New Source Performance Standards
Metal Furniture Surface Coatings
Public
Participation
                     A public hearing on
                     the  proposed regula-
                     tion is scheduled for
                     January 9, 1981 at
                     9 a.m. at the Environ-
                     mental Research Cen-
                     ter Auditorium, Re--
  search Triangle Park, NC. Those wishing to
  present additional data, views, or other com-
  ments on this NSPS are invited to participate.
  If you plan to speak at the hearing, contact
  Deanna Tilley, Standards  Development
  Branch, Emission Standards and Engineering
  Division,(MD13), Environmental Protection
  Agency, Research Triangle Park, NC  27711,
  telephone 919-541-5477,  no  later  than
  January 2, 1981.
Written comments (in duplicate if possible)
will be accepted on or before February 8,
1981 and should be addressed to: Central
Docket Section (A-130), Attention: Docket
Number  A79-47, U.S. EPA, 401 M Street,
SW, Washington, DC 20460.  The docket
contains all information considered by EPA in
developing these proposed standards, and is
open for public inspection. The background
information document, "Surface Coating of
Metal Furniture—Background Information for
Proposed Standards" (EPA-450/3-80-007a),
discusses this material in detail and is available
from the EPA Library (MD-35), Research Tri-
angle Park, NC 27711, telephone 919-541-
2777.
Status of
Regulation
  This proposed NSPS was published in the
  Federal Register (45 FR 79390) on November
  28, 1980. A public hearing is scheduled for
January 9, 1981.  The final regulation  is
expected around November, 1981.
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                       United States
                       Environmental Protection
                       Agency
                          Office of Air Quality
                          Planning and Standards
                          Research Triangle Park, NC 27711
         December 1980
                       New Source Performance Standards
xvEPA
Metal Furniture Surface Coatings
                       Proposed Regulation

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•New Source Performance Standards-
 Metal Furniture Surface Coatings
New Source
Performance
Standards
 The Clean Air Act, as amended in 1977, calls
 for a comprehensive national program to re-
 duce air pollution and improve air quality.
 The Act requires the U.S. Environmental Pro-
 tection Agency (EPA) to establish nationwide
 emission standards for selected new industrial
 stationary sources. These New Source Per-
 formance Standards (NSPS),  in accordance
 with Section 111 of the Act, are designed to
 prevent new air pollution problems.  NSPS
 apply  to  categories of new, modified, or
 reconstructed stationary sources that cause or
 contribute significantly to air pollution that
 could endanger public health or welfare. EPA
 has proposed NSPS for metal furniture sur-
 face coating operations.
 Metal Furniture
 Surface Coatings
                                           V
                      Section  111 of the
                      Clean Air Act requires
                      EPA to  set  Federal
                      emission  limits for
                      stationary sources iden-
                      tified  as significant
                      contributors to air pol-
                      lution that endanger
 public health and welfare. After careful study
 and evaluation, EPA has classified new, mod-
 ified, and reconstructed surface coating facil-
 ities at metal furniture manufacturing plants
 as one such source.

 Paints traditionally used in metal furniture
 coating operations contain organic solvent
 mixtures, and their use results in the emission
 of volatile organic compounds (VOC). VOC
 emissions occur during the coating application,
 touch-up and flash-off processes, and in the
 bake oven area of the plant.

 VOC react in the atmosphere to form ozone,
 the main component of photochemical smog.
 Ozone  irritates the respiratory system and
 aggravates chronic respiratory diseases. It also
 damages plant tissues, and deteriorates rubber
 and other materials.

 In 1975, the metal furniture industry emitted
 about 95,000 metric tons of VOC. The selec-
 tion of industrial surface coating of metal
 furniture for regulation is based on EPA's de-
 termination that  it is a significant source of
 VOC emissions as well as analyses of painting
 methods, yearly  VOC emission rates, pro-
 jected industry growth, and the number and
 location of affected facilities in or near highly
 populated urban areas.

