overspray (sprayed  coatings  that miss the piece).  Overspray
 eventually dries, releasing VOC's,  and becomes a  solid waste
 source  for the  facility.   Thus,  by  increasing  transfer
 efficiency,  both air  emissions and'solid  waste are reduced.
     Traditionally, the EPA's position on transfer efficiency has
been one  that advocates the use  of more efficient  transfer
methods, but EPA contends  that emission reductions resulting from
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these methods  cannot be generally quantified for every coating
situation  or easily monitored on a continuous basis, and, thus,
sources cannot receive emission credits for improving transfer
efficiency.  To deal with this issue, the Committee explored a
work practice  which would require the use of technologies
believed to result in more efficient application of coating.  To
encourage  innovation in application equipment, the work practices
include an equipment requirement that does not require the use of
specific application equipment but limits the use of conventional
air guns because they are the least efficient transfer method.
Exempted situations may include one in which a source is using
low-VOC coatings (less than 1.0 kg VOC/lb solids [i.o lb VOC/lb
solids]) or add-on control devices; transfer efficiency is not as
critical in these situations.  Also, if the use of air guns is
limited to specialty operations but more efficient application
methods were used for the majority of coatings, the environmental
impact of  using conventional air guns would be minimal.  The
specific exemptions to the conventional air spray gun prohibition
are provided in Table 5-2.
     Operator  training on coating application is also a required
work practice.  By training the operators in proper equipment
operation, transfer efficiency will increase,  resulting in a
reduction  of VOC emissions to the atmosphere.   This work practice
is discussed further later in the chapter.
5.3.2  Cleaning and Washoff Operations
     As discussed in Chapter 2,  cleaning activities that occur at
wood furniture manufacturing operations include cleaning of spray
guns, lines conveying coatings from storage to the spray guns,
and spray  booths.   The Committee also agreed on work practices
for washoff operations.  Washoff involves the use of solvents to
remove coating from furniture.  In determining the work practices
to be selected for cleaning and washoff operations, the Committee
considered work practices that were being performed in the source
category to limit emissions from these activities.
     The Committee concluded that there were reasonable work
practices  in use by existing facilities in the source category to
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 limit emissions from each major cleaning and washoff  activity:
 gun/line cleaning,  spray booth cleaning,  and furniture
 washoff/general cleaning activities.   These  work practices are
 summarized in Table 5-2 and are discussed below.
      5.3.2.1  Gun/Line Cleaning.  The cleaning  of spray  guns  and
 of  lines that carry the coating from  storage to the spray  guns  is
 a common practice in wood furniture operations.   Cleaning  is
 necessary so that dried resins or other materials do  not build  up
 in  the lines or spray equipment.  The frequency of cleaning
 varies by plant,  depending on the different  types of  coating
 sprayed with a given gun,  the extent  to which a gun is used,  and
 other plant-specific factors.   Typically,  a  gun is cleaned each
 time  it is used to  spray a different  coating.   If a gun  is
 dedicated to one type of coating (e.g., topcoat),  cleaning
 frequency may be reduced.   The practice of dedicating a  gun to  a
 particular coating  type is not common, however,  especially at
 smaller shops that  have fewer spray stations.
      One cleaning operation work practice  included in RACT
 requires that solvent used for cleaning be collected  into  a
 closed container.   For example,  if  a  line  is  flushed,  the
 cleaning solvent  could be  collected into a container with  a lid
 that  has an opening of sufficient size for the line to fit in;
 the rest of the  container  could be  covered.   Such a container
 could be prefabricated onsite,  or purchased from an outside
 vendor,  at  a  minimal  cost  to the plant.  Another work practice
 that  is  included  in RACT and that could be easily implemented is
 the use  of normally closed containers, that is,  covering cleaning
 solvent  containers  when not  in use.  As discussed for VOC  storage
 containers associated with coating operations, such a practice  is
 straightforward and inexpensive  to implement.
      5.3.2.2  Spray Booth Cleaning.  The work practices
 identified as part  of  RACT require the use of strippable spray
booth materials with  a VOC content no greater than 0.8 kg VOC/kg
solids  (Ib VOC/lb solids).  A strippable spray booth material is
one  that is applied to spray booth walls;  coating overspray is
collected on the material, and the material is regularly stripped
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 off  and  disposed of.   Therefore,  only  small quantities of solvent
 are  needed to clean the spray  booth walls.  The work practice
 standards  prohibit  the use  of  solvents for spray booth cleaning
 except in  limited circumstances because facilities could easily
 convert  to using strippable spray booth materials that eliminate
 the  use  of solvents for this purpose.  The Committee recognized
 that there were  instances in which it  was unreasonable to
 prohibit solvent use  for cleaning.  Specifically, it was agreed
 that conveyors carrying furniture or furniture components through
 the  spray  booth  could continue to be cleaned with solvent.
 Likewise,  metal  filters will still require solvent cleaning.  The
 Committee  was not aware of  substitute  materials that could be
 used for cleaning this equipment, or of any strippable coating
 such as  the coating that is available  for the spray booth walls.
 Additionally, industry representatives pointed out that small
 tears and  holes  may be generated  in the ^strippable booth coating
 during the manufacturing process.  In  these cases, some staining
 of the spray  booth  walls may occur.  The Committee agreed that
 sources  could use small quantities of  solvent, no more than
 3.8  liters (1.0  gallon)  per booth, to  clean these areas when the
 strippable coating  was being replaced.
      5.3.2.3  Furniture Washoff/General Cleaning Activities.  The
 final area of concern for which a work practice has been
 identified is the procedure known in the industry as washoff.
Washoff  is  the removal  of the  coatings from a piece of furniture
or a furniture component because the quality of the finish does
not meet company specifications.  By washing off the coatings,
the  substrate can be  refinished.  Washoff is typically
accomplished by  dipping the furniture into a tank containing
solvent.    The Committee agreed that there were some measures that
sources  could implement  that are reasonable and that would
minimize emissions  from washoff activities.  As with coating and
other cleaning operations,  it was agreed that wash tanks could be
covered when  they are  not in use to limit solvent emissions.
Also, sources could minimize "dragout" by tilting and/or rotating
the piece  to drain as much solvent as possible and allowing
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 sufficient drip time.   Dragout is the solvent  that remains on a
 part  after it is removed from the washoff  tank;  this solvent
 evaporates and is eventually emitted through room ventilation to
 the atmosphere.   Minimizing dragout would  therefore minimize
 emissions.
      During the Committee's discussions, it  was  apparent  that
 cleaning and washoff practices are not well  documented by
 sources.   For example,  most sources do not know  the quantity of
 solvent  used for cleaning and washoff operations,  how many pieces
 are washed off,  the reason for washoff, and  the  fate of spent
 solvent  from cleaning and washoff operations.  Tracking washoff
 practices will focus attention on quality  control  issues.
 Tracking may result in  quicker identification  of process  problems
 which will reduce efforts on refinishing and save  money on
 materials and labor.  A reduction in refinishing will also mean
 better working conditions due to  less washoff  emissions.   The
 Committee also agreed that one of the first  steps  in reducing
 emissions is to  know the quantity of  solvent used  for the various
 operations onsite.   Only then can a source identify operations
 that  are  perhaps wasteful or inefficient.  Therefore, the Work
 Group proposed that the  work practices include a tracking system
 plan  through which sources  would:
      1.   Maintain a log  of  the quantity and type of  solvent used
 for washoff  and  cleaning,  the  number  of pieces washed off  daily,
 and the reason for the washoff; and
      2.   Record  the quantity  of spent solvent generated from  each
 activity,  and its  ultimate  fate either onsite or offsite.
     The  cleaning  and washoff  solvent usage quantities could be
 calculated and reported  at  some pre-established  frequency.  The
model rule in Appendix B  identifies monthly calculations  and
 reporting  of  these monthly quantities.
 5.3.3  General Work Practice Requirements
     After reviewing the work practices included in RACT,   the
Committee concluded that in order for the work practices  to be
successfully  implemented, employees that would actually have to
carry them out should be involved in their implementation.
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 Therefore,  an operator training program  is  included as a  required
 work practice.   The  Committee  believed that operator training was
 especially  important for new employees and  therefore recommends
 that new  employees be trained  upon hiring.  Any rule implementing
 this requirement should be  flexible and  allow sources to  develop
 programs  that work best for their facility  or that could  be
 coordinated with existing training programs.  At a minimum,
 however,  this work practice requires that the employee training
 program address  coating application, cleaning and washoff
 techniques  that  minimize emissions; proper  equipment operation;
 methods to  reduce solvent usage; and proper management of cleanup
 wastes.   The  work practice  also requires that employees be
 retrained on  an  annual  basis.
     Finally,  the Committee recognized that a source should
 maintain  a  plan  to implement the work practices included  in RACT.
 Therefore,  the work practices  include the development of  an
 Implementation Plan  that describes how sources plan to comply
 with the  work practice  requirements on an on-going basis.  Based
 on the work practices included in RACT,  the Committee believed
 that any  Implementation Plan should include, at a minimum, the
 following:
     1.   Checklists to  document that:
        all storage containers are covered where not in use;
        solvents are not being used for spray booth cleaning
except when metal filters or conveyors are being cleaned  or the
 spray booth is being refurbished;
        conventional air spray guns are not in use except for the
specific  situations identified;
        cleaning solvent from gun/line cleaning has been
collected into a closed container;and
        the washoff tank is covered when not in use;
     2.  An I&M plan as discussed above;
     3.  A tracking system for washoff and cleaning solvents as
discussed above;  and
     4.  The operator training program discussed above.
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      The Work Practice Implementation Plan would be followed and
 maintained onsite to demonstrate ongoing compliance,  and made
 available at the request of the Agency at any time.
 5.4  SELECTION OF COMPLIANCE PROVISIONS
      In discussing the compliance provisions,  the Committee
 decided only on some general requirements regarding compliance.
 The Committee,  for example, believed that any rule codifying RACT
 should allow the use of reference control technologies,  as well
 as  other technologies that may be equivalent to the reference
 control technologies in terms of air emission control.   Examples
 of  how a rule could accomplish this are discussed in Chapter 7.
      The Committee also agreed that,  when reference control
 technologies are used,  compliance should be accomplished through
 reporting and recordkeeping,  with reporting occurring on a
 semiannual basis.   Specifically,  reports should include  a
 statement that  compliant coatings have been used at all  times
                                        r
 during the reporting period.   The source should maintain records,
 that  is certified product data sheets,  for their coatings to
 demonstrate they are compliant.   If the data sheet  provided by
 the coating supplier identifies  the VOC content in
 kg VOC/kg solids (Ib VOC/lb solids) and the facility  then dilutes
 the coating,  the facility must account for this dilution and
 report  the VOC  content  of the  coating  that is actually applied,
 not the VOC content  of  the coating  as  purchased.
      In summary,  the compliance provisions contained  in  the rule
 that  implements  RACT should include:
      l.   Methods  that allow compliance  through  the use of
 reference control  technologies as well  as  other control methods
 that  can  be  demonstrated as  equivalent;
      2.   The means by which alternate methods are demonstrated as
equivalent;
      3.   Compliance  through reporting and  recordkeeping, with
reporting  occurring  on a  semiannual basis; and
      4.  When reference  control technologies are used, compliance
through reports of the VOC content of coatings, as applied,  in
kg VOC/kg  solids  (Ib VOC/lb solids).
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     The model rule presented in Appendix B allows facilities to
use one of three methods, or a combination of the three methods,
to comply with the requirements of the model rule.  These include
use of compliant coatings, use of an add-on control device, or
use of an averaging approach.  The model rule provides detailed
guidance on monitoring, recordkeeping, and reporting requirements
associated with each of these compliance methods.
5.5  SMALL BUSINESS CONSIDERATIONS
     Because of the large number of small businesses that could
potentially be impacted by regulation of the wood furniture
industry, the Committee considered carefully the impact of each
aspect of presumptive RACT on small businesses.  The regulatory
negotiation Committee included two small wood furniture
manufacturers and a representative of a trade association
consisting primarily of small businesses.  A Small Business Work
Group was formed to specifically address small business issues.
     In evaluating compliance options, the Committee tried to
ensure that the compliance options would impose a minimum burden
on small businesses.  For example, presumptive RACT does not
require the use of control devices that require a significant
capital investment and impose an unfair burden on small
businesses that typically have trouble raising capital.  In
addition, the Committee tried to ensure that the recordkeeping
and reporting requirements of the proposed standards were not
beyond the resources of small businesses.
     The Committee also evaluated whether the proposed work
practice standards presented any particular problems to small
businesses.  Some members felt that developing an operator
training program might pose some problems to small businesses.
Rather than exempt small businesses from what the Committee feels
is a key work practice, the Committee decided to recommend that
small business work together to develop a training program.  The
Committee also suggested that large businesses that already have
training programs in place could share the key components of
those programs with small businesses.  Finally, the Committee
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 recommended that State small business  assistance programs assist
 small businesses in developing their training program.
      The Small Business Work Group made several recommendations
 to the Committee,  including a recommendation that  the EPA draft a
 document that would provide guidance to small businesses  on how
 to obtain a Federally-enforceable  limit on  their potential to
 emit  and recordkeeping requirements that might be  associated with
 the limit.   In addition,  small business representatives proposed
 that  the EPA draft a memorandum responding  to questions developed
 by the Small Business  Work Group pertaining to area sources that
 become major sources.
      The EPA,  California Air Pollution Control Officers
 Association,  and the California Air Resources Board  (CARB)  have
 completed a model  rule for use by  the  California Air Pollution
 Control  Districts.   Because the rule should prove  to be an
 inexpensive and efficient means of  limiting the potential
 emissions of  thousands  of sources,  the EPA  believes that parts  of
 the rule may  be helpful for other States to review and consider.
 The proposed  rule  is designed to place smaller sources under
 annual emissions limits which restrict their potential to  emit
 and thus their  exposure to major source  requirements of the  Clean
 Air Act.  The rule ensures compliance  through a series of
 recordkeeping and reporting requirements which are tapered to
 reduce burdens  as source  size decreases.  The rule applies  only
 to  sources  that agree to  limit  their emissions to  50 percent or
 less of  the major source  threshold.  Sources with emissions  above
 this level must either  comply with all applicable major source
 requirements or secure  a  source-specific, Federally-enforceable
 Air Pollution Control District permit  that properly limits
 emissions to below major  source  thresholds.   Therefore,  the  rule
 is designed to provide  smaller sources with a Federally-
 enforceable means of limiting their potential emissions.5
     The Small Business Work Group also recommended that the EPA
discuss  in the preamble to the NESHAP the benefits of general
permits  for small businesses and encourage their use where
appropriate.  The Agency agreed and a discussion of general
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permits is included in the NESHAP preamble.  The Small Business

Work Group also recommended that the EPA, in conjunction with the
State of North Carolina Small Business Ombudsman Office, develop

an information outreach program to serve as a resource for small

wood furniture manufacturers.  The Agency has agreed to work with
the North Carolina Small Business Ombudsman Office to develop

this program.

5.6  REFERENCES FOR CHAPTER 5
 l.  Memorandum and attachment from Lingelbach,  J.,  and
     S. Wildau, CDR Associates, to Wood Furniture Regulatory
     Negotiation Committee Members.  October 27,  1994.   Final
     Document and Signature Document.

 2.  Code of Federal Regulations.   40 CFR Part 63.   Subparts F,
     G, H,  and I.   National emission standards for hazardous air
     pollutants (NESHAP)  from synthetic  organic chemical
     manufacturing industry equipment leaks.   Promulgated
     April  22,  1994.

 3.  Code of Federal Regulations.   40 CFR Part 63.   Subpart L.
     National emission standards for hazardous air pollutants for
     coke oven batteries.   Promulgated October 27,  1993.

 4.  Code of Federal Regulations.  ,,40 CFR Part 63.   Subpart A.
     National emission standards for hazardous air pollutants for
     source categories--General Provisions.   Promulgated
     March  16,  1994.

 5.  Memorandum and attachments from Seitz,  J.S,  and
     R.I. Van Heweler,  EPA,  to Director,  Air,  Pesticides,  and
     Toxics Management Division, Regions  I and IV,  et al.
     January 25,  1995.  Options for Limiting the  Potential to
     Emit (PTE)  of a Stationary Source Under Section 112 and
     Title  V of the Clean  Air Act.
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           6.0  COST, ENVIRONMENTAL, AND ENERGY IMPACTS

     This  chapter addresses  the  cost, environmental, and  energy
 impacts of the RACT  requirements for finishing, cleaning, and
 washoff operations presented in  Chapter 5.  Typically, this
 chapter addresses the  impact of  each of the control options
 presented  in Chapter 3.  However, as discussed in Chapters 1 and
 5,  the presumptive norm  for  RACT for the wood furniture industry
 was developed through  a  negotiation process.  Although options
 other than those agreed  upon by  the regulatory negotiation
 committee  were discussed during  the negotiation process,  a
 detailed analysis of the impacts of those options was not
 prepared.   Therefore,  this chapter  will focus on the impacts of
 the RACT requirements  agreed upon by the Committee.
     The EPA recognizes  the  need for States to have information
 on  other control options and their  impacts.  The costs presented
 in  this chapter are extrapolated from the costs developed for an
 earlier draft version  of the  CTG and a report prepared by the
 industry that addressed  options  for controlling VOC emissions
 from wood  furniture finishing operations and the costs of those
 options.1'2  Both the  earlier version of the draft CTG and the
 industry report were begun before the industry and EPA agreed to
 negotiate  the recommended RACT requirements.  Therefore,   both
 contain costs for other control  options, although they are based
 on different model plants than the model plants presented in
 Chapter 4.
     Section 6.1 of this chapter discusses the cost associated
with each of the elements of the presumptive RACT requirements.
Section 6.2 presents the total cost of meeting the presumptive
RACT requirements by model plant, and Section 6.3 presents the
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nationwide  costs and  emission  reductions for facilities  in
nonattainment areas and  the  ozone transport region.  Section 6.4
presents  the environmental and energy impacts of the presumptive
RACT  requirements on  the industry.  Section 6.5 presents the
costs of  other control options based on data from EPA's earlier
version of  the draft  CTG and industry's report.  Section 6.6
presents  a  listing of the chapter references.
6.1   COST OF THE RECOMMENDED RACT OPTIONS
      As discussed in  Chapter 5, the RACT options agreed to by the
Committee include limitations  on the VOC content of the coatings
that  are  used, a set  of  work practice standards which include
restrictions on the type of  application equipment that can be
used, and other practices to reduce emissions from finishing,
cleaning, and washoff operations.  This section will discuss the
costs associated with each of  these requirements.
6.1.1  Limitation on  VOC Content of Coatings
      There  are two technologies that the industry can use to meet
the RACT  requirements for coatings.  A facility may choose to use
(l) waterborne topcoats  (or  other topcoats with a VOC content
less  than or equal to the limit for waterborne topcoats), or
(2) higher  solids sealers and  topcoats.   The costs to the
facility  will vary according to the technology presently being
used as well as the technology they choose to use to comply with
RACT.
     One  characteristic  common to both of the RACT coating
options presented here,  and  to most lower VOC coating systems,  is
that the  coatings have a higher solids content than conventional
solventborne coatings.   In instances where the quantity of solids
applied to  the piece  (the build) determines how much coating is
used, an  increase in  solids content results in a decrease in
coating usage.   This  is the case with filler,  sealer,  and topcoat
materials.  In instances where the degree of color penetration
(rather than build)  determines how much coating is used, a higher
solids content does not automatically result in decreased coating
usage.  This is the case with stains,  washcoat,  and highlight
materials.  In general,  a facility switching to coatings that
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 meet either of the RACT options will decrease their annual
   t
 coating usage.
      Following is a discussion of the costs associated with each
 of the RACT options for coatings.  All costs are presented in
 1991 dollars.
      6.1.1.1  Higher Solids Sealer and Topcoat.   The only
 quantifiable cost to the industry for converting to higher solids
 sealers and topcoats is an increase in coating cost.   In
 developing the costs for higher solids sealers and topcoats,  it
 was  assumed that the cost of the coating  increases as the solids
 content increases.   Based on information  collected by EPA in
 developing the Automotive Plastic Parts CTG,  the cost of the
 higher solids  coating is equivalent to the  ratio of the solids
 content of the higher solids coating to the baseline  coating,
 plus 20 percent,  multiplied by the cost of  the baseline coating.3
 For  example, if the baseline coating contains  2  Ib solids/gal and
 the  higher solids coating contains 4 Ib solids/gal,  then the cost
 of the higher  solids coating will be 2.2  times the price of  the
 baseline coating.   Because a facility will  use 50  percent less  of
 the  higher solids coating,  the net effect is a 20  percent
 increase in coating cost.   There  may be other  costs associated
 with the use of higher solids  sealers and topcoats that  can  not
 be quantified,  such as increased  drying time.  An  increase in
 drying time would require  modification of finishing lines and
 would lower productivity  in terms  of  units produced in a given
 period of time.
      6.1.1.2  Waterborne Topcoats.  Although facilities  may meet
 the  0.8  Ib VOC/lb solids limitation on topcoats using
 technologies other  than waterborne coatings, the costs associated
with meeting the limit are based on facilities converting to
waterborne topcoats.  There are four major components included  in
the cost  of converting to waterborne  coatings  including  an
increase  in coating cost,  increased drying capability,
modifications to existing paint circulation systems, and material
storage.   The cost of each of these components is discussed in
detail in  the following paragraphs.
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      6.1.1.2.1   Coating  costs.  Facilities converting to
waterborne  topcoats will use approximately 20 percent less
coating  than baseline, due  to the higher solids content of these
waterborne  coatings.  However, there is still a net increase in
coating  cost because waterborne coatings cost more per gallon
than  the conventional solventborne coatings.  According to the
report prepared  by industry, the average cost of all conventional
solventborne coatings used  by the industry is $7.50 per gallon
while the average cost for  waterborne coatings is $13.00 per
gallon.4 In calculating the cost of converting to waterborne
topcoats, the cost of the waterborne topcoats was assumed to be
$13.00 per  gallon and the cost of all other coatings was assumed
to be $7.50 per  gallon.
     6.1.1.2.2   Additional  drying capability.  Based on input
from coating material suppliers, the use of waterborne coatings
will require increased drying time, unless process modifications
are made.   These modifications may include additional ovens,
increases in airflow rate,  decreases in line speed, or increases
in conveyor length.  For the purposes of this analysis,  it was
assumed  that increased drying requirements will be met by the
addition of drying ovens.
     According to vendor information, if a wood furniture
manufacturer were to replace an oven, or obtain an additional
oven,  they  would most likely purchase a turbolator oven.5'6'7
These types of ovens offer a higher airflow rate than
conventional convection ovens:   566 cubic meters per minute
(m3/min)   [20,000 cubic feet per minute (ft3/min)]  compared to
85 rrrVmin (3,000 ft3/min) for conventional ovens.   This higher
airflow  rate translates into increased drying capability.  The
vendors  estimated the total installed capital cost of a new
20 foot  turbolator oven at  $48,600.  A facility's operating costs
will also increase with the addition of new ovens.  Annual fuel
and electricity  costs for a turbolator oven are approximately
$3,500 per  oven.
     In  developing costs it was assumed that a new oven was
required for all waterborne topcoat steps.   -For example,
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 facilities in the long spray model plant type,  model  plants 4,  5,
 and 6,  have three topcoat applications,  so it was  assumed that
 they will need three new ovens.   If a model plant  has multiple
 lines,  as do model plants 5 and  6,  then  an oven is needed for
 each topcoat application on each line.   The exception to this is
 for the model plants representing the very small facilities,  for
 example,  model plant 4a.   It was assumed that these facilities
 will only need one oven because  they do  not have tow  lines or
 conveyors.   Pieces are rolled into the spray booths on carts,
 finished,  and then manually moved to the next spray booth.
 Multiple applications of  the same coating step are often made in
 the same booth.   Therefore,  facilities in these model plants  are
 likely  to apply one topcoat step,  place  the piece  in  the oven to
 be  dried,  apply the next  topcoat step, and place the  piece back
 in  the  same oven.
      6.1.1.2.3   Paint circulation systems.   Facilities using
 waterborne  coatings need  to use  passivated stainless  steel
 delivery systems and mix  tanks.   In developing  the  cost of  the
 required systems it was assumed  that the very small and small
 model plants  pump their coating  materials  directly  from a drum
 (located at the  spray booth)  to  the spray gun,  that is,  they do
 not  have  a  central  mix room.   For the medium and large model
 plants  it was assumed that a  central pump  room  is used to supply
 all  coating materials  to  the  spray  booths.   For  costing  purposes,
 each booth  is assumed to be an average of  200 feet from the mix
 room.8
     For  the very small and small model plants to use waterborne
 topcoats, the equipment used  to  transfer the  coatings  from the
drum to the spray gun must be  stainless steel.   For these plants
a modular passivated stainless steel paint delivery system is
necessary.  The  components of this  system  include the following:
     - stainless steel storage drum;
     - fluid pump;
     - drum cover elevator assembly;
     - fluid regulator;
     - fluid filter/strainer;
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      - fluid and air hoses;
      - valves; and
      - oil/water extractor for air supply.
      Based on an average of vendor costs, the above modular
stainless steel system has an estimated total installed capital
cost  of $9,100 per unit.9'11  The 55 gallon stainless steel drum
from  which the coating material is pumped was assumed to be
provided by the coating supplier.
      For medium and large facilities, new passivated stainless
steel paint circulation systems are necessary.  Modifications are
required in the mix room, at the spray booths, and with the
material transfer lines.  Changes in the mix room are required to
accommodate waterborae coating material storage and agitation of
the material, and for pumping and regulating coating materials.
Based on vendor information,  the following components are
required in the mix room:
      - stainless steel mix tank;
      - fluid pump;
      - agitator and lid assembly;
      - hoses, regulators;
      - back pressure valve with gauge; and
      - filter/valves (to isolate filter)
     Based on an average of costs supplied by vendors,  the
estimated installed capital cost of the mix tank is $25,600 and
the total installed capital cost of the mix tank assembly
(agitator, pumps,  valves, hoses) is $8,800.9"11  In developing
model plant costs, it was assumed that one mix tank and mix tank
assembly was required for each finishing line.
     Equipment modifications  are also required at the spray booth
if waterborne coatings are used.  For medium and large
facilities,  the following stainless steel equipment will be
required at each spray booth:
      - fluid valves;
      - fluid regulator;
     - fluid hose to gun;
     - paint heater;
                               6-6

