United States Office of Enforcement EPA Contract No. 68-01-4747
Environmental Protection Office of General Enforcement April 1980
Agency Washington, DC 20460
vvEPA Enforceability Aspects
of RACT for Factory
Surface Coating of Flat
Wood Paneling
-------
EPA-340/1-80-005
Enforceability Aspects of RACT for
Factory Surface Coating of
Flat Wood Paneling
by
PEDCo Environmental, Inc.
Cincinnati, Ohio 45246
Contract No. 68-01 -4747
Task No. 129
Technical Service Area 3
PN 3570-3-L
EPA Project Officer: John R. Busik
Task Manager: Robert L King
Prepared for
U.S. ENVIRONMENTAL PROTECTION AGENCY
Division of Stationary Source Enforcement
Washington, D.C. 20460
April 1980
-------
DISCLAIMER
This report has been reviewed by the Division of Stationary
Source Enforcement, U.S. Environmental Protection Agency. and
approved for publication. Approval does not signify that the
contents necessarily reflect the views and policies of the U.S.
Environmental Protection Agency, nor does mention of trade names
or commercial products constitute endorsement or recommendation
for use.
11
-------
CONTENTS
Figures iv
Tables v
Acknowledgment vi
1. Executive Summary 1
2. Introduction 6
2.1 Background 6
2.2 Purpose and Scope 7
2.3 Sources of Information 7
3. Industry Characterization 9
3.1 Process Description 9
3.2 Demography 15
3.3 Emissions 20
3.4 Growth Projections 26
4. Control Technologies 30
4.1 Proposed Regulations 31
4.2 Description and History of Controls 32
5. Compliance Schedule 37
5.1 Schedule 37
5.2 Industry Reaction and Comments on Compliance
Schedule 39
6. Enforcement of Proposed Regulations 41
6.1 Problems in Matching RACT and Processes: Industry
Comment 41
6.2 Factors Affecting Enforcement 44
6.3 Recommendations 46
References 48
Appendix A Tabular Data About Flat Wood Paneling Plants 50
iii
-------
FIGURES
Number Page
1 Printed Interior Paneling Line (Lauan, Hardboard,
and Particle Board 10
2 Simplified Schematic of Roll Coaters 11
3 Pressure-head Curtain Coater 14
4 Emission Sources in the Coating Line 21
IV
-------
TABLES
Number Page
1 Distribution of Coating Plants by EPA Region 2
2 Advantages and Disadvantages of VOC Control
Methods Used in the Paneling Industry 3
3 1977 Census of Manufactures Information on
Paneling Coating Plants with Shipments
of $100,000 or More 17
4 Summary of Flat Wood Paneling Plants with
Surface Coating Operations 18
5 Attainment Status of Flat Wood Paneling Plants
with Surface Coating Operations 19
6 Volatile Organic Content of Conventional Flat
Wood Coatings 22
7 Vapor Pressure and Evaporation Rate of Solvents
Used in Coatings 23
8 Estimate of VOC Emissions from Typical Large
and Small Paneling Coating Plants 25
9 Potential VOC Emissions from Flat Wood Operations
Using Conventional Coatings 27
10 Number of Plants in Flat Wood Industry from 1976
to 1979 28
11 Flat Wood Industry Production 29
12 Paneling Industry Problems with VOC Control
Methods 42
A-l Directory of Flat Wood Paneling Plants with
Surface Coating Operations 51
A-2 Flat Wood Paneling Plants with Surface Coating
Operations 57
A-3 Summary of Panel Plant Information Supplied in
Forest Industries Magazine (April 1979) 58
-------
ACKNOWLEDGMENT
This report was prepared for the Division of Stationary
Source Enforcement, U.S. Environmental Protection Agency. Mr.
John R. Busik served as the Project Officer, and Mr. Robert L.
King served as the Task Manager. Mr. Thomas C. Ponder served as
PEDCo's Project Director and Ms. Catherine E. Jarvis as the
Project Manager. Principal authors of this report were Ms.
