EPA/453/
R-95/009
A
EPA-453/R-95-009a
DRAFT
Architectural Coatings -
Background for Proposed Standards
Emission Standards Division
U.S. Environmental Protection Agency
Office of Air and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
March 1996
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DISCLAIMER
This report is issued by the Emission Standards Division of
the Office of Air Quality Planning and Standards of the
Environmental Protection Agency. Copies of this report are ~N
available through the Library Services Office (MD-35), U. S. /\
Environmental Protection Agency, Research Triangle Park, NC \* _ *"
27711, telephone 919-541-2777 (FTS 629-2777), or may be ^ ^ ,
obtained for a fee from the National Technical Information --
Service, 5285 Port Royal Road, Springfield, VA 22161,
telephone 703-487-4650.
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TABLE OF CONTENTS
Page
1.0 INTRODUCTION 1-1
1.1 References 1-3
2.0 PRODUCT CATEGORY DESCRIPTION 2-1
2.1 Function and Purpose 2-1
2.2 Coating Composition and Formulation 2-2
2.3 Product Types and Uses 2-3
2.3.1 Flat Coatings 2-4
2.3.2 Nonflat Coatings 2-4
2.3.3 Specialty Coatings 2-5
2.4 Coating Selection and Use 2-5
2.5 State Regulations 2-9
2.6 Baseline VOC Emissions and Sales 2-9
2.6.1 VOC Emission Mechanisms 2-12
2.6.2 National Baseline Sales 2-13
2.6.3 National Baseline Emissions 2-14
2.6.4 VOC Emissions from Specialty Coating
Categories 2-19
2.7 References 2-21
3.0 INDUSTRY PROFILE 3-1
3.1 Industry History and Development 3-1
3.2 Industry Structure 3-2
3.2.1 Raw Material Consumption 3-2
3.2.2 Architectural Coatings Manufacturers . . 3-4
3.2.3 Distributors and Retail Markets . . . . 3-11
3.3 Current Industry Trends 3-16
3.3.1 Architectural Coating Sales 3-16
3.3.2 Industrial Maintenance and Traffic
Coating Sales 3-18
3.3.3 Coating Technology Trends 3-18
3.3.4 Trends in Alternatives to Coatings . . . 3-20
3.4 References 3-22
4.0 EMISSION CONTROL TECHNIQUES 4-1
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TABLE OF CONTENTS
(CONTINUED)
Page
4.1 Lower-VOC Coating Technologies 4-3
4.1.1 Waterborne Coatings 4-3
4.1.2 Higher-Solids Coatings 4-4
4.1.3 Powder Coatings 4-5
4.2 Product Reformulation 4-8
4.2.1 Resins 4-8
4.2.2 Pigments 4-8
4.2.3 Plasticizers 4-9
4.2.4 Reactive Diluents 4-9
4.2.5 Thixotropes and Dispersants 4-10
4.3 Examples of Types of Category-specific Product
Reformulation Limitations 4-10
4.3.1 Magnesite Cement Coatings 4-10
4.3.2 Dry Fog Coatings 4-11
4.3.3 Fire-retardant Coatings 4-11
4.3.4 IM Coatings 4-11
4.3.5 Lacquers, Shellacs, and Varnishes . . . 4-11
4.3.6 Metallic Pigmented Coatings 4-11
4.3.7 Pretreatment Wash Primers 4-11
4.3.8 Stains 4-12
4.3.9 Swimming Pool Coatings 4-12
4.3.10 Waterproofing Sealers 4-12
4.3.11 Wood Preservatives 4-12
4.4 References 4-14
5.0 VOC AND HAP EMISSION REDUCTIONS 5-1
5.1 VOC Emissions Reduction Estimate 5-1
5.1.1 Base Survey Data 5-2
5.1.2 Assumptions for the Emission Reduction
Calculation 5-4
5.1.3 Procedure to Calculate Emission
Reductions 5-5
5.1.4 Summary of VOC Emission Reduction
Assumptions 5-7
5.2 Hazardous Air Pollutant Emissions 5-13
5.3 References 5-15
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LIST OF TABLES
Page
2-1 State VOC limits 2-10
2-2 1990 National Sales, Industry Average VOC Content
at Maximum Thinning and Total VOC Emissions at
Maximum Thinning for AIM Coatings 2-15
2-3 Relative Contribution of Individual Specialty
Categories to VOC Emissions from Architectural Specialty
Coatings 2-20
3-1 1991 Resin Consumption by Coating and Resin Type . . 3-5
3-2 1991 Pigment Consumption by Coating and Pigment Type 3-6
3-3 1991 Solvent Consumption by Coating and Solvent Type 3-7
3-4 1991 Consumption of Paint Additives by Coating and
Additive Type 3-8
3-5 Major U.S. Producers of Architectural Coatings . . . 3-10
3-6 Major U.S. Producers of Industrial Maintenance
Coatings and Traffic Coatings 3-12
3-7 Summary of Architectural Coating Distributors and Retail
Markets 3-14
3-8 1979 to 1991 Consumption of Coatings 3-17
3-9 Use Percentages for Waterborne and Solventborne
Architectural Coatings, by Coating Type 3-21
5-1 Volatile Organic Compound Content and National
Emission Reductions for Architectural Coatings at
Maximum Thinning 5-8
5-2 Major Bias Factors and Assumptions Influencing the
Calculated Emission Reduction 5-12
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LIST OF FIGURES
Page
3-1 Coatings Industry Structure 3-3
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1.0 INTRODUCTION
National air quality monitoring data from 1989 through
1991 indicate that there are approximately 170 geographic
areas that failed to attain the National Ambient Air Quality
Standards (NAAQS) for ozone, with approximately 19 percent
being classified as being serious or severe, and 22 percent
being classified as being moderate or submarginal.1 Ozone is
a photochemical oxidant that is formed in the atmosphere
through a series of chemical reactions between precursor
emissions of volatile organic compounds (VOC) and oxides of
nitrogen (NOX) in the presence of sunlight.
Although most large, stationary sources of VOC emissions
are covered by existing regulations, an examination of
emissions data completed in 1989 by the Congressional Office
of Technology Assessment (OTA) indicates that individual
small, dispersed sources of VOC (area sources) contribute
significantly to the continuing ozone nonattainment problem.
According to the OTA report, "Catching Our Breath: Next Steps
for Reducing Urban Ozone," one area source of VOC emissions is
the use of a wide range of consumer and commercial products.2
These products include architectural coatings.
Section 183(e) of the 1990 Amendments to the Clean Air
Act requires the EPA to conduct a study of emissions of VOC
into the ambient air from consumer and commercial products.
The study and report to Congress, which was completed in March
1995, examined the potential of VOC emissions from consumer
and commercial products to contribute to ozone nonattainment
and prioritized groupings of products for regulation. Under
Section 183(e), the EPA is required to regulate one group of
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products every two years, with the first group regulated no
later than two years after publishing the list. The EPA
published the consumer product category list and schedule for
regulation in the Federal Register on March 23, 1995.
Accordingly, the EPA is required to regulate the first group
of products, which includes architectural coatings, no later
than March 1997. Justification for placement of architectural
coatings in the first grouping is based on several factors
including the magnitude of VOC emissions and the cost-
effectiveness of control.
Almost all architectural coatings contain VOC. The
volume of coating used and VOC content are the primary factors
that affect the total amount of VOC emitted by this product
category. The VOC emitted from architectural coatings
includes VOC that are part of a coating's original
formulation, VOC that are added during thinning, and VOC
released as reaction byproducts while the coating dries and
hardens. The total national amount of VOC emitted from
architectural coatings was estimated to be 530,000 tons per
year (at maximum thinning).3
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1.1 REFERENCES
1. Code of Federal Regulations. Designation of Areas for
Air Quality Planning Purposes, 40 CFR Part 81. Office of
the Federal Register, Washington, DC.
2. U.S. Congress, Office of Technology Assessment. Catching
Our Breath: Next Steps for Reducing Urban Ozone.
U.S. Government Printing Office. Washington, DC.
Publication No. OTA-0-412. July 1989. p. 16.
3. Memorandum from Harrison, R., Radian Corporation, to
Ducey, E., U.S. Environmental Protection Agency, Emission
Standards Division. Determination of Architectural and
Industrial Maintenance Coatings Baseline Sales and VOC
Emissions. November 14, 1995.
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2.0 PRODUCT CATEGORY DESCRIPTION
The purpose of this chapter is to define and describe
architectural coatings and to describe the volatile organic
compound (VOC) emissions associated with their use. These
coatings =.re applied in the field to stationary structures and
their appurtenances, portable buildings, pavements, or curbs.
Architectural coatings contain VOC, typically as solvents,
which are released to the air while the coating dries and
hardens. Coatings that are used in a shop setting in
manufacturing, repair, or line applications are not included
in the definition of an architectural coating. Some
applications in a shop setting are covered under a control
techniques guideline (CTG) document for the control of
emissions from the coating of miscellaneous metal parts in
ozone nonattainment areas.1
2.1 FUNCTION AND PURPOSE
Architectural coatings protect the substrates on which
they are applied from corrosion, abrasion, decay, ultraviolet
light damage, and/or the penetration of water and/or
chemicals. Some architectural coatings may also increase the
aesthetic value of a structure by changing the color or
texture of its surface. These coatings may also be important
in constructing a structure as well as protecting or enhancing
the appearance of the finished structure. Examples of the
latter are concrete form-release compounds, which prevent
concrete from sticking to forms, and concrete-curing
compounds, which allow concrete to cure properly. Another
function of architectural coatings is to promote and/or
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maintain public safety, such as making structures more fire
retardant and marking traffic patterns.
In general, without the protection afforded by
architectural coatings, stationary structures would be more
susceptible to deterioration (e.g., mechanical wear and/or
corrosion) and would require more frequent repair and
replacement, which would increase the cost of maintaining such
structures. In addition to the economic impact, increased
maintenance would increase the consumption of resources to
repair and replace these structures. The actual dollar value
of these benefits is not easily quantified, although the cost
of coating a structure is usually only a small fraction of the
overall cost of the structure. The value of some benefits,
such as aesthetic benefits of decorative coatings, is highly
subjective.
2.2 COATING COMPOSITION AND FORMULATION
The essential components of most coating formulations
include the resin (or binder), the solvent, and the pigments.
Clear coatings, such as varnishes, normally do not contain
pigments. Other components that are typically included for
performance purposes or to improve the coating manufacturing
or application process include antisettling agents,
antiskinning agents, defoamers and antifoamers, dispersing and
emulsifying agents, driers, preservatives and fungicides,
ultraviolet light absorbers, catalysts, coalescing agents, and
surfactants. Various combinations of these components will
produce a wide range of coatings for many different
applications.2
Solvents impart fluid characteristics to resins by
creating a solution, emulsion, or dispersion, and usually
evaporate during the application, drying, or curing of the
coating. Organic solvents include aliphatic and aromatic
hydrocarbons, alcohols, ethers, esters, and ketones, some of
which are often used in combination. Chlorinated hydrocarbons
and nitroparaffins are less commonly used as solvents.3 The
most important criteria for selecting an organic solvent are
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its odor, toxicity, and solvency; that is, a solvent's ability
to make the resin soluble and its evaporation rate.3"4 The
solvent component of a coating is usually the largest source
of VOC, although with some resin systems, the reaction
byproducts of curing may account for 30 to 50 percent of the
VOC.5
Water is a polar solvent that cannot dissolve most resins
used in coatings. However, water can be used in emulsion and
dispersion coatings as a diluent, such as in latex and
emulsion coatings.&-& Some resins can be chemically modified
to become water-soluble or water-reducible, thereby allowing
water to be used as a replacement for a portion of the organic
solvent needed to create the proper solution viscosity.9
Acrylic and alkyd resins are examples of resins that can be
modified for use in water-soluble coatings.10
Coatings may be considered to be solventborne,
waterborne, or 100 percent solids, depending on whether an
organic solvent, water, or a reactive diluent is used as the
principal flow controller. The U.S. Environmental Protection
Agency (EPA) defines solventborne coatings as "coatings which
contain only organic solvents. If water is present, it is
only in trace quantities."11 A waterborne coating is "a
coating which contains more than 5 weight-percent water in its
volatile fraction.nl2 From a practical viewpoint,
solventborne coatings are those with resins dissolved in an
organic solvent (or blend of solvents). Conversely,
waterborne coatings are those with the resin system suspended
in water as liquid emulsions or solid dispersions.
2.3 PRODUCT TYPES AND USES
Coatings can be classified in many ways and the terms
used generally describe some aspect of their composition or
function. The majority of the State regulations in effect for
VOC content of architectural coatings categorize coatings
partially according to their intended function or end use and
partially by composition. These coating categories are
generally well recognized and understood by many coating
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manufacturers and users. These coating types include flats,
nonflats, and specialty coatings, which include industrial
maintenance (IM) coatings. Descriptions of flat, nonflat, and
a general description of specialty coatings are provided
below.
2.3.1 Flat Coatings
Flat coatings are defined as coatings that register a
gloss of less than 15 on an 85-degree meter, or less than 5 on
a 60-degree meter, as measured by American Society for Testing
and Materials (ASTM) Method D-523-89 Standard Test Method for
Specular Gloss.
Flat coatings used on interior walls and trim are
primarily waterborne vinyl acetate and acrylic latexes.1-^
Vinyl latexes are less expensive than acrylics and have good
color retention and grease and oil resistance. Acrylics have
excellent color retention and better durability, and are more
water-resistant than vinyl acetate latexes.9/14 Acrylic
latexes modified with alkyds have been developed as an
improvement on acrylic latexes for exterior housepaints.15
2.3.2 Nonflat Coatings
Nonflat coatings are those that register a gloss of 15 or
greater on an 85-degree meter, or 5 or greater on a 60-degree
meter, as measured by ASTM Method D-523-89, Standard Test
Method for Specular Gloss. Like flats, nonflat coatings are
used for both interior and exterior wall and trim paint.
Nonflat coatings have a range of glosses that are
described with such terms as high-gloss, semigloss, or
eggshell finish. The gloss level corresponding to each of
these terms may vary from manufacturer to manufacturer.