-------
      -  air hose;  and
      -  oil/water extractor for air supply.
      Based on an average of cost information supplied by vendors,
 the total installed capital cost of the above equipment,  except
 for the paint heater,  is $1,400.9'10  The paint  heater is
 supplied separately at a total installed capital cost of $1,850.
 The above equipment is required at each booth using waterborne
 coatings.
      In addition  to mix room and spray booth equipment,  the
 material transfer lines circulating between  the  mix room and
 spray booths would also need to be passivated stainless  steel.
 Based on information supplied by vendors, the installed  capital
 cost of stainless steel piping (304 grade or better)  suitable for
 transferring coatings  is estimated as  $20/foot pipe.12'13
      6.1.1.2.4 Material storage.   According to  industry
 representatives and furniture manufacturers,  conventional
 solventborne coating material storage  procedures vary according
 to  the  size  of the facility.14"21  Based on  the  information
 supplied by  these sources,  facilities  in the very small  and  small
 model plants are  assumed to store all  coating materials  in
 55-gallon  drums.   Medium and large facilities store their color
 coats (stains, glazes,  and  highlights)  in 55-gallon drums, but
 they store their  solventborne clear  coats (washcoat,  sealer, and
 topcoat) in  bulk  tanks  outside.
     A very  small  or small  facility  converting to waterborne
 topcoats will  not  have  to change  their  storage procedures.  The
 coatings will  continue  to be  stored  in  the containers  in which
 they are shipped.  However, a medium or large  facility converting
 to waterborne  topcoats  will have to  change their storage
procedures.  Waterborne  coatings are susceptible to freezing so
 they can not be stored  outside unless they are in a heated
building.  They are also more susceptible to contamination,  so
bulk storage is risky.   Therefore, in developing costs, it was
assumed that medium and large facilities converting to waterborne
topcoats will have to purchase a 2-hour fire-rated building to
store drums of waterborne coatings.
                               6-7

-------
     The total installed capital cost of the storage facilities
is a function of the quantity of material to be stored.  These
costs were provided by vendors on a per drum basis.   24  Based
on an average of costs provided by vendors, it was estimated that
the installed capital cost of waterborne material storage is
$380 per drum.  The number of drums requiring storage was
calculated for each model plant using the total amount of
waterborne topcoat used by the model plant per year and assuming
a monthly turnover rate.  To allow for increased production, it
was assumed that the building will be large enough to hold a
20 percent excess in capacity.
6.1.2  Application Equipment Requirements
     There are three cost components associated with the
application equipment requirements.  These are the cost savings
resulting from the decrease in coating usage,  the capital costs
of the application equipment, and an increase in labor costs for
some plants.
     As discussed in Chapter 5,  presumptive RACT will require the
industry to use application technologies other than conventional
air spray.   Conventional air spray can only be used for the
limited circumstances discussed in Chapter 5.   The presumptive
RACT requirements do not mandate the application technology to be
used.   Airless,  air assisted airless,  high volume low pressure
(HVLP),  electrostatic,  dipping,  and roll/curtain coating are all
application technologies that can be used.   Most facilities are
expected to move to HVLP application equipment to meet the
requirements because it is generally considered to be more
efficient than the other spray technologies,  and it is not as
limited in the applications for which it can be used as other
technologies such as roll/curtain coating.  5  Therefore, the
costs of the application equipment requirements are based on the
industry switching to HVLP application equipment.
     It is difficult to measure transfer efficiency because there
are so many factors in addition to the type of application
equipment that are involved.   Therefore,  it is difficult to
assign a percentage reduction in coating usage resulting from a
                               6-8

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 change in application technology.   The  industry  report assigned a
 26 percent reduction in coating usage for  facilities  switching
 from conventional air to HVLP equipment.25 The  Pacific Northwest
 Pollution Prevention Research Center sponsored a testing program
 for evaluating the transfer efficiency  of  different types  of
 application equipment under various scenarios.   This  report
 showed that the difference in transfer  efficiency between  HVLP
 and conventional air ranged from 0  percent to  more than
 30 percent.26   In evaluating the cost of a facility changing from
 conventional air to HVLP application technology, it was assumed
 that coating usage will decrease 10 percent.
      According to information supplied  by  vendors, the average
                                            *)H 9 ft
 cost of an HVLP spray gun is $400 installed.   '  °  In calculating
 the cost  to the industry it was  assumed that two guns will be
 purchased for  each spray booth.  The exception is for facilities
 using waterborne topcoats.   As discussed in Chapter 5, the
 Committee agreed to exempt these coatings,  and others with a VOC
 content less than 1 kg VOC/kg solids (1 Ib VOC/lb solids), from
 the application equipment requirement.  Therefore, facilities
 that convert to waterborne topcoats to meet the coating
 requirements of RACT will not have  to switch to other application
 technologies to apply those coatings.
      In addition to the capital  cost of the application
 equipment,  a facility may need additional  spray booth operators
 to  apply  some  coatings with HVLP application equipment.  High
 volume  low pressure spray guns have a slower delivery rate than
 conventional air guns.   This  slower delivery rate can be a
 problem when applying stains  because they are formulated with
 faster  evaporating  solvents.  To overcome  this problem, a
 facility may need an  additional operator for the stain booths.
 In developing  the costs  associated with a  facility switching to
HVLP spray  equipment,  it  was  assumed that all medium and large
 facilities will  require  two additional spray booth operators for
the stain booths.   It was assumed that smaller facilities  will
not require  additional operators because many of these facilities
                               6-9

-------
do not have tow lines and those that do typically move at lower
speeds than the lines at medium and large facilities.
6.1.3  Work Practice Standards
     The Committee agreed to a number of work practice standards
to reduce VOC emissions from finishing, cleaning, and washoff
operations.  While it is assumed that these work, practice
standards will result in a decrease in coating, cleaning, and
washoff solvent usage and will likely result in an overall
savings to the facility, there is not enough data available to
quantify either the reduction in emissions or costs associated
with most of these standards.  The exception is for the operator
training requirements.  Following is a discussion of the costs
associated with these requirements.
     As with the application equipment requirements, the
reduction in coating usage that can be achieved by training spray
booth operators and other employees that use solvent is difficult
to quantify.  However, the report from the Pacific Northwest
Pollution Prevention Research Center shows that well trained
spray booth operators can achieve higher transfer efficiencies
with comparable spray equipment.26  The Center compared the
transfer efficiency achieved by expert painters with that
achieved by novice painters.  In almost every case,  the expert
painter achieved a higher transfer efficiency using the same
equipment, with the difference ranging from 0 percent to almost
30 percent.  For this analysis,  it was assumed that spray booth
operator training will result in a 5 percent decrease in coating
usage,  which will decrease the facility's coating costs.
     While there will be a decrease in coating usage and costs
due to the operator training requirements,  there will be some
labor costs associated with the requirements.  For this analysis,
it was assumed that 50 percent of the employees at a facility
will need to be trained, (except for upholstery plants where only
25 percent are assumed to require training),  and each of these
employees will require 8 hours of training per year.  It was
assumed that only 50 percent of the employees will require
training because many of the employees at a wood furniture
                              6-10

-------
 manufacturing facility are involved in assembly operations or
 provide clerical support.  These employees do not use solvents
 and will not require training.   While new employees may require
 more than 8 hours of training,  it was assumed that these
 employees already receive some  basic training so no more than an
 additional 8 hours of training  will be required.
      For facilities represented by the roll/curtain coat model
 plants,  it was assumed that there will be no reduction in coating
 usage from the operator training requirements because these
 facilities do not use spray application equipment.   However,
 employees in these facilities will still have to be trained
 because they handle coatings and solvents.   The training
 requirements will reduce emissions,  but the reduction has not
 been estimated because of a lack of available data.   In
 estimating the costs of training,  it was assumed that 50 percent
 of  the  employees at these facilities will have to be trained,  but
 the training will be less comprehensive than training at other
 facilities and will only require 4 hours per year.
 6.2  MODEL PLANT COSTS
      The  first step in evaluating the costs of the  presumptive
 RACT requirements by model plant is  to determine which option
 each model plant type is likely  to use to meet the  VOC content
 limitations on the coatings.  As discussed  earlier  and in
 Chapter 5,  a facility can choose to  use  topcoats with a VOC
 content less than 0.8 kg VOC/kg  solids (0.8  Ib VOC/lb solids)  to
 meet  the  presumptive RACT requirements for  coatings  or they may
 choose to use  higher solids  sealers  and  topcoats with VOC
 contents  less  than or equal  to 1.9 and 1.8  kg  VOC/kg  solids
 (1.9  and  1.8  Ib  VOC/lb solids),   respectively.  For  facilities
 using conversion varnishes and vinyl  sealers the limits  are
 2.0 and 2.3  kg VOC/kg solids  (2.0  and 2.3 Ib VOC/lb  solids),
 respectively.  Although each  facility subject  to the  presumptive
RACT  requirements  can choose  the approach best suited to their
product requirements,  it  is expected  that some types  of
facilities are more  likely to choose  to use waterborne  topcoats
and some are more  likely  to choose higher solids  sealers  and
                              6-11

-------
topcoats.  In developing the model plant costs, it was assumed
that some model plant types will use waterborne topcoats to meet
the presumptive RACT requirements for coatings and some will use
higher solids sealers and topcoats to meet the requirements.
     In developing the cost of the VOC limitation on coatings by
model plant, it was assumed that facilities in the short spray,
roll/curtain coat, and kitchen cabinet model plant types will use
higher solids sealers and topcoats to meet the PACT requirements.
The majority of kitchen cabinet manufacturers already use vinyl
sealers and conversion varnishes so it was assumed that they will
choose to meet the RACT requirements by using topcoats with a VOC
content less than or equal to 2.0 kg VOC/kg solids (2.0 Ib VOC/lb
solids) and sealers with a VOC content less than or equal to
2.3 kg VOC/kg solids (2.3 Ib VOC/lb solids).  The conversion
varnishes used by these facilities already meet the 2.0 kg VOC/kg
solids (2.0 Ib VOC/lb solids) limit, so the only cost and
emission reduction for these facilities resulting from-the
coating limitations will come from reformulating their sealers to
meet the 2.3 kg VOC/kg solids (2.3 Ib VOC/lb solids)  limit.
     Facilities in the roll/curtain coat model plants already use
sealers and topcoats that meet the higher solids limits of 1.8 kg
VOC/kg solids (1.8 Ib VOC/lb solids) for topcoats and 1.9 kg
VOC/kg solids (1.9 Ib VOC/lb solids) for sealers.   Therefore,
these facilities will incur no cost in meeting the VOC limits for
these coatings.
     Facilities in the short spray model plant type can choose to
meet the VOC limitation on coatings by using waterborne topcoats,
or their equivalent,  or higher solids sealers and topcoats.  In
developing costs,  it was assumed that these facilities will
choose to meet the RACT requirements for coatings by
reformulating to higher solids sealers and topcoats.   Many of the
facilities represented by the short spray model plant type
already use slightly higher solids coatings than those used by
the long spray facilities.   Manufacturers of office furniture and
public building furniture,  (SIC codes 2521 and 2531),  typically
use acid-catalyzed coatings that are higher in solids than the
                              6-12

-------
 conventional nitrocellulose lacquers used by much of the
 industry,  manufacturers of store fixtures use higher solids
 basecoats  and enamels.   These facilities need coatings  that are
 tougher and more resistant to chemicals and scratching,  and the
 higher solids coatings  provide these characteristics.   Therefore,
 it is likely that these facilities will meet the  presumptive RACT
 requirements for coatings by converting to higher solids
 coatings,  and the costs and emission reductions were calculated
 using this assumption.
      It was assumed that facilities represented by the  long spray
 and upholstered model plant types  will  choose to  use waterborne
 topcoats to meet the presumptive RACT requirements for  coatings.
 Several of the facilities manufacturing upholstered  furniture
 that responded to EPA's survey had already moved  to  waterborne
 coatings.   These facilities are likely  to convert to waterborne
 coatings because they would not experience some of the  same
 problems of other facilities.   As  discussed earlier,  waterborne
 coatings dry more slowly than  solventborne coatings.  This  slower
 drying  is  less likely to be a  problem in facilities  manufacturing
 upholstered furniture because  many of these  facilities are  like
 small  facilities in that the pieces  to  be  finished are moved
 manually from booth to  booth,  rather than  on a tow line  or
 automated  conveyor.  Therefore,  the  additional drying time  that
 is  required for waterborne  coatings  is  not as much of a problem
 for upholstered furniture operations as  it  is for facilities with
 automated  lines.  Therefore, the costs  and emission  reductions
 for upholstered furniture facilities were  calculated assuming
 they switch to waterborne topcoats.
     Facilities  represented by  the long  spray model plant
 currently use  nitrocellulose sealers and topcoats that are  lower
 in  solids  than the  sealers  and  topcoats used by the other model
plant types.   Conversion to higher solids sealers and topcoats
may be more difficult for them  than for the model plant types
already using higher solids coatings.  In addition, the higher
solids coatings may not provide them with the required
aesthetics.  Therefore,  these facilities are expected to convert
                               6-13

-------
to waterborne  topcoats  to meet the presumptive RACT requirements/
and the  costs  and emission  reductions were calculated using this
assumption.
     Table  6-1 presents the costs for the model plants converting
to higher solids sealers and topcoats to meet the VOC limitation
on coatings.   Table  6-2 presents the costs for the model plants
converting  to  waterborne topcoats to meet the limits.  The total
annual costs and the cost effectiveness for each model plant are
presented in Table 6-3.
     The total capital  cost in Table 6-3 is based on the total
capital cost of HVLP guns,  total capital cost of additional
drying capacity, total  capital cost of the paint circulation
system, and total capital cost of coating material storage.  The
total annualized capital cost is based on a 10 year lifetime and
10 percent  interest.  The total operating cost is based on labor
cost, incremental annual coating cost, incremental fuel and
electric cost  for ovens, incremental disposal cost for waterborne
coatings, and  taxes, insurance, and administrative costs
(4 percent of  total  capital cost).  The total annual cost is the
sum of the total operating  cost and the total annualized capital
cost.  Costs to implement the presumptive RACT requirements for
the model plants range  from a cost savings of more than $900/Mg
to a cost of over $3,600/Mg.
6.3  NATIONWIDE IMPACTS OF  PRESUMPTIVE RACTS
     Nationwide cost impacts and emission reductions were
estimated for  the presumptive RACT options.   The CTG will only
apply to wood  furniture facilities located in ozone nonattainment
areas and in the ozone  transport region.   Therefore,  to calculate
nationwide cost impacts and emission reductions,  the total number
of facilities  located in nonattainment areas and the ozone
transport region was estimated.  In developing the distribution
of facilities  in nonattainment areas and the ozone transport
region, a relationship between the total number of employees and
the size of the facility was developed.   Table 6-4 presents the
distribution of plants by model plant number for plants in
nonattainment areas and the ozone transport  region.   This table
                               6-14

-------
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6-15

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    TABLE 6-2.   COST  BY  MODEL PLANT FOR PLANTS  CONVERTING TO
                            WATERBORNE TOPCOATS9"

Low-VOC coatina costs
Incremental annual coating
cost, $
Incremental disposal cost-
waterbome coatings, $
Total capital cost of additional
drying capacity, S
Incremental fuel and electric
cost for ovens, $
Total capital cost of paint
circulation system, $
Total capital cost of coating
material storage, $
Application equipment costs
Incremental annual coating
cost, $
Labor cost, $b
Total capital cost of HVLP
guns, $
Operator training costs
Incremental annual coating
cost, $
Labor cost, $°
Model plant
4a
11,056
632
48.600
3,470

9,100
0
(4,391)
0
5,184
(4,455)
5,375
4
26,060
1,489
145,800
10.410

27,300
0
(10,350)
0
6,048
(10,498)
12,447
5
75,416
4,309
291,600
20,820

121,044
17,100
(29,925)
141,400
14,688
(30,371)
26,591
6
110,559
6,317
291,600
20,820

121,044
25,080
(43,898)
141,400
14,668
(44,537)
42,432
10
21,640
1,078
48,600
3,470

9,100
0
(8.438)
0
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(7,410)
8.9H
aAll costs are presented in 1991 dollars.
"Includes operating labor at $8.50/hr, supervisory labor equivalent to 15 percent of operating labor at
 $17/hr, and overhead at 60 percent of total labor.
                                      6-16

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  TABLE  6-3.   MODEL  PLANT  CONTROL COSTS FOR  PRESUMPTIVE  RACT1
Model
plant
la
1
2
3
4a
4
5
6
7a
7
8
9
10
lla
11
12
13
Total capital
cost, $
3,456
3.456
7.776
7,776
62,884
179.148
444,432
452,412
0
0
0
0
60,292
2,592
2,592
5,184
5,184
Total
annualized
capital cost,
$b
492
492
1,107
1,107
8,955
25,511
63,287
64,423
0
0
0
0
8,586
369
369
738
738
Total
operating
cost, $/yr
5,103
11,765
95,114
109,835
14,202
36,724
226,057
251,230
2,687
6,223
13,295
21,216
21,663
(4,466)
(15,868)
30,718
17,387
Total ann11"!
cost, $/yr
5,595
12,257
96,221
110,942
23,157
62,234
289,344
315,653
2,687
6,223
13,295
21,216
30,221
(4,097)
(15,499)
31,456
18,126
Total VOC
reductions,
Mg/yr
18.1
36.2
108.3
158.2
11.7
27.6
79.8
117.1
0.0
0.0
0.0
0.0
19.1
5.8
17.2
42.4
66.0
Cost
effectiveness,
S/Mg
309
337
887
701
1,979
2,255
3,626
2,6%
N/A
N/A
N/A
N/A
1.584
(706)
(901)
742
275
aAH costs are presented in 1991 dollars.
 Annualized capital cost based on a 10 year lifetime and 10 percent interest (a capital recovery
 factor = 0.1424).
                                      6-17

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 was developed using the distribution of  facilities  in  EPA's  data
 bafee,  the 1987 Census of Manufactures data base  that provides
 information on plant location by county,  and  EPA's  1991  data base
 of  attainment and nonattainment areas.   Plants located in the
 ozone  transport region,  which includes the States of Connecticut,
 Delaware,  Maine,  Maryland,  Massachusetts,  New Hampshire,  New
 Jersey,  New York,  Pennsylvania,  Rhode Island, Vermont, and the
 consolidated metropolitan statistical area that  includes  the
 District of Columbia and some counties in Virginia  are also
 included in the table.
     The distribution of facilities  in Table  6-4 includes only
 those  facilities  that are considered to be large enough,  based on
 EPA's  survey of the industry,  to emit greater than  or  equal  to
 22.7 Mg  (25 tons)  of VOC's  per year.  As  discussed  in  Chapter 5,
 the Committee recommended that RACT  be applied to facilities that
 emit,  or have the  potential to emit,  greater  than or equal to
 22.7 Mg  (25 tons)  of VOC's  per year.  The  Committee recommended
 that an  exception  be made for facilities  located in extreme
 nonattainment areas.   For these  facilities, the Committee
 recommended that RACT be applied to  facilities that emit, greater
 than or  equal to 9.1 Mg  (10 tons) of  VOC's per year.
 6.3.1  Nationwide  Emission  Reductions
     Table  6-5  presents  baseline and  controlled VOC emissions by
 model plant for facilities  located in nonattainment areas and the
 ozone transport region.   Controlled emissions represent the  level
 of  emissions  after the application of the presumptive RACT
 requirements.   The  emission reductions achieved by the limitation
 on  the VOC  content  of the coatings assumes that some model plant
 types will  choose  to use higher  solids sealers and topcoats  to
meet the limitation, and some model plant types will choose  to
use waterborne  topcoats, or  their equivalent,  to meet the
 limitation.   In determining  the  emission reductions achieved by
 the coating VOC limitations, it was assumed that plants
represented by the short spray  (model plants la - 3),  roll/
curtain coat  (7a - 9), and kitchen cabinet (lla - 13)  model plant
types would convert to higher solids sealers and topcoats.
                               6-21

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      TABLE 6-5.  BASELINE AND CONTROLLED VOC EMISSIONS3-
Model
plant No.
la
l
2
3
4a
4
5
6
7a
7
8
9
10
lla
11
12
13
Total
Nationwide VOC
emissions
baseline --
total , Mg/yr
7,801
6,631
1,867
1,704
8,951
6,352
2,827
2,073
1,347
1,291
1,030
363
1,401
4,042
4,275
4,089
1,673
57,718
Nationwide VOC
emissions
controlled- -
total , Mg/yr
4,179
3,544
999
910
5,911
4,194
1,867
1,369
1,347
1,291
1,030
363
923
3,232
3,428
3,282
1,342
39,213
Nationwide
reductions in
VOC emissions
from baseline,
Mg/yr
3,622
3,087
868
794
3,040
2,158
960
704
0
0
0
0
478
810
847
807
331
18,505 '
aEmissions correspond to those plants located in ozone
 nonattainment areas and transport regions.  Controlled
 emissions represent those after the application of
 presumptive RACT.
                             6-22

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 Further,  it was  assumed that  plants  represented by the long  spray
 (model  plants  4a -  6),  and upholstered  (model plant 10) model
 plant types would convert  to  waterborne  topcoats.   These are the
 same assumptions that were used in developing the  costs for  each
 model plant.   The basis for these  assumptions was  discussed  in
 Section 6.2.
     As shown  in Table  6-5, the presumptive norm for RACT will
 reduce  VOC  emissions from  major sources  in nonattainment areas
 and the ozone  transport region  by  18,505 Mg  (20,335 tons).
 Additional  reductions may  be  achieved by application of the  work
 practice standards, but these potential  reductions,  with the
 exception of reductions associated with  the application equipment
 and operator training requirements,  have not been  estimated  for
 the reasons discussed in Section 6.1.3.
 6^3.2   Nationwide Costs
     Table  6-6 presents the nationwide costs and cost
 effectiveness  of  implementing the  presumptive RACT requirements
 to sources  that  are expected  to be subject to RACT located in
 nonattainment  areas and the ozone  transport region.  These costs
 were calculated using the  total  annual costs by model plant
 presented in Table 6-3  and the  distribution of plants by model
 plant presented  in Table 6-4.   The cost of implementing the
 recommended RACT  requirements to all affected sources in the wood
 furniture industry is $20,156,609  and the cost effectiveness is
 $l,089/Mg.
 6.4  ENVIRONMENTAL AND  ENERGY IMPACTS
     There  are a  number of potential environmental and energy
 impacts associated with the recommended RACT requirements.
 Environmental impacts,   including effects on air and water
quality,  as well  as hazardous wastes, are discussed in
Section 6.4.1.   The energy impacts of the recommended RACT
requirements are presented in Section 6.4.2,  and other
environmental impacts are discussed in Section 6.4.3.
6.4.1  Environmental Impacts
     6.4.1.1  Air Quality Impacts.   As discussed in
Section 6.3.1,  the application of presumptive RACT by source
                              6-23