Jarvis and Ms. Cathie Gardinier. The authors appreciate the
review and comments provided by Mr. King and Mr. Ponder.
VI
-------
SECTION 1
EXECUTIVE SUMMARY
Revised State Implementation Plans (SIP's) must include con-
trols for emissions of volatile organic compounds (VOC's) from
the factory surface coating of flat wood paneling. States having
nonattainment areas for oxidants must establish controls for this
industry in the plans to be issued by July 1, 1980. The U.S.
Environmental Protection Agency (EPA) Control Technique Guideline
(CTG) for flat wood paneling recommends materials changes, process
changes, or add-on controls. Because paneling coaters have not
been regulated in the past (except in California), PEDCo was
asked to investigate potential enforceability problems associated
with the regulation of this industry-
This report identifies the coaters in the flat wood paneling
industry, discusses the processes involved in finishing panels,
identifies sources of VOC and particulate emissions, estimates
VOC emissions, discusses the compatibility of coating operations
with control technology, and assesses the ability of the industry
to comply with the proposed regulations in the time allowed.
Anticipated enforcement problems are then discussed.
The information in this report was obtained from industry
directories; Department of Commerce statistics; technical litera-
ture; and contacts with state air pollution control agencies,
paneling coaters, and coating suppliers. Six plant visits were
made.
The VOC emission guidelines apply to printed interior panel-
ing made of hardwood plywood or thin particle board, natural-
finish hardwood panels, or hardboard paneling with Class II fin-
ishes. Proposed VOC emission limits for these classes of products
-------
2 2
are 2.9 kg/100 m (6.0 lb/1000 ft ) from printed interior panels,
2 2
5.8 kg/1000 m (12.0 lb/1000 ft ) from natural-finish plywood
panels, and 4.8 kg/100 m (10.0 lb/1000 ft ) from Class II.fin-
ishes. The limits do not apply to exterior siding, tile board,
particle board used in furniture, or softwood panels. Process
descriptions and flow diagrams identifying emission sources are
presented in Section 3.1. The various coatings and coating
methods are also discussed.
The study identifies 57 coaters of flat wood paneling to
which the proposed regulations apply. Most of these manufactur-
ers are located in the South and West. Their distribution by EPA
Region is shown in Table 1.
TABLE 1. DISTRIBUTION OF COATING PLANTS BY EPA REGION
EPA Region
I
II
III
IV
V
VI
VII
VIII
IX
X
Number of coating
plants identified
1
2
7
13
9
6
0
1
8
10
The CTG indicated a much greater number of coaters than the
57 identified here; however, this study does not include the
coating of softwood products or of products other than panels
(such as furniture components). The number of coaters has also
declined over the last few years.
Sixty-one percent of the 57 plants are in attainment areas
for oxidants; 75 percent of the plants are in attainment areas
for particulates.
According to information from various coating suppliers,
factory surface coating of flat wood paneling emitted a total of
-------
about 11,000 tons of VOC in 1978. Emissions in 1970 were esti-
mated at 34,000 tons VOC. These figures show an emission reduc-
tion of approximately 70 percent with a production decrease of 15
percent.
Methods currently used to control VOC emissions from factory
surface coating of paneling are incineration, use of water-based
coatings rather than solvent-based coatings, and use of ultravio-
let-curable (UV) and electron-beam-curable (EB) coatings. The
advantages and disadvantages of each control method are summarized
in Table 2. Carbon adsorption has not been used as a control
method in this industry.
TABLE 2. ADVANTAGES AND DISADVANTAGES OF VOC CONTROL METHODS
USED IN THE PANELING INDUSTRY
Control method
Advantages
Disadvantages
Water-based
coatings
Ultraviolet- and
electron-beam-
curable coatings
Incineration
(or afterburners)
Fewer fumes
Greater worker com-
fort
Less fire hazard
Lower insurance
Easier cleanup
Good quality finish
Very fast curing
Allows use of more
solvent while
meeting emission
standards
More difficult to dry
Requires experimentation
to develop satisfactory
coating for a particular
line
Requires some equipment
changes
Must store above freezing
temperatures
Expensive to buy and operate
Requires safety precautions
Some adhesion problems with
other coatings
Expensive to buy and operate
Efficiency may be low
Use of water-based coatings, the most widely applied method,
is significantly decreasing VOC emissions. During the last
decade, conversion to water-based coatings has been accompanied
-------
by experimentation and improvement in product quality. Conver-
sion is likely to continue as coaters improve the technology of
the products and as VOC control regulations are adopted.