Nonflats are similar in composition to flat coatings in that
the most popular formulations are waterborne vinyl acetate and
acrylic latexes.
Flat coatings and nonflat coatings together make up what
are often referred to as trade sales paints. These are shelf
goods intended for use by the do-it-yourself and professional
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painter for painting both interior and exterior walls and trim
with a brush or roller.13'15"17 Trade sales paints may also
be formulated for spray application.16
2.3.3 Specialty Coatings
Specialty coatings are distinct from flat and nonflat
coatings because they are intended for more specialized
applications than coating interior and exterior walls and
trim. Most individual specialty coating categories represent
only a small percentage of total architectural coating use,
but collectively account for approximately 42 percent of
architectural coating use and, more importantly, represent
about 70 percent of architectural coating VOC emissions.18
Specialty architectural coatings are formulated to meet
the needs of specific applications. As a result, the demand
for some of these coatings may be limited and they may be
produced by only a few manufacturers. However, many of these
coatings have a relatively high solvent content. As a result,
they collectively account for VOC emissions that are
disproportionate to the total volume used. There are
many categories of these specialty coatings.
2.4 COATING SELECTION AND USE
The proper selection and use of coatings are the primary
factors in determining whether a structure (e.g., bridges)
will be protected effectively by the coating. The following
paragraphs describe the factors that are typically considered
in architectural coating selection.
The factors that are considered in the selection of a
coating depend on the knowledge and requirements of the person
selecting and applying the coating. Important factors in
consumer selection of a coating are price, availability, and
name recognition (reputation). Decorative and protective
qualities of the coating are also significant considerations;
a coating should provide the desired results and perform under
the conditions specified by the user. The relative importance
of these criteria will differ from consumer to consumer.
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Coatings must also be compatible with preexisting
coatings over which they will be applied. In coating systems
requiring a primer and a topcoat, the resins and solvents in
the topcoat must be compatible with those in the primer to
prevent premature coating deterioration. Some coatings,
therefore, are selected as a coating system.
Although most architectural coating use is by painting
contractors, public works departments, or institutional or
industrial facility owners, about 40 percent of architectural
coatings are applied by do-it-yourself painters or
homeowners.19 Homeowners want a house paint that has the
decorative qualities they desire (e.g., color and gloss) and
that is easy to apply and durable. Homeowners may rely on
past experience, advertising, cost, brand recognition, color
selection, and information from the retailer in selecting a
coating. Specific performance information supplied by the
manufacturer is usually limited to product sales literature
and a statement on the container about coverage.
For interior use, waterborne latex paints are most
commonly applied to walls, and both latex and oil-based alkyds
are used for interior woodwork and trim. Waterborne latex
paints have the advantages of being fast drying, easy to apply
and clean up, and have minimal solvent odor.16 Alkyds,
however, may brush on smoother and typically offer good
adhesion and stain resistance, but may be slower drying and
harder to clean up. Important factors in selecting an
interior paint are hiding power, resistance to fading and
stains, ability to withstand scrubbing, and resistance to
blocking (which is required for windows, doors, shelves, or
other cases in which coated surfaces contact each other or
other objects). Blocking refers to the tendency for some
waterborne latex coatings to soften and become sticky even
after they have dried.20"22
For exterior applications to homes, alkyds have some
advantages over latexes, although they are more prone to
yellowing when they are "shielded from the bleaching effect of
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direct sunlight (e.g., under eaves or a porch roof)."
Although latexes are easier to apply and clean up, alkyds may
have better adhesion, do not exhibit blocking, and provide a
smoother finish with more initial gloss. Latexes, however,
offer better protection against mildew and may maintain their
original color better over time when exposed to the weather.
Other factors considered when selecting an exterior house
paint are resistance to chalking and dirt.23
Commercial painting contractors who work on small-scale
projects, such as residential homes, usually choose a coating
based on the customer's specifications for color and finish.
However, because of the level of competition in bidding among
contractors, coating cost is one of the few variables that the
contractor can control to develop a competitive bid.24
Painting contractors also provide services to State
departments of transportation (DOT) that use IM coatings to
protect bridges and traffic marking coatings to mark
pavements. In most States, the DOT does its own performance
testing of coatings and establishes selection criteria based
on these tests. Durability is one of the most important
factors in selecting a coating for DOT work.25 other factors
that affect the selection of traffic marking materials
include: VOC emissions, visibility, pavement type, traffic
density, position of the line or marking, climatic conditions,
drying or setting time, safety of material, application
procedure, amount to be applied, initial cost, annual cost,
and equipment availability.26
In IM coating applications, long-term coating performance
is usually the greatest concern in coating selection. These
coatings are intended to protect equipment and other
structures against severe environments that may include
immersion in water, wastewater, or chemicals, exposure to
corrosive solutions or fumes, exposure to high temperatures,
exposure to heavy abrasion, or exterior exposure of metal
substrates. Furthermore, coating application may be costly
and difficult, as with a bridge or water tower. In many
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cases, the facility owner relies on the painting contractor or
the coating manufacturer for guidance. Unfortunately, there
is no manufacturers' consensus on standard performance testing
and what constitutes "acceptable results." Some large
contractors have addressed this problem by developing their
own criteria for selecting a coating based on the
manufacturers' test data.27
Several different types of coatings are used for IM
applications, depending on the demands of the particular
application. The most commonly used coatings include those
based on chlorinated rubber, vinyl chloride, alkyd,
bituminous, epoxy, or polyurethane resin systems.
Chlorinated rubber coatings are one of several coating
types used for protecting steel and concrete in IM
applications. They are fast drying, show good adhesion
between coats, are very durable compared to conventional
coatings, and are very resistant to moisture, acids, bases,
and many solvents. Their disadvantages are that they are
difficult to apply with a brush and can be degraded by animal
fats, oils, and some solvents. In addition, they also contain
residual carbon tetrachloride, a carcinogen.28
Vinyl coatings are used to protect steel and concrete
under very corrosive conditions and are resistant to
chemicals, moisture, and weather. However, they typically
have a low solids content and, consequently, produce a
relatively thin film with each coat.29
Bituminous coatings are used for the protection of buried
or submerged steelwork or as roof coatings when mixed with
aluminum pigments.29
Alkyd coatings are used in IM situations where exposure
conditions are relatively mild and a decorative finish is
desired.29
Epoxy coatings are used as both primers and finish coats
for steel and concrete where chemical, solvent, and abrasion
resistance is required. Epoxy coatings tend to chalk when
exposed to sunlight. Solventless epoxy coatings can be
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applied to submerged steel and can be used for lining storage
tanks and other confined spaces.30
Polyurethane coatings can be formulated with varying
amounts of flexibility and hardness for a variety of IM
applications. They are weather- and abrasion-resistant as
well as being resistant to chemicals and solvents. Flexible
polyurethane coatings can be formulated to accommodate the
dimension changes of exterior woodwork.31
2.5 STATE REGULATIONS
Currently, no Federal EPA regulations limit VOC content
or VOC emissions from architectural coatings. In 1990, five
States--Arizona, California, New Jersey, New York, and Texas--
had architectural coating regulations that limit VOC content.
Since 1990, a few States have developed their own
architectural coating regulations, but many are relying on a
national rule to provide needed VOC emission reductions.
The VOC limits in Arizona only apply to Maricopa County
(where Phoenix is located), and the New York limits apply only
to the New York City metropolitan area. The California Air
Resources Board (CARB) established a model rule for use by the
air pollution control and air quality management districts in
developing their rules. Of the 43 California districts,
25 had adopted architectural coating rules as of 1989. The
New Jersey limits apply statewide. The Texas limits apply to
16 counties. All State rules, except those of Texas, apply to
coating categories that are defined primarily by the coating
use and function. The Texas limits are based on coating resin
types, as well as coating function.
The Arizona, CARB model rule, New Jersey, New York, and
Texas regulatory limits are summarized in table 2-1.
2.6 BASELINE VOC EMISSIONS AND SALES
During the development of the Architectural Coatings
proposed rule, 1990 was used as the baseline year for
architectural coating sales and VOC emissions. The 1990 sales
and VOC content data were obtained using, a 1992 survey (that
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TABLE 2-1. STATE VOC LIMITS
(GRAMS VOC/LITER COATING, LESS WATER)
Coating
Categories
All other architectural
coatings
Bond breakers
Concrete-curing compounds
Dry fog coatings: At I
Flat
Nonf I at
Enamel undercoaters
Flat architectural coatings
Fire-retardant coatings:
Clear
Pigmented
Form- re I ease compounds
General primers, sealers
& undercoaters
Graphic arts (sign) coatings
IM High-temperature coatings
1M Ant igraf f i ti coatings
IM coatings
Lacquers
Magnesite cement coatings
Mastic texture coatings
Metallic pigmented coatings
Multicolored coatings
Nonflat architectural coatings
Opaque stains
Pretreatment wash primers
Quick-dry enamels
Quick-dry primers, sealers
& undercoaters
Roof coatings
Sanding sealers
Semi transparent stains
Shellacs:
Clear
Pigmented
Specialty flat products
Specialty primers, sealers
& undercoaters
Swimming pool coatings
Swimming pool repair &
maintenance coatings
AZb
(7/13/91 )c
350
420
400
350
350
420
680
350
400
300
350
400
350
CA-CARBd
(9/1/92)c
350
350
400
650
350
250
350
500
550
340
340
680
600
300
500
420
350
780
300
550
350
730
550
650
340
NJe
(8/8/90)c
250
600
350
400
250
850 (all
others)
500 (opaque)
350
450
650
450
680
200
500
600
380
350
500
300
550
730
550
600
NYf TX9
(7/1/89)° (1/1/91)c
600
350
400
850 (all
others)
500 (opaque)
350
450
650
450
680
200
500
600
350
500
300
550
730
550
600
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TABLE 2-1. STATE VOC LIMITS
(GRAMS VOC/LITER COATING, LESS WATER)a (CONTINUED)
Coating
Categories
Tile-like glaze coating
Traffic coatings
Varnishes
Waterproofing mastic coating
Waterproofing sealers
Wood preservatives: All
Opaque
Semi transparent and clear
Below ground
Nonflat & flat latex paints
Interior alkyd paints
Exterior alkyd paints
Epoxy paints
Exterior stains
Interior stains
Urethane coatings
Alkyd varnishes
Nitrocellulose-based lacquers
AZb CA-CARBd NJe NYf
(7/13/91)° (9/1/92)c (8/8/90)c (7/1/89)c
550
250 250 250 250
350 350 450 450
300 300 300
400 400 600 600
350 550 550
350
350
600
TX9
260
420
480
540
720
840
54C
540
670
aBlanks indicate that no definition and/or limit exists for that category.
"Arizona Regulation Ill-Control of Air Contaminants, Rule 335-Architectural Coatings,
Section 300-Standards. Applies only to Maricopa County.
cEffective date.
dAir Resources Board (ARB)-California Air Pollution Control Officers Association (CAPCOA) Suggested
Control Measure for Architectural Coatings; a model rule that applies to the whole State.
eNew Jersey Administrative Code Title 7, Chapter 27, Subchapter 23-Volatile Organic Substances in
Consumer Products, Section 7:27-23.3 Architectural Coatings. Applies to the whole State.
'New York Title 6, Chapter Ill-Air Resources, Part 205, Section 205.4, Prohibitions and Requirements.
Applies only to the New York City metropolitan area.
9Texas resin categories listed at the end of the table. Texas Air Control Board, Regulation V (31 TAC
Chapter 115)-Control of Air Pollution from Volatile Organic Compounds, Section 115.191. Applies to the
following counties: Dallas, Tarrant, Brazoria, Galveston, Harris, Jefferson, Orange, El Paso,
Chambers, Collin, Denton, Fort Bend, Hardin, Liberty, Montgomery, and Waller.
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collected 1990 data) sponsored by the National Paints and
Coatings Association (NPCA), Bureau of the Census Current
Industrial Reports, and the SRI International U.S. Paint
Industry Database.18'32"33 The NPCA survey included 116
coating manufacturers that manufactured coatings in a total of
38 coating categories. This survey represents the most recent
and comprehensive source of VOC content and sales information
from this industry. The 1990 emissions baseline data includes
the impacts of the State rules described in section 2.5 since
the baseline was established from a national survey that
included data from sales within these States.
Section 2.6.1 of this chapter briefly describes the VOC
emission mechanisms. Sections 2.6.2 and 2.6.3 of this chapter
describe how the national architectural coatings baseline
sales and emissions, respectively, were developed from the
NPCA survey database. Section 2.6.4 discusses the VOC
emissions from the specialty categories.
2.6.1 VOC Emission Mechanisms
Volatile organic compound emission estimates for
architectural coatings include the VOC in the coating, any
solvent added as thinner by the user, and any VOC emitted as
reaction byproducts. These VOC are emitted as the coating is
applied and dries or hardens, either through solvent
evaporation or chemical reaction.
The amount of solvent or thinner added to a coating to
bring it to the proper consistency for application will
directly affect the VOC emissions. Despite guidance from
manufacturers, the amount of thinner added often depends on
the preference of the user. Some coatings may be applied
with no additional thinning and most waterborne coatings may
be thinned with water, which does not affect VOC emissions.
Some manufacturers have argued that VOC regulations may
not be effective due to over-thinning of lower VOC coatings in
the field. A study conducted in California on architectural
coating thinning practices found that 2 percent of all
architectural coatings observed had been thinned in excess of
klk 72/04
2-12
-------
the local air pollution control district VOC limits.34 As a
result of this thinning, 6 percent of architectural specialty
coatings exceeded the VOC limits. A coating was considered to
exceed the VOC limit if the VOC content exceeded the specified
limit by more than 10 percent, to allow for laboratory error
in the analysis of field collected samples. In this study,
121 coatings were observed at 85 different sites and
49 coatings were sampled and analyzed for VOC content.34
2.6.2 National Baseline Sales
The 1990 national architectural coating baseline sales
were determined to be 654,822,000 gallons using the following
approach:
1. The 1991 Current Industrial Reports, produced by the
Bureau of Census, provides 1990 national sales
estimates for architectural coatings. The
definition of "architectural coatings" used in the
Bureau of Census Report is more narrow than the
"architectural coatings" definition in the proposed
rule. Specifically, the Bureau of Census definition
excludes industrial maintenance coatings, traffic
marking coatings, and some special-purpose coatings.