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  TABLE  6-6.  NATIONWIDE CONTROL COSTS FOR PRESUMPTIVE RACT3-
Model
plant No .
la
1
2
3
4a
4
5
6
7a
7
8
9
10
lla
11
12
13
Total
Nationwide
control cost,
$
1,119,000
1,041,845
769,768
554,710
5,997,663
4,854,252
3,472,128
1,893,918
126,289
124,460
66,475
21,216
755,525
(569,483)
(759,451)
597,664
90,630
20,156,609
Nationwide
reduction in
VOC emissions,
Mg/yr
3,622
3,087
868
794
3,040
2,158
960
704
0
, 0
0
0
478
810
847
807
331
18,505
Cost
effectiveness ,
$/Mg
309
337
888
701
1,979
2,255
3,626
2,696
N/A
N/A
N/A
N/A
1,584
(706)
(901)
742
275
1,089
aCosts and emission reductions correspond to applying
 presumptive RACT to those facilities in ozone nonattainment
 areas and transport regions.  All costs are presented in
 1991 dollars.  Numbers in parentheses indicate a net
 savings.
                             6-24

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 facilities in nonattainment areas and the ozone transport region
 will  reduce VOC emissions from the industry by 18,505 Mg/yr
 (20,335  tons/yr)  from the estimated baseline value  of
 57,718 Mg/yr (65,426 tons/yr).   The estimated  reductions  include
 reductions associated with the work practice standards and the
 coating  emission limits.
      As  discussed in Chapter 1,  the EPA has developed a NESHAP
 for the  wood furniture industry and the requirements for  both the
 CTG and  NESHAP were negotiated by the Committee.  Because the
 work  practice standards and the application equipment
 requirements are part of  both the presumptive  RACT  requirements
 and the  NESHAP,  for most  model  plants,  the  RACT requirements will
 not result in HAP emission reductions in  addition to those
 achieved by the NESHAP.   However,  the NESHAP will not apply to
 most  of  the very small plants  (represented  by  model plants la,
 4a, 7a,  and lla),  although these plants.will be subject to RACT.
 Therefore,  the presumptive RACT requirements will also reduce HAP
 emissions  from these plants.
      The limitation on the VOC  content  of the  coatings may result
 in some  decrease  in HAP emissions  but  the decrease can not be
 quantified.   The  majority of the HAP  that will  be regulated by
 the NESHAP are VOC.   The  NESHAP  limits  the  HAP  content of  the
 stains,  washcoats,  sealers, and  topcoats to 1.0 kg organic HAP/kg
 solids (1  Ib organic HAP/lb solids).  Therefore, facilities
 converting to waterborne  topcoats, which have a VOC limit  of
 0.8 kg VOC/kg solids (0.8  Ib VOC/lb solids) (which is equivalent
 to no more than 0.8  kg organic HAP/kg solids (0.8 Ib organic
HAP/lb solids)), will  be decreasing their HAP emissions from
their topcoats by at  least  20 percent more  than required by the
NESHAP.  Smaller  facilities not  covered by  the NESHAP that are
subject  to RACT and  choose  to convert to waterborne topcoats will
likely reduce  their  HAP emissions  from topcoats substantially.
Total HAP  emissions  from facilities converting to higher solids
sealers and  topcoats will likely decrease.
     6.4.1.2  Water Quality Impacts.  No adverse water pollution
impacts are  expected to result from the implementation of  the
                               6-25

-------
presumptive RACT requirements.  For this analysis, it was assumed
that a constantly recirculating coating delivery system will be
used with waterborne coatings.  Thus, the use of waterborne
coatings is not expected to increase flushing of the lines and
will therefore not result in increased wastewater.
     6.4.1.3  Hazardous Waste.  Both solid and liquid hazardous
waste are generated at most wood furniture manufacturing
facilities.  The dry filters used to collect coating overspray
account for the majority of the solid hazardous waste generated.
Although the solids content of lower-VOC coatings is higher, less
of the coating is used, so the frequency of changing these dry
filters is not expected to change if lower-VOC coatings are used.
     The liquid hazardous waste generated by a wood furniture
facility consists primarily of spent solvent and coatings.  The
work practice standards should reduce the amount of solvent used
and the application equipment requirements should reduce the
amount of coating used, so the presumptive RACT requirements
should result in a decrease in liquid hazardous waste.
6.4.2  Energy Impacts
     The additional ovens required for facilities converting to
waterborne topcoats will result in an increase in both
electricity and natural gas use.   The increase in energy usage
associated with the conversion to waterborne topcoats is
summarized in Table 6-7.

             TABLE 6-7.  ENERGY USE ASSOCIATED WITH
                     WATERBORNE TOPCOATS5"7
Model plant
No.
4a
4
5
6
10
Increase in
natural gas
usage, MMBtu/yr
181,300
163,800
50,400
25,200
17,500
Increase in
electricity
usage, kWh/yr
3,108
2,808
864
432
300
                              6-26

-------
 6.4.3  Other Environmental Impacts
  »    The use of waterborne coatings and higher solids coatings
 will reduce worker exposure to organic solvents.   The worker
 training requirements and work practice requirements such as
 closed containers and the limit on the amount  of  solvent used for
 spray booth cleaning should also reduce solvent usage and worker
 exposure.
      Facilities may choose to use polyester or polyurethane
 coatings that meet the VOC content limitations for higher solids
 topcoats.   These coatings contain small amounts of isocyanates,
 so  additional safety procedures may be required.   If the
 appropriate precautions are taken,  no  additional  risk to the
 worker is  expected to result.
      The presumptive RACT requirements require facilities to
 purchase additional equipment.   This is considered an
 irreversible and irretrievable  commitment of resources.
 Manufacturing stainless steel paint circulation lines, storage
 tanks,  and ovens will consume steel and other  raw materials.
 However, compared to the current  level  of use  of  these materials
 by  the industry,  this increase  in consumption  is  not  considered
 significant.
 6.5   IMPACTS  OF OTHER CONTROL OPTIONS
      As  discussed earlier,  this  chapter of a typical  CTG
 addresses  the impacts,  both environmental and  cost, of a  number
 of  control  options.   These  impacts  are  then used  in making  a
 determination of  RACT for the industry.  In addition  to
 evaluating  the impacts  of a number  of options  in  order to make a
 determination of  what the EPA believes  is RACT, the analysis of
 several  options provides  States with guidance  they can use  in
 writing  their own rules.  For example,  a particular State may
 decide that the presumptive norm  for RACT does not result in
 sufficient emission  reduction from plants in that State.   If an
 analysis of more  stringent  options has been conducted by  EPA in
 developing the CTG,  the State can use this analysis to develop a
more stringent rule.
                               6-27

-------
     In this  case, however, the presumptive RACT requirements
were developed through a negotiation process.  During the
negotiation,  several other options besides those finally chosen
were discussed, but a complete analysis of the impacts of those
options was not conducted.  While Chapter 3 provides a detailed
discussion of the available control options for the wood
furniture industry, it does not address the industry impacts
associated with implementing those control options.
     Before beginning the negotiation of the presumptive norm for
RACT, the EPA had already begun development of a CTG for the wood
furniture industry.  Drafts of several of the chapters,  including
the cost chapter, had already been completed.  The cost chapter
in the earlier draft CTG evaluated the impacts of many of the
control options discussed in Chapter 3.  While EPA was developing
the CTG, the industry developed their own report that evaluated
the impacts of control options for reducing VOC emissions from
the industry.  Both the earlier draft CTG and the industry report
addressed some of the same control options.  The CTG evaluated
the impacts of add-on controls, hybrid and full waterborne
coating systems.  The industry report also evaluated the impacts
of add-on controls and hybrid and full waterborne coating
systems.
     In order to provide States with some guidance on the
potential impacts of control options other than those selected by
the Committee as the presumptive norm for RACT,  a summary of the
impacts of these three additional control options is presented
here.  The summary includes both the EPA's estimate of the
impacts, as presented in the earlier draft version of the CTG,
and industry's estimate of the impacts, as presented in their
report.  In evaluating the summary of the impacts presented here,
the reviewer should note that the model plants used in developing
the impacts for both the earlier version of the draft CTG and the
industry report are different than the model plants presented in
Chapter 4.  A summary of the model plants contained in the
industry report is presented in Table 6-8.  Table 6-9 presents a
summary of the model plants from the earlier version of the draft
                               6-28

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TABLE 6-9.  EARLIER DRAFT CTG MODEL PLANTS1
Model
plant No.
1
2
3
4
5
6
7
8
9
10
11
Type of product
Residential furniture
Residential furniture
Residential furniture
Residential furniture
Residential furniture
Residential furniture
Office furniture and
kitchen cabinets
Office furniture and
idtchen cabinets
Office furniture and
Idtchen cabinets
Office furniture and
idtchen cabinets
Office furniture and
dtchen cabinets
No. of
employees
<100
100-249
>249
<100
100-249
>249
<100
100-249
>249
100-249
>249
No. of
finishing
steps
6
6
6
10
10
10
3
3
3
3
3
Type of topcoat
Nitrocellulose lacquer
Nitrocellulose lacquer
Nitrocellulose lacquer
Nitrocellulose lacquer
Nitrocellulose lacquer
Nitrocellulose lacquer
Catalyzed
Catalyzed
Catalyzed
Catalyzed
Catalyzed
VOC
emissions
from
finishing,
Mg/yr
45
204
454
45
204
454
45
204
454
204
454
                   6-30

-------
 CTG.   The model plants presented in Chapter 4 are based on some
 of the model plants presented in the industry report,  but they
 are scaled to represent a range of facility sizes.  The model
 plants developed for the earlier version of the draft  CTG are
 similar to the model plants presented in Chapter 4,  so a
 comparison of the impacts is reasonable.
      The cost information from the earlier draft CTG and the
 industry report is presented for informational purposes.
 However,  a direct comparison of the costs from the earlier draft
 CTG and the industry report must be done cautiously.   First,  the
 model plants evaluated in the two reports were slightly different
 (as can be seen by comparing Tables 6-8  and 6-9}.   For purposes
 of this section,  costs for "equivalent"  model plants are
 presented,  but it is important to note that model  plants  in the
 two reports are not identical and that judgment was used  in
 determining "equivalent"  model plants.   Secondly,  the  assumptions
 made  in estimating the costs associated  with the use of add-on
 controls  and reformulated coatings were  different  in the  two
 reports.   These differing assumptions  led to different estimates
 of costs.   Only total  estimated costs  and emission reductions  are
 presented in this section;  a detailed  discussion of the
 assumptions used in developing the costs is  not provided.   For
 additional  information concerning the  development  of these  costs,
 the reader  is  referenced  to the earlier  draft  CTG, the industry
 report. Appendix C,  and a memorandum comparing the two
 reports.1'2'29
 6.5.1   Hybrid Waterborne
     Both the earlier  draft version of the CTG and the  industry
 report  evaluated  the impacts of  the industry converting to  a
 hybrid  waterborne  coating system.   The number  of coating steps  in
 a  hybrid  waterborne  system  that  are waterborne  depends upon the
 finishing sequence.  For  example,  for a  short  finishing sequence
 (stain, sealer, and  topcoat)  the  sealer  and topcoat are
waterborne  coatings.   For a long  finishing sequence (stain,
washcoat, filler, glaze,  sealer, and multiple topcoat
applications) all coating steps after the washcoat are
                               6-31

-------
waterborne.  The  industry  report and the earlier draft version of
the CTG both indicated  that hybrid waterborne was technically
feasible for all  of their  model plants.  Table 6-10 presents the
emission reduction and  cost effectiveness for hybrid waterborne
systems for both  the industry and earlier draft CTG model plants.
As shown in the table,  a hybrid waterborne system can reduce
emissions by 28 to 85 percent at a cost effectiveness ranging
from a cost savings of  $521/Mg to a cost of almost $13,000/Mg.
6.5.2  Full Waterborne
     In a full waterborne  coating system, all coatings are
waterborne coatings.  The  earlier draft CTG and the industry
report agree that a full waterborne coating system is not
technically feasible for all model plants.  The earlier draft CTG
indicates that a  full waterborne system is not technically
feasible for facilities manufacturing residential furniture with
a long finishing  sequence.  According to the industry report, a
full waterborne system  is  technically feasible only for model
plants representing facilities with short finishing sequences.
Two of the industry model  plants with short finishing sequences
represent facilities that  finish and then assemble their
furniture,  and two represent facilities that manufacture
miscellaneous wood parts and products.
     Table 6-11 presents the emission reduction and cost
effectiveness for a full waterborne system for the model plants
in the industry report and the earlier draft CTG' for which the
technology was considered  feasible.   As shown in the table, the
emission reduction from a  full waterborne system ranges from
60 to 93 percent,  with a cost effectiveness ranging from
$2,lOO/Mg to more than $9,500/Mg.
6.5.3  Add-On Controls
     As discussed in Chapter 3,  there are several types of add-on
control devices that can be used by the industry to reduce VOC
emissions from coating operations.   These include recuperative
thermal incinerators,  regenerative thermal incinerators,
fixed-bed catalytic incinerators,  fluidized-bed catalytic
incinerators,  and a combination of carbon adsorbers and
                              6-32

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6-33

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 incinerators.   The  industry  report  evaluated the  feasibility and
 impacts  of  each of  these  options, and  concluded that add-on
 control  devices were  technically feasible for each of their model
 plants.  The earlier  draft version  of  the CTG also evaluated the
 feasibility and impacts of a number of add-on control devices.
 including recuperative and regenerative thermal incinerators,
 catalytic incinerators, and  a combination of carbon adsorbers and
 thermal  incinerators.  The earlier  draft CTG also concluded that
 add-on controls  were  technically feasible for each of their model
 plants,  although, as  in the  industry report, some types of add-on
 controls were not considered feasible  for some model plants.
     Table  6-12  presents  the emission  reduction and cost
 effectiveness for add-on  control devices taken from the industry
 report and  earlier draft  CTG.  The values presented represent the
most cost effective add-on control device for each model plant.
As shown in the  table, the emission reduction achieved by add-on
controls ranges  from 67 to 98 percent,  and the cost effectiveness
ranges from $527/Mg to more than $25,000/Mg.
                              6-35

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6-36

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 6.6   REFERENCES  FOR CHAPTER 6
  1.   Control  of  VOC Emissions  from Wood Furniture  Coating
      Operations  -  Draft  Chapters  1 -  5  of  Control  Techniques
      Guideline.  U.  S. Environmental  Protection Agency.   Research
      Triangle Park,  NC.   October  1991.

  2.   ENSR Consulting and Engineering.   An  Evaluation  of VOC
      Emissions Control Technologies for the Wood Furniture and
      Cabinet  Industries.   Prepared for  the American Furniture
      Manufacturers Association, Business and Institutional
      Furniture Manufacturers Association,  Kitchen  Cabinet
      Manufacturers Association, and the National Paint and
      Coatings Association.  January 1992.

  3.   Alternative Control  Techniques Document:   Surface Coating of
      Automotive/Transportation and Business Machine Plastic
      Parts.   U,  S.  Environmental  Protection Agency, Research
      Triangle Park,  NC.   EPA 453\R-94-017.  February  1994.

  4.   Ref.  2,  pp. 7-3, 7-4.

  5.   Telecon.  Christie,  S., Midwest Research Institute,  with
      Miller,  D., George Koch & Sons, Inc^.  August  6,  1991.   Oven
      costs.

  6.   Telecon.  Christie,  S., Midwest Research Institute,  with
      Rhodes,  A., Rhodes Machinery.  August 6, 1991.   Oven costs.

  7.   Telecon.  Christie,  S., Midwest Research Institute,  with
      DiGibani, C., Binks  Manufacturing,   Inc.  August  6, 1991.
      Oven  costs.

  8.   Telecon.  Christie,   S., Midwest Research Institute,  with
      Runyan,  L., American Furniture Manufacturer's Association.
      July  29,  1991.  Stainless steel paint circulation systems.

  9.   Telecon.  Christie,  S., Midwest Research Institute,  with
      Moser, R., Binks Manufacturing.   August 12, 1991.  Stainless
      steel paint circulation systems.

10.   Letter and attachments from Daignault, C.,  Nordson
      Corporation, to Christie,  S., Midwest Research Institute.
     August 28, 1991.  Stainless steel paint circulation  systems.

11.  Telecon.  Christie,  S., Midwest Research Institute,  with
     Muir, G., Graco, Incorporated.  July 24,  1991.  Stainless
     steel paint circulation systems.

12.  Telecon.  Christie,  S., Midwest Research Institute,  with
     Oxler, W., U.  S. Engineering.  August 9,  1991.  Stainless
     steel paint circulation systems.
                              6-37

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13.  Telecon.   Caldwell, M. J., Midwest Research Institute, with
     Kish,  S.,  Grace  Incorporated.  August 13, 1991.  Stainless
     steel  paint  circulation systems.

14.  Memorandum from  Christie, S., Midwest Research Institute, to
     Moseley, R.,  Hickory Chair.  Trip report:  Observation of
     waterborne coatings test.

15.  Telecon.   Christie, S., Midwest Research Institute, with
     Perry, S., Business and Institutional Furniture
     Manufacturers Association.  July 15, 1991.  Coating material
     storage procedures.

16.  Telecon.   Christie, S., Midwest Research Institute, with
     Titus, R., Kitchen Cabinet Manufacturers Association.
     July 16, 1991.   Coating material storage procedures.

17.  Telecon.   Christie, S., Midwest Research Institute, with
     Bombay, B.,  Kraftmaid Cabinetry, Inc:  July 15, 1991.
     Coating material storage and transfer procedures.

18.  Telecon.   Christie, S., Midwest Research Institute, with
     Butterfield,   G. , Merillat, Inc.  July 25, 1991.  Coating
     material storage and transfer procedures.

19.  Telecon.   Christie, S., Midwest Research Institute, with
     Moseley, R.,   Hickory Chair. July 15, 1991.  Coating material
     storage procedures.

20.  Telecon.   Christie, S., Midwest Research Institute, with
     Sale, W.,  Broyhill Furniture Industries.  July 15,  1991.
     Coating material storage and transfer procedures.

21.  Telecon.   Christie, S., Midwest Research Institute, with
     Bublitz, T.,   Herman Miller, Incorporated.  July 29, 1991.
     Coating material storage and transfer procedures.

22.  Letter and attachments from Schurr,  D.,  Safety Storage,"
     Inc., to Christie,  S.,  Midwest Research Institute.
     August 14,  1991.  Coating material storage costs.

23.  Telecon.  Christie, S., Midwest Research Institute, with
     Stanwyck, W., Precision Quincy Corporation.,   August 7, 1991.
     Coating material storage costs.

24.  Telecon.  Christie, S., Midwest Research Institute, with
     Osborne, J.,  Osborne Environmental.   August:  7, 1991.
     Coating material storage costs.

25.  Ref. 2, p.  7-44.
                              6-38

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26.  Transfer Efficiency and VOC Emissions of Spray Gun and
     Coating Technologies in Wood Finishing.  Pacific Northwest
 1    Pollution Prevention Research Center.  Seattle, WA.  1992.
     p. 5.

27.  Survey response and attachments from Binks Manufacturing
     Company, to Caldwell, M. J.  Midwest Research Institute.
     March 29, 1990.

28.  Survey response and attachments from Graco, Inc. to
     Caldwell, M. J.,  Midwest Research Institute.  March 26,
     1990.

29.  Memorandum from M. Caldwell,  Midwest Research Institute, to
     Project file. February 29,  1992.  Joint Industry Steering
     Committee Report Summary.
                              6-39

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                     7.0  RACT IMPLEMENTATION

 7.1   INTRODUCTION
      This  chapter presents  information  for air quality management
 agencies to consider  in  the development of an enforceable  rule
 limiting volatile organic compound  (VOC) emissions from wood
 furniture  operations.  Information  is provided on important
 definitions,  rule applicability, format of standards, performance
 testing and monitoring,  and reporting and recordkeeping.   Where
 several options exist for implementing  a certain aspect of the
 rule, each option is discussed along with its advantages and
 disadvantages.  In some  cases, there may be other equally  valid
 options.   The State or other implementing agency can exercise its
 prerogative to consider  other options provided that they meet the
 objectives prescribed in this chapter.
      The guidance concerning RACT implementation that is included
 in this chapter is for instructional purposes only and, as such,
 is not binding.  Appendix B contains an example rule
 incorporating the guidance provided in  this document.  The
 example rule provides an organizational framework and sample
 regulatory language specifically tailored for wood furniture
 operations.  The example rule is also not intended to be binding.
 The State  or other enforcement agency should consider all
 information presented in this document along with additional
 information about specific sources to which the rule will  apply.
The reasonably available control technology (RACT)  rule,  however,
 should address all the factors listed in this chapter and  in
Chapter 5  to ensure that the rule has reasonable provisions for
demonstrating compliance and is enforceable.
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 7.2  DEFINITIONS
     The RACT  rule  should accurately describe the types of
 sources that would  be affected and clearly define terms used to
 describe the industry or applicable control methods.  Example
 definitions of pertinent terms are presented in Appendix B for
 reference by the enforcement agency when drafting a RACT
 regulation for wood furniture operations.  These definitions are
 intended to offer guidance to agencies in selecting terms that
 may need to be clarified when used in a regulatory context.  The
 definitions in Appendix B have been compiled using both industry
 and EPA sources.
 7.3  APPLICABILITY
     The recommended RACT described in this document applies to
 any facility that finishes wood furniture,  or performs cleaning
 or washoff associated with wood furniture finishing operations.
 The wood furniture  industry is described in more detail in
 Chapter 2.  For purposes of this CTG,  wood furniture can be
 summarized as:
     1.  Residential (household)  furniture - including
 upholstered furniture and casegoods such as beds,  bookcases,
 chairs, tables, couches,  etc.,  as well as reed and rattan and
 other wicker furniture,  and garden and lawn furniture;
     2.  Cabinets - including kitchen,  bath, stereo,  radio,
 sewing machine, and television cabinets;
     3.  Wood office furniture -  including bookcases,  cabinets,
 benches, chairs,  desks,  tables,  and other furniture;
     4.  Public building and related furniture - including
 benches, blackboards,  bleachers,  chairs and church furniture; and
     5.  Wood office and store fixtures,  partitions,  shelving,
 and lockers.
     The nine SIC codes considered in the CTG analysis are
presented in Chapter 2 and in the model rule.  Any rule based on
 the CTG could include all or a portion of these nine SIC codes,
 as well as any other coating processes the regulatory agency
believes are best described as a wood furniture manufacturing
 operation.
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      This guidance applies to in-house wood finishing processes
 located at a manufacturing site.   It applies to finishing
 operations that involve the prefinishing of individual
 components,  which may then be assembled elsewhere within the
 facility or sent to another facility for final  finishing and/or
 assembly.  It also applies to the finishing of  unassembled and
 assembled pieces that are manufactured both onsite and offsite.
 The guidance only applies to the  wood finishing processes--other
 processes such as metal coating are not covered.   A furniture
 finishing line processes wood furniture pieces  composed primarily
 of  wood;  however,  some of the components of the piece may be
 plastic,  metal,  or other materials which need to be given a
 finish appearance of simulated wood.   This  guidance does apply
 where either the piece to be finished requires  a simulated wood
 appearance or where the finished  surface area of the piece to  be
 finished  is  mostly wood.   Similarly,  the guidance does not apply
 to  other  operations that may occur in the facility such as gluing
 and particleboard manufacturing.
      The  emission points covered  are  the finishing,  cleaning,  and
 washoff operations.  The finishing operation includes  the
 finishing application  area,  flashoff  areas,  curing ovens,  and
 assorted  cooldown zones.   Emissions can occur throughout  the
 entire finishing  operation.   Finishing  operation-related  cleaning
 includes  application equipment  cleanup,  process equipment
 cleaning,  and  spray booth cleaning.   Cleaning operations  occur
 primarily in the application area,  though miscellaneous  cleaning
 operations may occur along any part of  the  finishing operation.
 Washoff operations  are also  covered by  the model  rule.  Washoff
 includes  the removal of  finishing material  from a piece of
 furniture that does  not meet  specifications.
     The  presumptive norm that has been  selected as RACT  applies
differently  depending on  the  type of  topcoat and sealer that is
used.  Sources that use acid-cured alkyd amino conversion varnish
 topcoats  and acid-cured alkyd amino vinyl sealers have different
requirements for higher-solids coatings than those sources  that
use conventional topcoats and sealers.   (See related discussion
                               7-3