Water-based coatings are desirable for several reasons. The
coating emits fewer fumes because its organic content is low;
worker comfort is increased and fire hazards are reduced, which
in turn reduce equipment and insurance costs. Finally, plants
are more likely to meet air pollution standards.
In the years of experimentation, many quality control prob-
lems have been solved but few satisfactory water-based inks and
topcoats have been developed. Suppliers expect their development
to require several more years. Conversion also means substantial
investments for new or modified drying ovens, as well as changes
in equipment (such as coating trays that are plated to minimize
corrosion).
Coatings that are cured by ultraviolet light or an electron
beam nearly eliminate VOC emissions. The systems are capital
intensive, however, which has slowed their adoption.
Incinerators are rarely used because fuel costs are prohib-
itive; only one plant in the survey uses afterburners on its
drying ovens.
In general, particulate emissions irom sanders and groove
cutters at coating plants are easily controlled by cyclones and
fabric filters. These controls were used in all the plants
visited.
The EPA guideline document for this industry allows up to 2
2
years for the reduction of VOC emissions. About half of the
industry people who commented on the compliance schedule felt
that it was realistic. Some expressed concern over the costs of
meeting VOC emission standards within this time. A smaller num-
ber (17 percent) believed that the standards were too stringent
for a 2-year time period, primarily because of the need for
technology development.
-------
Enforcement of standards for coating plants in the paneling
industry is not expected to require a major effort, for the fol-
lowing reasons:
The number of plants is relatively small. Most are in
attainment areas for oxidants (61 percent) and particulates
(75 percent).
The amounts of VOC and TSP emissions are also relatively
small.
Widespread use of water-based coatings is significantly
reducing VOC emissions. This trend is expected to continue.
Growth in the industry is slow. Few new plants will be
added to the inventory in the next few years, and small
plants will continue to close.
-------
SECTION 2
INTRODUCTION
2.1 BACKGROUND
Regulations published in the Federal Register of August 28,
1979 (Vol. 44, No. 168) require states to submit revised State
Implementation Plans by July 1, 1980, reflecting volatile organic
compound (VOC) regulations for (among others) factory surface
coating of flat wood paneling. As a result, state and local
agencies will become involved with an industry that had not pre-
viously been regulated for VOC emissions (except in California).
In June 1978, a Control Technique Guideline (CTG) was pub-
lished for control of VOC from factory surface coating of flat
wood paneling. The CTG provides emission limitations that can
be achieved through the application of reasonably available con-
trol technology (RACT). In the flat wood finishing industry,
RACT consists mainly of the use of water-based and high-solids
coatings. Other RACT options include add-on devices, either in-
cineration or adsorption, and process changes, specifically ul-
traviolet or electron-beam curing.
Because VOC emissions from the industry have not generally
been regulated in the past, this study is designed to character-
ize the industry and to evaluate its ability to comply with the
proposed regulations. Our intention is to review the coating
processes and to assess the compatibility of the unit operations
with various RACT options. We have reviewed problems or successes
encountered by some plants that have already adopted RACT options,
and have included some industry comments. We have also reviewed
2
the compliance schedule in the guideline document.
-------
2.2 PURPOSE AND SCOPE
The Division of Stationary Source Enforcement (DSSE) of the
U.S. Environmental Protection Agency (EPA), under Contract No.
68-01-4147, authorized PEDCo to conduct a 6-month study of the
enforceability aspects of RACT for factory surface coating of
flat wood paneling. The purpose of the study was to identify
problems that the industry will face in adopting RACT when VOC
regulations are enacted by individual states.
