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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