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in Chapter 5.)  Enforcement agencies may choose to evaluate
sources within their jurisdiction to determine the extent to
which sources using conversion varnishes and vinyl sealers
actually differ from those using conventional topcoats and
sealers.
     As indicated in the model rule in Appendix B, this guidance
has been developed for affected sources in areas of marginal,
moderate, serious, or severe nonattainment that have the
potential to emit greater than or equal to 25 tons per year
(tons/yr) of VOC's.  The guidance is intended to apply to
affected sources in extreme areas, however, if potential VOC
emissions are greater than or equal to 10 tons/yr.  The
enforcement agency has the flexibility- to apply RACT as deemed
necessary.  For example, an agency may apply RACT to all sources
that have the potential to emit greater than or equal to
10 tons/yr of VOC's.
7.4  FORMAT OF STANDARDS
     The selected RACT contains two elements:  emission standards
limiting the VOC content of coatings and work practice standards.
The VOC content should be calculated as-applied to account for
in-house dilution of coatings purchased from an outside source.
     To incorporate some flexibility,  the model rule allows
sources to use either an averaging approach or add-on air
pollution control equipment to meet the RACT requirements.   To
use an add-on control device,  the source must demonstrate,
through the use of a series of calculations,  that they are
achieving an emission reduction equivalent to that achieved by
sources using compliant coatings.
     Sources using an averaging approach must demonstrate that
their emissions are no greater than 90 percent of what they would
be if they were using compliant coatings.   Section B.4(a) (4)  of
the model rule provides guidance on how to determine if the
source is achieving the required emission reduction.   The model
rule contains extensive guidance for States that decide to allow
averaging as a method of demonstrating compliance.   However,
States have the option of not allowing an averaging approach to
                               7-4

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 be used.   They can also place limitations  on the averaging
 i
 program if they wish to do so.   For example,  they may limit
 averaging to facilities of a certain size,  limit the  number of
 coatings  that can be averaged,  or they could limit the amount of
 time a source could use averaging in anticipation that,  in the
 future,  compliant coatings will be available for every situation.
      The  baseline for each finishing material included in the
 averaging program shall be the  lower of the actual or allowable
 emission  rate as of the effective date of  the State's RACT rule.
 For example,  if the source is already using a 0.3 Ib  VOC/lb
 solids topcoat,  they are not entitled to 0.5 Ib  VOC/lb solids
 trading credits.   Methods used  in determining the usage of each
 finishing material shall be accurate enough to .ensure that the
 affected  source's actual emissions are less than the  allowable
 emissions,  as  calculated using  Equation 1  or 2 in B,4(a)(4),  on a
 daily basis to a level  of certainty comparable to that  for
 traditional control  strategies  applicable  to surface  coating
 sources.
      The  recommended RACT also  contains many work practices that
 are believed to  limit emissions  from finishing,  cleaning,  and
 washoff operations.   Work practices are recommended when
 physically measuring emissions  from a source  is  impossible or at
 least  impracticable.  The work practices that were selected as
 RACT  are  practices that  are  being  employed  in  the  source
 category,  but  for which  emission limits could not be assigned.  A
 disadvantage of  the  format of work practice standards is  that  it
 is difficult to demonstrate  equivalence.  If a State wishes to
 use alternate  standards  to the work practice standards,  the
 burden is  on the State to  demonstrate to the EPA Administrator
 that the  standards are equivalent.
 7.5  COMPLIANCE AND MONITORING PROVISIONS
 7.5.1  Compliance Provisions
     Regardless of the format selected by the enforcement  agency,
 compliance and monitoring provisions are essential to confirm.
 that an affected source is in compliance with a rule,  and  to
determine whether compliance is continuous  or intermittent.  The
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 compliance  provisions  in  the model rule in Appendix B were
 developed assuming  that the rule would follow the format of a
 limit on the  Ib VOC/lb solids of specific coatings, but alternate
 compliance  provisions  may be appropriate for standards that are
 in a different format.  The compliance provisions should account
 for the various control methods that affected sources may use to
 comply with the rule.  For example, in the model rule, compliance
 provisions  are identified depending on whether any of the
 following control methods are used:  (1) compliant coatings;
 (2) averaging; or  (3)  an  air pollution control system consisting
 of a capture  and control  device.
     Sources  using  compliant coatings demonstrate compliance by
maintaining records of the certified product data sheets for the
VOC content of the  as-supplied coating and data sheets
demonstrating how the  as-applied value for the coating was
calculated.   Attachment 3 of the model rule provides guidance to
States on potential compliance provisions for sources using an
averaging approach  to  comply with the rule.   The States should
use this guidance in developing their averaging programs for
submittal to  the Administrator for approval.  At a minimum,
sources using an averaging approach must submit the results of
the calculations from  inequalities (1)  or (2)  in
Section B.4(a)(4)  of the model rule and data on daily coating
usage and VOC content that support the calculations.
     The model rule recognizes that the overall control
efficiency  of an air pollution control system is dependent upon
both the capture and control efficiency.  Therefore, it is
important that any rule contain provisions for determining both.
There are two methods available to determine the capture
efficiency  associated with an air pollution control system.  One
method is to  perform a capture efficiency test on the capture
system used to direct emissions to the add-on control device.  A
second method is to demonstrate that a capture system meets EPA's
total enclosure criteria,  and is therefore assigned a capture
efficiency  of 100 percent.  Both methods are presented in the
model rule.   In the wood  furniture industry, sources may operate
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 individual spray booths or groups  of  booths  within an  enclosure,
 or they may operate the entire finishing room as  an enclosure.
 The test methods in the model rule can be applied to any of these
 situations.
      Depending upon the conditions at a test site,  one of the
 following test methods from 40 CFR Part 60,  Appendix A,  should be
 used to determine the inlet and outlet VOC concentrations of a
 gas stream sent to a control device,  and thus,  the control
 efficiency of the device:
      1.   EPA Method 18;
      2.   EPA Method 25;  or
      3.   EPA Method 25A.
      The method selected should-be based on  consideration of the
 diversity of organic species present  and their  total
 concentration and on consideration of the potential presence of
 interfering gases.   Because of the different response  factors for
 the many organic compounds which may  be  present either in the
 coatings or as a result  of the combustion process, EPA Method 25
 or 25A,  which measure total VOC as carbon, should be used for
 determining destruction  efficiency of  thermal incinerators,
 catalytic incinerators,  or combined adsorption/thermal
 incineration systems when  the stream  constituents  are  well known.
 However,  EPA Method  18 is  more appropriate for speciating organic
 emissions when the presence of pollutants  is more  ambiguous.
 Because  EPA Method 18  is more sophisticated,  associated  costs are
 generally higher.
     The  following test methods  are used  in  conjunction  with the
VOC measurement methods  identified above:
     1.   EPA Methods  1 or  1A of  40 CFR Part  60, Appendix A,
should be used for velocity traverses;
     2.   EPA Methods 2, 2A,  2C,  or 2D of 40 CFR Part 60,
Appendix  A should be used  for velocity and volumetric flow rates;
     3.   EPA Methods  3 or  3A of  40 CFR Part  60, Appendix A,
should be  used for O2, and  C02 analysis; and
     4.   EPA Method 4 of 40 CFR  Part 60, Appendix A, should be
used for  stack gas moisture.
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 7.5.2  Monitoring Requirements
     Under  the amended Act, paragraph  (3) to Section 114(c)
 requires  enhanced monitoring of stationary sources to indicate
 the compliance status of the source, and whether compliance is
 continuous  or intermittent.  The enhanced monitoring provisions
 have been codified in 40 CFR Part 64.  The model rule in
 Appendix  B  has been developed to account for situations in which
 either compliant coatings, averaging, or an add-on control device
 are used, and incorporates the concepts of enhanced monitoring.
 In this industry, it is likely that the majority of sources will
 use compliant coatings to comply with the recommended RACT; add-
 on control  devices will be used in very limited situations.  The
 monitoring  requirements of the model rule reflect this premise.
     The  continuous compliance monitoring methods that are
 identified  in the model rule for sources using add-on control
 devices are consistent with previous regulations developed by the
 EPA.  Agencies responsible for enforcing RACT may choose other
 methods as  long as they meet the enhanced monitoring provisions
 of 40 CFR Part 64.  For example, the model rule identifies
 continuous  parameter monitoring for sources using add-on
 controls; specifically,  sources using incinerators must
 continuously monitor the combustion temperature.  It has been
 shown that  lower temperatures can cause significant decreases in
 combustion  control device efficiency.  Temperature monitors with
 strip charts and flow indicators are relatively inexpensive and
 easy to operate.   Flow indicators confirm that the streams are
 being routed to the incinerators.   In the model rule,  operation
 at a combustion temperature less than the value established for
 compliance  during the initial compliance test for any 3-hour
period constitutes noncompliance with the standaird.
     Another option would be to require the use of continuous
 emission monitors (CEM's)  on the inlet and outlet gas stream so
 that a percent destruction efficiency could be continuously
monitored.  Or,  an outlet CEM could be used,  with the outlet
 concentration serving as the operating parameter to be monitored
 (the value  of the outlet concentration could not exceed that
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 established during the initial performance test).   For
 incinerators,  the EPA believes that temperature monitoring is a
 good determination of compliance and is considerably less
 expensive than operating CEM's.   Another factor that agencies
 must consider in establishing compliance provisions is the
 averaging time over which compliance will be  determined.   For
 example,  in the model rule,  sources using add-on controls must
 average the operating parameter value over each 3-hour period to
 determine compliance or noncompliance with the  standard.   In the
 model rule,  compliance monitoring is identified only for
 incinerators and carbon adsorbers because other types of  add-on
 control devices are not likely to be used for compliance.   If an
 alternate control device is  expected to be used«by  affected
 sources within an agency's jurisdiction,  the  rule may include
 compliance provisions appropriate for that device as well.
      The  model rule also recognizes that the  overall control
 efficiency of  a control system does not depend  only on the
 destruction efficiency of the  device but on the capture
 efficiency as  well.   The model  rule identifies  the  methods  to be
 used to demonstrate that the capture efficiency measured  during
 the  initial  test  is continuously maintained.  The provisions
 contained in the  model  rule require monitoring  of an operating
 parameter that verifies that the capture  system is  operating  at
 the  same  efficiency as  it was during the  initial compliance test.
 The  amount of  air the fans are directing  to the control device
 could be  used  as  an indicator of the relative capture  efficiency.
 Continuous measurement  of  the airflow from each of  the areas
 exhausted to the  control  device  (each spray booth,   oven, etc.)  is
 one  suggestion.   Whichever parameter is measured as  an  indicator
 of capture efficiency,  it  should be measured during  the initial
performance  test, a minimum or maximum value established  (as
appropriate),  and continuous monitoring should be compared to
 this value.
     As previously stated, most  affected sources are expected  to
meet  the  requirements of RACT by using the compliant coatings
that are  the presumptive norm.   Initial and ongoing  compliance
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for these  sources are demonstrated through reporting and
recordkeeping requirements.  When compliance is achieved through
the use  of compliant coatings, EPA believes that reporting and
recordkeeping to demonstrate continuous compliance fulfill
enhanced monitoring requirements.  Enforcement agencies may
develop  innovative techniques for determining the compliance
status of  sources using compliant coatings; these are appropriate
provided they meet the enhanced monitoring requirements of 40 CFR
Part 64.
     Attachment 3 of the model rule provides guidance to States
on potential monitoring requirements for sources using an
averaging  approach to comply with the rule.  The States should
use this guidance in developing their averaging programs for
submittal  to the Administrator for approval.
     The model rule requires semiannual reporting of a source's
compliance status when compliant coatings are used.
Specifically, sources using compliant coatings or spray booth
materials  must submit a semiannual compliance certification that
states that the materials documented in the certified product
data sheet are the ones actually being used.  The EPA has
identified semiannual reporting in the model rule because direct
emission measurement is not being required, yet the records and
reports are being used directly for compliance determinations.
Other enforcement agencies should consider the reporting
frequency  they consider necessary for determining the compliance
status of  a source,  and should also explore how this reporting
will compare with that required as part of the Title V operating
permit program.   Small business impacts should also be
considered.
     The model rule contains compliance provisions for the work
practice standards as well.  The EPA thought it necessary to
identify compliance provisions for the work practice standards
because much of the emission reduction that will be achieved by
the proposed rule is through the work practice standards.
Obviously,  direct measurement of emissions is not appropriate
because emission points being controlled by work practices are
                              7-10

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 not point sources that emit through a stack.   The model rule
 requires all of the recordkeeping associated with work practices
 to be included in the work practice implementation plan.   The way
 continuous compliance is ensured in the model rule is  through a
 semiannual compliance certification that states that the  work
 practice implementation plan is being followed.
 7.6  REPORTING AND RECORDKEEPING
      Each facility subject to RACT requirements should keep
 records  of certain key parameters that would determine initial
 and continuous compliance.  To accomplish this, the model rule
 requires an initial compliance report,  with subsequent compliance
 reports  submitted on a semiannual basis.   Regardless of the type
 of reports required by a rule,  some basic information  should be
 conveyed to the enforcement agency.   First,  the facility  should
 identify the control method selected to meet  the RACT
 requirements.   Next,  the results  of  any performance testing
 should be recorded.   Further,  the facility should record  all
 parameters monitored on a routine basis to indicate continued
 compliance with the RACT emission limit.   These parameters  differ
 depending on the means  by which the  RACT requirements  are met.
 Any exceedances of  the  monitored  parameters also should be
 recorded along with any corrective actions taken.
     Records should be  kept  to  demonstrate that coating materials
 comply with VOC content limits  for each regulated category  of
 material.   The affected source  should maintain  a certified
 product  data sheet  for  each  coating  subject to  the  emission
 limitations.   They  should also maintain records  of  the VOC  and
 solids content,  as  applied,  of  each  coating.  Sources using an
 averaging  approach must  keep the above  records  as well as records
 of  the quantity  of  each material used,  and the  emission
 calculations that demonstrate equivalence.  As  stated in
 Section  7.6, an  initial  report may be used to convey the above
 information  to demonstrate initial compliance, and the
 information  then reported on a semiannual basis  to demonstrate
continuous compliance.  The  semiannual reports may take the  form
of compliance  certifications in which a responsible official at
                               7-11

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the  facility  certifies that the source is in continuous
compliance.   (This  concept is discussed in more detail below.)
     Sources  should also maintain records associated with the
work practice implementation plan, including records showing the
date each operator  was trained, records associated with the leak
inspection and maintenance plan, and records associated with the
application equipment requirements.  As discussed in Section 7.6,
initial compliance  may be demonstrated by submitting a statement
that the work practice implementation plan has been developed and
is being implemented.  Continuous compliance may be demonstrated
by sources if they  submit a certification statement that reports
that the work practice implementation plan has been followed as
written, whether changes were made and the reasons for these
changes, and  any actions that were taken to correct actions
performed contrary  to the constraints of the plan.
     In the model rule, semiannual compliance certifications are
required for  sources that use compliant materials, and for
sources demonstrating compliance with the work practice
implementation plan.  The authority for requiring these
compliance certifications is found in paragraph (3)  to
Section 114 (c),  and is analogous to the compliance certification
required by the Parts 70 and 71 operating permit programs.
Therefore,  the compliance certification required by this proposed
rule is consistent with other regulatory actions that may also
apply to the affected sources.
     Sources that use add-on air pollution control systems to
meet RACT requirements will require different types of reporting
and  recordkeeping than sources using compliant coatings.
Enforcement agencies should refer to the General Provisions
(Subpart A)  to Part 63 (the MACT standards).   These provisions
identify the types of records and reports that are appropriate
when add-on control systems are used and monitoring is required.
For example,  these provisions cover performance test reporting;
                              7-12

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compliance monitoring system records; startup, shutdown, and
malfunction provisions; reports of exceedances; and summary
reports certifying no excess emissions.
                              7-13

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APPENDIX A




 CONTACTS

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 COATING SUPPLIERS
  i
 AEXCEL Corporation
 7373 Production Drive
 Mentor,  OH  44061-0780
 Mr.  Richard Milhem

 Akzo Nobel Coating,  Inc.
 P.  O. Box 2124
 High Point,  NC  27261
 Mr.  Gerry M. Currier
 Mr.  Bob Matejka

 Alternative Materials Technology,
 Inc.
 1266 Humboldt Avenue
 Chico,  CA  95928
 Mr.  Bill Malligie

 Ameron Corporation
 P. O. Box 192610
 Little Rock, AR  72219-2610
 Mr.  Mike Harris

 Amity Finishing Products
 P. O. Box 107
 Sun  Prairie, WI  53590
 Mr.  George Cash

 Avery--Decorative Films  Div.
 650  West 67th Place
 Schererville,  IN  46375
 Mr.  Greg Emily

 C. E.  Bradley Laboratories,  Inc.
 P. 0.  Box 811
 Battleboro,  VT  05301
 Mr.  Rasheed  H.  Kanaan

 Cardinal Industrial  Finishes
 1329  Potrero Avenue
 South El Monte,  CA  91733
 Mr.  Sam  Ortolono

 Chemcraft Sadolin International, Inc.
 P.O. Box 669
 Walkertown,  NC  27051
 Mr. Gary Marshall

 Crown Metro,  Inc.
 P. O. Box 2910
 Lenoir,  NC  28645
 Mr. Greg Sprole

 Guardsman Chemicals, Inc.
 2147  Brevard Road
 High  Point,  NC 27261-1029
 Mr. Ron  Tucker

 Hood  Products, Inc.
 P. O. Box 163
 Freehold,  NJ  07728
Mr. Eric  Kasner
 James B.  Day & Company
 Day Lane
 Carpentersville,  IL  60110
 Mr. Steven J.  Plumley

 Lawrence  McFadden Company
 7430 State Road
 Philadelphia,  PA  19136
 Mr. Peter Beck

 Lilly Industries,  Inc.
 733 South West Street
 Indianapolis,  IN  46225
 Mr. Bill  Dorris

 Lilly Industries,  Inc.
 P.  O.  Box 2358
 High Point,  NC  27261
 Mr. Archie Martz

 PPG Industries,-.Inc.
 7601 Business  Park Drive
 Greensboro,  NC  27409
 Mr. Andy  Riedell

 Pratt  t Lambert
 Industrial Coatings Division
 16116  East 13th Street
 Wichita,  KS  67230
 Mr. Wallace  A.  Steele
Radcure, Inc.
217 Freedman Drive
Port Washington, WI
Mr. Keith Clark
53074-0247
Reneer Films Corporation
Old Hickory Road
Auburn, PA  17922
Ms. Wendy Steed

Snyder Brothers
Avon Street
Toccoa, GA  30577
Mr. Len Snyder

Spruance Southern, Inc.
Old Highway 52 South
Winston-Salem, NC  27107
Mr. David King

D. S. Cellulose
520 Parrott
San Jose, CA
Ms. Jennifer O'Hara

Union Carbide Corporation
39 Old Ridgebury Road L-4
Danbury,  CT  06817
Mr. Thayer West
                                      A-l

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Valspar Corporation
1647 English Road
High Point, NC  27261
Mr. James Bohannon
                                    A-2

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 RESIN SUPPLIERS

 Aqualon/Hercules
 1313 N. Market St.
 Wilmington, DE  19899-8740
 Mr. John Devido

 Cargill
 2301 Crosby Road
 Wayzeta, MN  55391
 Mr. Al Heitkamp

 Ciba Geigy
 3 Skyline Drive
 Hawthorne, NY  10532-2188
 Mr. William Collins

 Dow Chemical Company
 2040 Willard H. Dow Center
 Midland,  MI  48674
 Ms. Karen Krigbaum

 Eastman Chemicals
 Eastman Road
 Kingsport, TN  37660
 Mr. Jeff Powell

 ICI Resins
 1717 Rivermist Drive
 Lilburn,  GA  30247
 Mr. Edward Elkins

 Mobay Corporation
 Mobay Road
 Pittsburgh,  PA  15205-9741
 Dr.  Bernd H.  Riberi

 Mobil Oil Corporation
 3225 Gallows  Road
 Fairfax,  VA  22037
 Mr.  Bill  Press

 PPG Industries
 Greensboro Customer  Service Lab
 7601 Business  Park Drive
 Greensboro, NC  27409

 Reichhold Chemicals,  Inc.
 525-T North Broadway
 White Plains, NY   10603
 Mr.  Jeffrey Dannerman
Rohm and Haas
Independence Mall West
Philadelphia, PA  19105
Mr. Pete Nicholson

Sanncor Industries
300 Whitney Street
Leominster, MA  01453
Mr. Henry Merken
                                     A-3

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FURNITURE MANUFACTURERS
Allied Wood Industries
P. O. Box  1823
Southern Pines,  NC   28387
Mr. David  Allen

American Woodmark Corporation
Rt. 220 South, Industrial Pk.
Moorefield,  WV   26836
Mr. Bob Taylor

Aristokraft,  Inc.
1 AristoKraft Square
Jasper, IN  47546
Mr. Dave Hurst

Basset Furniture Industries, Inc.
Main St.,  P.  O.  Box  626
Bassett, VA  24955
Mr. Mike Nelson

Bernhardt  Furniture  Company
P. O. Box  740
Lenoir, NC  28645
Mr. Buck Deal
Mr. Dean Reid

Broyhill Furniture Industries, Inc
1 Broyhill  Park
Lenoir, NC  28633
Mr. William Sale

Corrections Industries
Penitentiary of  New Mexico
Santa Fe,  NM
Mr. L. D. Alexander

Daniel Peters Woodworking
2056 Lock  Haven Drive
Roanoke, VA  24019
Mr. Daniel  Peters

Elite Furniture Restoration
P. O. Box  623
Toluca, IL   61369
Mr. Don Scrivner

Ethan Allen,  Inc.
P. O. Box  639
Old Fort, NC  28762
Mr. Mickey  O'Keefe
Fieldstone Cabinetry, Inc.
Highway 105 East
Northwood, IA  50459
Mr. Steve Teunis

Florida Furniture Industries, Inc.
P. O. Box 610
Palatka, FL  32177
Mr. Fount Rion, Jr.
Henkel-Harris Company,  Inc.
P.O. Box 2170
Winchester, VA  22601
Mr. Rex Davis

Henrendon
P. O. Box 70
Morgantown, NC  28655
Mr. Paul (Buck) Smith

Herman Miller, Inc,
8500 Byron Road
Zealand, MI  49464
Mr. Paul Murray

HON Industries Technical Center
505 Ford Avenue
Muscatine IA  52761
Mr. Scott Lesnet

Hickory Chair
37 9th St.  PI. S.E.
Hickory, NC  28603
Mr. Richard Mosley
Kincaid Furniture
P. O. BOX 605
Hudson, NC  28638
Mr. Mike Soots
Mr. Rick Penley
  Company
Kitchen Kompact
P. O. Box 868
Jeffersonville,
Mr. Walt Gahm
IN  47131
KraftMaid Cabinetry
16052 Industrial Parkway
Middlefield, OH  27711
Mr. Byron Bombay

McGuire Furniture
1201 Bryant Street
San Francisco, CA  94103
Mr. Randy Sheparcl

Masco Corporation
21001 Van Born Road
Taylor, MI  48180
Dr. Paul Eisele, PhD

Merillat Industries, Inc.
P.O. Box 1946
Adrian, MI  49221
Mr. Gary Butterfield

Mills Pride, Inc.
423 Hopewe11 Road
Waverly, OH  45690
Ms. Debra Hannah
                                     A-4

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 O'Sullivan Industries, Inc.
 1900 Gulf Street
 Lamar, MI  64759
 Mr. Ralph Williston

 Platform Beds, Inc.
 400 North First Street
 Grants, NM  87020
 R. T. Miller

 Pulaski Furniture Corporation
 P. O. Box 3431
 Martinsville, VA  24115

 Pridgen Cabinet Works
 Route 2, Box 36
 Whiteville,  NC  28472
 Jack Burgess

 Stanley Furniture
 Highway 57 West
 Stanleytown,  VA  24168
 Mr.  Alex Teglas

 Steelcase
 P. O.  Box 1967/CS-2S08
 Grand Rapids,  MI   49501
 Mr.  Phil Schneider

 Stow & Davis  Wood Division
 Cane Creek Industrial Park
 Fletcher,  NC   28732
 Mr.  L.  T.  Ward

 Stylecraft Corporation
 P. O.  Box 458
 Blue Ball, PA  17506
 Mr.  David Rothermel

 Terra  Furniture
 17855 Arenth Avenue
 City of  Industry,  CA   91744
 Mr.  Gary Stafford