The project includes five subtasks:
1. Develop information on the population and geographic
distribution of the industry, estimating annual emis-
sions for a reasonable range of production rates.
2. Review the processes and the emission control method-
ologies for the purpose of identifying problems in
matching procesa equipment to control equipment.
3. Based on items 1 and 2, recommend realistic compliance
schedules for the industry.
4. Investigate existing control methodologies for the
industry and determine potential problem areas.
5. Prepare a final report of the findings of the first
four subtasks.
2.3 SOURCES OF INFORMATION
Many sources, as listed below, were used to identify coaters:
Directory of Panel Plants - USA (Forest Industries)
4
County Business Patterns (U.S. Dept. of Commerce)
Directory of Hardwood Plywood Prefinish Industry (Hardwood
Plywood Manufacturers Association)5
Compliance Data System (Quick Look Report)
Control of Volatile Organic Emissions from Existing Station-
ary Sources - Volume VII: Factory Surface Coating of Flat
Wood Paneling (EPA)l
Guidance to State and Local Agencies in Preparing Regula-
tions To Control Volatile Organic Compounds from Ten Sta-
tionary Source Categories (EPA)2
-------
In addition to these specific sources, we contacted air pollution
control agencies for each state where coaters or paneling plants
are located.
From these sources, we compiled a list of 501 paneling
plants. We contacted each plant by phone to identify those that
coat paneling.
Statistical data on the industry were obtained from the 1977
Census of Manufactures, published by the Bureau of Census (U.S.
Department of Commerce), for SIC's 2435 (Hardwood Veneer and
Plywood), 2492 (Particle board), and 2499 (Hardboard). Other
sources of statistical data were journal articles and the CTG;
some data were also obtained from trade associations, coating
plants, and coating suppliers.
Process description information was obtained from the CTG,
from literature, and from the six plant visits that we conducted
during the study.
Emissions data were obtained from coating suppliers, trade
associations, and coating plants. We also asked representatives
at these sources to comment on the compliance schedule, on the
RACT options, and on their implementation.
-------
SECTION 3
INDUSTRY CHARACTERIZATION
3.1 PROCESS DESCRIPTION
Printed interior paneling products are made by applying a
decorative finish to the surface of lauan (an imported tropical
hardwood), hardboard, or particle board. The components and pro-
cedures of the coating production lines vary from plant to plant.
The basic series of coatings is filler, base coat, inks, and top-
coat. Most lines also in.-lude a groove coat.
The following general process descriptions and flow diagram
(Figure 1) show typical production line variations. Product
categories include printed interior paneling and natural hardwood
plywood interior paneling.
The first step in finishing the board is sanding or brush
dusting to provide a smooth, dust-free surface. Hardboard may
need to be tempered with oil and resin for added strength and
stability before brushing.
The next step is application of filler. Filler is normally
applied by reverse-roll coating. Roll coating is a process in
which coating is applied to the wood by cylindrical rollers. The
reverse-roll coater (Figure 2A) consists of a coating applicator
roll that rotates in the direction of panel movement, followed by
a wiper roll that rotates against the direction of the panel
movement. The reverse roller forces the filler into the depres-
sions, voids, and cracks in the panels and removes excess coating
material. Filler provides a smooth, even surface for further
coating applications.
-------
FEEDER
*l 15KU.
i
J CAWnCD I
5HER
i
FILLER
(RRC)
OVEN
CAwnFR
CUT
GROOVE
-^-
GROOVE
COAT
(SPRAY)
COOLING
1
*-| OVEN
r
TOPCOAT
(DRC
OR CC)
INKS
(OFFSET
GRAVURE)
OVEN
FIRST OR
SECOND
BASECOAT
(DRC)
OVEN
SEALER
OR FIRST
BASECOAT
(DRC OR
SPRAY)
INSPECTION
PACKAGING
SHIPMENT
RRC = REVERSE ROLL COATING
DRC = DIRECT ROLL COATING
CC = CURTAIN COATING
Figure 1. Printed interior paneling line (lauan, hardboard, and particle board).