Therefore, in order to include all architectural
coating sales, as defined in the regulation, sales
data from the following categories were included
from the Bureau of Census Report:
"Architectural coatings;"
"Industrial new construction and maintenance
paints;"
"Traffic marking paints;" and
"Special-purpose coatings not specified by
kind."
The 1990 national sales for these categories are
645,365,000 gallons. Note that this estimate does
not include sales of wood preservatives, which
cannot be desegregated from "other miscellaneous
allied paint products."
2. The 1990 NPCA survey population baseline sales are
reported to be 489,738,102 gallons in the NPCA
Survey.18
3. During regulatory negotiations, the architectural
coating industry and representatives from State
Departments of Transportation indicated that the
volume of traffic coatings reported in the survey
kl). 72
2-13
-------
was only about half of what was actually sold in
1990.35-36 Consequently, traffic paint sales (and
emissions) were doubled to give a revised survey
population estimate of 502,125,461 gallons
(489,738,102 gallons + 12,387,359 gallons =
502,125,461 gallons).
4. Sales of wood preservatives, 7,251,644 gallons, were
subtracted from the revised survey estimate of
502,125,461 gallons, to give a survey baseline sales
estimate, excluding wood preservatives, of
494,873,817 gallons (502,125,461 gallons -
7,251,644 gallons = 494,873,817 gallons).
5. The survey baseline sales estimate, excluding wood
preservatives, of 494,873,817 gallons includes sales
of the same categories included in the national
sales estimate of 645,365,000 gallons, which also
excludes wood preservative sales. This survey
estimate represents 76.6812 percent of the national
sales estimate (494,873,817 gallons/645,365,000
gallons = 0.766812 gallons).
6. The 1990 survey estimate of 502,125,461 gallons,
including sales of wood preservatives, is assumed to
represent 76.6812 percent of total national sales,
including wood preservatives. The estimate for
total national sales becomes 654,822,000 gallons
(502,125,461 gallons/0.766812 =
654,822,000 gallons). Table 2-2 shows the national
sales per category.
2.6.3 National Baseline Emissions
National VOC emissions from architectural coatings were
estimated to be 530,000 tons using the following procedure.
1. The VOC emissions at maximum thinning from the
survey population are 785,232,553 pounds, or
392,616 tons, prior to adjusting for underreported
traffic paints emissions.
2. After doubling the estimate for traffic paints
emissions, the revised survey estimate is
413,452 tons (785,232,553 pounds + 41,671,510 pounds
= 826,904,063 pounds or 413,452 tons). Note that
this estimate includes emissions of acetone, which
was added to the VOC exemptions list on June 16,
1995. The emissions are adjusted for the acetone
redesignation in step 4.
3. The survey estimate of VOC emissions is assumed to
represent 77 percent of national VOC emissions,
klk\72/(W
2-14
-------
TABLE 2-2. 1990 NATIONAL SALES, INDUSTRY AVERAGE VOC CONTENT
AT MAXIMUM THINNING AND TOTAL VOC EMISSIONS AT
MAXIMUM THINNING FOR ARCHITECTURAL COATINGS18
Coating Category
Anti-Graf f iti Coatings
Solventborne
Waterborne
Appurtenances*3
Solventborne
Waterborne
Below Ground Wood
Preservatives
Solventborne
Waterborne
Bituminous Coatings
Solventborne
Waterborne
Bond Breakers
Solventborne
Waterborne
Concrete Curing Compounds
Solventborne
Waterborne
Dry Fog Coatings
Solventborne
Waterborne
Fire-Retardant/Resistive
Coatings
Solventborne and
Other/Exempt
Waterborne
Flats
Solventborne
Waterborne
Unknown
Form Release Compounds
Solventborne
Waterborne
Graphic Arts Coatings
Solventborne
Waterborne
Total Volume
Sold
(thousand
gallons) a
9
6
69
2
175
N/A
1,822
25,414
N/A
N/A
369
64
3,411
1,450
38
48
4, 821
211, 925
61
352
2
322
21
Average
VOC Content at
Maximum
Thinning
(Ib/gal)
4 .89
2.43
3.49
0.95
4 .55
N/A
2.68
0.03
N/A
N/A
6.27
0.82
3.13
1.29
N/A
0.27
2.81
0.48
3 .60
5.06
N/A
3.46
0.35
National
VOC at
Maximum
Thinning
(tons/yr) a
21
7
120
1
398
N/A
2,442
335
N/A
N/A
1, 156
26
5,331
938
1
6
6,770
49,370
110
890
N/A
556
4
klk 7:
2-15
-------
TABLE 2-2. 1990 NATIONAL SALES, INDUSTRY AVERAGE VOC CONTENT
AT MAXIMUM THINNING AND TOTAL VOC EMISSIONS AT
MAXIMUM THINNING FOR ARCHITECTURAL COATINGS18 (CONTINUED)
Coating Category
High Temperature Coatings
Solventborne
Waterborne
Unknown
IM Coatings
Solventbornec
Waterborne
Unknown
Other/Exempt
Lacquers
Solventborne
Waterborne
Magnesite Cement Coatings
Solventborne
Waterborne
Mastic Texture Coatings
Solventborne
Waterborne
Metallic Pigmented Coatings
Solventborne
Waterborne /Unknown and
Other/Exempt
Multi-colored Coatings
Solventborne
Waterborne
Nonf lats
Solventborne
Waterborne
Unknown
Opaque Stains
Solventborne
Waterborne
Unknown
Opaque Wood Preservatives
Solventborne
Waterborne
Total Volume
Sold
(thousand
gallons) a
166
N/A
0
34,420
3,950
13
83
5,815
163
12
N/A
N/A
512
1,708
7,577
60
555
1
34,924
126,779
56
8,401
7,463
387
814
210
Average
VOC Content at
Maximum
Thinning
(Ib/gal)
4.89
N/A
N/A
3 .59
0.94
3 .63
0.58
6.14
2 .50
N/A
N/A
N/A
2.33
1.19
3.85
2.92
2.68
1.00
3.40
0.62
2.84
3 .60
0.48
3.17
3 .72
0.32
National
VOC at
Maximum
Thinning
(tons/yr) a
406
N/A
1
59,909
1,957
26
24
17, 840
203
30
N/A
N/A
595
1, 015
14 , 576
105
745
1
60,840
40,876
80
15, 137
1,796
614
1, 528
52
klk\72/M
2-16
-------
TABLE 2-2. 1990 NATIONAL SALES, INDUSTRY AVERAGE VOC CONTENT
AT MAXIMUM THINNING AND TOTAL VOC EMISSIONS AT
MAXIMUM THINNING FOR ARCHITECTURAL COATINGS18 (CONTINUED)
Coating Category
Pretreatment Wash Primers
Solventborne
Waterborne /Other
Primers
Solventborne
Waterborne
Unknown
Other /Exempt
Quick-Dry Enamels
Solventborne
Waterborne
Quick-Dry Primers, Sealers,
and Undercoaters
Solventborne
Waterborne
Roof Coatings
Solventborne
Waterborne
Sanding Sealers
Solventborne
Waterborne
Sealers
Solventborne
Waterborne
Other/Exempt
Semitransparent Stains
Solventborne
Waterborne
Unknown
Semitransparent & Clear Wood
Preservatives
Solventborne
Waterborne
Other/Exempt
Shellacs
Solventborne
Waterborne
Total Volume
Sold
(thousand
gallons) a
224
7
14,216
23,510
113
9
2,201
N/A
4,666
24
26,938
3,904
944
20
2,535
2,762
0
15,930
2, 148
203
7,144
1,102
12
1,356
N/A
Average
VOC Content at
Maximum
Thinning
(Ib/gal)
6.01
2.53
3.12
0.42
3.20
0 .04
4 .03
N/A
3.70
0.26
2.24
0.24
4 .59
1.60
5.31
0 .34
3.50
4.40
0.71
4 .47
4.67
0.37
5.51
4 .51
N/A
National
VOC at
Maximum
Thinning
(tons/yr) a
672
8
22,756
4,924
181
0
4,441
N/A
8,630
3
30,213
461
2,167
16
6,734
476
0
35, 007
765
454
15, 837
205
33
3,061
N/A
klk'72'04
2-17
-------
TABLE 2-2. 1990 NATIONAL SALES, INDUSTRY AVERAGE VOC CONTENT
AT MAXIMUM THINNING AND TOTAL VOC EMISSIONS AT
MAXIMUM THINNING FOR ARCHITECTURAL COATINGS18 (CONTINUED)
Coating Category
Total Volume
Sold
(thousand
gallons) a
Average
VOC Content at
Maximum
Thinning
(Ib/gal)
National
VOC at
Maximum
Thinning
(tons/yr) a
Swimming Pool Coatings
Solventborne
Waterborne
Traffic Marking Coatings
Solventbornec
Waterborne
Unknown
Undercoaters
Solventborne
Waterborne
Varnishes
Solventborne
Waterborne
Unknown
Waterproofing (Treatment)
Sealers - Clear
Solventborne
Waterborne
Other/Exempt
Waterproofing (Treatment)
Sealers - Opaque
224
2
29,246
3,052
13
1,197
1,248
8,855
166
I
12,115
766
3
4.77
2.39
3.64
0.72
1.16
3 .20
0.37
4.17
0.97
3 .74
5.49
1 .67
N/A
543
1
50,726
1, 094
24
1,918
218
18,452
80
2
33,276
641
6
Solventborne
Waterborne /Unknown
TOTAL
3 ,452
68
654, 822
2.03
0 .58
3 , 501
19
534, 382
a!990 baseline data from the 1992 NPCA survey was (reference 18)
scaled to a national population using the Current Industrial Reports
produced by the Bureau of Census (reference 32).
^Sortie manufacturers incorrectly listed coatings under the definition of
"Appurtenance," which is not a coating category. These coatings were left
under this definition for the VOC emission inventory, since they could not
be reclassified.
cExcludes acetone emissions.
N/A = Not available or not applicable.
klk-72/W
2-18
-------
based on the calculation of national baseline sales.
National VOC emissions are estimated to be
539,183 tons (413,452 tons/0.77 = 539,183 tons),
prior to adjusting for the exclusion of acetone.
4. After excluding the national acetone emissions
reported in the SRI database (i.e., 2,300 tons for
industrial maintenance and 2,500 tons for traffic
paints), the revised national VOC emission estimate
is 530,000 tons (539,183 tons - 2,300 tons -
2,500 tons = 534,383 tons or 530,000 tons, rounded
to thousands of tons).33 "For each coating category,
table 2-2 shows the VOC content per gallon at
maximum thinning and the national VOC emissions at
maximum thinning.
The EPA estimates that the total 1990 national emissions
of VOC from architectural coatings is 530,000 tons. By
comparison, national emissions of VOC from all anthropogenic
sources, including transportation, stationary source fuel
combustion, industrial processes, solid waste disposal, and
miscellaneous sources, were estimated by the EPA to be
20.4 million tons/yr in 1989.37 Architectural coatings,
therefore, represent about 2.6 percent of all VOC emissions in
the United States.
2.6.4 VOC Emissions from Specialty Coating Categories
Some architectural coating categories are greater VOC
emission sources than others because of their VOC contents
and/or the volume of use. Estimates of the relative
contributions of different coating categories to VOC emissions
are available from the 1992 NPCA survey. Some of the
specialty categories have relatively high VOC contents. As a
result, VOC emissions from specialty categories (including IM
coatings) represent 70 percent of VOC emissions from
architectural coatings, even though they represent only about
45 percent of architectural coating sales. The relative
contributions to VOC emissions from the different specialty
categories based on the 1992 NPCA survey are presented in
table 2-3. The IM coating category is the largest VOC
emissions contributor, contributing approximately 15 percent
of the emissions from specialty categories.
klk\7:/04 2-19
-------
TABLE 2-3. RELATIVE CONTRIBUTION OF INDIVIDUAL SPECIALTY
CATEGORIES TO VOC EMISSIONS FROM ARCHITECTURAL
SPECIALTY COATINGS18
Anti-graffiti Coatings
Appurtenances
Below Ground Wood Preservatives
Bituminous Coatings
Bond Breakers
Concrete Curing Compounds
Dry Fog Coatings
Fi re- re tardant /Resistive Coatings
Form Release Compounds
Graphics Arts Coatings (Sign Paints)
High Temperature Coatings
Industrial Maintenance Coatings
Lacquers
Magnesite Cement Coatings
Mastic Texture Coatings
Metallic Pigmented Coatings
Multi-colored Coatings
Opaque Stains
Opaque Wood Preservatives
Pretreatment Wash Primers
Primers
Quick- dry Enamels
Quick-dry Primers, Sealers, and Undercoaters
Roof Coatings
Sanding Sealers
Sealers
Semitransparent Stains
Semitransparent and Clear Wood Preservatives
Shellacs
Swimming Pool Coatings
Traffic Marking Coatings
Undercoaters
Varnishes
Waterproofing (Treatment) Sealers - Clear
Waterproofing (Treatment) Sealers - Opaque
Total
0.01%
0.03%
0.11%
0.74%
N/Aa
0.31%
1.67%
<0.01%
0.24%
0.15%
0.11%
16.45%
4 .80%
0.01%
0.43%
3 .90%
0.2%
4 . 66%
0.42%
0.18%
7.4%
1.18%
2.29%
8.15%
0.58%
1.92%
9.63%
4.27%
0.81%
0.14%
13.78%
0.57%
4.92%
9.01%
0.94%
100 %
a N/A = not available.
klk\72/04 2-20
-------
2.7 REFERENCES
1. U.S. Environmental Protection Agency. Control of
Volatile Organic Emissions from Existing Stationary
Sources - Volume VI: Surface Coating of Miscellaneous
Metal Parts and Products. Research Triangle Park, NC.