 The  Bartley Collection, Ltd
 3  Airpark Drive
 Easton,  MD 21601
 Mr.  Joe  Layman
The Knoll Group
Water Street
East Greenville, PA
Mr. Lou Newett
18041
                     Thomasville Furniture  Industries,
                     Inc.
                     P.  O. Box  339
                     Thomasville, NC   27361
                     Mr. Dave Masters

                     Vaughn Furniture
                     P.  O. Box  1489
                     Galax, VA  24333
                     Mr. Pres Turbyfill

                     Vintage Piano Company
                     P.  0. Box  51347
                     Chicago, IL  60651
                     Mr. John Gonzalves

                     Virginia House Furniture Corp.
                     P. 0. Box  138
                     Arkins, VA 24311
                     Mr. Randall Sparger

                     Wambold Furniture
                     6800 Smith Road
                     Simi Valley,  CA  93063
                     Mr. Mark Trexler

                     WCI Cabinet Group
                     701 South N Street
                     Richmond,  IN  47374
                     Mr. Bob Livesay

                     Wood-Mode Cabinetry
                     1 Second Street
                    Kreamer,  PA  17833
                    Mr.  Gronlund

                    WoodCo Incorporated
                    5225 Quast Avenue. N.E.
                    Rodgers,  MN  55374
                    Mr.  Rick Wood

                    WoodMark Manufacturing
                    No.  4,  Sapona Business Park
                    Lexington,  NC  27292
                    Mr.  Ellis  Murphy
The Lane Company, Altavista
Operations
Box 151
Altavista, VA  24517-0151
Mr. Jon Parish
                                      A-5

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 APPLICATION SYSTEMS VENDORS

 Air Power,  Inc.
 P.  O.  Box 41165
 Raleigh,  NC  27629
 Mr.  Ron Lowe

 Apollo Sprayers  International,  Inc.
 10200  Hemstead Highway
 Houston,  TX  77092
 Mr.  Paul  McClure

 Sinks  Manufacturing Company
 9201 W. Belmont  Avenue
 Franklin  Park, IL  60131
 Mr.  Rick  Campobasso

 CAN-AM Engineered Products, Inc.
 30850  Industrial Road
 Livonia,  MI  48150
 Mr.  M.  H. Bunnell

 DeVilbiss Company
 300  Phillips Avenue
 Toledo, OH   43692
 Ms.  Nancy Lieber

 Graco,  Inc.
 24775  Crestview  Court
 Farmington  Hills, MI   48335
 Mr.  Peter Bankert

 Graco,  Inc.
 4050 Olsen  Memorial Highway
 Minneapolis,  MN   55440-1441
 Mr. Glenn Muir
Graco, Inc.
9451 W. Belmont
Franklin Park, IL
Mr. Steven Kish
60131-2891
High Point Pneumatics
Box 5802
High Point, NC  27262-5802
Mr. Wayne Roach

Kremlin, Inc.
211 South Lombard
Addison, IL  60101
Mr. Ken Ehrenhofer

Nordson Corporation
1321 Cedar Drive
Thomasville, NC  27360
Mr. John Collett

Nordson Corporation
555 Jackson Street
Amherst, OH  44001
Ms. Cindy Daignault
Paint-O-Matic
Box  1426
Willits, CA  65490
Mr.  Ron Budish

Ransburg, Inc.
3939 West 56th Street
Indianapolis, IN  46208
Mr.  Loren Simonson

S. A. Services
P. O. Box 129
Dudley, NC  28333
Mr.  Fred McLeod

Speedflo Manufacturing Corporation
4631 Winfield Road
Houston, TX  77039
Mr. Dave Masterson

Stiles Machinery
3965 44th Street Southeast
Grand Rapids, MI  49508
A. J. Stranges

The DeVilbiss Co.
300 Phillips Ave., P. O. Box 913
Toledo, OH  43692-0913
Mr. John Truschill

Union Carbide Chemicals
6230 Fairview Road
Charlotte, NC  28210-3297
Ms. Renee Morgan

Volstatic, Inc.
7960 Kentucky Drive
Florence,  KY  41042
Mr. James Baugh
                     Wagner Spray Tech  Corporation
                     1770 Fernbrook Lane
                     Minneapolis, MN  55447
                     Mr. Gale  Finstad
                                     A-6

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 ADD-ON CONTROL VENDORS
 ABB Flakt Alpha
 29333 Stephenson Hwy.
 Madison Heights, MI  48071

 Baron-Blakeslee
 2003 North Janice Avenue
 Melrose Park,  IL  60160
 Mr. Sherman McGrew

 Calgon Carbon Corporation
 P.  O. Box 717
 Pittsburgh,  PA  15230-0717
 Mr. Mark Weissert

 Combustion Engineering
 Andover Road,  Box 372
 Wellsville,  NY  14895
 Mr. Brian Cannon

 CVM Corporation
 402 Vandever Avenue
 Wilmington.  DE  19802
 Ms. Roxanne  Pietro

 DCI International
 1229 Country Club Road
 Indianapolis,  IN  46234
 Mr.  Bob Zopf

 Durr Industries
 40600 Plymouth Road
 Plymouth,  MI  48170-4297
 Mr.  Dinesh Bhushan

 George Koch  Sons,  Inc.
 10  S.  Eleventh Avenue
 Evansville,  IN  47744
 Mr.  Don Miller

 Global Environmental
 P.  O.  Box 2945
 Greenville,  SC  29602
 Mr.  John  Hatcher

 Hirt  Combustion Engineers
 931  South Maple Avenue
 Montebello,  CA  90640
 Mr.  Chris Oakes

 Hoyt Manufacturing Corp.
 251-T  Forge  Road
 Westport,  MA  02790
Mr.  Steven Rooney

Huntington Energy Systems
 1081 Briston Road
Mountainside,  NJ  07092
Mr.  Ray Elsman
 Industrial Technology Midwest
 P.  O.  Box 626
 Twin Lakes,  WI  53181
 Mr. William Nowack

 M & W Industries
 P.  O.  Box 952
 Rural  Hall,  NC  27045
 Mr. Jim Minor

 Met-Pro Corporation
 160 Cassell  Road
 Harleysville,  PA  19438
 Dr. Robert Kenson

 Moco Fume Incinerators
 First  Oven Place
 Romulus,  MI   48174
 Mr. Bill Diepenhorst

 Nucon  International,  Inc
 P.  O.  Box 29151
 Columbus,  OH  43229
 Mr. Joseph Enneking

 Ray-Solve,  Inc.
 100 West Main Street
 Boundbrook,  NJ  08805
 Mr.  Jules Varga

 Reeco,  Inc.
 6416 Carmel  Road
 Charlotte, NC 28226
 Mr. George Yundt

 Salem  Industries
 245 South Mill Street
 South  Lyon,  MI   48178
 Mr. Lyman Thornton

 Smith  Engineering  Company
 P.  O.  Box 359
 Broomhall, PA 19008-0359
 Mr. Roy Mcllwee

 Stiles Machinery,  Inc.
 3965 44th  Street Southeast
 Grand  Rapids, MI   49508
 A.  J.  Stranges
Terr-Aqua Enviro Systems,
700 East Alosta, Unit 19
Glendora, CA  91740
Mr. Lynn Shugarman

Tigg Corporation
Box 11661
Pittsburgh, PA  15228
Mr. John Sherbondy
Inc.
                                     A-7

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VARA International, Inc.
1201 19th Place
Vero Beach, FL  32960
Mr. Jerald Mestemaker

VIC
1620 Central Avenue, NE
Minneapolis, MN  55413
Mr. Tom Cannon

Weatherly, Inc.
1100 Spring St.,NW, Suite 800
Atlanta, GA  30309
Mr. Rick Daeschner
                                     A-8

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 GOVERNMENT AGENCIES
 Bay Area Air Quality Mgmnt. District
 939 Ellis Street
 San Francisco, CA  94109
 Ms. Carol Lee
 Mr. Dan Belik
 Ms. Sandra Lopez

 City of Dallas,  Env. Health Div.
 320 E.  Jefferson,  Rm. LL 13
 Dallas, TX  75203
 Mr. Gary Burlbaw

 California Air Resources Board
 P. O.  Box 2815
 Sacramento,  CA  95812
 Ms. Linda Nunn

 FL Dept.  of Environmental Regulation
 2600 Blairstone  Rd.-Twin Towers
 Tallahassee,- FL  32399-2400
 Mr. James K.  Pennington

 GA Department of Natural Resources
 205 Butler St.,  Suite 1162
 Atlanta,  GA  30334
 Mr.  Bill  Mitchell

 Illinois  Environmental Protection
 Agency
 Div.  of Air Pollution Control
 2200  Churchill Road
 Springfield,  IL  62794-9276
 Mr.  David A.  Asselmeier
 Mr.  John  Reed

 Indiana Dept.  of Environmental  Mgmnt.
 105 S.  Meridian Street
 Indianapolis,  IN 46206-6015
 Mr. David Mclver
 Ms. Ann Heighway
 Mr. Andy  Knott
 Mr.  Paul  Dubenetzky

 Maryland  Air  Management Division
 2500 Broening Highway
 Baltimore, MD 21224
 Mr. Frank Courtright

 MI  Dept.  of Natural Resources
 P. O. Box 30028
 Lansing,  MI   48909
 Mr. Bob Irvine
 Mr. Dave  Yanochko
 Mr. David Ferrier
Mr. Ray Gray
Mr. Greg  Edwards
Mr. Tom Julian
Ms. Linda Davis
 NC Dept.  of Env.,  Health,  & Nat.  Res
 8025 N.  Point Blvd.,  Suite 100
 Winston-Salem,  NC   27106
 Mr. Myron Whitely

 NC Dept.  of Environment, Health,  &
 Natural  Resources,
 P. O.  Box 950
 Mooresville,  NC 28115
 Mr. Keith Overcash

 NC Dept.  of Environment, Health,
 & Natural Resources
 P. O.  Box 27687
 Raleigh,  NC  27611
 Mr. Sammy Amerson
 Mr. Bob Wooten

 NC Dept.  of Environment, Health,  &
 Natural Resources
 Division  of Environmental  Management-
 Air Quality
 P. O.  Box 29535
 Raleigh,  NC  27626
 Mr. Alan  Klimek
 Ms. Joelle Bryan

 NC Dept.  of Environment, Health,
 & Natural Resources
 Office of Waste Reduction
 Pollution Prevention  Program
 3825 Barrett  Drive
 Raleigh,  NC  27609
 Mr.  Gary  Hunt
 Ms.  Sharon Johnson
 Mr.  David Williams

 NC Office of  the Small Business
 Ombudsman
 3825 Barret Drive
 Raleigh,  NC   27609
 Ms.  Edythe McKinney
 Ms.  Finn  Johnson

 NJ Dept.  of Environmental  Protection
 Bureau of Engineering and  Regulatory
 Support
 Trenton,  NJ   08625
 Ms.  Beth  Raddy

 NJ Dept.  of Environmental  Protection
 New Source Review
 Trenton,  NJ   08625
 Mr.  Mike  Sabol

 NY State Dept. of Env. Conservation
 50 Wolfe Road
Albany, NY  12233-3254
Mr.  Jim Coyle
                                     A-9

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 Occupational Safety & Health Admin.
 200  Constitution Avenue
 Washington,  D.  C.   20210
 Mr.  Joe  Bodie
 Mr.  Sangi  Kanth

 Occupational Safety & Health
 Administration
 Route  1, Box 259-C
 Black  Mountain,  NC  28711

 Mr.  Don  Jackson
 Ohio EPA Southeast District
 2195 Front Street
 Logan, OH   43138
 Ms.  Susan  Clay
 Mr,  Glen Greenwood

 Ohio EPA Northeast Regional  Office
 2110 East  Aurora Road
 Twinsburg, OH  44087
 Ms.  Bridgett Burns

 Ohio EPA,  Div.  of  Pollution  Control
 1800 Water Mark Drive
 Columbus,  OH 43266-0149
 Mr.  Mike Riggelman

 Ohio EPA Southwestern District
 40 South Main Street
 Dayton, OH  45402
 Mr.  Lawrence Harrell

 PA Div. of Environmental Resources
 Bureau of Air Quality
 200  Pine Street
 Williamsport, PA  17701
 Mr.  Richard  Maxwell

 PA Dept. of  Environmental Resources
 101  S. 2nd St.,  114 Executive House
 Harrisburg,  PA  -17120
 Mr.  Krishnan Ramamurthy

 San Diego County APCD
 9150 Chesapeake  Drive
 San Diego,  CA  92123
 Mr. Ben Hancock

 South Coast  Air  Quality Mgmnt.
 District
 9150 Flair Drive
 El Monte. CA 91731
 Ms. Jeanine  Pandis
 Mr. Roger Oja

Texas Air Control Board
 6330 Hwy 290  East
Austin, TX   78723
Mr. Lane Hartsock
 TN Div.  of Air  Pollution Control
 701 Broadway, Customs House 4th Fl.
 Nashville, TN   37247-3101
 Mr. David Carson

 U.  S. EPA Region V
 230 South Dearborn Street
 Chicago, ZL  60604
 Mr. Steve Rosenthal

 U.  S. Environmental Protection  Agency
 Emissions Standards Division  (MD-13)
 Research Triangle Park, NC  27711
 Mr. Paul Amodovar
 Mr. Jack Edwardson

 U.  S. EPA Region III
 841 Chestnut Building
 Philadelphia, PA  19107
 Mr. Ray  Chalmers
 Ms. Eileen Glen

 U.  S. Environmental Protection  Agency
 AEERL, MD-62B
 Research Triangle Park, NC  27711
 Mr. Charles Darviri
 Mr. Robert McCrillis

 D.  S. Environmental Protection  Agency
 Region I
 JFK Federal Building
 One Congress  Street
 Boston, MA  02203
 Ms. Janet Beloin

 VA Dept. of Air Pollution Control
 7701-03 Timberlake Road
 Lynchburg,  VA  24502
 Mr. Terry Moore

 VA State Air Pollution Control  Board
 P. O. Box 10089
 Richmond, VA  23240
Mr. Robert Mann

WI Dept. of Natural Resources
Box 7921
 Madison, WI  53707
Mr. Robert Park
Mr. Jon Heinrich
                                     A-10

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 ASSOCIATIONS

 American Furniture Manufacturers
 Assn.
 P. O. Box HP-7
 High Point, NC  27261
 .Mr. Larry Runyan

 American Furniture Manufacturers
 Association
 918 16th Street, NW, Suite 402
 Washington, DC  20006
 Mr. Joe Gerard

 American Lung Association of NC
 P. O. Box 27985
 916 W. Morgan Street
 Raleigh, NC  27611
 Mr. Steve Wilcox

 Architectural Woodwork Institute
 13924 Braddock-Road, Suite 100
 Centreville,  VA  22020
 Ms.  Judith Durham

 Business & Instit.  Furn.  Mfg.  Assn.
 2680 Horizon Drive,  S.E.,  A-l
 Grand Rapids,  MI  49546
 Mr.  Brad Miller

 Canadian Paint & Coatings Assn.
 9900 Cavendish Blvd.,  Suite 103
 Quebec St.Laurent,  Quebec,  CANADA
 H4MZVZ
 Ms.  Karen David

 Canadian Kitchen Cabinet  Assn.
 27 Goulburn Avenue
 Ottawa,  Ontario,  CANADA  K1N8C7
 Mr.  Marco Durepos

 Kitchen Cabinet  Manufacturers Assn.
 1899  Preston White Drive
 Reston,  VA 22091-4326
 Mr.  Richard Titus

 Manufacturers  of Emissions  Controls
 Assn.
 1707  L  Street, NW, Suite  570
 Washington, DC   20036
 Mr. Raymond Connor

 National  Paint & Coatings Assn.
 1500 Rhode  Island Avenue, NW
 Washington, DC  20005
 Mr. Bob Nelson
 Mr. Allen Irish

 New York  ITAC
 253 Broadway, Room 302
New York, NY  10007
Mr. Jon Zeltsman
Southern CA Finishing & Fab. Assn.
2552 Lee Avenue
S. El Monte, CA  91733
Mr. Ed Laird

Western Furnishings Mfg. Assn.
12631 East Imperial Hwy., Suite 106F
Sante Fe Springs, CA  90670
Mr. Jay Walton
                                     A-ll

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 OTHER
 CDR Associates
 100 Arapahoe Avenue
 Boulder,  CO  80302
 Mr. John Lingelbach
 Ms. Susan Wildau

 ENSR Consulting & Engineering
 35  Nagog Park
 Acton,  MA  01720
 Mr. Kevin Jameson
 Ms. Vicky Putsche

 Environmental Defense  Fund
 128 East Hargett St.
 Raleigh,  NC  27601
 Mr. Brian Morton
EnvironTech  Associates,
485 Juniper  Street
Warminster,  PA  18974
Mr. Pete Obst
Inc.
Southern California Edison
Customer Technology Application
Center
6090 N. Irwindale Avenue
Irwindale, CA  91702
Mr. Paul Delaney
Mr. John Hornung

The Furniture Mfg. and Management
Center
NC State University
Campus Box 7906
Raleigh, NC  27695

West Michigan Environmental Action
Council
Grand Valley State University
1 Campus Drive
Allendale, MI  49401
Ms. Janet Vail
IRTA
2800 Olympic Blvd. #101
Santa MOnica,  CA  90404
Ms. Katy Wolf

Journal of Waterborne Coatings
1 Technology Plaza
Norwalk, CT  06854
Mr. Stewart Ross

Miller, Johnson, Snell, & Cummiskey
800 Calder Plaza Building
Grand Rapids,  Mi  49503
Ms. Sue Perry

Patton, Boggs, & Blow
1660 Lincoln,  Suite 1975
Denver, CO  80264
Mr. J.G. Arbuckle

Rettew Associates, Inc.
3020 Columbia  Avenue
Lancaster, PA  17603
Mr. Terry Black

Ron Joseph & Associates Inc.
12514 Scully Avenue
Saratoga, CA   95070
Mr. Ron Joseph

Sierra Club
394 E. Blaisedell Dr.
Claremont, CA  91711
Mr. Freeman Allen

Sizemore & Associates
1807 Pembroke  Road
Suite 4
Greensboro, NC  27408
Mr. Trip Sizemore
                                     A-12

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           APPENDIX B.

 MODEL RULE  FOR WOOD  FURNITURE
FINISHING AND CLEANING OPERATIONS

-------

-------
            APPENDIX B.  MODEL RULE FOR WOOD FURNITURE
                 FINISHING AND CLEANING OPERATIONS

B.1   INTRODUCTION
      This  appendix presents a model rule for limiting volatile
organic  compound  (VOC)  emissions from wood  furniture
manufacturing facilities located in ozone nonattainment areas or
in the ozone transport  region.  The model rulers a product  of
negotiations with the wood furniture industry, environmental
group representatives,  State representatives, and the
U. S. Environmental Protection Agency.  -The model rule addresses
various  factors, including applicability, definitions, emission
standards, work practice standards, compliance and monitoring,
test  methods, and recordkeeping and reporting requirements,  that
need  to  be addressed in writing an enforceable rule.  The model
rule  is  for illustrative purposes only; it does not preclude the
use by States of alternative approaches, including more stringent
ones, that are consistent'with basic program requirements.
      The model rule also provides information on how to
incorporate an emission averaging program to meet the
requirements of the model rule.  The model rule does not address
all situations or options for control; it only contains the
presumptive requirements for a State to receive Federal approval
of their rules developed for the wood furniture industry.  The
Economic Incentive Program Rules (EIP),  promulgated on April 7,
1994  (59 FR 16690),  provide more general information on using
innovative strategies to meet Clean Air Act requirements,
including reasonably available control technology (RACT).  The
EIP contains a range of options for States to use in
incorporating economic  incentives/innovative strategies into