-------
APPLICATOR
COATING
DOCTOR BLADE
REVERSE ROLLER
PANEL
A. REVERSE ROLL COATER
COATING
APPLICATOR
PANEL
B. DIRECT ROLL COATER
Figure 2. Simplified schematic of roll coaters.
11
-------
Fillers must dry fast, sand easily, seal the board (espe-
cially if no separate sealer is applied), and not shrink with
age. Several different fillers, each with various advantages and
disadvantages, are available: (1) polyester filler, which is
ultraviolet cured, (2) water-based filler, (3) lacquer-based
filler, (4) polyurethane filler, and (5) alkyd-urea-based filler.
Water-based fillers are in common use on printed paneling lines.
Filler is not applied to prefilled particle board or to boards
that can remain nonfilled. It is sometimes applied more than
once to assure complete coverage of particularly porous sub-
strates, and can be followed by application of a separate sealing
compound. The sealer may be water- or solvent-based, and is
usually applied to seal off pores and substances in the wood that
could affect subsequent finishes. Filling and sealing operations
are both followed by ovens (steam heated, convection, infrared,
or ultraviolet) and by sanders.
The next step in many coating lines is groove cutting, fol-
lowed by groove coating. Groove cutting can, however, be per-
formed at other points in the coating process—before filling,
for example. Groove color can be applied in different ways, but
commonly by air sprays. Groove coats are usually pigmented, low-
resin solids that are reduced with water before use. Even in
coating operations that are entirely solvent based, the groove
coat may be water based.
The next step for printed paneling is application of the
base coat, which provides a smooth surface of the appropriate
color on which to print the wood grain or other pattern (the
original grain is completely obscured). Base coats must be fast
drying and provide good coverage. In printed paneling, they fall
into the following categories: lacquer, synthetic, vinyl, modi-
fied alkyd urea, catalyzed vinyl, and water based (used primarily
on lauan paneling at this time.
Basecoats are usually applied by direct-roll coaters (Figure
2B). This coater is an applicator cylinder that rotates in the
same direction as the panel movement.
12
-------
After passing through an oven (gas fired, infrared, etc.)*
the panel is printed. Inks are applied by an offset gravure
printing operation similar to direct-roll coating. Several
colors may be used to reproduce the appearance of wood, marble,
leather, textured cloth, and so on. The final effect depends on
surface smoothness, color of the base coat and inks, strength and
transfer properties of the inks, and other variables. Most lauan
printing inks are pigments dispersed in alkyd resin, with some
nitrocellulose added for better wipe and printability. Water-
based inks may have a good future for cost and ecological reasons,
but they are not currently used in any significant amounts.
After printing (or after base coat application, if no print-
ing is done), a clear, protective topcoat is applied to the board
by one or two direct-roll coaters or curtain coaters. These are
wet-on-wet applications. Most topcoats are organic-solvent-based
coatings, some are synthetic, being prepared from solvent-soluble
alkyd or polyester resins, urea formaldehyde cross-linkings, or
other resins. Some water-based topcoats are used; these often
contain an alkyd-urea catalyst. The synthetic topcoats are
catalyzed and sent through a hot-air oven for curing; other
topcoats are cured in infrared or ultraviolet ovens. The panels
are cooled prior to stacking, inspection, and shipping.
A curtain coater applies a free-falling film of coating to
the panel* In a pressure-head curtain coater (Figure 3), coating
material is metered into a pressure head, then forced through a
calibrated slit between two knives. The rate of panel movement
and the controlled uniform flow of the film determines the coat-
ing thickness. The important variables are physical properties
of the material, temperature, slit width, coating flow rate, and
panel speed. Excess coating is caught in a trough and recircu-
lated.
Natural-finish hardwood plywood interior paneling undergoes
a more involved coating process. This paneling is produced in
very few plants (probably only six plants in the entire United
13
-------
COATER HEAD
COATING
TROUGH
COATING
RESERVOIR
PUMP
Figure 3. Pressure-head curtain coater.
14
-------
States, according to an industry representative). Only a brief,
general description of the process will be presented here; some
variations occur among plants.