Publication No. EPA-450/2-78-015. June 1978.
2. Brandau, A. Introduction to Coatings Technology,
Federation Series on Coatings Technology. Federation of
Societies for Coatings Technology. Blue Bell, PA.
October 1990. pp. 12-14.
3. Reference 2, p. 11.
4. Ellis, W. H. Solvents, Federation Series on Coatings
Technology. Federation of Societies for Coatings
Technology. Philadelphia, PA. 1986. p. 7.
5. U.S. Environmental Protection Agency. Procedures for
Certifying Quantity of Volatile Organic Compounds Emitted
by Paint, Ink, and Other Coatings. Research Triangle
Park, NC. Publication No. EPA-450/3- 84 - 019. December
1984. pp. iii-iv.
6. Morgans, W. M. Outlines of Paint Technology, Third
Edition. New York, Halsted Press. 1990. p. 344.
7. Reference 2, p. 25.
8. Wicks, Z. W., Jr. Film Formation, Federation Series on
Coatings Technology. Federation of Societies for Coating
Technology. Blue Bell, PA. June 1986. p. 12.
9. Reference 6, p. 349.
10. Martens, C. R. Waterborne Coatings: Emulsion and Water-
Soluble Paints. New York, Van Nostrand Reinhold Company.
1981. pp. 58-73.
11. U.S. Environmental Protection Agency. Glossary for Air
Pollution Control of Industrial Coating Operations,
Second Edition. Research Triangle Park, NC. Publication
No. EPA-450/3-83-013R. December 1983. p. 19.
12. Reference 11, p. 23.
13. Reference 2, p. 34.
14. Reference 10, p. 192.
15. Reference 2, p. 35.
klk72'04 2-21
-------
16. Reference 10, p. 191.
17. Reference 11, p. 21.
18. Industry Insights. Architectural and Industrial
Maintenance Surface Coatings VOC Emissions Inventory
Survey. Prepared for the National Paint and Coatings
Association in Cooperation with the AIM Reg-Neg Industry
Caucus. February 6, 1995.
19. SRI International. U.S. Paint Industry Database.
Prepared for National Paint and Coatings Association.
Menlo Park, CA. 1990. p. 50.
20. Interior Latex Paints. Consumer Reports. 53(9):568-573.
September 1988.
21. Interior Semigloss Paints. Consumer Reports. 54(5) :317-
321. May 1989.
22. Interior Latex Paints. Consumer Reports. 56 (5) :335 - 337.
May 1991.
23. Paints for Finishing Touches. Consumer Reports.
55 (9) :6l9-623. September 1990.
24. Oldham, C., Radian Corporation, telecommunication with
Fitch, J., May Company. March 22, 1991. Conversation
about coating selection by painting contractors.
25. Oldham, C., Radian Corporation, telecommunication with
Medford, B., North Carolina Department of Transportation.
March 12, 1991. Conversation about specifications and
testing program of NCDOT.
26. U.S. Environmental Protection Agency. Reduction of
Volatile Organic Compound Emissions from the Application
of Traffic Markings. Research Triangle Park, NC.
Publication No. EPA-450/3- 88-007. August 1988. p. 8.
27. Oldham, C., Radian Corporation, telecommunication with
Moore, P., Ammon Painting Company. March 12, 1991.
Conversation about coating selection by painting
contractors.
28. Reference 6, pp. 371-372.
29. Reference 6, pp. 377-378.
30. Reference 6, pp. 379-383.
31. Reference 6, p. 384.
2-22
-------
32. Gromos, D. J. Current Industrial Reports: Paint and
Allied Products 1990. Bureau of Census, U.S. Department
of Commerce. Washington, DC. Publication
No. MA28F(90)-1. October 1991. 8 pp.
33. SRI International. U.S. Paint Industry Database.
Prepared for, and provided to the U.S. EPA by, National
Paint and Coatings Association. Menlo Park, CA. 1992.
p. A-18.
34. Giorgi, S., and J. J. Morgester. Field Investigation on
Thinning Practices During the Application of
Architectural Coatings in Selected Districts in
California. California Air Resources Board. Sacramento,
CA. Publication No. 91-CD-TP-2. December 1991. 12 pp.
35. Meeting Summary - AIM Coatings Regulation Negotiations
Committee Meeting, June 8-9, 1993. Docket
Number A-92-18, Docket Item II-E-48, pg. 18.
36. Meeting Summary - AIM Coatings Regulatory Negotiations
Committee Meeting, February 3-4, 1994. Docket
Number A-92-18, Docket Item II-E-68, pg. 14.
37. U.S. Environmental Protection Agency. National Air
Pollutant Emission Estimates 1940-1989. Research
Triangle Park, NC. Publication No. EPA-450/4- 91-004.
March 1991. 74 pp.
klK72'04 2-23
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3.0 INDUSTRY PROFILE
The purpose of this section is to describe the history,
development, and structure of the architectural coatings
industry, along with current economic trends and trends in the
types of products that are sold.
3.1 INDUSTRY HISTORY AND DEVELOPMENT
The first U.S. paint patent was issued in 1865 for a
composition of zinc oxide, potassium hydroxide, resin, milk,
and linseed oil.1 More recent developments in coating
technology in the 1940's were ready-to-use waterborne emulsion
paints for architectural applications. Acrylic and vinyl
acetate latex paints were first developed in Germany during
and after World War II and introduced into the United States
in the 1950's. The development of the hand roller at about
the same time promoted the use of waterborne coatings by
homeowners.^ The earliest latexes were flat coatings and were
used only for interiors, but exterior and semigloss latexes
were introduced in 1957 and 1968, respectively.3
Industrial maintenance (IM) coatings have also developed
significantly in the last half century. Polyurethane resins
were developed in 1939, epoxy resins in 1947, and both are now
commonly used in industrial maintenance (IM) coatings.3 in
the early 1950's, water-soluble and water-dispersible alkyds
were introduced for industrial applications.4 Powder coatings
based on polymer resin technology were developed in 1953, but
were first used in manufacturing settings, and only recently
have been used as IM coatings.3/5-6
.klk\72/04
3-1
-------
3.2 INDUSTRY STRUCTURE
The coatings industry, as represented in figure 3-1,
produces three types of coating products: architectural
coatings, special purpose coatings (including IM and traffic
marking coatings), and product finishes. Paint and coating
manufacturers purchase raw materials (resins, solvents,
pigments, and additives) and process them into coating
products that are sold to end users and applicators.7
Although traffic marking coatings and IM coatings are
considered by the U.S. Environmental Protection Agency (EPA)
to be categories of architectural coatings, many references
present data for them as either a separate category of
specialty or special purpose coatings. This distinction will
be maintained in this section to present more detail on the
structure of the architectural coatings industry.
Product finishes, marine coatings, and automotive
refinishing coatings will not be considered further in this
document. Product finishes were addressed in regulatory
programs developed in the 1970's and 1980's. Marine coatings
and automotive refinishing coatings are the subject of other
consumer and commercial product regulations under the Clean
Air Act, as amended in 1990 (Act).
The following subsections describe the structure of the
U.S. architectural coatings industry in terms of raw material
consumption, manufacturers, and distributors and retail
markets.
3.2.1 Raw Material Consumption
The raw materials that are consumed by the architectural
coatings industry are resins or binders (representing
28.4 percent of total raw materials used by weight), pigments
(51 percent), solvents or carriers (18.7 percent), and
additives (1.9 percent). In 1991, a total of 4,396 million
pounds of resins, pigments, solvents, and additives were used
as raw materials in architectural coatings.^ About 75 percent
of these raw materials are derived from fossil fuels, with
Uk\72/04
3-2
-------
Agricultural Products
Basic
and
Intermediate
Raw Materials
Consumer
Professional
Commercial/
Industrial
Automotive
Refinishing
Industrial
Maintenance
Marine
Traffic Marking
Prefinished
Materials for
Fabrication
Original
Equipment
Manufacturers
Acquisition of
Source Material
Chemical/Material
Manufacturing
Paint Materials
Manufacturing
Manufacturing/
Formulating
Product
Types
Uses
I.
B
Figure 3-1. Coating industry structure.
3-3
-------
the remainder being derived from both mineral and agricultural
product materials.9
In 1991, the architectural coatings industry consumed
approximately 1,250 million pounds of resins. The bulk were
alkyd, acrylic, and vinyl resins used in architectural
coatings. The consumption of resins by coating and resin type
for 1991 is presented in table 3-1.10"11
Types of pigments used in architectural coatings include
colors, fillers and extenders, and corrosion inhibitors.
Titanium dioxide is the most commonly used pigment due to its
hiding power. Clays, talcs, silicas, and calcium carbonate
are the most commonly used fillers and extenders. Zinc dust
and zinc oxide are the pigments most commonly used as
corrosion inhibitors. Pigment consumption for architectural
coatings in 1991 is summarized in table 3-2.^O,12
Total solvent consumption for architectural coatings in
1991 was 821.5 million pounds or 410,750 tons. Over one-half
of the solvents used in 1991 were aliphatic hydrocarbons. The
solvent consumption by coating and solvent type for 1991 is
presented in table 3-3.10*13 As indicated in the table, 6 of
the 19 solvents listed are hazardous air pollutants (HAP's)
subject to the provisions of section 112 of the CAA.
Additives represent only a small percentage of the raw
materials used in the manufacture of architectural coatings.
The bulk of additives are used in architectural coatings, with
only small amounts used in IM coatings and traffic markings.
Thickeners, surfactants and dispersing agents, and antifoaming
agents are the most commonly used coating additives. The
consumption of additives in 1991 by coating type and additive
is presented in table 3-4.10*14
3.2.2 Architectural Coatings Manufacturers
Architectural, IM, and traffic coatings accounted for
52 percent of the volume of all paint and allied products
shipped in 1990 and 46 percent of their value. In 1990,
1,219 million gallons (Mgal) of all paints and allied products
klk\72/CW
3-4
-------
TABLE 3-1. 1991 RESIN CONSUMPTION BY COATING
AND RESIN TYPE (MILLIONS OF POUNDS)11
Resin Type
Alkyd
Acrylic
Vinyl
Epoxy
Urethane
Phenolic
Styrene
Architectural
246
262
355
-
40
8
15
Coating Type
Industrial
Maintenance
6
9.9
14
41.9
23.7
1.6
.
Traffic
75.5
10.7
-
-
-
-
_
Butadiene
Polyester
Chlorinated
Rubber
Natural (e.g.,
shellac, gums)
Linseed Oil
Other
Totalsa
70
17
1,019
2.0
17.2
116.3
0.6
1.0
26.5
114.3
aTotal architectural coatings resin use (including IM
and traffic marking coatings) in 1991 was
1,249.6 million pounds.
klk\72/04
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TABLE 3-2. 1991 PIGMENT CONSUMPTION BY COATING
AND PIGMENT TYPE (MILLIONS OF POUNDS}12
Pigment Type Architectural
Coating Type
Industrial
Maintenance
Corrosion
Inhibitors
and Others
Totalsa
19
1,648
29.2
100.6
Traffic
Colors
Fillers and
Extenders
510
1,119
52.4
19
281.9
209.9
491.8
aTotal architectural coatings pigment use (including IM
and traffic marking coatings) in 1991 was
2,240.4 million pounds.
k.lk\72/04
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TABLE 3-3. 1991 SOLVENT CONSUMPTION BY COATING
AND SOLVENT TYPE (MILLIONS OF POUNDS)13
Coating Type
Solvent Type
Architectural
Industrial
Maintenance
Traffic
Aliphatic
Hydrocarbons
Toluene3-
Xylenesa
Other Aromatics
Butyl Alcohol
Ethyl Alcohol
Isopropyl Alcohol
Other Alcohols
Acetone
Methyl Ethyl Ketonea
Methyl Isobutyl
Ketonea
Ethyl Acetate(s)
Butyl Acetates
Propyl Acetates
Other Ketones and
Esters
Ethylene Glycola
Propylene Glycol
Glycol Ethers3 &
Ether Esters
Chlorinated Solvents
Miscellaneous
Totalsb
420
32
69
28
12
568
3.3
24.2
31.0
9.4
3.1
4.7
2.0
8.5
6.1
19.3
4.4
6.1
5.5
2.0
129.6
25.8
58.7
0.9
14.7
4.9
7 .4
11.5
123.9
aHAP's subject to the provisions of section 112 of the
Act, as amended in 1990.
bTotal architectural coatings solvent use (including IM
and traffic marking coatings) in 1991 was
821.5 million pounds.
3-7
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TABLE 3-4.
1991 CONSUMPTION OF PAINT ADDITIVES BY
COATING AND ADDITIVE TYPE
(MILLIONS OF POUNDS)14
Coating Type
Additive
Industrial
Architectural Maintenance
Traffic
Surfactants and
Dispersing
Agents
Driers
Thickeners
Preservatives
and Mildewcides
Antiskinning
Agents
Antifoaming
Agents
Totalsa
27.0
0.0
33.0
6.0
2.0
16.0
84.0
0.11
0.08
0.19
0.16
0.30
0.46
aTotal AIM coatings additives use (including IM and
traffic marking coatings) in 1991 was 84.65 million
pounds.
,klk\72/04
3-8
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with a value of approximately $12.4 billion were shipped from
U.S. manufacturers.15
In this section, information is presented on the number
and size of the manufacturers of architectural coatings, first
for manufacturers of architectural coatings, then for
manufacturers of IM coatings (sometimes referred to as
"industrial new construction and maintenance coatings" and
"high performance maintenance coatings") and traffic marking
coatings (sometimes called just "traffic coatings").
3.2.2.1 Architectural Coating Manufacturers. In 1987,
there were 285 companies that each had total shipments of
architectural coatings* of $100,000 or more in value.16
A second source reports that 527 companies produced
architectural coatings in 1989.9 The difference in these two
estimates is probably due to the fact that the second
reference includes those companies that produced less than
$100,000 worth of architectural coatings, as well as special-
purpose coatings and product finishes. For comparison, the
1987 Census of Manufactures identified 1,123 companies
operating 1,426 establishments that manufactured all types of
paints and allied products.^
The bulk of architectural coatings are produced by
20 large companies. In 1989, the top 20 companies accounted
for 59.6 percent ($2,808 million) of the value of total
architectural coating shipments.9 These top 20 companies and
the value of their U.S. shipments are provided in table 3-5.1*?