                               B-l

-------
 their  State  implementation plans  (SIP's).  A State may use  the
 EIP  rule  to  develop an alternative  trading method for meeting the
 wood furniture RACT requirements  that are defined by this model
 rule.
     This document  provides guidance on emission averaging  as
 applied specifically to the wood  furniture RACT requirements.
 None of the  provisions are intended to apply, a priori, to
 emission  trading programs  involving other source categories
 covered by SIP's or other  Clean Air Act requirements.
     Attachment 1 includes additional information pertaining to
 small  businesses.   Attachment 2 includes information related to
 the  emission standards presented  in Section B.4 and the
 monitoring requirements presented in B.6.  Attachment 3 includes
 an example of a wood furniture manufacturing facility using an
 averaging approach  to meet RACT requirements.
 B.2  APPLICABILITY
     (a)   Provisions of this rule apply to:
     (1)   Each wood furniture manufacturing facility located in
 marginal,  moderate,  serious, or severe ozone noriattainment  areas,
 or in  the ozone transport  region  that has the potential to  emit
 greater than or equal  to 25 tons per year of volatile organic
 compounds  (VOC); and
     (2)   Each wood  furniture manufacturing facility located in
 an extreme ozone nonattainment area that has the potential  to
 emit greater than or equal  to 10 tons per year of volatile
 organic compounds.
 B.3  DEFINITIONS AND NOMENCLATURE
     (a)   Provided below is a list of definitions for terms as
 they are  used in this model rule.    (State-adopted rules should
 include definitions  for these terms, as well as any other terms
 in their  rule whose  definition may be ambiguous..)
     Adhesive means  any chemical substance that is applied  for
 the purpose  of bonding  two surfaces together other than by
mechanical means.   Under this model rule,  adhesives shall not be
 considered coatings  or  finishing materials.
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     Administrator means the Administrator of the United States
 Environmental  Protection Agency or his or her authorized
 representative.
     Affected  source means a wood furniture manufacturing
 facility  that  meets the criteria listed in Section B.2(a).
     Agency means the regulatory agency responsible for
 enforcement of the rule.
     Alternative method means any method of sampling and
 analyzing for  an air pollutant that is not a reference or
 equivalent method but that has been demonstrated to the
 Administrator's satisfaction to, in specific cases, produce
 results adequate for a determination of compliance.
     As applied means the VOC and solids content of the finishing
 material  that  is actually used for coating the substrate.  It
 includes  the contribution of materials used for in-house dilution
 of the finishing material.
     Basecoat  means a coat of colored material,  usually opaque,
 that is applied before graining inks, glazing coats, or other
 opaque finishing materials and is usually topcoated for
 protection.
     Baseline  conditions means the conditions that exist prior to
 an affected source implementing controls,  such as a control
 system.
     Capture device means a hood,  enclosed room,  floor sweep, or
 other means of collecting solvent emissions or other pollutants
 into a'duct so that the pollutant can be directed to a pollution
 control device such as an incinerator or carbon adsorber.
     Capture efficiency means the fraction of all organic vapors
 generated by a process that are directed to a control device.
     Certified product data sheet means documentation furnished
by a coating supplier or an outside laboratory that provides the
VOC content by percent weight,  the solids  content by percent
weight, and density of a finishing material,  strippable booth
 coating,  or solvent,  measured using the EPA Method 24,  or an
equivalent or alternative method (or formulation data if the
coating meets the criteria specified in §  B.7(a)).   The purpose
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 of the CPDS is to assist  the  affected source  in  demonstrating
 compliance with the emission  limitations  presented  in  B.4.
 Therefore,  the VOC content  should represent the  maximum VOC
 emission potential of  the finishing material,  strippable booth
 coating,  or solvent.
      Cleaning operations  means operations  in  which  organic
 solvent is used to remove coating materials from equipment  used
 in wood furniture manufacturing operations.
      Coating means a protective,  decorative,  or  functional
 material  applied in a  thin  layer  to a surface.   Such materials
 include,  but are not limited  to,  paints, topcoats,  varnishes,
 sealers,  stains,  washcoats, basecoats, inks,  and temporary
 protective  coatings,
      Coating solids (or solids) means the part of the  coating
 that  remains after the coating is  dried or cured; solids content
 is  determined using data  from EPA Method 24, or  an  alternative or
 equivalent  method.
      Compliant  coating means  a finishing material or strippable
 booth coating that  meets  the  emission limits specified  in
 Section B.4(a)  of  this model  rule.
      Continuous  coater means a finishing system  that continuously
 applies finishing materials onto furniture parts moving along a
 conveyor  system.  Finishing materials  that are not  transferred to
 the part  are  recycled to  the  finishing material  reservoir.
 Several types of application methods  can be used with a
 continuous  coater including spraying,  curtain coating,  roll
 coating,  dip  coating, and flow coating.
      Continuous compliance means that the affected source is
meeting the emission limitations and other requirements of the
 rule  at all times and is fulfilling all monitoring and
 recordkeeping provisions of the rule in order to demonstrate
 compliance.
      Control device means any equipment that reduces the quantity
of a  pollutant that is emitted to the air.  The device may
destroy or secure the pollutant for subsequent recovery.
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 Includes,  but is not limited to,  incinerators,  carbon adsorbers,
 and condensers.
      Control device efficiency means  the ratio  of  the pollution
 released by a control device and  the  pollution  introduced to the
 control  device,  expressed as a fraction.
      Control system means the combination of  capture  and control
 devices  used to  reduce emissions  to the  atmosphere.
      Conventional air spray means a spray coating  method in which
 the coating is atomized by mixing it  with compressed  air at an
 air pressure greater than 10 pounds per  square  inch  (gauge)  at
 the point  of atomization.   Airless and air assisted airless spray
 technologies are not conventional air spray because the  coating
 is  not atomized  by mixing it with compressed  air.  Electrostatic
 spray technology is also  not considered  conventional  air spray
 because  an electrostatic  charge is employed to  attract the
 coating  to the workpiece.
      Data  quality objective (POO) approach means a set of
 approval criteria that  must be met so that data from  an
 alternative test method can be used in determining the capture
 efficiency of  a  control system.   For  additional information,  see
 Guidelines for Determining  Capture Efficiency. January 1994.
 (Docket  No.  A-93-10,  Item No. IV-B-1).
      Day means a  period of  24 consecutive  hours beginning at
 midnight local time,  or beginning at  a time consistent with a
 facility's operating  schedule.
      Disposed  offsite means  sending used organic solvents or
 coatings outside  of the facility boundaries for disposal.
      Emission means the release or discharge,  whether directly  or
 indirectly,  of VOC  into the ambient air.
      Enamel means a coat of colored material,  usually opaque,
 that  is applied as a protective topcoat over a basecoat,  primer,
or previously applied enamel coat.  In some cases,  another
 finishing material may be applied as a topcoat over the enamel.
     Equipment leak means emissions  of volatile organic compounds
from pumps, valves, flanges, or other equipment used to transfer
or apply finishing materials or organic solvents.
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      Equivalent method means  any method of sampling and analyzing
 for an  air pollutant  that  has been demonstrated to the
 Administrator's satisfaction  to have a consistent: and
 quantitatively known  relationship to the reference method under
 specific  conditions.
      Finishing application station means the part of a finishing
 operation where the finishing material is applied, e.g., a spray
 booth.
      Finishing material means a coating used in the wood
 furniture industry.   For the  wood furniture manufacturing
 industry,  such materials include, but are not limited to,
 basecoats, stains, washcoats, sealers, and topcoats.
      Finishing operation means those activities in which a
 finishing material is applied to a substrate and is subsequently
 air-dried, cured in an oven,  or cured by radiation.
      Incinerator means, for the purposes of this industry, an
 enclosed  combustion device that thermally oxidizes volatile
 organic compounds to CO and C02.   This term does not include
 devices that burn municipal or hazardous waste material.
      Lower confidence limit (LCD  approach means a set of
approval  criteria that must be met so that data from an
alternative test method can be used in determining the capture
efficiency of a control system.   For additional information,  see
Guidelines for Determining Capture Efficiency.  January 1994
 (Docket No. A-93-10,  Item No.  IV-B-1).
     Material safety data sheet (MSDS)  means the documentation
required  for hazardous chemicals by the Occupational Safety and
Health Administration (OSHA)  Hazard Communication Standard (29
CFR 1910)   for a solvent,  cleaning material,  finishing material,
or other material that identifies select reportable hazardous
ingredients of the material,  safety and health considerations,
and handling procedures.
     Noncompliant coating means  a finishing material or
strippable booth coating that has a VOC limit greater than the
emission  limitation specified in Section B.4(a)  of this model
rule.
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      Nonpermanent final finish means  a material  such as a wax,
 polish,  nonoxidizing oil,  or similar  substance that must be
 periodically reapplied to  a surface over its  lifetime to maintain
 or restore the reapplied material's intended  effect.
      Normally closed container means  a container that is closed
 unless an operator is actively engaged in activities such as
 emptying or filling the container.
      Operating parameter value means  a minimum or maximum value
 established for a control  device or process parameter that,  if
 achieved by itself or in combination  with one or more other
 operating parameter values,  determines that an owner or operator
 has complied with an applicable emission limit.
      Organic solvent means a liquid containing volatile organic
 compounds that is used for dissolving or dispersing constituents
 in a coating,  adjusting the viscosity of a coating,  cleaning, or
 washoff.   When used in a coating, the organic solvent  evaporates
 during drying and does not become a part of the  dried  film.
      Overall control efficiency means the efficiency of  a  control
 system,  calculated as the  product of  the capture and control
 device efficiencies,  expressed  as a percentage.
      Ozone nonattainment area means an area that  does  not  attain
 the National Ambient Air Quality Standard for ozone, pursuant to
 Section  107  of  the  Clean Air Act.
      Permanent  total  enclosure means a permanently  installed
 enclosure  that  completely  surrounds a source of  emissions  such
 that  all  emissions  are captured and contained for discharge  '
 through  a  control device.  The enclosure must meet the criteria
presented  in §  B.7(e)(l)(i) through (iv).  For additional
 information,  see Guidelines for Determining Capture Efficiency.
January  1994  (Docket No. A-93-10, Item No. IV-B-1).
      Potential  to emit means the maximum capacity of a stationary
source to  emit a pollutant  under its physical and operational
design.  Any physical or operational limitation on the capacity
of the source to emit a pollutant,  including air pollution
control equipment and restrictions  on hours of operation or on
the type of material combusted, stored, or processed, shall be
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 treated as part  of  the  design  if  the  limitation or the effect  it
 would have on emissions is  federally  enforceable.
      Recycled onsite means  the resuse of an organic solvent  in a
 process other than  cleaning or washoff.
      Reference method means any method of sampling and analyzing
 for an air pollutant that is published in Appendix A of
 40 CFR 60.
      Responsible official has  the meaning given to it in
 40 CFR Part 70,  State Operating Permit Programs (Title V
 permits).
      Sealer means a finishing material used to seal the pores  of
 a wood substrate before additional coats of finishing material
 are applied.   Washcoats, which are used in some finishing systems
 to optimize aesthetics, are not sealers.
      Solvent means  a liquid used in a coating for dissolving or
 dispersing  constituents in a coating, adjusting the viscosity  of
 a coating,  cleaning, or washoff.  When used in a coating, it
 evaporates  during drying and does not become a part of the dried
 film.
      Stain  means any color coat having a solids content by weight
 of no more  than  8.0 percent that is applied in single or multiple
 coats directly to the substrate.  Includes,  but is not limited
 to, nongrain  raising stains, equalizer stains, sap stains,  body
 stains, no-wipe stains,  penetrating stains,  and toners.
     Storage  containers means vessels or tanks,  including mix
 equipment,  used to hold finishing, cleaning,  or washoff
materials.
     Strippable booth coating means a coating that:   (1)  is
applied to  a booth wall to provide a protective film to receive
overspray during finishing operations; (2)  that is subsequently
peeled off  and disposed; and (3)  by achieving (1)  and (2),
reduces or  eliminates the need to use organic solvents to clean
booth walls.
     Substrate means the surface onto which coatings are applied
 (or into which coatings are impregnated).
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      Temporary total enclosure means an enclosure that meets the
 requirements of § B.7(e)(1)(i) through (iv)  and is not permanent,
 but constructed only to measure the capture  efficiency of
 pollutants emitted from a given source.  In  addition to meeting
 the requirements of § B.7(e)(1)(i)  through (iv),  any exhaust
 point from the enclosure shall be at least 4 equivalent duct or
 hood diameters from each natural draft opening.   For additional
 information,  see Guidelines  for Determining  Capture Efficiency.
 January 1994 (Docket No.  A-93-10,  Item No. IV-B-1).
      Thinner means a volatile  liquid that is used to dilute
 coatings (to reduce viscosity,  color strength,  and solids, or to
 modify drying conditions).
      Topcoat means the last  film-building finishing material
 applied in a finishing system.   Non-permanent final finishes are
 not topcoats.
      Touch-up and repair  means the  application of finishing
 materials  to cover minor  finishing  imperfections.
      Volatile organic compound (VOC)  means any organic  compound
 that  participates  in atmospheric photochemical  reactions; that
 is, any organic  compound  other than those that  the  Administrator
 designates  as  having negligible photochemical  reactivity.  VOC  is
 measured by a reference method, an  equivalent method, an
 alternative method,  or by procedures  specified under any rule.   A
 reference method,  an equivalent method, or an alternative method,
 however, may also measure nonreactive organic compounds.  In such
 cases,  any  owner or operator may exclude  the nonreactive organic
 compounds when determining compliance with a standard.  For  a
 list  of  compounds  that the Administrator  has designated as having
 negligible  photochemical reactivity, refer to 40 CFR  51.00.
     Washcoat means  a  transparent special purpose coating having
a solids content by  weight of 12.0 percent or less.  Washcoats
are applied over initial stains to protect and control color and
to stiffen  the wood  fibers in order to aid sanding.
     Washoff operations means those operations in which organic
solvent is used to remove coating from a substrate.
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      Waterbome coating means  a  coating  that  contains more than
 five  percent water by weight in  its  volatile  fraction.
      Wood furniture means  any  product made  of wood,  a wood
 product  such as rattan or  wicker,  or an  engineered wood product
 such  as  particleboard that is  manufactured  under any of the
 following standard industrial  classification  codes:   2434,
 2511,  2512,  2517,  2519,  2521,  2531,  2541, 2599,  or 5712.
      Wood furniture component  means  any  part  that is used in the
 manufacture  of  wood furniture.   Examples include,  but are not
 limited  to,  drawer sides,  cabinet  doors, seat cushions,  and
 laminated tops.
      Wood furniture manufacturing  operations  means the finishing,
 cleaning,  and washoff operations associated with the production
 of wood  furniture  or wood  furniture  components.
      Working day means a day,  or any part of  a day,  in which a
 facility is  engaged in manufacturing.
      (b)   The nomenclature used  in this  rule  has the following
 meaning:
      (1)   A^ =  the  area of each natural  draft opening (k)  in a
 total enclosure, in square meters.
      (2)   C  = the VOC content  of a coating  (c),  in kilograms of
VOC per  kilogram of  coating solids (kg VOC/kg solids),  as
applied.   Also given in  pounds of  VOC per pound  of coating  solids
 (Ib VOC/lb solids),  as applied.
      (3)   Ca.j =  the  concentration  of VOC in gas  stream (j)
exiting  the  emission control device,  in parts per  million by
volume.
      (4)    CJ.JJL =  tne  concentration  of VOC in gas  stream  (i)
entering  the  emission  control device, in parts per million  by
volume.
      (5)    Cdi =  the  concentration of VOC in gas  stream  (i)
entering  the  emission  control device from the affected  emission
point(s),  in  parts per million by volume.
      (6)    Cfk =  the  concentration of VOC in each uncontrolled gas
stream (k) emitted directly to the atmosphere from the  affected
emission point(s),  in parts per million by volume.
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      (7)   E = the emission limit achieved by the affected
 emission point(s), in kg VOC/kg solids.
      (8)   F = the control device efficiency,  expressed as a
 fraction.
      (9)   FV = the average inward face velocity across all
 natural draft openings in a total enclosure,  in meters per hour.
      (10)  N = the capture efficiency,  expressed as a fraction.
      (11)  Q_-: = the volumetric flow rate of  gas stream (j)
             AJ
 exiting the emission control device,  in dry standard cubic meters
 per hour.
      (12)  Qj.,^ = the volumetric flow rate of  gas stream (i)
 entering  the emission control device,  in dry  standard cubic
 meters  per hour.
      (13)  Q^ = the volumetric flow rate of  gas stream (i)
 entering  the emission control device from the affected emission
 point(s), in dry standard cubic meters  per hour.
      (14)  Qj^ =  the volumetric flow rate of  each uncontrolled
 gas stream (k)  emitted directly to the  atmosphere from the
 affected  emission point(s),  in dry standard cubic meters per
 hour.
      (15)   Q^n ^  = the volumetric flow  rate of gas stream (i)
 entering  the total enclosure  through a  forced makeup air duct,  in
 standard  cubic meters per hour (wet basis).
      (16)   Qout -i  -  tne volumetric flow rate  of gas stream (j)
 exiting the total  enclosure through an  exhaust duct or hood,  in
 standard  cubic meters per hour (wet basis).
      (17)   R = the overall efficiency of  the  control  system,
 expressed as a percentage.
 B.4  EMISSION  STANDARDS
      (a)   Each owner  or operator  of an  affected source subject  to
 this rule shall limit VOC emissions from  finishing  operations by:
      (1)   Using topcoats  with a VOC content no greater than
 0.8 kg VOC/kg  solids  (0.8  Ib VOC/lb solids),  as applied;  or
     (2)   Using a  finishing system of sealers  with  a VOC content
no greater than 1.9 kg VOC/kg solids  (1.9 Ib VOC/lb solids), as
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applied,  and topcoats with a VOC content no greater than 1.8 kg
VOC/kg  solids (1.8 Ib VOC/lb solids),  as applied; or
      (3)   For affected sources using acid -cured alkyd amino vinyl
sealers or acid- cured alkyd amino conversion varnish topcoats,
using sealers and topcoats based on the following criteria:
      (i)   If the  affected source is using acid- cured alkyd amino
vinyl sealers and acid- cured alkyd amino conversion varnish
topcoats,  the sealer shall contain no more than 2.3 kg VOC/kg
solids  (2.3  Ib VOC/lb solids),  as applied,  and the topcoat shall
contain no more than 2.0  kg VOC/kg solids (2.0 Ib VOC/lb solids) ,
as applied;  or
      (ii)  If. the affected source is using a sealer other than an
acid- cured alkyd  amino vinyl sealer and acid- cured alkyd amino
conversion varnish topcoats,  the sealer shall contain no more
than 1.9  kg  VOC/kg solids (1.9  Ib VOC/lb solids), as applied, and
the topcoat  shall contain no more than 2.0  kg VOC/kg solids
(2.0 Ib VOC/lb solids), as applied;  or
      (iii)   if the affected source is  using an acid- cured alkyd
amino vinyl  sealer and a  topcoat other than an acid- cured alkyd
amino conversion  varnish  topcoat,  the  sealer shall contain no
more than 2.3  kg  VOC/kg solids  (2.3  Ib VOC/lb solids),  as
applied,  and the  topcoat  shall  contain no more than 1.8 kg VOC/kg
solids  (1.8  Ib VOC/lb solids),  as applied;  or
      (4)  Meeting the provisions established in B.10 for sources
using an  averaging approach and demonstrating that actual
emissions  from the affected source are less than or equal to the
lower of  the  actual versus allowable emissions using one of the
following  inequalities:
       0.9 (0.8  (TCi + TC2 + . . .))  ^(ER^)  (TCJ  + ER^ (TC2)  +  . . . )    (1)
     0.9 {[1.8 (TCj + TC2 + ...)] + [1.9 (SEj + S^ + . . )] 4-
     [9.0 (WCj + WCj + ...)] + [1.2 (BCj -f BC2 +...)] +
     [0.791 (STi + ST2 + . . .)]} £ [ERTC1 (TCJ + ERTC2 (TC^) + ...] +
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      [ERSE1 (SEj) -f ERSE2 (SE^ + ...] + (ERWC1 (WCj) + ERWC2 (WCj) + ...] +
      [ERBCJ CBCj) + ERBC2 (BC2) + ...] + [ER^ (ST^ -f ER^ (ST2) + . . .]
 where:
           -= kilograms of solids of topcoat "i" used;
           = kilograms of solids of sealer "i" used;
           «= kilograms of solids of washcoat "i" used;
           «= kilograms of solids of basecoat "i" used;
           * liters of stain "i"  used;
     ERTCi « VOC content of  topcoat "i" in kg VOC/kg solids, as
             applied;
     ERSEi * VOC content of  sealer "i" in kg VOC/kg solids, as
             applied;
     ERWCi = VOC content of  washcoat "i" in kg VOC/kg solids, as
             applied;
     ERBCi = VOC content of  basecoat "i" in kg VOC/kg solids, as
             applied;  and
     ERSTi = VOC content of  stain "i"  in kg VOC/liter  (kg/1), as
             applied.
      In  inequalities  (l)  and (2)  the  facility must use the actual
VOC  content of the finishing materials used before they were
subject  to  RACT if the VOC  content is less  than the allowed VOC
content.  For  example,  if the facility was  using topcoats with a
VOC  content of 1.7 kg VOC/kg solids (Ib VOC/lb solids) before
being subject  to RACT,  they need to use that value in inequality
 (2)  rather  than 1.8.
      (5)  Using a  control system that will  achieve an equivalent
reduction in emissions as the requirements  of paragraph (a)(1)  or
 (2)  of this section,  as calculated using the compliance
provisions  in  section B.6(a)(2)  of this rule,  as appropriate; or
      (6)  Using a  combination of  the  methods presented in
paragraphs  (a)(l),  (2),  (3),  (4),  and (5).
      (b)  Each owner  or operator  of an affected source subject to
this rule shall limit VOC emissions from cleaning operations when
using a strippable booth  coating.   A  strippable booth coating
shall contain  no more than  0.8 kg VOC/kg  solids,  as applied
(0.8 Ib VOC/lb solids).
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 B.5   WORK PRACTICE STANDARDS
      (a)   Work practice^-mplementation  plan.
      (l)   Each owner or  operator  of  an  affected  source  subject  to
 this  rule shall prepare  and maintain a  written work practice
 implementation plan that defines  work practices  for each  wood
 furniture manufacturing  operation and addresses  each of the
 topics  specified  in paragraphs  (b) through  (j) of this  section.
 The plan  shall be developed no more  than 60 days after  the
 compliance date.   The owner or operator of the affected source
 shall comply with each provision  of  the work practice
 implementation plan.  The written work  practice  implementation
 plan shall be  available  for inspection  by the Agency, upon
 request.   If the  Agency  determines that the work practice
 implementation plan does not adequately address each of the
 topics  specified  in paragraphs  (b) through  (j) of this  section,
 the Agency may require the  affected  source to modify the  plan.
      (b)   Operator  training course.   Each owner or operator of an
 affected  source shall train all new  and existing personnel,
 including contract  personnel,  who are involved in finishing,
 cleaning,  or washoff operations or implementation of the
 requirements of this rule.  All new personnel, those hired after
 the effective  date  of the rule, shall be trained upon hiring.
All existing personnel,  those hired before the effective  date of
 the rule,  shall be  trained within 6 months of the effective date
of the  rule.   All personnel shall be given refresher training
annually.  The affected source shall maintain a copy of the
training program with the work practice implementation plan.  The
 training program shall include, at a minimum,  the following:
     (1)  A list of all current personnel by name and job
description that are required to be trained;
     (2)  An outline of the subjects to be covered in the initial
and refresher training for each position,  or group of personnel;
     (3)  Lesson plans for courses to be given at the initial and
the annual refresher training that include,  at a minimum,
appropriate application techniques,  appropriate cleaning and
washoff procedures, appropriate equipment setup and adjustment to
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 minimize finishing material usage and overspray,  and appropriate
 management of cleanup wastes; and
      (4)   A description of the methods to be used at the
 completion of initial or refresher training to demonstrate and
 document successful completion and a record of the date each
 employee is trained.
      (c)   Leak inspection and maintenance plan.   Each owner or
 operator of an affected source shall prepare and  maintain with
 the work practice implementation plan a written leak inspection
 and maintenance plan that specifies:
      (1)   A minimum visual inspection frequency of once per month
 for all  equipment used to transfer or apply finishing materials
 or organic solvents;
      (2)   An inspection schedule;
      (3)   Methods for documenting the date and results of each
 inspection and any repairs that were mad,e;
      (4)   The timeframe between identifying a leak and making  the
 repair, which adheres to the following schedule:
      (i)   A first attempt at repair (e.g.,  tightening of packing
 glands) shall be made no later than 5 working days after the leak
 is  detected;  and
      (ii)   Final repairs shall be  made within 15  working days,
 unless the leaking equipment is to be replaced by a new purchase,
 in  which  case repairs shall  be completed  within 3  months.
      (d)   Cleaning and washoff solvent accounting system.   Each
 owner or  operator of an affected source shall  develop an organic
 solvent accounting form to record:
      (1)   The quantity and type of  organic  solvent  used each
month for washoff  and cleaning;
      (2)   The number of  pieces  washed off,  and the  reason for  the
washoff;  and
      (3)   The  net  quantity of  spent  organic solvent generated
from each  activity.   The net quantity of spent solvent  is
equivalent to  the  total amount  of organic solvent that  is
generated  from the activity minus any organic  solvent  that  is
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reused  onsite  for operations other  than cleaning or washoff and
any organic  solvent that was sent offsite for disposal.
      (e)  Spray booth cleaning.  Each owner or operator of an
affected  source shall not use compounds containing more than
8.0 percent  by weight of VOC for cleaning spray booth components
other than conveyors, continuous coaters and their enclosures,
and/or  metal filters, unless the spray booth is being
refurbished.   If the spray booth is being refurbished, that is,
the spray booth coating or other material used to cover the booth
is being  replaced, the affected source shall use no more than
1.0 gallon of  organic solvent to prepare the booth prior to
applying  the booth coating.
      (f)  Storage recruirements.  Each owner or operator of an
affected  source shall use normally closed containers for storing
finishing, cleaning, and washoff materials.
      (g)  Application equipment requirements.  Each owner or
operator  of  an affected source shall not use conventional air
spray guns for applying finishing materials except under any of
the following  circumstances:
      (1)  To apply finishing materials that have a VOC content no
greater than 1.0 kg VOC/kg solids (1.0 Ib VOC/lb solids), as
applied;
      (2)  For touch-up and repair under the following
circumstances:
      (i)  The finishing materials are applied after completion of
the finishing operation; or
      (ii)   The finishing materials are applied after the stain
and before any other type of finishing material is applied, and
the finishing materials are applied from a container that has a
volume of no more than 2.0 gallons.
      (3)  If spray is automated, that is,  the spray gun is aimed
and triggered automatically, not manually;
      (4)  If emissions from the finishing application station are
directed  to a control device;
      (5)  The conventional air gun is used to apply finishing
materials and the cumulative total usage of that finishing
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 material is no more than 5.0 percent of. the total gallons of
 finishing material used during that semiannual reporting period;
 or
      (6)   The conventional air gun is used to apply stain on a
 part for which it is technically or economically infeasible to
 use any other spray application technology.  The affected source
 shall demonstrate technical or economic infeasibility by
 submitting to the Agency a videotape,  a technical report,  or
 other documentation that supports the affected source's claim of
 technical or economic infeasibility.   The following criteria
 shall be used,  either independently or in combination,  to support
 the affected source's claim of technical or economic
 infeasibility:
      (i)   The production speed is too high or the part  shape is
 tt>o complex for one operator to coat  the part and the application
 station is not  large enough to accommodate an additional
 operator;  or
      (ii)   The  excessively large vertical spray area of the part
 makes it  difficult  to avoid sagging or runs in the stain.
      (h)   Line  cleaning.   Each owner  or operator of an  affected
 source  shall pump or drain all organic solvent used for line
 cleaning  into a normally  closed container.
      (i)   Gun cleaning.   Each  owner or operator of an affected
 source  shall collect all  organic solvent  used to clean  spray guns
 into  a  normally closed container.
      (j)   Washoff operations.   Each owner or operator of an
 affected  source shall  control  emissions  from washoff  operations
 by:
      (1)   Using normally  closed tanks  for washoff;  and
      (2)   Minimizing dripping  by tilting  or rotating  the part to
 drain as much organic  solvent  as possible.
 B.6  COMPLIANCE PROCEDURES AND MONITORING REQUIREMENTS
      (a)   The owner  or operator  of an  affected source subject to
 the emission standards in  § B.4  of this rule  shall  demonstrate
 compliance with  those provisions by using  any  of  the  following
methods:
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      (1)   To  support  that  each  sealer,  topcoat, and  strippable
booth  coating meets the  requirements of § B.4(a)(1),  (2),  or  (3)
or B.4(b)  of  this  rule,  maintain certified product data  sheets
for each  of these  finishing materials.   If solvent or other VOC
is added  to the finishing  material before application, the
affected  source shall maintain  documentation showing the VOC
content of the finishing material as applied, in kg  VOC/kg solids
(Ib VOC/lb solids).
      (2)   To  comply through the use of  a control system  as
discussed in  B.4(a)(5):
      (i)   Determine the  overall control  efficiency needed  to
demonstrate compliance using Equation 3;
                      R =  KC - E)/C] (100)                     (3)
      (ii)  Document that the value of C  in Equation  3 is obtained
from the VOC  and solids  content of the as-applied finishing
material;
      (ill)  Calculate the  overall efficiency of the  control
device, using the procedures in § B.7(d) or (e), and demonstrate
that the value of R calculated by Equation 6 is equal to or
greater than  the value of  R calculated by Equation 3.
      (b)   Initial compliance.
      (l)   Owners or operators of an affected source  subject to
the provisions of § B.4(a)(l),  (2),  or  (3)  or B.4(b)  that  are
complying  through the procedures established in § B.6(a)(l) shall
submit an  initial compliance status report,  as required  by
B.9(b), stating that compliant sealers and/or topcoats and
strippable booth coatings  are being used by the affected source.
     (2)   Owners or operators of an affected source subject to
the provisions of B.4(a)(l),  (2), or (3) that are complying
through the procedures established in B.6(a)(1) and are  applying
sealers and/or topcoats  using continuous coaters shall
demonstrate initial compliance by:
     (i)   Submitting an initial compliance status report stating
that compliant sealers and/or topcoats,  as determined by the VOC
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 content of the finishing material in the reservoir and the VOC
 content as calculated from records, are being used; or
      (ii)   Submitting an initial compliance status report stating
 that compliant sealers and/or topcoats, as determined by the VOC
 content of the finishing material in the reservoir, are being
 used and the viscosity of the finishing material in the reservoir
 is being monitored.   The affected source shall also provide data
 that demonstrates the correlation between the viscosity of the
 finishing material and the VOC content of the finishing material
 in the  reservoir.
      (3)   Owners or operators of an affected source using a
 control system (capture device/control device)  to comply with the
 requirements of  this rule,  as allowed by §§ B.4(a)(5)  and
 B.6(a)(2)  shall  demonstrate initial compliance by:
      (i)   Submitting a monitoring plan that identifies the
 operating  parameter  to be monitored for the capture device and
 discusses  why the parameter is appropriate for demonstrating
 ongoing compliance;
      (ii)   Conducting an initial performance test using the
 procedures and test  methods listed in § B.7(c)  and (d)  or (e);
      (iii)   Calculating the overall control efficiency (R)  using
 Equation 6;  and
      (iv)   Determining those operating conditions critical to
 determining compliance and  establishing operating parameters  that
 will ensure compliance with the  standard.
      (A)   For  compliance with a  thermal incinerator, minimum '
 combustion temperature shall be  the operating parameter.
      (B)   For  compliance with a  catalytic  incinerator  equipped
with a  fixed catalyst  bed,  the minimum gas  temperature both
upstream and downstream of  the catalyst bed shall be the
operating parameter.
      (C)   For  compliance with a  catalytic  incinerator  equipped
with a  fluidized  catalyst bed, the  minimum gas  temperature
upstream of the catalyst  bed and the pressure drop across  the
catalyst bed shall be  the operating parameters.
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      (D)   For compliance with a  carbon adsorber,  the operating
parameters shall  be  either  the total regeneration mass stream
flow for  each regeneration  cycle and the carbon bed temperature
after each regeneration, or the  concentration level of organic
compounds exiting the adsorber,  unless the owner  or operator
requests  and  receives approval from the Administrator to
establish other operating parameters.
      (E)   For compliance with a  control device not listed in this
section,  the  operating parameter shall be established using the
procedures identified in section B.6(c)(3)(vi).
      (v)   Owners  or  operators complying with paragraph (b) (3) of
this  section  shall calculate the site-specific operating
parameter value as the arithmetic average of the maximum or
minimum operating parameter values, as appropriate, that
demonstrate compliance with the  standards, during the three test
runs  required by§B.7(c)(l).
      (4)   Owners  or  operators of an affected source subject to
the work  practice standards in section B.5 shall submit an
initial compliance status report, as required by B.9(b),  stating
that  the  work practice implementation plan has been developed and
procedures have been established for implementing the provisions
of the plan.
      (c)   Continuous compliance demonstrations.
      (1)   Owners or  operators of an affected source subject to
the provisions of §  B.4 that are complying through the procedures
established in § B.6(a)(l)  shall demonstrate continuous
compliance by using  compliant materials,  maintaining records that
demonstrate the materials are compliant,  and submitting a
compliance certification with the semiannual report required by
§ B.9(c) .
      (i)  The compliance certification shall state that compliant
sealers and/or topcoats and strippable booth coatings have been
used each day in the semiannual reporting period,  or should
otherwise  identify the days of noncompliance and the reasons for
noncompliance.  An affected source is in violation of the
standard whenever a noncompliant material,  as determined by
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 records or by a sample of the finishing material,  is used.  Use
 of a noncompliant material is a separate violation for each day
 the noncompliant material is used.
      (i±)   The compliance certification shall be signed by a
 responsible official of the company that owns or operates the
 affected source.
      (2)   Owners or operators of an affected source subject to
 the provisions of B.4 that are complying through the procedures
 established in B.6(a)(1)  and are applying sealers  and/or topcoats
 using continuous coaters  shall demonstrate continuous compliance
 by following the procedures in (i)  or (ii)  of this paragraph.
      (i)   Using compliant materials,  as determined by the VOC
 content of the finishing  material in the reservoir and the VOC
 content as calculated from records,  and submitting a compliance
 certification with the semiannual report required  by B.9(c).
      (A)   The compliance  certification  shall state that compliant
 sealers and/or topcoats have been used  each day in the semiannual
 reporting  period,  or should otherwise identify the days of
 noncompliance and the reasons for noncompliance.   An affected
 source  is  in violation of the standard  whenever a  noncompliant
 material,  as determined by records or by a  sample  of the
 finishing  material,  is used.   Use of  a  noncompliant material  is a
 separate violation for each day  the noncompliant material is
 used.
      (B)   The compliance  certification  shall  be signed by a
 responsible  official  of the company that  owns or operates the"
 affected source.
      (ii)  Using  compliant  materials, as  determined by the VOC
 content of the  finishing  material in  the  reservoir,  maintaining
 a viscosity  of  the  finishing material in  the  reservoir that is no
 less than  the viscosity of  the initial  finishing material by
monitoring the viscosity  with a viscosity meter or  by  testing  the
viscosity of  the  initial  finishing material and retesting the
material in  the reservoir each time solvent  is  added,  maintaining
records of solvent additions, and submitting  a  compliance
certification with the  semiannual report required by B.9(c).
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      (A)  The  compliance  certification shall state that compliant
sealers and/or topcoats,  as  determined by the VOC content of the
finishing material  in  the reservoir, have been used each day in
the semiannual reporting  period.  Additionally, the certification
shall state that the viscosity of the finishing material in the
reservoir has  not been less  than the viscosity of the initial
finishing material, that  is, the material that is initially mixed
and placed in  the reservoir, for any day in the semiannual
reporting period.
      (B)  The  compliance  certification shall be signed by a
responsible official of the  company that owns or operates the
affected source.
      (C)  An affected  source is in violation of the standard
when a sample  of the as-applied finishing material exceeds the
applicable limit established in B.4(a)(l), (2), or (3), as
determined using EPA Method  24, or an alternative or equivalent
method, or the viscosity  of  the finishing material in the
reservoir is less than the viscosity of the initial finishing
material.
      (3)  Owners or operators of an affected source subject to
the provisions of B.4  that are complying through the use of a
control system  (capture/control device)  shall demonstrate
continuous compliance by  installing, calibrating,  maintaining,
and operating the appropriate monitoring equipment according to
manufacturers specifications.
      (i)  Where a capture/control device is used,  a device to
monitor the site-specific operating parameter established in
accordance with B.6(b)(2)(i)  is required.
      (ii)  Where an incinerator is used,  a temperature monitoring
device equipped with a continuous recorder is required.
      (A)  Where a thermal incinerator is used,  a temperature
monitoring device shall be installed in the firebox or in the
ductwork immediately downstream of the firebox in a position
before any substantial heat exchange occurs.
      (B)  Where a catalytic  incinerator equipped with a fixed
catalyst bed is used,  temperature monitoring devices shall be
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 installed in the gas stream immediately before and after the
 catalyst bed.
      (C)   Where a catalytic incinerator equipped with a fluidized
 catalyst bed is used,  a temperature monitoring device shall be
 installed in the gas stream immediately before the bed.  In
 addition,  a pressure monitoring device shall be installed to
 determine the  pressure drop across the catalyst bed.   The
 pressure drop  shall be measured monthly at a constant flow rate,
      (ill)   Where a carbon adsorber is used:
      (A)   An integrating regeneration stream flow monitoring
 device  having  an accuracy of +. 10 percent,  capable of recording
 the  total  regeneration stream mass flow for each regeneration
 cycle;  and a-carbon bed temperature monitoring device having an
 accuracy of ±1 percent of the temperature  being monitored
 expressed  in degrees Celsius or +0.5 C,  whichever is  greater,
 capable of  recording the carbon bed temperature after each
 regeneration and within 15 minutes of completing any  cooling
 cycle;
      (B)  An organic monitoring device,  equipped with a
 continuous  recorder,  to indicate the concentration level  of
 organic compounds exiting the carbon adsorber;  or
      (C)  Any  other monitoring device that  has  been approved by
 the Administrator as allowed under B,6(b)(3)(iv)(D).
      (iv)   Owners or operators of  an affected source  shall not
 operate the capture  or control device at a  daily average  value
 greater than or  less than (as appropriate)   the  operating
 parameter value.   The  daily  average  value shall  be  calculated as
 the average of all values  for a monitored parameter recorded
 during  the  operating day.
      (v)  Owners  or  operators  of an  affected source that  are
 complying through the  use  of  a catalytic incinerator  equipped
with a  fluidized  catalyst  bed shall  maintain a  constant pressure
drop, measured monthly, across  the catalyst bed.
      (vi)  An owner  or operator using  a control  device not listed
in this section shall  submit  to the  Administrator a description
of the device,  test  data verifying the performance  of the device,
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 and appropriate  operating parameter values that will be monitored
 to  demonstrate continuous compliance with the standard.
 Compliance  using this device  is  subject to the Administrator's
 approval.
      (4)  Owners or operators of an affected source subject to
 the work practice standards in § B.5 shall demonstrate continuous
 compliance  by following the work practice implementation plan and
 submitting  a compliance certification with the semiannual report
 required by § B.9(c).
      (i)  The compliance certification shall state that the work
 practice implementation plan is  being followed, or should
 otherwise identify the periods of noncompliance with the work
 practice standards.  Each failure to implement an obligation
 under the plan during any particular day is a separate violation.
      (ii)   The compliance certification shall be signed by a
 responsible official of the company that owns or operates the
 affected source.
 B.7  PERFORMANCE TEST METHODS
      (a)  The EPA  Method 24 (40  CFR 60) shall be used to
 determine the VOC  content and the solids content by weight of the
 as  supplied finishing materials.   The owner or operator of the
 affected source may request approval from the Administrator to
 use an alternative or equivalent method for determining the VOC
 content of  the finishing material.  If it is demonstrated to the
 satisfaction of the Administrator that a finishing material does
 not release VOC reaction byproducts during the cure (that is,  no
VOC is produced by the reaction), for example,  all VOC is
 solvent, then batch formulation  information shall be accepted.
 In the event of any inconsistency between an EPA Method 24 test
and a facility's formulation data, that is,  if the EPA Method 24
value is higher,  the EPA Method 24 test shall govern.   Sampling
procedures  shall follow the guidelines presented in "Standard
 Procedures  for Collection of Coating and Ink Samples for VOC
 Content Analysis by Reference Method 24 and Reference
Method 24A," EPA-340/1-91-010.
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      (b)   Owners or operators demonstrating compliance with the
 provisions of this rule via a control system shall determine the
 overall control efficiency of the control system (R)  as the
 product of the capture and control device efficiencies, using the
 test methods cited in § B.7(c)  and the procedures in § B.7 (d)  or
 (e) .
      (c)   Owners or operators using a control system shall
 demonstrate initial compliance using the procedures in paragraphs
 (c)(1)  through (c)(6)  of this section.
      (1)   The EPA Method 18,  25,  or 25A (40 CFR 60)  shall be used
 to determine the VOC concentration of gaseous air streams.  The
 test shall consist of  three separate runs,  each lasting a minimum
 of 30 minutes.
      (2)   The EPA Method 1 or 1A  (40 CFR 60)  shall be used for
 sample  and velocity traverses.
      (3)   The EPA Method 2,  2A, 2C,  or 2D (40 CFR 60)  shall be
 used to measure velocity and volumetric flow rates.
      (4)   The EPA Method 3 (40  CFR 60)  shall be used  to analyze
 the  exhaust gases.
      (5)   The EPA Method 4 (40  CFR 60)  shall be used  to measure
 the  moisture in the stack gas.
      (6)   The EPA Methods 2,  2A,  2C,  2D.  3,  and 4 shall be
 performed,  as applicable,  at  least twice  during each  test period.
      (d)   Owners  or operators using  a control system  to
 demonstrate compliance with this  rule shall  use the following
 procedures:
      (1)   Construct the  overall VOC  control  system so that
volumetric flow rates and VOC concentrations  can be determined  by
 the  test methods  specified in § B.7(c)(l) through (6);
      (2)   Measure the capture efficiency  from the affected
emission point(s) by capturing, venting,  and  measuring all VOC
emissions  from  the  affected emission  point(s).   To measure the
capture efficiency  of a  capture device  located in an  area with
nonaffected VOC emission point(s), the  affected emission point(s)
shall be isolated from all other VOC  sources  by one of the
following methods:
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      (i)   Build a  temporary total enclosure  (see  §  B.3)  around
the affected emission point (s);
      (ii)   Shut down all  nonaffected VOC emission point (s)  and
continue  to exhaust  fugitive emissions  from  the affected emission
point (s)  through any building ventilation system  and other  room
exhausts  such as drying ovens.  All  exhaust  air must be  vented
through stacks  suitable for testing; or
      (Hi]   Use another methodology  approved by the Agency
provided  it complies with the EPA criteria for acceptance under
Part 63,  Appendix  A,  Method 301.
      (3)   Operate  the control system with all affected emission
point (s)  connected and operating  at  maximum  production rate;
      (4)   Determine  the efficiency (F)  of the control device
using Equation  4;
                      n            P
                      E   Obi Cbi - £ Qaj Caj
                 F = Ali _ ¥1 _     (4)
                             n
                            E  Qbi Cbi
     (5)  Determine the efficiency  (N) of the ceipture system
using Equation 5;
                             n
                            .E  Qdi Cdi
                 N = - ili - _ -     (5)
                      n             P
                      E  Qdi Cdi + E Qf k cf k
                     i=l          k=l