The first step in finishing a natural-finish hardwood panel
is to fill the open knots with a putty material. The second step
is to cut a groove and paint it with an opaque finish. The panel
is then sanded prior to application of a stain, which gives the
surface a uniform color without raising the grain of the wood
fiber. The stain is normally applied by a direct-roll coater.
The panel is then dried in a high-velocity or infrared oven.
A thin wash coat, known as a toner if it is colored with
dyes or transparent pigments; may then be directly rolled on to
seal the stain and to improve the clarity and lightness of the
finish. Next, the plywood is filled, usually by a reverse-roll
coater, and then dried and polished in a brush unit.
The primer sealer is the next coating applied, normally by
direct-roll coating. The sealer, which floods the complete
panel, protects the wood from moisture, provides a smooth base
for the topcoat, and gives gloss to the grooves. The sealed
board is then dried, sanded, and buffed.
At this point, the surface of the panel is embossed and
valley printed to give a distressed or antique appearance. One
or more print steps may then be added. The panel is then dried,
and it is sealed with a direct-roll coater to smooth the surface
in preparation for topcoating.
One or more topcoats are applied to provide durability,
protection, and gloss. Direct-roll coating is the usual appli-
cation method, but curtain coating may also be utilized. The
final topcoat is cured and the panels are cooled, buffed, and
stacked for shipment.
3.2 DEMOGRAPHY
One of the first requirements of this study was an accurate
inventory of flat wood paneling coating plants. The first refer-
ence consulted was the Census of Manufactures. According to
15
-------
this source, about 670 flat wood plants were in operation in
1977. This total, however, includes many plants to which the
regulations do not apply, either because the plants make or coat
products other than paneling or because they coat softwood prod-
ucts. Table 3 provides information on the plants that actually
produce prefinished interior paneling. This information does not
indicate the total number of plants with coating operations,
because some plants produce more than one kind of prefinished
product.
Other sources were thus investigated to reduce this number
to include only those plants covered by the proposed flat wood
paneling regulations. Listings from the 1979 Directory of Panel
3 CQ
Plants-U.S.A. and from wood products associations, ' together
with direct phone contacts, were used to compile total plant
numbers for all flat wood plants with surface coating operations.
The results of this survey are presented in Table 4. From this
information, we can see that the total number of interior panel-
ing coating plants is small when compared with the total flat
wood industry (see Appendix A, Table A-3, for further data):
only 57 plants were identified in this survey. Further, the 13
largest plants (20% of coating plants) account for about 60 per-
cent of the production.
Although coating plants are found throughout the United
States, most are located in the South and on the West Coast.
(Table 4 shows the distribution of plants by EPA region.) Region
IV (the southeastern states) and Regions IX and X (the Pacific
coast states) contain more than half the plants and most of the
biggest producers. Appendix A presents a state-by-state tally of
coating plants. California, Virginia, and Oregon are the three
states with the largest production of prefinished interior panel-
ing (about 50% of total production). Table 5 summarizes the
attainment status of flat wood paneling coating operations. Of
the 57 flat wood coating plants, 35 plants (61%) are located in
attainment areas for oxidants; and 43 plants (75%) are located in
attainment areas for particulates.
16
-------
TABLE 3. 1977 CENSUS OF MANUFACTURES INFORMATION ON -
PANELING COATING PLANTS WITH SHIPMENTS OF $100,000 OR MORE'
Product
(SIC code)
Prefinished hardwood plywood
(24352 00)
Hardwood veneer panels
(24353 31)
Prefinished hardboard panel ings
from self -produced hardboard
(24996 11)
From purchased hardboard
(24998 03)
Coated or prefinished mediumr
density fiberboard0
(24997 11)
Prefinished particle board0
(24999 65)
Number of
companies
26
9
12
19
11
21
Product shipments3
Quantity
(million ft2)
2565.1
107.1
4864.8
419.1
230.1
NA
Value
(million dollars)
390.2
12.8
353.9
90.1
28.9
66.5
Includes all producers, not just shipments over $100,000.