The U.S. production of architectural coatings is
geographically dispersed. In 1987, the top six States for the
production of architectural coatings, based on the value of
shipments, were (in decreasing order) California, Illinois,
Texas, Maryland, Georgia, and Ohio. These six States
*The Bureau of the Census defines architectural coatings as
"Coatings for on-site application to interior or exterior
surfaces of residential, commercial, institutional or
industrial buildings. These are protective and decorative
finishes applied at ambient temperatures for ordinary use and
exposure."
,klk\72/04
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TABLE 3-5. MAJOR U.S. PRODUCERS OF
ARCHITECTURAL COATINGS1'7
Rank
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
Company
Sherwin- Williams*3
Benjamin Moore
Glidden (ICI)C
PPGd
DeSoto
Valspar
Grow Group
United Coatings
Williams Holdings
Courtaulds (Porter)
Kelly -Moore
M.A. Bruder
Dunn - Edwards
Duron
Pratt & Lambert
Standard T
Vogel
Sinclair
O'Brien
Jones-Blair
Other
Total
Value of Shipment sa
($Million)
$475
350
300
235
173
165
143
100
100
95
90
82
70
70
70
65
65
60
52
48
1.906
$4,714
aU.S. shipments only of paints manufactured by that
producer (may include transfers to company stores).
^Acquired DeSoto in 1990.
clncludes purchase of Roach Paint Co.
^Acquired Olympic/Lucite in 1989.
klk\72/04
3-10
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represented 56.6 percent of the total value of U.S.
architectural coating shipments.16
3.2.2.2 IM and Traffic Coatings Manufacturers. Data for
manufacturers of IM coatings and traffic marking coatings are
compiled by the Bureau of the Census separately from their
data for architectural coatings manufacturers. However, they
are compiled in a category described as "special-purpose
coatings," which also includes marine coatings, auto
refinishing coatings, and aerosol coating concentrates. Some
of the data for IM and traffic marking coatings from the
Bureau of the Census are not separated from the overall
statistics for special-purpose coatings.
Industrial maintenance coatings and traffic coatings
accounted for about 44 percent of the volume and 32 percent of
the value of special-purpose coatings in 1990.13 In 1987,
there were 245 companies that had total shipments of special-
purpose coatings of $100,000 or more in value.16 The major
U.S. producers of special-purpose coatings whose principal
products also include IM coatings and traffic coatings are
listed in table 3-6. The companies listed in table 3-6
represented 41 percent of the total value of special-purpose
coating shipments in 1989.18 -phe value of IM and traffic
coating shipments is not known for these companies.
Like architectural coatings, the production of special-
purpose coatings is geographically dispersed; therefore, the
same is probably true for IM coatings and traffic coatings.
In 1987, the top six States for production of special-purpose
coatings based on the value of shipments were (in decreasing
order) Ohio, Missouri, New Jersey, California, Texas, and
Illinois. These States represented 55 percent of the total
value of special purpose coating shipments in 1987.16
3.2.3 Distributors and Retail Markets
Architectural and IM coatings are sold to painting
contractors and commercial and IM users through company
stores, independent dealers, mass retailers, and through
chains of home improvement centers. Do-it-yourself consumers
u 3-11
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TABLE 3-6.
MAJOR U.S. PRODUCERS OF IM COATINGS
AND TRAFFIC COATINGS18
Company
Value of Shipments
in 1989 ($Million)a Principal Products*3
Sherwin-Williams
RPMC
Courtlands
Rust -Oleum
Glidden
Ameron
Grow
Tnemec
Sigma
ConLux
Morton
International
Valspar
Centerline
360
150
115
65
55
53
45
30
25
20
20
20
17
Auto refinishing,
maintenance
Protective
Maintenance ,
Protective
Maintenance
Protective
Maintenance,
Protective
Maintenance,
Maintenance
Traffic
Maintenance
Traffic
marine
marine
marine
aValue of shipments include sales of the product
categories listed to the right.
t>Auto refinishing and marine coatings are included
because the Rauch Guide did not separate these
categories by value of shipments. Protective coatings
are equivalent to industrial protective coatings.
Maintenance coatings are equivalent to high-performance
architectural coatings. Protective coatings have
higher performance requirements than maintenance
coatings.
clncludes Kop Coat acquired in 1990.
,klk\72'«
3-12
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and homeowners purchase architectural coatings through many of
the same sellers as other coating users, but generally do not
purchase IM coatings. Summary statistics for architectural
coating distributors and retail markets are presented in
table 3-7 and described in more detail below.16'19"20
The National Paint and Coatings Association (NPCA)
estimates that there were about 42,000 retail outlets for
architectural coatings in 1992. Of these, 3,750 are stores
operated by paint companies, 4,700 are independent retailers
that purchase paint from a wholesaler, 14,700 are lumber and
other building material dealers, 14,900 are hardware stores,
and 4,000 are mass merchandisers.21
The Bureau of the Census estimates that 29,900 firms were
engaged in the application of architectural and IM coatings in
1987. The value of this activity in 1987 was $7.9 billion, of
which $6.3 billion was for building construction and
$976 million was for nonbuilding construction. Construction
work "not specified by kind" accounted for $686 million in
value.2^ Building construction includes residential,
commercial, and institutional buildings that most likely
represent architectural coating applications. Nonbuilding
construction includes bridges and elevated highways, utility
plants, and heavy industrial facilities that probably
represent IM coating applications.
3.2.3.1 Architectural Coatings. According to the 1990
U.S. Census of Paint and Allied Product Manufactures, 558 Mgal
of architectural coatings at a value of $4,862 million were
shipped in 1990.1^ Interior waterborne coatings are the
largest segment of the architectural market representing
47 percent of the volume and 41 percent of the value of
coatings shipped. These are followed by exterior waterborne
coatings (26 percent of the volume, 24 percent of the value),
exterior solventborne (14 percent of the volume, 18 percent of
the value), and interior solventborne (10 percent of the
volume, 13 percent of the value). The remainder of
, klk\72/04
3-13
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TABLE 3-7.
SUMMARY OF AIM COATING DISTRIBUTORS
AND RETAIL MARKETS
Category
AIM Coating Retailers19
AIM Coating Applicators
(1987)20
Architectural Coating
Shipments (1990) 16
Industrial Maintenance
Shipments (1990) 16
Traffic Marking Shipments
(1990)16
All Paint and Allied Products
(1990)16
Number or
Volume
42,000
29,900
558 Mgal
58.9 Mgal
22.2 Mgal
1,219 Mgal
Value
($Million)
(Not Available)
7,953
4,862
723
122
12,368
vklk\72/04
3-14
-------
architectural coatings (3.1 percent of both the volume and the
value) are lacquers and coatings "not specified by kind."13
A study sponsored by the NPCA estimated that about
60 percent of architectural coatings were used for residential
structures and the remainder on commercial, institutional, or
light-industrial structures. About two-thirds of the paint
applied to residential structures is done by homeowners and
the rest by contractors.22
3.2.3.2 IM Coatings. Industrial maintenance coatings
accounted for 59 Mgal of coating shipments in 1990 at a value
of $723 million. Exterior coatings represented 62 percent of
the total volume of IM coatings shipped and 68 percent of the
value.13
About 30 percent of IM coatings are used on new
construction, about 75 percent are applied to iron or steel,
and about 67 percent are applied using spray techniques.
Nonfactory structures account for 30 percent of the use of
these coatings and include utilities, bridges, highways,
railroads, sewer and water plants, and other processing
plants.23
Some grades of IM coatings are intended for very high
performance and are similar to original equipment manufacturer
(OEM) finishes. Others are intended for lower performance and
are more similar to architectural coatings. Industrial
maintenance coatings are generally solventborne and include
alkyd, vinyl, epoxy, and urethane formulations. Polyurethane
and epoxy systems are the dominant and fastest-growing
systems.23
3.2.3.3 Traffic Marking Coatings. Traffic marking
coatings accounted for 22.2 Mgal of shipments in 1990, valued
at about $122 million.13 These coatings are used for marking
pavement on roads, parking lots, runways, and roadside
posts.23 They must be durable and visible under all surface
and weather conditions. Fast-drying products are highly
desirable to minimize application costs and traffic delays
since the travel lane being marked must be closed to traffic.
3-15
-------
In 1990, solventborne alkyd and alkyd-chlorinated rubber
resins accounted for most of the volume used. Waterborne
acrylic coatings accounted for about 10 percent of the volume
used. The remainder were two-component epoxies,
polyester-based coatings, and hot-extruded thermoplastic
coatings.24
About 65 percent of total consumption of traffic marking
paints is by State highway departments, about 25 percent are
sold to city and county road authorities, and the rest are
used in parking lots and garages.24 Traffic coatings are
usually sold by competitive bid to government agencies and are
applied by contractors or government employees.23 Some
States, however, manufacture their own traffic marking
coatings.
3.3 CURRENT INDUSTRY TRENDS
3.3.1 Architectural Coating Sales
The consumption of architectural coatings is closely tied
to national economic trends. Between 1981 and 1991, the
volume of architectural coatings shipped by manufacturers
increased at the average rate of about 1 percent per year. In
this period, the volume of architectural coatings sold
significantly dropped during the recessionary years of the
early 1980's. In 1991, there was a 5 percent drop because of
economic slowdown.25 This drop in volume sales reflected a
sharp drop in residential construction and, more importantly,
a sharp drop in sales of existing houses. This drop was
offset slightly by an increase in the do-it-yourself market
for architectural coatings and an overall increase in
architectural coating sales from 1983 to 1991.26
Sales of architectural coatings recovered in the period
from 1983 to 1987 and remained level from 1987 to 1989, with
greater than a 5 percent drop in 1991, as shown in
table 3-8.13'27"28 Data from the Bureau of the Census
indicate an increase in the shipment of architectural coatings
from 1989 to 1990.13 Shipments of architectural coatings are
forecast to be 565 Mgal in 1995.9 The reason for the
3-16
-------
TABLE 3-8. 1979 to 1991 CONSUMPTION OF COATINGS
(MILLIONS OF GALLONS)
Coating Type
Architectural
Highway and
Industrial Traffic
Year SRI^7 Census^^S Maintenance^"? Markings^7
1979
1980
1981
1982
1983
1984
1985
1986
1987
1988
1989
1990
1991
459
432
415
391
431
455
465
480
493
495
493
498
470
457.
477.
498.
527.
535.
537.
557.
3
9
1
0
9
5
7
28.
29.
30.
27.
25.
27.
28.
28.
29.
31.
32.
32.
32.
5
5
5
5
0
5
0
0
0
0
0
0
0
44
42
41
40
40
41
41
42
42
42
42
42
41
3-17
-------
increasing difference between the SRI and Bureau of the Census
estimates shown in table 3-8 is not known.
3.3.2 Industrial Maintenance and Traffic Coating Sales
The trend in shipments of IM coatings since 1979 is
similar to that of architectural coatings, even though this
category was formerly thought to be "recession proof."^9
Consumption of IM coatings increased throughout the 1980's
except for a decline in 1982 and 1983. Industrial maintenance
coating consumption tends to lag behind economic recoveries,
and the recovery in IM coatings follows that for architectural
coatings by 1 or 2 years.^
Traffic coating consumption has remained relatively
stable since 1979 (table 3-8). However, usage has declined
since 1989 due to higher prices, government budget
constraints, and the use of more durable coatings.9
3.3.3 Coating Technology Trends
The development of lower-volatile organic compound (VOC)
technology through the use of higher-solids and waterborne
coatings has been a general trend in the coating industry,
including architectural and IM coatings. In the 1970's,
coatings were generally of two types: waterborne latexes and
low-solids solventborne coatings. Lower-VOC coating
technology now includes higher-solids coatings, water-soluble
coatings, and solventless (powder or 100 percent solids
liquid) coatings, in addition to waterborne latex coatings.30
These lower-VOC technologies are discussed in more detail in
chapter 4.0, Emission Control Techniques.
The forces driving this technological trend are a desire
by consumers for waterborne coatings and, more recently, the
regulation of VOC emissions by States to meet the National
Ambient Air Quality Standard for ozone.31 These State
regulations were outlined earlier in chapter 2.0, Product
Category Description. Concerns about the supply of petroleum-
derived solvents was a factor encouraging lower-VOC technology
in the 1970's and early 1980's, but has not been a factor
since the mid-1980's.31
Uk\72/04
3-18
-------
The overall trend towards lower-VOC coatings is reflected
in the consumption of solvents compared to that of resins as
raw materials since 1979. During the recession of the early
1980's, resin consumption did not drop as far as that of
solvents and recovered more quickly following the recession.
Solvent use dropped 19 percent from 1979 to 1982 and in 1989
had recovered to only 95 percent of the 1979 consumption rate,
and then experienced a 7 percent drop from 1989 to 1991.32,33
In contrast, resin use dropped only 15 percent and by 1989 had
increased to 8 percent above the 1979 consumption rate, with
only a 5 percent drop from 1989 to 1991.34,35
The fraction of resin used in higher-solids and
waterborne coatings, such as epoxies and acrylics, has grown
faster than the fraction used in solventborne coatings, such
as alkyds and vinyls. This is reflected in an overall decline
in solvent consumption, particularly in the use of aliphatic
hydrocarbons, the solvent type most often used in conventional
solventborne coatings. This decline in use of aliphatic
hydrocarbons is also due to their low solvency power and their
replacement by stronger solvents to produce higher-solids
coatings. Aliphatic hydrocarbons represented 20 percent of
total paint solvent consumption in 1991, compared to
30 percent in 1973.29
In 1991, about 76 percent of architectural coatings were
waterborne. Interior architectural coatings were about
76 percent waterborne and exterior architectural coatings were
about 68 percent waterborne. The percentages that are
waterborne have leveled off since the late 1970's. However,
the trend toward increased use of waterborne coatings is
expected to resume as a result of increased State and Federal
regulations to lower VOC emissions.^7
Table 3-9 summarizes the percentages of several types of
architectural coatings that are waterborne and solventborne
for 1973, 1981, and 1991.10/36 There has been a trend towards
waterborne architectural coatings for interior and exterior
flats, interior semiglosses, and exterior stains, as well as
klk\72/CW
3-19
-------
interior and exterior coatings listed as "other" in table 3-9.