     (6)  Compliance is demonstrated if the value of (R) in
Equation 6 is greater than or equal to the value of R calculated
by Equation 3 in accordance with  § B.6(a) (2) (i) .

                         R = (F x N) (100)                       (6)

     (e)  An alternative to the compliance method presented  in
§ B.7(d) is the installation of a permanent total enclosure.  A
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 permanent total enclosure presents prima facia evidence that all
 VOC emissions from the affected emission point (s)  are directed to
 the control device.   Each affected source that complies using a
 permanent total enclosure shall :
      (1)   Demonstrate that the total enclosure meets the
 following requirements:
      (i)   The total  area of all natural draft openings shall not
 exceed 5  percent of  the  total surface area of the  total
 enclosure's walls,  floor,  and ceiling;
      (ii)   All sources of emissions within the enclosure shall be
 a minimum of four equivalent diameters away from each natural
•draft  opening;
      (Hi)   Average  inward face velocity (FV)  across all natural
 draft  openings shall be  a minimum of 3,600 meters  per hour
 (200 ft/min)  as determined by the following procedures:
      (A)   All forced makeup air ducts and all exhaust ducts are
 constructed so that  the  volumetric flow rate in each can be
 accurately determined by the test methods and procedures
 specified  in §  B.7(c) (2)  and (3).   Volumetric flow rates shall be
 calculated without the adjustment normally made  for moisture
 content; and
     (B)   Determine  FV by  the following equation:
                        n            p
                       E Qout j " E  Qin i
                                    ili _    (7)
                               q
                               E
                              k=i

      (iv)  All access doors and windows whose areas are not
included as natural draft openings and are not included in the
calculation of FV shall be closed during routine operation of the
process .
      (2)  Determine the control device efficiency using
Equation 4, and the test methods and procedures specified in
§ B.7(c) (!) through (6) .
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      (3)   If the permanent  enclosure  is  demonstrated to  be total,
 the value  of N in Equation  5  is  equal to 1.
      (4)   For owners  or  operators using  a control  system to
 comply with the provisions  of this  rule,  compliance  is
 demonstrated if:  •
      (i)   The installation  of a  permanent total enclosure is
 demonstrated (N=l); and
      (ii)   The value  of  (R) calculated by Equation 6  in
 accordance with B.7(d) is greater than or equal to the value  of  R
 calculated by Equation 3 in accordance with § B.6(a)(2).
 B.8  RECORDKEEPING REQUIREMENTS
      (a)   The owner or operator  of  an affected source subject to
 the emission limits in § B.4  of  this  rule shall maintain records
 of the following:
      (1)   A certified product data  sheet  for each  finishing
 material and strippable booth coating subject to the  emission
 limits in  B.4;
      (2)   The VOC  content,  kg VOC/kg  solids (Ib VOC Ib/solids),
 as applied,  of each finishing material and strippable booth
 coating subject  to the emission  limits in B.4, and copies  of  data
 sheets documenting how the  as applied values were determined.
      (b)   The owner or operator  of  an affected source following
 the compliance procedures of  B.6(c)(2) shall maintain the  records
 required by B.8(a) and records of the following:
      (1)   Solvent and finishing material  additions to the
 continuous  coater reservoir; and
      (2)   Viscosity measurements.
      (c)   The owner or operator of an affected source following
 the compliance method of § B.6(a)(2) shall maintain the  following
 records:
      (1)   Copies of the calculations to support the equivalency
 of using a  control system,  as well as the data that are necessary
 to support  the calculation of E in Equation 3 and the calculation
 of R in Equation 6;
      (2)   Records of the daily average value of each continuously
monitored parameter for each operating day.  If all recorded
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 values for a monitored parameter are within the range established
 during the initial performance test, the owner or operator may
 record that all values were within the range rather than
 calculating and recording an average for that day; and
      (3)   Records of the pressure drop across the catalyst bed
 for facilities complying with the emission limitations using a
 catalytic incinerator with a fluidized catalyst bed.
      (d)   The owner or operator of an affected source subject to
 the work practice standards in § B.5 of this rule shall maintain
 onsite the work practice implementation plan and all  records
 associated with fulfilling the requirements of that plan,
 including,  but not limited to:
      (l)   Records demonstrating that the operator training
 program is in place;
      (2)   Records maintained in accordance with the inspection
 and maintenance plan;
      (3)   Records associated with the cleaning solvent accounting
 system;
      (4)   Records associated with the limitation on the use of
 conventional  air spray guns showing total  finishing material
 usage  and the percentage of finishing materials applied with
 conventional  air spray guns for each semiannual reporting  period;
      (5)   Records showing the VOC content  of  compounds  used for
 cleaning  booth components,  except for solvent used to  clean
 conveyors,  continuous  coaters and their  enclosures, and/or metal
 filters;  and
      (6)   Copies  of logs and other documentation developed to
 demonstrate that  the other provisions of the  work practice
 implementation plan are followed.
      (e)   In  addition  to the records  required by paragraph (a) of
 this section,  the owner or operator of an affected source  that
 complies  via  the  provisions of  §  B.6(a)(1) or §  B.5 shall
maintain  a  copy of the  compliance certifications  submitted in
accordance  with § B.9(c)  for each semiannual  period following  the
compliance  date.
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      (f)   The  owner or operator  of an affected  source  shall
maintain  a copy  of  all other  information submitted with the
initial status report  required by § B.9(b) and  the semiannual
reports required by §  B.9(c).
      (g)   The  owner or operator  of an affected  source  shall
maintain  all records for a minimum of 5 years.
      (h)   Failure to maintain the records required by  (a) through
 (g) of this section shall constitute a violation of the rule for
each day  records are not maintained.
B.9  REPORTING REQUIREMENTS
      (a)   The  owner or operator  of an affected  source  using a
control system to fulfill the requirements of this rule are
subject to the following reporting requirements:
 (Note:  Regulatory  agencies may  want to adopt the reporting
requirements contained in § 63.7 through § 63.10 of the General
Provisions to  part  63  [MACT standards].  These  requirements
specify timeframes  for reporting performance test results,
monitoring parameter values, and excess emissions reports.)
      (b)   The  owner or operator  of an affected  source  subject to
this rule  shall  submit  an initial compliance report no later than
60 days after  the compliance date.  The report  shall include the
items required by §  B.6(b)  of this rule.
      (c)   The  owner or  operator  of an affected  source subject to
this rule  and demonstrating compliance in accordance with
§ B.6(a) (1) or (2)   shall submit a semiannual report covering the
previous 6 months of wood furniture manufacturing operations
according  to the following schedule:
     (i)   The first  report shall be submitted 30 calendar days
after the  end of the first 6-month period following the
compliance  date.
     (ii)    Subsequent reports shall be submitted within
30 calendar days after  the end of each 6-month period following
the first  report.
     (iii)  Each semiannual report shall include the information
required by § B.6(c), a statement of whether the affected source
was in compliance or noncompliance,  and,'if the affected source
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 was  in  noncompliance,  the  measures  taken to bring the affected
 source  into compliance.
 B.10 SPECIAL PROVISIONS FOR SOURCES USING AN AVERAGING APPROACH
      The  owner or operator of an affected source complying with
 the  emission limitations established in  B.4 through the .
 procedures  established in  B.4(a)(4) shall also meet the
 provisions  established in  (a)  through  (i)  of this section.
 (Attachment 3 includes an  example of a facility  that is planning
 to use  an averaging approach to  meet the requirements of the
 model rule.   The  example addresses  each  of the provisions
 discussed below.)
      (a)  Program goals and rationale.   The owner or operator of
 the  affected source shall  provide a summary of the reasons  why
 the  affected source would  like to comply with the emission
 limitations through the procedures  established in B.4(a)(4)  and a
 summary of  how averaging can be  used to  meet the emission
 limitations.   The  affected source shall  also document that  the
 additional  environmental benefit  requirement is  being met through
 the  use of  the inequalities  in B.4(a)(4).   These inequalities
 ensure  that  the affected source  is  achieving an  additional
 10 percent  reduction in emissions when compared  to affected
 sources using a compliant  coatings  approach to meet the
 requirements  of the rule.
      (b)  Program  scope.   The  owner or operator  of  the  affected
 source shall  describe  the  types of  finishing materials  that  will
 be included  in the affected  source's averaging program.  Stains,
 basecoats, washcoats,   sealers, and topcoats  may  all be  used  in
 the  averaging program.  The  affected source may  choose  other
 finishing materials for its  averaging program, provided the
 program complies with  the  State's case-by-case basis  for VOC
 averaging in the SIP.   Finishing materials that  are applied  using
 continuous coaters may only be used in an averaging program  if
 the affected source can determine the amount of  finishing
material used each day.  Although the example facility  discussed
 in Attachment 3 is meeting a daily average,  the  State may
 incorporate longer averaging periods in their rules if  the
                               B-31

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 facility  that wishes  to use a longer averaging period can
 demonstrate  that  their emissions do not fluctuate significantly
 on a day  to  day basis.
      (c)   Program baseline.  The baseline for each finishing
 material  included in  the averaging program shall be the lower of
 the actual or allowable emission rate as of the effective date of
 the State's  RACT  rule.  In no case shall the facility baseline
 emission  rate be  higher than what was presumed in the
 1990 emissions inventory for the facility unless the State has
 accounted for the increase in emissions as growth.
      (d)  Quantification procedures.  The owner or operator of
 the affected source shall specify methods and procedures for
 quantifying  emissions.  Quantification procedures for VOC content
 are included in B.7.  The owner or operator shall specify methods
 to be used for determining the usage of each finishing material.
 The quantification methods used shall be accurate enough to
 ensure that  the affected source's actual emissions are less than
 the allowable emissions,  as calculated using Inequality 1 or 2 in
 B.4(a) (4), on a daily basis to a level of certainty comparable to
 that for  traditional control strategies applicable to surface
 coating sources.
     (e)  Monitoring, recordkeeping. and reporting.   The owner or
 operator  of  an affected source shall provide a summary of the
monitoring,  recordkeeping,  and reporting procedures that will be
used to demonstrate daily compliance with the inequalities
presented in B.4(a)(4).   The monitoring,  recordkeeping,  and
 reporting procedures shall  be structured in such a way that
 inspectors and facility owners can determine an affected source's
 compliance status for any day.   Furthermore,  the procedures must
 include methods for determining required data when monitoring,
 recordkeeping,  and reporting violations result in missing,
 inadequate, or erroneous  monitoring and recordkeeping.   These
procedures must ensure that sources have sufficiently strong
 incentive to properly perform monitoring and recordkeeping.
     (f)  SIP creditability and audit/reconciliation procedures.
 [The State must specify values for rule compliance and program
                              B-32