Includes noncoated production.
c Includes products used for purposes other than paneling.
NA = Not available.
17
-------
TABLE 4. SUMMARY OF FLAT WOOD PANELING
PLANTS WITH SURFACE COATING OPERATIONS
EPA
region
I
II
III
IV
V
VI
VII
VIII
IX
X
Total
Total
plants
1
2
7
13
9
6
0
1
8
10
57
Hardwood
plywood
1
2
3
6
3
3
6
3
27
Particle
board
2
2
2
1
1
2
10
Hardboard
panel board,
fiber board
2
5
6
1
1
5
20
Production
>200 million
ft2/yr
2
2
2
5
2
13
<200 million
ft2/yr
1
2
5
11
7
6
1
3
8
44
CO
-------
TABLE 5. ATTAINMENT STATUS OF FLAT WOOD PANELING
PLANTS WITH SURFACE COATING OPERATIONS
EPA
region
I
II
III
IV
V
VI
VII
VIII
IX
X
Total
Number of
plants
1
2
7
13
9
6
0
1
8
10
57
Percentage 100
Oxidants
Attainment
0
0
4
9
7
1
0
1
4
9
35
61
Nonattainment
1
2
3
4
2
5
0
0
4
1
22
39
Parti culates
Attainment
1
1
7
9
6
4
0
0
6
9
43
75
Nonattainment
0
1
0
4
3
2
0
1
2
1
14
25
19
-------
3.3 EMISSIONS
The predominant emissions from flat wood surface coating
operations are volatile organic compounds, which are emitted by
the evaporation of the volatile organic solvents contained in
conventional coatings. Other emissions include small quantities
of particulates from sanding and groove-cutting operations and
combustion emissions from gas-fired ovens.
3.3.1 Sources and Quantity of VOC Emissions
The VOC emissions from flat wood coating plants occur pri-
marily at the coating lines. Figure 4 presents a schematic dia-
gram of emission sources in the coating line. Oven exhausts are
discrete point sources. Printing operations may be enclosed in a
room with controlled airflow. In this case, the printer repre-
sents a point source, with emissions vented to the roof along
with oven exhausts. All other coaters and rollers are considered
fugitive emission sources. Another source of fugitive VOC emis-
sions is the vaporization of organics at paint mixing and storage
areas.
The solvents in organic-based coatings are usually multi-
component mixtures, including methyl ethyl ketone, methyl isobu-
tyl ketone, toluene, xylene, butyl acetates, propanol, ethanol,
butanol, VM and P naphtha,* methanol, amyl acetate, mineral spir-
its, SoCal I and II, glycols, and glycol ethers. Organic solvents
most often used in water-based coatings are glycol, glycol ethers
(such as butyl cellosolve), propanol, and butanol. Table 6 shows
the amounts of volatile organics in the different conventional
coatings supplied to the flat wood coating industry, as well as
the estimated emission factors (solvent density). The composi-
tion of the solvent determines the type of VOC emitted. Water-
based coatings are discussed in Section 4.
*
VM and P: Varnish maker's and painter's; a refined solvent
naphtha.
20
-------
[ FEEDER [
BRUSHER
i
FILLER
(RRC)
OVEN
1C
SANDER
>
c
CUT
GROOVE
[ \
GROOVE
COAT
COOLING
H
OVEN
^
TOPCOAT
(DRC
OR CC)
^
INKS
(OFFSET
GRAVURE)
f
nVFN
FIRST OR
S.ECOND
BASECOAT
(DRC)
f'
* nvrN
^ UVLli
SEALER
OR FIRST
BASECOAT
(DRC OR
SPRAY)
INSPECTION
SHIPMENT
T =
RRC = REVERSE-ROLL COATING
DRC = DIRECT-ROLL COATING
CC = CURTAIN COATING
FUGITIVE VOC
VENTED VOC
PARTICULATE
Figure 4. Emission sources in the coating line.