 There are presently 1400 metal furniture
 manufacturing plants nationwide, 70 percent
 of which are located in highly populated
 urban areas.  EPA projects a four percent an-
 nual growth  rate  for the metal furniture in-
 dustry through 1985.
 Setting Standards
 to Limit
 Emissions
The proposed NSPS would apply to all new,
modified, and reconstructed metal furniture
surface coating facilities for which construc-
tion began after November 28, 1980. The
recommended standards would limit VOC
emissions to 0.70 kilogram of VOC per liter
of coating solids applied. This emission limit
could be met by use of 68-percent-by-volume
solids coating (with a solvent density  of 0.88
kilogram per liter) applied at a 60 percent
transfer efficiency.  In addition, waterborne,
powder, and  other high solid coatings and
add-on control  equipment may also be
employed to  achieve the numerical limit.

VOC emissions from existing metal furniture
                     coating operations are
                     controlled by State air
                     pollution regulations.
                     If  controlled  only
                     through existing State
                     regulations,   yearly
                     VOC emissions would
                     be  about 60 percent
                                                                        less compared to uncontrolled operations.
                                                                        The proposed standards would result in an ad-
                                                                        ditional 30  percent emission  reduction
                                                                        beyond State regulations. For facilities oper-
                                                                        ating with no pollution controls, the proposed
                                                                        standards would reduce  VOC emissions by
                                                                        51,000 metric tons during the next five years.
Achieving and
Maintaining the
Standards
                            lated to air quality.
                     The proposed NSPS
                     reflect the best  dem-
                     onstrated system  of
                     continuous  emission
                     reduction, considering
                     costs, health, environ-
                     mental,  energy,  and
                     other  impacts unre-
                            Several different control options are available
                            for reducing VOC emissions. Emission control
                            technologies  include the  use of (1)  low or-
                            ganic solvent coatings; (2) improved trans-
                            fer efficiencies based on  coating application
                            techniques; or (3) add-on control devices.

                            A combination of control options would be
                            acceptable providing equivalent VOC emission
                            reduction could be demonstrated. These op-
tions include waterborne coatings applied by
electrostatic air or airless spray, dip, electro-
deposition or flow techniques; powder coat-
ings applied by electrostatic spray or fluidized
bed; and lower content of solids within paints
(less than 68-percent-by-volume solids coating
if the increased solvent content is offset  by
higher transfer efficiencies).

Two reference methods would be used to  de-
termine compliance with the proposed emis-
sion standards. Reference Method 24 (pro-
mulgated  on October 3, 1980) would deter-
mine the  VOC content of coating materials;
however,  the use  of coating manufacturers'
data would be allowed in calculating the VOC
content of coatings.  Reference Method 25
(promulgated on Octobers, 1980) would be
used to determine the VOC concentration in
exhaust gas streams.
Impacts
Energy:  Actual energy requirements would
vary depending on the control option select-
ed to meet the proposed standards.  For a
typical metal furniture manufacturer com-
plying with existing State requirements, en-
ergy use would decrease by about 20 percent
(1500 gigajoules) if powder coatings  were
used. However, energy use would increase if
waterborne coatings or incineration  plus a
State compliance coating were used by 3 per-
cent (230 gigajoules) and 7 percent (520 giga-
joules), respectively.

Environmental: No adverse environmental im-
pacts would result from the standards. Nega-
tive impacts from control options are  possible
only for water and solid wastes.  The impacts
on solid waste and water quality would depend
                     on the specific control
                     option selected.

                     Economic/Industrial:
                     Economic impacts of
                     the proposed  NSPS
                     would vary, depending
on the control option selected. The estimat-
ed total capital costs are about the same for
all control options.  Total annualized costs for
the first five years would vary depending on
the control option used, and annualized sav-
ings are possible. The maximum possible eco-
nomic impact would be for  small manufac-
turers, regardless of  the control option selec-
ted. It  could  mean up to a  1.3 percent in-
crease in the wholesale price  of their product.

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