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 uncertainty factors based on program elements  such as  the
 quantification and enforcement procedures  and  on the predictive
 quality of the information used by the State to develop  the
 projections of emission reductions.   The State must include a
 justification for the values assigned to these factors.   If a
 direct  determination of emissions  is available,  then rule
 compliance and uncertainty factors can be  presumed to  be 1.
      The State must also specify the auditing  methods  that  will
 be  used to demonstrate successful  operation of the averaging
 program.]
      (g)   Implementation schedule.   The owner  or operator of an
 affected source shall submit an averaging  proposal for State and
 EPA approval any time after [State needs to insert the date that
 EPA approves this averaging framework.  This must ensure that all
 sources  are in compliance with the State's rule  by the effective
 date.   Submittal of the averaging  proposal does  not provide an
 exemption  from the model rule.   The  source must  submit the
 averaging  proposal by a date that  allows sufficient time for EPA
 approval.]
      (h)   Administrative procedures.   [The State  needs to provide
 this  information,  which should include  the requirements  for  who
 may submit  an  averaging proposal,  who the  proposal should be
 submitted  to,  and when the  proposal may be submitted.
 Administrative procedures must  recognize that EPA must approve
 proposals  before  an averaging program may  be used  to meet the
 rule.]
      (i)   Enforcement  mechanisms.   [The State needs to
 incorporate  provisions  that provide adequate enforcement measures
 for noncompliance with  any  source requirements, including
monitoring,  recordkeeping,  and reporting.   Each program must
 include provisions  ensuring that State/local and Federal
statutory maximum penalties preserve the deterrent effect of
programs that do not allow averaging.  Enforcement provisions
should preserve the criminal sanctions  (for knowing violations)
authorized in the Clean Air Act for violations  of State-
Implementation Plan requirements.
                               B-33

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     Compliance with monitoring, recordkeeping, and reporting
requirements is critical to the integrity and success of the
averaging program.  Therefore, these penalty provisions must
include enforcement provisions that establish a regulatory
structure that clearly and effectively deters inadequate or
improper monitoring, recordkeeping, and reporting.
     The example permit located at (insert location of sample
permit that includes averaging) demonstrates how these provisions
will be applied by the (insert name of permitting authority).]
                              B-34

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 Attachment 1


               Attachment 1 to EPA's Model Rule for
              Wood Furniture Manufacturing Facilities

      The model rule reflects,  to the extent possible,  concepts
 laid out in tentative agreements by the regulatory negotiation
 committee and the "Harrisburg Work Group," a small working group
 of committee members.  Some of the items regarding small business
 which,  by their nature,  do not fit into draft model rule format
 are briefly described here:

 A.   Reporting and Recordkeeping Associated with Federally
 Enforceable VOC Limits which are Below the RACT Applicability
 Threshold

      Facilities emitting 75 percent or less of the "RACT
 applicability threshold"  should maintain records  of emissions
 based on purchases^ adjusted by inventory and submit annual
 reports.   Sources with annual  emissions of 75 percent  to
 100 percent of the RACT threshold should keep records  either
 based on purchases adjusted by inventory or based  on usage,  with
 quarterly reporting.   A source whose emissions cross from below
 the 75  percent level  to  above  should notify the permitting agency
 and submit quarterly  reports for the remainder of  that year and
 the next  year.   If such  a source emits at the 75 percent or less
 level throughout that next year,  it can ,return to  annual
 reporting the third year.

 B.   Clarification Regarding New Source Review (NSR)  for  Major
 Sources

      In response to a request  to clarify issues  dealing  with New
 Source  Review that may affect  small businesses:

      1.   If an  area source^  or "synthetic minor" source4
 modifies  its  facility but  plans  to  remain below  the  RACT
 applicability threshold, does  it, as  a result  of facility
 modifications with a  potential  increase  in VOC emissions,  have  to
 undergo NSR?
     1 The RACT applicability threshold for this model rule is
10 tons for wood furniture facility located in an extreme ozone
nonattainment area, and 25 tons per year for a wood furniture
facility located in a marginal, moderate,  serious or severe ozone
nonattainment area or the ozone transport region.

     2 VOC data on coatings must use EPA Method 24 as the basis.

     3 An area source is one whose emissions are not sufficient
to make the facility a major source.

     4 A synthetic minor source is a source which has obtained a
Federally enforceable permit limitation to limit its potential to
emit such it is no longer a major source.

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      Under current regulations,  the  source would not have  to
 undergo NSR if it requests  and is given a Federally enforceable
 limit that ensures that  it  remains below the  threshold  limit  for
 major sources and the threshold does not subsequently change.  It
 may not be necessary to  receive a new  limit if  the old  federally
 enforceable limit (1)  contains conditions that  still apply and
 (2)  ensures that  the source remains  a  minor source even after the
 modification has  occurred.   For reference, see  40 CFR 52.21(r)(4)
 and 52.21 (b)(7)  which pertain to the  "Prevention of Significant
 Deterioration," and 40 CFR  51.165  (a)(5)(ii)  and
 51.165(a)(1)(xiv)  which  pertain to nonattainment NSR.

      2.   If an area source  or  synthetic minor source increases
 its actual or potential  emissions above the applicability
 threshold and eliminates its Federally enforceable emission
 limit,  but does not modify  its plant,  does it,  as a result of its
 increase in VOC emissions,  have  to undergo NSR?

      Under current "source  obligation  provisions" in the NSR
 rules removing a  federal limitation  is considered a modification.
 Therefore,  if  removing an existing limitation causes a  source to
 have  a  potential  to emit that  is higher than  the major  source
 threshold for  the  locality,  the  source is subject to NSR.  For
 reference,  see 40  CFR  52.21(r)(4) and  52.21 (b) (7)  which pertain
 to  the  Prevention  of Significant Deterioration, and 40  CFR
 51.165(a)(5)(ii) and 51.165(a)(1)(xiv)  which  pertain to
 nonattainment  NSR.

 C.  General  Permits

      It  was  recommended  that the CTG explain  and encourage the
 use of general permits .  In addition,  the CTG should recommend
 that  small  businesses, where appropriate, establish a Federally
 enforceable permit  limitation  such that their potential to emit
 is below the RACT  applicability threshold.

 D.  Information Outreach  for small business

      It  was recommended  that an Information Outreach Program be
 developed to serve as a  resource for small wood furniture
manufacturers and  enabling or guidance document be prepared that
 will  set  forth guidance  on aspects of the CTG.  It should also
 detail the process of obtaining a Federally enforceable permit
 limitation  that restricts a facility's potential emissions to
below the RACT applicability threshold.  This is being worked on
     5 A general permit is defined under 40 CFR 70 as a permit
that meets the requirements of Section 70.6(d).  It is issued by
the permitting authority to cover numerous similar sources.  The
permitting authority grants the conditions and terms of the
general permit to sources which qualify for it.

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by the North Carolina Small Business Ombudsman with the EPA's
Federal Small Business Assistance Program.

E-  Extension of Compliance Date for RACT

     It was understood by the committee that the compliance date
for facilities to comply with RACT would be May of 1995.  The
committee recommended that a source emitting less than 50 tons of
VOC's annually be allowed an additional period of time to either
(1) establish a federally enforceable emission limit or, (2) if
it is above the RACT applicability threshold, to research
technologies, train employees, and develop recordkeeping
capabilities.  This period of time recommended is up until
November 1996.

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 Attachment 2
               Attachment 2 to EPA's Model  Rule  for
              Wood Furniture Manufacturing  Facilities


      A.   The units of "kilograms  VOC per kilogram coating  solid
 (pounds VOC per pound coating solid),"  which  are  the  units of  the
 emission  limitations  in Section B.4,  will  be  unfamiliar  to most.
 Two  notes are provided to help relate these units to  a basis
 which may be more familiar.   The  following two  notes  pertain to
 Sections  B.4.(a)(l) and B.4.(a)(2)  of the  preliminary draft model
 rule:

      1.   Section B.4(a)(1)  provides an  avenue for compliance that
 requires  the facility to use  a topcoat  with a VOC content  of no
 greater than 0.8 pounds VOC per pound of coating  solids.   A
 20 percent nitrocellulose lacquer (conventional)  topcoat has a
 VOC  content of approximately  4.0  pounds VOC per pound of solids.
 Therefore,  a topcoat  with a VOC content of 0.8  pound  VOC per
 pound of  coating solids represents  approximately  80 percent
 reduction in VOC from a 20  weight percent  solids  nitrocellulose
 lacquer topcoat.

     2.   Section B.4(a)(2)  provides an  avenue for compliance that
 requires  the facility to change both its topcoats  and sealers.
 Use  of sealers with a VOC content of  no greater than  1.9 pounds
 VOC  per pound  coating solids  represents approximately a
 53 percent  in  VOC from a 20 percent  nitrocellulose lacquer
 sealer, and use of a  topcoat  with a VOC content of no greater
 than 1.8  pounds VOC per pound solids  represents approximately  a
 55 percent  reduction  in VOC emissions from a  20 weight percent
 solids nitrocellulose lacquer topcoat.

     B.   This  model rule  also allows  some monitoring  requirements
 for  control  devices that may  not be appropriate for other  source
 categories.  These include monitoring requirements for catalytic
 incinerators equipped with a  fluidized  catalyst bed,   which are
 presented in B.6(b)(3)(iv)(C), and  for  carbon adsorbers,  which
 are presented  in B.6(b)(3)(iv)(D).  These monitoring  requirements
 have been negotiated  with the wood  furniture  industry, and the
 EPA feels that  they are appropriate for this  industry.  However,
 these monitoring requirements should not be adopted by another
source category without a complete evaluation as to whether they
are appropriate and reasonable for that source category.

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 Attachment 3
   *      Example of Permit Conditions Related to Averaging
            for a Wood Furniture Manufacturing Facility

  I.   Introduction

      On June 16,  1994,  representatives of  the Environmental
 Protection Agency visited a wood furniture manufacturing facility
 located in Pennsylvania.   The facility is  located in a
 nonattainment area and is subject to a source-specific RACT
 determination.   The source-specific RACT determination allows  the
 facility to meet the required emission limitations by averaging
 its  emissions across wood furniture finishing lines  on a
 production-weighted daily basis.   The facility also  intends  to
 use  averaging to meet the emission limitations in B.4 of this
 model rule.

      The purpose of the visit was to examine the monitoring  and
 recordkeeping practices currently being used at the  facility.
 This example provides guidance for developing source-specific
 monitoring and  recordkeeping requirements  for other  wood
 furniture manufacturing facilities.   In most cases the State must
 submit  an actual  permit that applies to a  source located within a
 nonattainment area within its borders if the State wishes to use
 the  two-step approach as  described in the  EIP to allow averaging.
 If a State's framework is extremely specific and includes all  of
 the  information related to implementation  schedule,  admini-
 strative procedures,  and  enforcement/penalty provisions,  the
 State will not  have to  submit the first  averaging protocol to  EPA
 for  approval also.   The following discussion addresses  each  of
 the  provisions  that were  presented in section B.10 of  the
 attached model  rule as  they relate to the  example facility,
 including program goals and rationale,  the program scope, the
 program baseline,  quantification  procedures,  and monitoring,
 recordkeeping,  and reporting procedures.   Each of  these
 provisions must be addressed by sources  that  wish to use  an
 averaging approach to meet  the emission  limitations presented  in
 B.4.  In addition,  the  example addresses information that needs
 to be provided by the State in which the facility  is located.

 II.  Permit  Conditions  for  Averaging

     A.   Program  Goals  and  Rationale

     Plant description.   The  facility manufactures custom office
 furniture.   The furniture is  typically finished and then
assembled.   Parts  are finished on one of two  lines, a hanging
line, where  the finishes  are  spray applied, and a flat line that
uses both  curtain  and roll  coaters.  Some pieces, such as
conference room table tops, are finished using spray application
technology in a booth.  Both  fully pigmented  finishes and wood
tone finishes are used.

     Pjrogram goals.  One of the goals of the averaging program is
to allow the facility to use  finishing materials that do not  meet

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 the  emission  limitations presented in B.4(a)(1) and  (2).  This
 facility wishes  to have this flexibility so that it  can continue
 to meet the demands  of the marketplace.  The plant will use
 finishing materials  with lower VOC contents to offset the
 emissions resulting  from the use of noncompliant finishing
 materials on  a weighted use basis.

     The facility is currently using a number of different types
 of lower-VOC  finishing materials, including waterborne and higher
 solids materials.  Many of these materials have a VOC content
 lower than the emission limitations presented in B.4(a)(1) and
 (2).  The facility also uses some waterborne basecoats.  Where
 feasible, the facility continues to explore and use  lower VOC
 finishing materials  to produce the finishes they desire.

     Because  of  the  custom nature of their work, the facility
 also chooses  to  use  finishing materials that do not meet the
 emission limitations presented in B.4.  The desire to use
 noncompliant  coatings is due partly to the need to match the
 color of previously  purchased furniture.

     The facility explored the use of abatement equipment.  They
 found, however,  that for their facility it is more cost effective
 to use averaging to  offset the emissions of the higher VOC
 finishing materials.  The facility would like to continue to
 offset the excess emissions from these higher VOC finishing
 materials by  using materials that have a lower VOC content than
 the emission  limitations in the model rule.  The facility would
 also like to  get credit for using waterborne basecoats.  The
 model rule does not  require the use of basecoats,  stains,  or
 washcoats with lower VOC contents.  Averaging would allow the
 facility to get credit for using these types of. finishing
materials with a lower VOC content.

     Averaging provides the flexibility the facility needs to
meet their product demands,  without violating the RACT emission
 limitations.   The facility feels that this flexibility will also
be needed to meet the requirements that will be established by
 the States in response to this model rule.   The facility does not
believe they will need to use averaging every day to meet the
 emission limitations.  They would like the option of using
 compliant coatings some days and an averaging program other days.

     The facility's  experience with averaging to meet the current
 State and Federal requirements has been positive.   Averaging has
 encouraged them to be innovative in their efforts to develop and
use lower-VOC finishing materials.

     Additional environmental benefit.  By using the inequalities
presented in B.4(a)(4)  of the model rule as the basis for the
 averaging program,  the facility will meet the requirement for
additional environmental benefit.  This equation ensures that the
 facility will reduce emissions an additional 10 percent over

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 facilities using a compliant coatings approach to meet the
 emission limitations.

      B.   Program Scope

      This averaging program applies  to this  facility and may be
 used by  this facility  to comply with the model rule on a daily
 basis.   The finishing  materials used in the  averaging program
 will vary from day to  day for this facility.

      C.   Program Baseline

      The baseline for  this facility  is the lower of the actual or
 allowable emissions that occurred before the application of their
 source-specific RACT requirements.

      D.   Quantification Procedures

      There are two components required to quantify the VOC
 emissions at the facility;  the amount of each finishing material
 used, including catalysts and thinners, and  the VOC content of
 each finishing material used.

      Finishing material usage is determined  by measuring the
 amount of finishing material  that the operator begins with and
 the  amount of  finishing material that is left after the operation
 is complete.   The amount of  finishing material the operator
 starts with may be measured using manufacturer supplied units,
 such as  five gallon containers, volumetric measuring devices,
 such as  a cup,  or by taking a beginning height measurement in a
 mixing pot.  After the  finishing operation is complete,  the
 operator measures the  remaining material with a yardstick to the
 nearest  0.5 inch.   The  height  measurements have been calibrated
 to determine the volume for every mixing container the company
 uses.  A copy  of the calibration tables is attached.

      Each employee is given training  on how  to obtain an accurate
 measurement.   For example, the specifications for  the use of 'the
 yardstick include putting  the  yardstick on the bottom of the
 container,  holding the  yardstick against a side, and withdrawing
 the  yardstick  to read the height (similar to  reading a dipstick
 in a car).

      The  VOC content of  the finishing material  is  calculated
using the  as supplied VOC content and  the contribution of
 thinner.    Finishing materials are sampled and tested using EPA
Method 24  to verify  the VOC content calculated from  formulation
data.

     The  facility  will use one of the  following  two  inequalities
to calculate actual and allowable emissions.

     0.9 {[1.8 (TCj + TCj +...)] + [1-9 (SEj 4- 5% + ..)] +

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  0.9  (0.8 (TCi + TC2  +...))

      [9.0 (WCt + WC2 + ...)] + [1-2 (BCj + BCj + ...)] +
      [0.791 (STj, + ST2 + . .  .)]} S [ERTC1 (TCj) + ERTC2 (TCj) + ....] +
                          •••] + [ERWC1 (WCj) + ERWC2 (WCj) + . .
                           .-.] + [ERsn (ST^ + ERg^ (ST2) + . . .]


 where :
           =  kilograms of solids of topcoat "i" used;
           =  kilograms of solids of sealer "i" used;
           =  kilograms of solids of basecoat "i" used;
      WC-  =  kilograms of solids of washcoat "i" used;
      ST^  =  liters of stain "i" used;
    ERTCi  =  voc content of topcoat "i" in kg VOC/kg solids,  as
             applied;
    ERSEi  =  V^ content of sealer "i" in kg VOC/kg solids, as
             applied;
    ERBCi  =  vo^ content °f basecoat "i" in kg VOC/kg solids, as
             applied;
    ERWCi  =  Voc content of washcoat "i",in kg VOC/kg solids, as
             applied; and
    ERSTi  =  voc content °f stain "i" in kg VOC/1, as applied.

     Inequality  1 would apply  when  the  facility  wished to comply
with B.4(a) (l) by averaging topcoats  with  a VOC  content of less
than 0.8 kg VOC/kg solids with those  that  have a VOC content of
more than  0 . 8 kg VOC/kg solids.

     Inequality  2 would apply  to other  averaging scenarios.  The
facility could use this  equation to average among their stains,
sealers, and topcoats or among their  sealers and topcoats only.

     Because the facility's source-specific requirements are
different  than the requirements associated with  this model rule,
the facility was not able to provide  an actual calculation using
these averaging  equations.  However,  the facility was  able to
provide information on  finishing materials they  use.   Following
is a summary of  the coating characteristics and  the  EPA' s
suggestion as to how the coatings could be used  in the averaging
calculation.

                         VOC                Usage      Usage
Finishing Material   (kg  VOC/kg solids)   (kg solids)   (liters)

Sealer                   2.0               123          380
Topcoat 1                0.9               258          380
Topcoat 2                1.9               123          380

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      For a facility using these finishing materials in these
 amounts,  the allowable and actual  emissions can be calculated
 using Inequality 2.   Using this equation the facility's allowable
 and actual emissions can be calculated as follows:

 0.9 [1.8 (381)  + 1.9(123}]  «= 828  kg  VOC = allowable emissions

 0.9(258)  + 1.9(123)  + 2.0(123)  = 712  kg VOC = actual emissions

      This calculation shows that the  facility is in compliance;
 the actual emissions are about  15  percent less than the allowable
 even though one of  the finishing materials,  topcoat 2,  would not
 comply if the facility were limited to a compliant  coatings
 approach.

      E.   Monitoring,  Recordkeeping, and Reporting

      The State would need to incorporate monitoring,
 recordkeeping,  and  reporting requirements consistent with the
 criteria in B.10(e)  in the permit.  The example facility is
 currently monitoring finishing  material and solvent usage closely
 and keeping extensive records on their usage.   Finishing material
 usage is  recorded by the  operator  on  a data sheet each  time a
 finishing material  is used.   Any solvent or catalyst that is
 added to  the  finishing material  is also recorded.   The  form used
 to  record finishing  material usage is checked and approved by the
 supervisor.   A copy  of the finishing  material  usage form is
 attached.

      Data  from the finishing material  usage  form are input into a
 spreadsheet to calculate  the VOC content of  the finishing
 material  as applied.   The  VOC content  of each  finishing  material,
 as  applied, and the  total  usage  for each finishing  material is
 then  input  into another spreadsheet to calculate  the  total VOC
 emissions  for the day.  The  spreadsheet  also calculates  the
 allowable'emissions  for the  day  so the facility can determine
 compliance  for  the day.  Copies  of these spreadsheets are also
 attached.

      The  facility was  asked  how  they would determine  compliance
 in  the event  of lost  data.  Although the facility has never
 encountered this problem,  they said the  data could  be
 reconstructed using production records and/or  finishing  material
 inventory,  presuming worse cast, that  is, assuming values  for the
 unknown variables that would yield the highest  weighted  emission
 rate  average.

      F.  State  Implementation Plan Creditability and Audit/
         Reconciliation Procedures

     This information would normally be provided by the  State.
The State must add language that requires the source to  submit
 the data needed for the audit process.  The  source needs  to

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specify a schedule for this data submittal that allows the State
to meet its specified audit frequency.

     G.  Implementation Schedule

     This information would normally be provided by the State.
This must ensure that all sources are in compliance with the
State's rule by the effective date.  Submittal of the averaging
proposal does not provide an exemption from the model rule.  The
source must submit the averaging proposal by a date that allows
sufficient time for EPA approval.

     H.  Administrative Procedures

     This information would normally be provided by the State.
This must specify how data is to be submitted to the State by the
source and when such data is to be submitted.

     I.  Enforcement Mechanisms

     Enforcement mechanisms consistent with the requirements of
B.lO(i) would need to be provided.  This information would
normally be provided by the State.  States need to specify any
special requirements that apply to the permitted source for
enforcement and compliance purposes such as definitions of what
constitutes violations of the various compliance provisions,
including the applicable emission limitations,  as well as the
penalty structure for addressing violations.

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                                    TECHNICAL REPORT DATA
                               (Please read Instructions on reverse before completing)
  1. REPORT NO.
    EPA-453/R-96-007
                                                                   3. RECIPIENT'S ACCESSION NO.
  4. TITLE AND SUBTITLE
  Control of Volatile Organic Compound Emissions from Wood
  Furniture Manufacturing Operations
                                5. REPORT DATE
                                  April 1996
                                                                   6. PERFORMING ORGANIZATION CODE
  7. AUTHOR(S)
                                                                   8. PERFORMING ORGANIZATION REPORT NO.
 9. PERFORMING ORGANIZATION NAME AND ADDRESS

    U.S. Environmental Protection Agency
    Office of Air Quality Planning and Standards
    Emission Standards Division
    Research Triangle Park, NC 27711
                                                                   10. PROGRAM ELEMENT NO.
                                11. CONTRACT/GRANT NO.
 12. SPONSORING AGENCY NAME AND ADDRESS

    Director
    Office of Air Quality Planning and Standards
    Office of Air and Radiation
    U.S. Environmental Protection Agency
    Research Triangle Park, NC 27711
                                                                   13. TYPE OF REPORT AND PERIOD COVERED
                                Final
                                14. SPONSORING AGENCY CODE
                                EPA/200/04
 15. SUPPLEMENTARY NOTES
 EPA Work Assignment Manager:
Paul Almodovar, (919) 541-0283
 16. ABSTRACT
        This Control Techniques Guideline (CTG) provides the necessary guidance for development of
 regulations to limit emissions of volatile organic compounds (VOC) from wood furniture finishing and
 cleaning operations.  This guidance includes emission limits for specific wood furniture finishing steps
 and work practices to reduce waste and evaporation through pollution prevention methods; these
 represent reasonably available control technology for wood furniture finishing and cleaning operations.
 This document is intended to provide State and local air pollution authorities with an information base
 for proceeding with their own analyses of RACT to meet statutory  requirements.
 17.
                                      KEY WORDS AND DOCUMENT ANALYSIS
                   DESCRIPTORS
                                                 b. IDENTIFIERS/OPEN ENDED TERMS
                                                   c. COSATI FkW/Group
 Air Pollution, volatile organic compound(s),
 Wood furniture manufacturing
 Emission limits
 Control techniques guideline
              Air Pollution control
 18. DISTRIBUTION STATEMENT

   Release Unlimited
              19. SECURITY CLASS (Repon)
                 Unclassified
21. NO. OF PAGES
      286
                                                 20. SECURITY CLASS (Page)
                                                    Unclassified
                                                                                      22 PRICE
EPA Form 2220-1 (Rer. 4-77)   PREVIOUS EDITION IS OBSOLETE

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U.S. Environmental Protection Agency
Region 5, Library (PL-12J)
77 West Jackson Boulevard, 12th Floor
Chicago.il  60604-3590

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