However, interior and exterior varnishes, interior glosses,
and exterior enamels remain almost entirely solventborne.9
In 1989, 85 percent of IM coatings and 85 percent of
traffic coatings were conventional solventborne coatings.
High-solids coatings (solventborne coatings with at least
60 percent solids by weight) were 10 percent of IM coatings.
Only 5 percent of IM coatings and 15 percent of traffic
coatings were waterborne.^7
3.3.4 Trends in Alternatives to Coatings
Wallpaper and vinyl wall coverings are alternatives to
interior architectural coatings. Their market shcire of sales
by paint, glass, and wallpaper stores has increased from about
10 percent in 1967 to 18 percent in 1987, while the share of
paint has dropped from 54 percent to 42 percent. The vinyl
siding market, which represents an alternative to the use of
exterior coatings, is also growing and represented 32 percent
of the market for coverings of exterior residential surfaces
in 1991.38 These trends are probably due to changes in
consumers' preferences and a desire for lower-maintenance
coverings, rather than a response to VOC regulations.
3-20
-------
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3.4 REFERENCES
1. Martens, C. R. Waterborne Coatings: Emulsion and
Water-Soluble Paints. New York, van Nostrand Reinhold
Company. 1981. p. 2,
2. Reference 1, p. 3.
3. Brandau, A. Introduction to Coatings Technology,
Federation Series on Coatings Technology. Federation
of Societies for Coatings Technology. Blue Bell, PA.
October 1990. p. 8.
4. Reference 1, p. 4.
5. Glass, T. and J. Depoy. New Resins and Equipment Make
Field-Applied Powder Coatings a Reality. Journal of
Protective Coatings and Linings. 8(7):33-36.
July 1991.
6. Glass, T. and J. Depoy. Protective Thermoplastic
Powder Coatings: Specifically Designed Adhesive
Polymers. In: Maintaining Structures With Coatings.
Proceedings of SSPC 91, Long Beach. Pittsburgh, Steel
Structures Painting Council. November 10-15, 1991.
pp. 267-279.
7. SRI International. U.S. Paint Industry Database.
Prepared for, and provided to the U.S. Environmental
Protection Agency by, National Paint and Coatings
Association. Menlo Park, CA. 1992. p. 2.
8. Reference 7, pp. A-9 - A-10.
9. Rauch Associates, Inc. The Rauch Guide to the U.S.
Paint Industry. Bridgewater, NJ. 1991.
10. Reference 7, p. A-18.
11. Reference 7, pp. A-7 - A-8.
12. Reference 7, pp. A-11 - A-12.
13. Reference 7, pp. A-15 - A-16.
14. Reference 7, p. A-18.
15. Gromos, D. J. Current Industrial Reports: Paint and
Allied Products 1990. Bureau of the Census,
U.S. Department of Commerce. Washington, DC.
Publication No. MA28F(90)-1. October 1991. 8 pp.
klk\72/04
3-22
-------
16. Bureau of the Census, U.S. Department of Commerce.
1987 Census of Manufactures - Paints and Allied
Products, Industry 2851. Washington, DC. Publication
No. MC87-1-28E. January 1990. 11 pp.
17. Reference 9, p. 64.
18. Reference 9, p. 85.
19. Information provided to the U.S. Environmental
Protection Agency by the National Paints and Coatings
Association at the Regulatory Negotiation Meeting,
March 19 and 20, 1992. Washington, DC.
20. Bureau of the Census, U.S. Department of Commerce.
1987 Census of Construction Industries - Painting and
Paper Hanging Special Trade Contractors, Industry 1721.
Washington, DC. Publication No. CC87-I-11.
January 1990. 36 pp.
21. Information provided to U.S. Environmental Protection
Agency at Regulatory Negotiation Committee Meeting.
April 15-16, 1992. Raleigh, NC.
22. SRI International. U.S. Paint Industry Database.
Prepared for and provided to the U.S. Environmental
Protection Agency by, National Paint and Coatings
Association. Menlo Park, CA. 1990. p. 50.
23. Reference 9, p. 86.
24. Reference 7, p. 79.
25. Reference 7, p. 47.
26. Reference 7, p. 49.
27. Reference 7, p. 44.
28. Shelton, N. A. Current Industrial Reports: Paint and
Allied Products 1989. Bureau of the Census,
U.S. Department of Commerce. Washington, DC.
Publication No. MA28F(89)-1. October 1990. 8 pp.
29. Reference 22, p. v.
30. Reference 7, pp. 31-32.
31. Reference 22, pp. 32-35.
32. Reference 22, p. 143.
33. Reference 7, p. 143.
klk\72/04
3-23
-------
34. Reference 22, p. 85.
35. Reference 7, p. 85.
36. Reference 7, p. 46.
37. Reference 22, p. 37.
38. Reference 1, pp. 50-51.
3-24
klk'72/M J ^
-------
4.0 EMISSION CONTROL TECHNIQUES
Reformulation to higher-solids and waterborne coatings
is the means by which volatile organic compound (VOC)
content of coatings is reduced. The extent to which either
of these is technologically and economically feasible will
vary among coating categories.
Advantages of waterborne products or formulations, in
addition to reduced VOC emissions, are related to the health
hazards associated with the solvents used in architectural
coatings. These solvents may be harmful if inhaled and are
usually flammable. The use of waterborne coatings may
reduce the potential for fires and solvent exposure of
workers during application, and therefore improve industrial
hygiene and safety for applicators and consumers.1 Easier
cleanup, faster drying time, and the reduced odor of
waterborne coatings are also major reasons they are
preferred over solventborne coatings in residential
applications.2
Despite these advantages, some industry representatives
claim that some lower-VOC coatings are inferior to
conventional higher-VOC coatings. In particular, the
argument has been made that lower-VOC coatings, especially
high-solids alkyds, may be more viscous and tend to produce
a thicker coat when applied directly from the can, therefore
increasing the amount of coating consumed and the VOC
emissions per unit of area covered. It has also been argued
that lower-VOC coatings may encourage more thinning, which
will negate any reduction in VOC content. Further arguments
include the position that some lower-VOC coatings may also
Uk\72/04
4-1
-------
require more priming and more topcoats, because of poor
adhesion and hiding ability, respectively. Industry
representatives have also argued that lower-VOC coatings dry
more slowly, are more susceptible to damage and defects
during drying, and are less durable. Consequently,
opponents of coating VOC restrictions maintain that
lower-VOC coatings will require more touchups and repair
work, and more frequent recoating. Finally, industry
representatives have argued that lower-VOC coatings will
require solvents that may be more reactive in the formation
of stratospheric ozone.3 However, advances in lower-VOC
technology have led to the development of some waterborne
and high-solids coatings that have performance equal to or
improved over that of higher-VOC coatings.4"7 Architectural
coatings are offered in varying degrees of quality at both
high- and low-VOC levels.
A lower-VOC coating may require a different resin
system. When comparing different coating systems for a
specific application, the resins involved may be evaluated
with respect to the following:
Chemical resistance;
Scuff/mark resistance;
Abrasion resistance;
Corrosion resistance;
Flexibility;
Color retention and gloss level;
Hardness;
Drying time; and
Temperature stability.
For example, where an epoxy may provide superior corrosion
resistance for a metal substrate than would an alkyd, the
alkyd may have better resistance to ultraviolet radiation.
The alkyd would likely exhibit greater color retention upon
exterior exposure but the epoxy may tend to chalk and its
color fade when exposed to sunlight. The performance
characteristics required of a resin may vary widely from
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application to application and a tradeoff among these is
often required.
Lowering the VOC content may involve substituting a
higher-solids, lower-VOC epoxy coating for a lower-solids,
higher-VOC alkyd coating to use in the same application.
Alternatively, a lower-VOC product may be available that
uses the same resin but has a different chemistry that
requires a lower solvent content.
4.1 LOWER-VOC COATING TECHNOLOGIES
Lower-VOC coating technology alternatives for
architectural coating applications can be divided into three
categories:
Waterborne coatings;
Higher-solids coatings; and
Powder coatings (limited applications).
The following sections discuss these technologies and how
they differ from conventional coatings.
4.1.1 Waterborne Coatings
Waterborne architectural coating technologies are
primarily emulsions (also known as latexes). These are two-
phase systems in which very fine droplets of resin (the
dispersed phase) are suspended or dispersed in water (the
continuous phase) in which the resin is insoluble.8
Emulsions form films by evaporation of the water, which
brings the resin droplets closer together until they
coalesce to form a continuous film.^"1^
Vinyl acetate and acrylic emulsions are commonly used
in architectural coatings. Coatings based on vinyl acetate
emulsions are used by professional and do-it-yourself
painters, primarily on interior walls and ceilings. Their
advantages include relatively low levels of organic
volatiles, ease of application with brushes or rollers,
short drying times (recoating is usually possible in a few
hours), and cleanup can be done with water.10
Coatings based on acrylic emulsions are used in many of
the same applications as vinyl acetate-based coatings for
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interior walls and ceilings. In addition, they are more
durable than vinyl acetate-based coatings and may be used as
wood primers and exterior finishes. Acrylic latex coatings
using harder polymers may be used as floor coatings and as
primers for new galvanized iron.11
Waterborne coatings may be brushed, rolled, and sprayed
with conventional equipment and are frequently used for flat
and nonflat house coatings. However, because of the drying
and adhesion requirements of some specialty coatings,
waterborne systems are not well suited to some specialty end
uses. Examples include dry fog coatings where high relative
humidity at the application site may limit water evaporation
and increase drying time, and concrete coatings where
alkalies may leach into the film and disrupt the resin
system. ^
4.1.2 Higher-Solids Coatings
Higher-solids coatings require less solvent to induce
flow and form thicker films than conventional coatings of
the same type. Examples of high-solids coatings include
some types of epoxies and polyurethanes.1^ Some
two-component resin systems contain no solvent and are
100-percent solids. The U.S. Environmental Protection
Agency (EPA) defines "higher-solids" coatings as generally
having greater than 60-percent solids by volume, but
recognizes that the term is relative to the typical solids
content for a particular coating category.1^
Thicker films are only desirable in some coating
categories. Waterproofing sealers and stains, for example,
have very low solids by design because their purpose is to
seal or color the surface being coated without creating a
film that hides the texture of the surface. Other coatings,
such as mastic texture coatings, are intended to be applied
as thick films, so they are formulated to have relatively
high solids contents. Most coatings with solids higher than
60 percent (including two-component, 100-percent solids
epoxy and polyurethane coatings) are associated with
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industrial maintenance (IM) coating applications, such as
bridge coatings and corrosion protection for storage
tanks.5/15-16
Current high-solids technology focuses on using lower-
molecular-weight resins of low viscosity. In 100-percent-
solids systems such as epoxy and polyurethane coatings,
which have been used on storage tanks and bridges, the
resins are nonvolatile liquids that react with each other
and harden without solvent evaporation.15'16 Producing
higher-solids coatings to meet specific performance criteria
often requires extensive hybridization and modification of
traditional resin systems. Some of the hybrid resin systems
and conventional two-component systems, such as
polyurethane, can be modified to use lower-molecular-weight
resins and can be applied with liquid hardeners.15"16
Like conventional coatings, most higher-solids coatings
can be applied by brush, roller, or spray. The principal
application method for 100-percent-solids coatings is by
spray because most of these coatings are two-component epoxy
or polyurethane systems that require component mixing during
application.15"16 The polyurethanes may have an advantage
over epoxies because they can be applied at colder
temperatures and, even though initial coating cost is
higher, may be less expensive over the life of the coating
because of greater durability depending on the exposure
situation.15
4.1.3 Powder Coatings
Powder coatings are a near-zero-VOC coating technology,
initially developed and used in metal product manufacturing
industries, that has now been adapted for other coating
applications. In manufacturing settings, powder coatings
are generally applied by two separate techniques:
Immersion of a heated substrate into a fluidized
bed of powder; or
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Electrostatic deposition of the powder to a
substrate that has been preheated or is
subsequently heated.
Heating of the powder system or substrate, or both, is
required to liquefy, induce flow, and initiate chemical
reactions within the coating to assure proper film
formation. Because of these constraints, powder coating
technology was formerly considered to be limited to the
coating of fabricated metal products. However,
technological advances in powder coatings and thermal spray
equipment have enabled their use in several IM coating
applications including the coating of bridges and other
steel structures. Powder coatings with field applications
are grouped into two systems: polymer resin systems and
metallizing systems. Powder coating systems as a group have
demonstrated good performance relative to more conventional
IM coatings in accelerated performance tests.5 The current
uses of these powder coating systems in various IM
applications are described below.
