-New Source Performance Standards—
Appliance Surface Coating Operations
Public
Participation
A public hearing on
the proposed regula-
tion is scheduled for
January 28, 1981 at 9
a.m. in the U.S. EPA,
Office of Administra-
tion Auditorium in
Research Triangle Park,
jN.C. Those wishing to
present oral testimony should notify Naomi
Durkee, Emission Standards and Engineering
Division, (MD-13), U.S. Environmental Pro-
tection Agency, Research Triangle Park, NC
27711, telephone (919) 541-5271 by January
21, 1981.
Written comments will be accepted on or be-
fore February 23, 1981, and should be ad-
dressed to: Central Docket Section (A-130),
Attn. Docket Number OAQPS A-80-6, U.S.
Environmental Protection Agency, 401 M
Street SW, Washington, DC 20460. The
docket contains supporting information used
by EPA in developing the standards, and is
open for public inspection.
The Background Information Document
(BID) for the proposed standards may be
obtained from the U.S. Environmental Pro-
tection Agency Library (MD-35), Research
Triangle Park, NC 27711, telephone (919)
541-2777. Please refer to Industrial Surface
Coating: Appliances, Background Informa-
tion for Proposed Standards, (EPA-450/3-
80-037a).
Status of
Regulation
NSPS for appliance surface coating operations
were published on December 24, 1980 (45 FR
85085). A public hearing has been scheduled
for January 28, 1981. Promulgation of final
NSPS for this industry is expected in Decem-
ber 1981.
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United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park, NC 27711
January 1981
New Source Performance Standards
v>EPA
Appliance Surface Coating Operations
Proposed Regulation
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-New Source Performance Standards—
Appliance Surface Coating Operations
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
Protection Agency to establish nationwide
emission standards to prevent air pollution
problems from selected new stationary indus-
trial sources. These New Source Performance
Standards (NSPS), in accordance with Section
111 of the Clean Air Act, apply to categories
of new, modified or reconstructed sources
causing or contributing to air pollution that
could threaten public health or welfare. Sur-
face coating operations within appliance as-
sembly plants are a significant pollution
source, and NSPS are being proposed for their
control.
Appliance Surface
Coating Operations
[The appliance coating
industry encompasses
I about 200 assembly
| plants nationwide
where organic paints
are applied to ovens,
refrigerators, room
heaters, fans and other
I appliances manufac-
tured for commercial, household or recrea-
tional use. Surface coating operations are an
integral part of appliance assembly plants,
accounting for about one-quarter to one-third
of the total space occupied by a typical plant.
Ohio, Illinois, Michigan, Kentucky, Tennessee
and California have the largest numbers of
these appliance assembly plants.
Most appliance coating materials, such as ep-
oxies, acrylics and polyesters, contain organic
solvents that are the major source of volatile
organic compounds (VOC) emitted from the
appliance coating industry. VOC evaporate
into the atmosphere during paint application,
and during drying (curing) operations.
VOC are major pollutants subject to Federal
control under the Clean Air Act. VOC react in
the atmosphere to form photochemical smog,
a complex pollutant that can impair breathing,
irritate eyes and damage plant tissue.
In 1976 the large appliance industry emitted
90 metric tons of VOC per plant, accounting
for annual nationwide industry emissions of
more than 15,000 metric tons.
NSPS proposed for the appliance surface coat-
ing industry would cover only new facilities,
or existing ones that are substantially modi-
fied or reconstructed. Physical or operational
changes resulting in increased emission rates
may be considered modifications. If the cost
of component replacement in an existing facil-
ity is more than 50 percent of the cost to con-
struct a new facility, that replacement may be
considered a reconstruction.
Setting Standards
to Limit Emissions
The proposed NSPS apply to all new, modi-
fied and reconstructed appliance surface coat-
ing operations for which construction began
on or after December 24, 1980.
The standards would establish emission limits
based on VOC content of the paints, and on
paint transfer efficiency (the volume of paints
required to coat a given surface). The pro-
posed NSPS would limit emissions from prime
and topcoat applications, from initial 'air dry-
ing' (flashoff) areas, and from curing ovens.
VOC emissions from each prime or topcoat
operation would be limited 0.90 kilogram of
VOC per liter (kg/I) of coating solids applied
to appliance parts or products.
Compliance with the
standards could be
achieved by (1) using
lower solvent paints
and application meth-
ods that result in VOC
emissions less than or
equal to 0.90 kg/I of
applied paint solids, or
(2) using higher solvent paints with an average
VOC content that, in conjunction with effec-
tive pollution control systems, result in emis-
sions less than or equal to 0.90 kg/I of coating
solids applied.
Achieving and
Maintaining
the Standard
The proposed NSPS
for appliance surface
coating operations re-
flect the degree of
emission control that
can be obtained by
using the best techno-
logical system of con-
tinuous emission re-
duction. In determining the most effective
controls forthis industry, EPA considered eco-
nomic impacts associated with various control
options, as well as health, energy, and envi-
ronmental factors unrelated to air quality.
The appliance coating industry is a complex
and diverse one, using many different coatings
and application methods. Because emissions
from this industry are widely dispersed, the
use of capture systems and control devices is
not a practical means of achieving compl iance.
Instead, VOC emission control is expected
through improvements in coating formula-
tions and application efficiency. Current
methods of paint application for the appli-
ance manufacturing industry include dip coat-
ing; flow coating; electrostatic coating; elec-
trodeposition (EDP); and air, airless, and
electrostatic spray coating.
Impacts
One of the major benefits of this standard is
that it will establish emission limits based not
just on VOC content, but on transfer effi-
ciency as well. Unlike most existing State
regulations (which do not include transfer ef-
ficiency provisions), the proposed NSPS would
allow tradeoffs between VOC content and
transfer efficiency. Thus, operators using ap-
plication equipment with a high transfer effi-
ciency could use a coating with a higher VOC
content. The provisions contained in the pro-
posed NSPS allow for the diversity of coatings
and application techniques within the indus-
try. The proposed NSPS would also establish
a degree of national uniformity that precludes
situations where some
states may attempt to
attract industries by
relaxing air pollution
standards relative to
other states.
Because the standards
require no new coat-
ings or application methods, EPA anticipates
minimal impacts on water pollution and solid
waste disposal. In addition, no economic or
energy impacts are expected for the 40 new,
modified or reconstructed facilities to be
affected by the proposed NSPS through 1986.
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