4.1.3.1 Polymer Resin Systems. Thermoplastic
polymers, such as polyethylene and polypropylene, were among
the first powder coatings to be developed. They also have
the simplest application mechanism, which involves melting
the solid polymer, spraying the hot liquid onto a heated
metal substrate, and resolidification of the polymer as a
thin film. However, these coatings have shown marginal
abrasion resistance because of poor film adhesion that can
cause the coating to fail completely if the film is
punctured.17 Efforts to improve performance have resulted
in the development of modified polymers that have
demonstrated greater ability to withstand physical and
corrosive attack than traditional polymers and even some
conventional epoxy coatings.6~7
Currently, polymer resin powder coatings are not cost
effective in most applications for steel structures compared
to more conventional coatings, such as two-part catalyzed
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epoxies. However, in some architectural coating situations
powder coatings are a better alternative. Specifically,
these include areas of high abrasion, such as highway light
poles subject to blowing sand and road salt, or where a
specific chemical resistance is needed, such as chemical
storage tank linings. In addition, because both the coating
and substrate are heated, application can be done in almost
all weather conditions, even extreme cold. One of the
primary limitations of these coatings is that they are not
very resistant to temperatures above 165 op^6-7
4.1.3.2 Metallizing Systems. Metallizing coatings are
applied to structural steel or other metal objects by
melting and spraying a metal. The most common metals
applied are zinc and aluminum, either separately or as an
alloy. 3-8 Metallizing systems are primarily used for
high-performance and industrial corrosion protection, such
as structural steel or tank linings. They have also been
used in a few cases to apply zinc coatings to steel-
reinforced concrete to protect the reinforcing rods from
corrosion.19-20
Specialized equipment is required to apply metallizing
systems. The metal coatings are applied using a gun that
melts a metal wire or powder and then uses compressed air to
spray the molten metal on the substrate to be coated. The
heat source to melt the wire or powder inside the gun is a
flame using an acetylene and oxygen mixture or an electric
arc.18
Metallizing coatings can only be applied to bare steel
or concrete that has been abrasive blasted. Because the
metal coating adheres to the substrate by mechanical
adhesion, the prepared surface must have the appropriate
surface roughness or profile.18
Regardless of whether applying polymer resin or
metallizing coating systems, the cost of thermal spray
equipment for field use is approximately two to three times
the cost of conventional coating equipment. This cost is
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mitigated in some circumstances because powder coating
lifespan is often two or three times longer than that of
conventional coatings when the coating must withstand severe
abrasion or corrosion.6-7,21
4.2 PRODUCT REFORMULATION
4.2.1 Resins
Next to the solvent, resins have the most significant
effect on VOC content. The need for solvent can be reduced
by reducing resin viscosity, which can be done by lowering
the molecular weight of the resin. However, with
conventional resin types this can impair the performance of
the coating.22
One alternative is to use a two-component resin system,
such as with an epoxy or urethane system, in which two low-
molecular-weight components are combined just prior to, or
during, application. These two components react during
curing to form larger molecules through cross-linking.
These types of systems may have good hardness and chemical
resistance, but, because of the tightly cross-linked
structure, they may lack flexibility and impact arid abrasion
resistance.22 Epoxy and polyurethane resins are used in
many IM coatings where hardness and chemical resistance are
needed, but this technology is poorly suited for consumer
use because of limited pot-life (i.e., storage life) and
increased complexity.15"16
A second alternative is to use natural-drying oil
resins, such as linseed oil, that are 100-percent solids and
do not require solvents. However, these resins are not
suitable for interior applications because they are prone to
yellowing, mildewing, and dry slowly.23
4.2.2 Pigments
Altering the pigment content of a coating is generally
not an effective means of lowering its VOC content. Adding
pigment, particularly if the pigment particles absorb the
resin, tends to increase the coating viscosity and may make
application more difficult.22 In addition, many coating
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properties are closely tied to the pigment volume
concentration.
Low-density hollow glass or plastic microspheres, or
materials that have been treated to have low rates of resin
absorption, can be added to a coating to build solids volume
without significantly affecting viscosity. These are more
effective in reducing VOC content than the addition of
conventional pigments.22
4.2.3 Plasticizers
Plasticizers are low-viscosity liquids with little
volatility. They can be used as fillers to increase the
"solids" volume while reducing the viscosity of the wet
paint. Plasticizers are commonly used in thermoplastic
coating systems, but these systems are high enough in VOC
that small volumes of additional plasticizers will not
significantly lower the VOC content.22
Plasticizers have also been used in thermosetting
systems such as epoxies and alkyds, but the plasticizer may
reduce the density of cross-linking and therefore impair
coating performance, such as reducing solvent resistance.
However, some plasticizers have been used successfully in
epoxy systems with no loss of film performance.22
4.2.4 Reactive Diluents
Reactive diluents are low-molecular-weight, low-
viscosity substances in which the resin is miscible or
soluble. They are similar to plasticizers in that they can
be used to increase the nonvolatile solids content, but are
different in that they react with and become part of the
resin system. Alone, reactive diluents have some
volatility, but this is rapidly lost when they are mixed
with and become part of the resin. One disadvantage is that
they may reduce the density of cross-linking in the dried
film and therefore reduce coating performance. Another
disadvantage is that they can be toxic compounds.22
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4.2.5 Thixotropes and Dispersants
Thixotropes and dispersants are added to control
sagging of coatings and the settling of pigment particles in
wet coating films, respectively. However, thixotropes and
dispersants that introduce any real viscosity are
counterproductive to reducing VOC content because additional
solvent is needed to reduce viscosity for application.
Thixotropes need to be carefully matched to the resin or
solvent in the coating. Some thixotropes and dispersants
are solventborne and therefore cannot be added without
increasing coating VOC content. Solid thixotropes and
nonvolatile dispersants can be added as part of the
nonvolatile portion of the coating, but only in limited
quantities before they begin to affect other coating
properties.22
4.3 EXAMPLES OF TYPES OF CATEGORY-SPECIFIC PRODUCT
REFORMULATION LIMITATIONS
Although significant advancements have been made in the
development of lower-VOC coatings, problems have been
identified for some categories by some manufacturers. Some
of these problems may have been or are likely to be solved
as coating technology continues to develop. Examples of
these types of problems were identified through two sources.
The first source was manufacturers' comments to the
California Air Resources Board (CARB) proposal for a model
architectural coatings rule in 1989.24 The second source
was the results of a 1991 EPA survey of nine large
architectural and IM coating manufacturers.25 This survey
was conducted to collect information on VOC content and the
availability of lower-VOC coatings. Listed below are
examples of reformulation problems were identified.
4.3.1 Magnesite Cement Coatings
Magnesite cement decking requires a coating that
resists alkali attack from the concrete substrate. It has
been argued that only high-VOC, lacquer-based coaitings
function in this application. According to the one
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manufacturer of this coating type, it cannot be economically
reformulated.26
4.3.2 Dry Fog Coatings
Lowering the VOC content of a dry fog coating may
affect its ability to dry quickly, which is the foremost
performance requirement.25
4.3.3 Fire-retardant Coatings
These coatings must comply with building codes and fire
safety codes. Reformulation, therefore, must take into
account a strict specification for performance. There is
some question in the fire safety industry whether the
American Society for Testing and Materials (ASTM) test
method for fire retardance accurately predicts performance
under actual fire conditions. The ASTM committee for paints
formed a task group to review and develop test methods for
fire-retardant coatings.27
4.3.4 IM Coatings
Industrial maintenance coatings designed for
high-temperature (greater than 400 °F) resistance may
require a higher VOC content than other types of IM
coatings.2^
4.3.5 Lacquers. Shellacs, and Varnishes
Comments have suggested that reformulation of these
coatings may adversely affect performance characteristics
such as drying time and film hardness.25
4.3.6 Metallic Pigmented Coatings
Reformulating for low-VOC content may impair the
high-temperature performance of metallic heat-resistant
coatings.25
4.3.7 Pretreatment Wash Primers
According to comments received on the CARB Model Rule,
low-VOC wash primers do not function adequately under
"normal conditions," but more specific information was not
supplied. A possible overlap with marine coating
regulations must be considered for this category because an
identical coating is used as a marine coating. For example,
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the Bay Area Air Quality Management District's marine
coatings and architectural coatings rules both include this
category and have set the same VOC content limit.29
4.3.8 Stains
Some manufacturers of stains indicated that lowering
VOC contents in some masonry stains would impair cidhesion
and flow characteristics and affect hard film formation at
low temperatures.25 Commenters on the CARB model rule have
stated that semitransparent wood stains require a higher-VOC
content than opaque stains and the performance of stains
that comply with the CARB model rule is much poorer than
higher-VOC stains.30
4.3.9 Swimming Pool Coatings
Lower-VOC epoxy pool coatings cannot be applied over
existing chlorinated rubber pool coatings and require
complete removal of the chlorinated rubber. Epoxy coatings
are not as easily applied by homeowners as chlorinated
rubber coatings, which have higher VOC levels, because they
require more extensive surface preparation and must be
applied more quickly.31
4.3.10 Waterproofing Sealers
According to some industry representatives,
multipurpose waterproofing sealers at 400 grams per liter
(g/L) do not meet minimum performance criteria for clear
waterproofing sealers (that is, 60 percent water repellency
for wood and 1 percent or less water absorption for brick).
Thus, product performance does not meet industry standards.
In addition, it has been stated that most of the 400-g/L
products change the appearance of the surface because they
are high-solids products that leave an oily residue or cause
darkening of some of the surfaces to which multipurpose
products are applied.32
4.3.11 Wood Preservatives
Several categories of wood preservatives are subject to
Federal Insecticide, Fungicide and Rodenticide Act (FIFRA)
requirements, which increases the time between developing
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and marketing a new coating and may delay the availability
of some reformulated coatings. In addition, the reported
reformulation problems with wood preservatives are analogous
to those associated with stains, particularly in maintaining
the translucence of semitransparent wood preservatives.25,30
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4.4 REFERENCES
1. Katchen, M. A. Solvent Syndrome. In: Maintaining
Structures With Coatings, Proceedings of SSPC 91, Long
Beach. Pittsburgh, Steel Structures Painting Council.
November 10-15, 1991. pp. 63-67.
2. Martens, C. R. Waterborne Coatings: Emulsion and
Water-Soluble Paints. New York, Van Nostrand Reinhold
Company. 1981. p. 7.
3. Wendoll, R. The Seven Deadly Sins. Dunn-Edwards Corp.
Los Angeles, CA. Presented to the AIM Coatings
Regulatory Negotiation Committee. Washington, DC.
September 17, 1992.
4. HEEU: A Non-VOC Modifier to Improve Gloss Properties
of Waterborne Coatings. Modern Paint and Coatings.
81(9): 28-32. September 1991.
5. Kogler, R., and J. Peart. Environmentally Acceptable
Materials for Corrosion Protection of Steel Bridges.
In: Maintaining Structures With Coatings, Proceedings
of SSPC 91, Long Beach. Pittsburgh, Steel Structures
Painting Council. November 10-15, 1991. pp. 113-124.
6. Glass, T., and J. Depoy. New Resins and Equipment Make
Field-Applied Powder Coatings a Reality. Journal of
Protective Coatings and Linings. 8(7):33-36. July
1991.
7. Glass, T., and J. Depoy. Protective Thermoplastic
Powder Coatings: Specifically Designed Adhesive
Polymers. In: Maintaining Structures With Coatings,
Proceedings of SSPC 91, Long Beach. Pittsburgh, Steel
Structures Painting Council. November 10-15, 1991.
pp. 267-279.
8. Brandau, A. Introduction to Coatings Technology,
Federation Series on Coatings Technology. Federation
of Societies for Coatings Technology. Blue Bell, PA.
October 1990. 46 pp. p. 25.
9. Prane, J. A. Introduction to Polymers and Resins,
Federation Series on Coating Technology. Federation of
Societies for Coatings Technology. Philadelphia, PA.
July 1986. p. 25.
10. Morgans, W. M. Outlines of Paint Technology, Third
Edition. New York, Halsted Press. 1990. p. 339.
11. Reference 10, p. 349.
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12. Venturini, P. D., R. A. Friesen, D. S. Simeroth, and
D. Donohoue. ARB-CAPCOA Suggested Control Measure for
Architectural Coatings: Technical Support Document.
State of California Air Resources Board Stationary
Source Division. Sacramento, CA. July 1989.
pp. 34-65.
13. Reference 10, p. 5.
14. U.S. Environmental Protection Agency. Glossary for Air
Pollution Control of Industrial Coating Operations,
Second Edition. Research Triangle Park, NC.
Publication No. EPA-450/3-83-013R. December 1983.
p. 9.
15. Kennedy, H. 100% Solids Polyurethanes, The Next
Generation of Water Tank Linings. In: Maintaining
Structures With Coatings, Proceedings of SSPC 91, Long
Beach. Pittsburgh, Steel Structures Painting Council.
November 10-15, 1991. pp. 15-21.
16. Johnson, S. D. Spray Applied 100% Solids Epoxy
Coatings. In: Maintaining Structures With Coatings,
Proceedings of SSPC 91, Long Beach. Pittsburgh, Steel
Structures Painting Council. November 10-15, 1991.
pp. 107-112.
17. Reference 2, p. 47.
18. Smith, L. M. SSPC Applicator Training Bulletin:
Thermal Spraying: An Introduction. Journal of
Protective Coatings and Linings. 8(l):58-59. January
1991.
19. News from the Field: Oregon DOT Uses Zinc Metallizing
with Cathodic Protection on Concrete Bridges. Journal
of Protective Coatings and Linings. 9(8):69-73.
August 1992.
20. Waldorf, J. News from the Field: Metallizing Protects
Reinforced Concrete Jetty. Journal of Protective
Coatings and Linings. 10(l):75-78. January 1993.
21. Gajcak, W. J., J. Buck, and F. Debellis. Problem
Solving Forum: Is the use of thermal- sprayed metal
(zinc or zinc/aluminum) in water tanks worth the extra
cost over traditional epoxy or vinyl linings? Journal
of Protective Coatings and Linings. 8(3):13-17. March
1991.
22. Hare, C. H. Anatomy of Paint: Formulating for Low
VOC. Journal of Protective Coatings and Linings.
8(9):73-78. September 1991.
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23. Minchew, C. Paint Technology and Performance.
Benjamin Moore & Co., Newark, NJ. Presented to the AIM
Coatings Regulatory Negotiation Committee. Washington,
DC. September 17, 1992.
24. Reference 12, pp. 34-65.
25. Memorandum from Buchanan, S. K., and C. Sarsony, Radian
Corporation, to Ducey, E., U.S. Environmental
Protection Agency/CPB. May 19, 1992. Analysis of the
six screening survey responses and select data from the
three performance survey responses.
26. Reference 12, pp. 45-46.
27. Reference 12, pp. 40-41.
28. Reference 12, pp. 42-45.
29. Reference 12, p. 52.
30. Reference 12, pp. 50-52.
31. Reference 12, pp. 63-64.
32. Memorandum from Borman, Earle K., Jr. and D.
Forestiere, L&F Products, to Ehrmann, J., and Stinson,
B., Keystone. July 21, 1994. Re: July 14, 1994 AIM
Coatings Rule Framework and Memorandum of Understanding
(MOU). Docket No. A-92-18, Docket Item II-D-188.
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5.0 VOC AND HAP EMISSION REDUCTIONS
This section discusses volatile organic compound (VOC)
emission reductions, and hazardous air pollutant impacts of
implementing VOC controls.
5.1 VOC EMISSIONS REDUCTION ESTIMATE
Quantifying the national VOC emission reductions from
VOC reduction strategies requires national baseline VOC
emissions. As discussed in chapter 2, baseline
architectural coating VOC emissions were calculated by
extrapolating from a VOC inventory survey conducted by the
National Paint and Coatings Association (NPCA) in 1992. The
survey data are summarized in a document that was produced
for NPCA by Industry Insights and is available in the
architectural coatings docket (A-92-18, item II-I-8).1 In
addition to the survey, supplemental sources were used to
determine the baseline sales needed to calculate the VOC
emissions. These other data sources are discussed in
chapter 2 of this document.
As discussed in the chapter 2, 1990 total national
sales were estimated to be 655,000,000 gallons. Total
national VOC emissions at maximum thinning were estimated to
be 530,000 tons.2 Based on an estimated 20 percent VOC
emissions reduction over the 1990 baseline, total national
VOC emissions are expected to be reduced by 106,000 tons
annually.3 Section 5.1.1 discusses the survey data.
Section 5.1.2 provides a detailed explanation of one of the
key assumptions underlying the emission reduction
calculation. Section 5.1.3 presents the calculation
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procedure and the emission reduction for each category.
Section 5.1.4 summarizes the emission reduction assumptions.
5.1.1 Base Survey Data
The NPCA survey was sent to a total of 173 coating
manufacturers; of these, approximately 116 responded that
they manufactured architectural coatings. The survey
included approximately 40 small manufacturers (annual net
sales of architectural coatings under $10 million) and
76 large manufacturers. The U.S. Environmental Protection
Agency (EPA) estimates that there were approximately
350 small manufacturers and 150 large manufacturers of
architectural coatings in the United States in 1990.
Therefore, the survey under-represents small manufacturers.
A comparison of the small manufacturers' sales to the large
manufacturers' sales indicated that the small manufacturers
tend to produce higher-VOC coatings, and more coatings
classified in specialty coating categories. Because these
higher-VOC coatings are underestimated, emissions reductions
estimates calculated from the survey data may be
underestimated.
During regulatory negotiations, the architectural
coating industry indicated that the volume of traffic
coatings reported in the survey was only about half of what
was actually sold in 1990. Therefore, the traffic coating
sales reported in the survey were doubled to increase the
accuracy of the baseline emission estimate and subsequent
emission reduction calculations.
The survey included data on coating VOC content,
hazardous air pollutant (HAP) content, sales, and
manufacturer profile information (e.g., manufacturer annual
net sales in dollars). The following data were collected on
a per-coating-product basis:
Coating category;
Coating type (i.e., solventborne or waterborne);
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VOC content of the coating in pounds of VOC per
gallon of coating, less water;
VOC content of the coating at maximum thinning in
pounds of VOC per gallon of coating, less water;
Percentage of the coating volume that is solids;
and
Sales of the coating in gallons.
The reported data were summarized by sorting first by
coating category, then by solventborne versus waterborne,
and finally by VOC content range. In all, coatings were
reported in 39 coating categories. In order to make
comparisons to existing State rules and to provide a
reasonable degree of resolution, the data were summarized in
50 grams per liter (g/L) VOC content ranges. The following
15 VOC content ranges, in grams of VOC per liter of coating,
were established:
0 to 50 051 to 100
101 to 150 151 to 200
201 to 250 251 to 300
301 to 350 351 to 400
401 to 450 451 to 500
501 to 550 551 to 600
601 to 650 651 to 700
701 and above
Since the manufacturers considered much of the sales
and VOC data collected by the survey to be confidential, the
raw data were maintained in confidence by Industry Insights.
The industry agreed that the data could be summarized in the
format described above, provided that there were at least
three products reported in each VOC content range. To
maintain confidentiality of survey responses, if less than
three products were reported in a VOC content range, the
data for that range were not shown in the survey data
summary tables. However, the data for these ranges were
included in the totals.
The survey data were then used to calculate the actual
VOC emissions in pounds. This was calculated by multiplying
the average VOC content (in pounds per gallon) of the
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coatings in a given VOC range by the sales (in gallons) for
the coatings in that range.
5.1.2 Assumptions for the Emission Reduction Calculation
In order to calculate the VOC emissions that would
result from any given set of VOC levels, it is necessary to
make assumptions concerning the sales volume of coatings
after the VOC levels take effect. These assumptions
directly affect the amount of emission reduction that is
calculated. The two different approaches that were
considered for estimating the sales volume of coatings after
regulation are discussed below. These approaches were the
"constant gallons" approach and the "constant solids"
approach.
Using the constant gallons approach, it is assumed that
the total volume (gallons) of coatings sold after regulation
remains the same as the volume sold before regulation. From
a coating coverage standpoint, this approach assumes that
coatings sold after the rule takes effect provide the same
area of coverage per gallon as those sold before.
Alternatively, using the constant solids approach, it is
assumed that the total amount of solids (in pounds) after
the regulation takes effect remains the same as it was
before regulation. In other words, even though the solids
content of individual coatings may change, the aggregate
amount of solids for all coatings in a particular category
remains constant. Since the solids content of individual
cans of coatings are expected to change after regulation,
the coverage per gallon will change. An increase in solids
content generally increases the amount of coverage per can.
This causes a decrease in sales (gallons), since less cans
are required to cover the same surface area.
For any given set of potential VOC content
requirements, the constant solids approach to calculating
VOC reductions will yield a greater emission reduction
estimate than the constant gallons approach. This is
because under the constant solids approach, both the VOC
klk\72/04
5-4
-------
content of the coatings and the volume of sales of the
coatings are assumed to decrease. Under the constant
gallons approach, the VOC content of the coatings decrease,
but the sales volume is assumed to remain at preregulation
levels.
After discussions with the industry, the EPA has
concluded that the constant solids approach more accurately
portrays what is expected to occur as a result of
implementing a national architectural coatings VOC rule.
However, this approach may tend to overestimate VOC emission
reductions since the relationship between coating solids and
coverage achieved in the field may not be as direct a
relationship as that theoretically assumed in the emission
reduction calculation. For most coating categories, the
solids content of the coating correlates to coverage (i.e.,
the more solids in a coating, the greater the coverage).
Total solids applied within a category can therefore be
expected to remain relatively constant assuming that the
total surface area needing coverage remains essentially
constant. Since solids per gallon (or ratio of solids to
solvent per gallon) would tend to increase after regulation,
overall sales would be expected to decrease. However, an
exception to this scenario was made for coatings that have a
low-solids content and do not form a film on the surface of
the substrate, including clear and semitransparent stains,
low-solids stains, and clear waterproofing sealers and
treatments. Since these coatings penetrate into the surface
and are not film building, the solids content is not
directly correlated with the coverage of the coating.
Therefore, when estimating emission reductions from these
particular categories, the constant gallons approach was
used.
5.1.3 Procedure to Calculate Emission Reductions
As described in the previous section, the EPA concluded
that the best approach for calculating emission reductions
was to assume that solids remain constant (with the
klk\72/04
5-5
-------
exception of the low-solids coatings). In addition, it was
assumed that sales of coatings above the regulatory VOC
content level will be replaced with sales of coatings at or
just below the VOC content level. To calculate the emission
reductions that would result from the EPA's proposed VOC
levels using this constant solids at the regulatory level
approach, the following procedure was used:
1. Determination of emission reduction based on
survey population.
STEP 1. The total solids content (gallons) in each
VOC range was calculated by multiplying the
percent volume solids by the volume of sales
in gallons.
STEP 2. The total solids in those ranges above the
VOC regulatory level were added to determine
the total solids above the VOC level.
STEP 3. The average pounds of VOC per gallon of
solids was calculated for each VOC range by
dividing the total pounds of VOC in a range
by the total gallons of solids in that range.
STEP 4. The total solids above the VOC level were
added to the solids at the VOC level range to
determine the total amount of solids at the
VOC level after regulation.
STEP 5. The new total solids at the VOC level
(calculated in step 4) were multiplied by the
average pounds of VOC per gallon at the VOC
level range (calculated in step 3) to yield
the new pounds of VOC at the VOC level.
STEP 6. The emissions from the category after
regulation were determined by adding the new
pounds of VOC at the VOC level (calculated in
step 5) to the total amount of VOC at average
content in the ranges below the VOC level.
STEP 7. The emission reduction based on average VOC
content was calculated by subtracting the new
category emissions (calculated in step 6)
from the baseline category emissions.
STEP 8. The procedure in steps 1 through 7 was
followed for both solventborne and waterborne
coatings, which were included in the database
separately. The results were totalled to
klk\72/(M
5-6
-------
obtain the total emissions, at average VOC
content, for each category.
STEP 9. The emissions reduction fraction was
calculated for each category by dividing the
emission reduction for each category by the
total actual survey baseline emissions from
all categories at average VOC content
(398,285 tons).
STEP 10. The emissions reduction fraction for each
category (calculation step 9) is assumed to
equal the emissions reduction fraction at
maximum VOC content for the national
population.
II. Determination of national emission reduction.
The emission reduction fraction for each category
was multiplied by the total estimated VOC
emissions at maximum thinning from architectural
coatings, 530,000 tons, to obtain the national
emission reduction at maximum thinning for each
category. The emission reductions for all
categories were totaled to obtain a national
emission reduction estimate of 106,000 tons.
Table 5-1 shows the VOC levels in the proposed rule and
the associated emission reduction at maximum thinning in
tons per year that is achieved from each category. In 1997,
the overall emission reduction estimated from the table of
standards in the proposed rule is 106,000 tons. The largest
emission reduction comes from traffic markings, which
accounts for 25 percent of the overall annual emission
reduction.
5.1.4 Summary of VOC Emission Reduction Assumptions
As mentioned in the sections above, several bias
factors were identified during the analysis of the survey
and the calculation of the emission reductions that had an
impact on the calculated emission reduction value. Some of
these factors tend to decrease the calculated emission
reduction while others tend to increase the calculated
emission reduction.
klk\72/04
5-7
-------
In table 5-2, each bias factor is listed along with a
qualitative description of its impact on the overall
emission reduction. Based on this analysis, the EPA has
concluded that the calculated emission reduction provides a
reasonable estimate of the emission reductions that will
result from the EPA's proposed Architectural Coatings Rule.
klk\72/04
5-8
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Note that this emissions reduction estimate does not
account for emission reductions from reduced usage of cleanup
and thinning solvents that would occur from a switch to lower-
VOC waterborne coatings. An estimate from The California Air
Resources Board (CARB) is that thinning and cleanup for
solventborne coatings requires 1 pint of solvent per gallon of
coating applied.^ However, the actual rate of solvent use for
cleanup will vary with the size of the job and the type of
coating application equipment used, the coating type, and the
individual practices of the applicator. A study done by the
New York State Department of Environmental Conservation
assumes half a pint of cleanup solvent is used for every
gallon of solventborne coating. This is based on the CARB
estimate of one pint of cleanup and thinning solve:nt used for
every gallon of solventborne coating and responses to New
Jersey and New York's paint and coatings industry survey
regarding the volume of organic solvent recommended for
thinning prior to application.5
5.2 HAZARDOUS AIR POLLUTANT EMISSIONS
Manufacturers faced with VOC content limits for
architectural coatings could elect to use solvents "exempt"
from regulation as a VOC (e.g., acetone), or may shift from
the use of aliphatics (alcohols) to aromatic hydrocarbons
(e.g., toluene, xylenes) that have a higher solvency power.6
Both toluene and xylene are HAP's listed under the; Act, as
amended in 1990. These potential shifts, if indeed they
occur, could increase HAP emissions and worker exposure to
toxic compounds compared to baseline emissions. However, HAP
content versus VOC content data obtained through the NPCA
survey does not indicate that lower-VOC coatings contain more
HAP's than higher-VOC coatings.1 Often, the opposite occurs
because many HAP constituents in AIM coatings are also VOC.
Furthermore, there is no evidence, based on the NPCA survey
data, indicating that lower-VOC coatings have increased
aromatic hydrocarbons. Because of both worker exposure and
HAP emissions considerations, it is unlikely that
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manufacturers would shift toward the use of more toxic
solvents in their effort to reduce the VOC content of their
coatings.
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5.3 REFERENCES
1. Industry Insights. Architectural and Industrial
Maintenance Surface Coatings VOC Emissions Inventory
Survey. Prepared for the National Paint and Coatings
Association in Cooperation with the AIM Reg-Neg Industry
Caucus. February 6, 1995.
2. Memorandum from Harrison, R., Radian Corporation, to
Ducey, E., U.S. Environmental Protection Agency/CPB.
November 14, 1995. Determination of Architectural and
Industrial Maintenance Coatings Baseline Sales and VOC
Emissions.
3. Memorandum from Sarsony, C., and Harrison, R., Radian
Corporation, to Ducey., E., U.S. Environmental Protection
Agency/CPB. February 22, 1996. Emission Reductions
Expected to Result from the Proposed Architectural
Coatings VOC Rule.
4. California Air Resources Board. Results of the 1988
Architectural Coatings Sales Survey. California Air
Resources Board, Stationary Source Division, Sacramento,
CA. May 1991. 23 pp. DRAFT.
5. New York State Department of Environmental Conservation.
New York and New Jersey Architectural Surface Coating
Study -- Phase I Report. Division of Air Resources,
Albany, NY. March 1987. p.8.
6. Venturini, P.D., R.A. Friesen, D.S. Simeroth, and
D. Donohove. ARB-CAPCOA Suggested Control Measure for
Architectural Coatings: Technical Support Document.
State of California Air Resources Board Stationary Source
Division. Sacramento, CA. July 1989. p.21.
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