-------
TABLE 6. VOLATILE ORGANIC CONTENT OF CONVENTIONAL FLAT WOOD COATINGS
Paint type
Filler
Sealer
Base coat
Grain ink
Topcoat
Density
kg/ liter
1.7
1.1
1.4
1.2
1.1
(Ib/gal)
(14.5)
(9)
(11.5)
(10)
(8.8)
Volatile organics,
weight percent
15 to 30
15 to 50
40 to 75
30 to 70
50 to 75
Source: Reference 9.
Particulate emissions from sanders and groove cutters are
collected with fabric filters and cyclones. If particulates from
precoating sanders can be collected separately from other partic-
ulates, the collected material can be sold or recycled. Other
particulates must be disposed of in landfills.
Natural gas is the primary fuel used in the drying and cur-
ing ovens; liquefied petroleum gas is the primary backup fuel
when natural gas supplies are curtailed or where natural gas is
not available. Some coating plants use infrared or ultraviolet
cure ovens, which are electrically heated. These ovens can elim-
inate oiisite combustion emissions, such as carbon monoxide,
unburned fuel, and nitrogen oxides. Ultraviolet ovens produce a
small amount of ozone, which is usually not a problem.
3.3.2 Factors Influencing VOC Emissions
Organics vaporize at ambient temperature and pressure.
Emissions from ovens are at ambient pressure and at temperatures
determined by the substrate and the coatings used. Table 7 lists
the common organic solvents used in conventional coatings and
their vapor pressures and relative evaporation rates. The evapo-
ration rate indicates the rate of VOC emissions relative to each
compound. For example, ethanol evaporates three times faster
22
-------
TABLE 7. VAPOR PRESSURE AND EVAPORATION RATE OF
SOLVENTS USED IN COATINGS
Compound
Butanol, Iso
Butanol , n
Butanol , sec
Ethanol , anhydrous
Propanol , anhydrous
Methanol
Methyl ethyl ketone
Methyl isobutyl ketone
Toluene
Xylene
Butyl acetate, sec
Butyl acetate, iso
Butyl acetate, n
VM and P naphtha
Amy! acetate (primary)
Glycols
Glycol ethers
Vapor pressure,
at 20°C, mmHg
8.8
4.4
12.7
44.0
31.2
96.0
70.6
16.0
38.0
9.5
4.0
12.5
7.8
2.0
4.0
<0.01
<1.0
Evaporation
rate3
0.63
0.46
0.90
1.9
1.7
3.5
4.6
1.6
1.5
0.75
1.9
1.45
1.0
0.45
0.4
<0.01
Relative to that of butyl acetate, 1.0.
Source: Reference 9.
23
-------
than isobutanol at a given temperature, pressure, and humidity.
Coating mixtures contain a number of these solvents, and the par-
ticular composition varies with each operation (filling, sealing,
base coating, topcoating) and at each plant. Consequently, VOC
emissions vary widely in mass rate per unit production, in mass
rate per unit weight of coating used, and in concentration.
In addition, the distribution of solvent emissions from
solvent handling, mixing, and application (workroom emissions
exhausted through roof vents and windows), and from drying ovens
(point sources) can vary widely. A plant that uses highly vola-
tile solvents, such as methanol, ethanol, and methyl ethyl ketone
will emit much greater amounts of VOC from handling, mixing, and
application (say 70%) than through drying oven exhaust (say 30%).
In contrast, a plant that uses relatively low-volatility solvents,
such as amyl acetate, butanol, and VM and P naphtha, will emit
much less VOC from handling, mixing, and application (say 20%)
than from drying oven exhaust (say 80%). The first example is
probably more typical.
3.3.3 Nationwide Emissions
Based on contacts with various coating manufacturers, we
estimate that 11,000 tons of VOC were emitted from flat wood
coating plants in 1978. This estimate is based on the production
of 3.0 billion square feet of paneling and on emission rates of
2
6.5 lb/1000 ft for printed interior paneling (90% of production)
2
and 12.0 lb/1000 ft for natural-finish interior paneling (10% of
production). The figures can be compared with those for 1970 to
show the reduction of VOC emissions over the time period. The
total for 1970 was 34,000 tons of VOC emissions, based on the
production of 3.5 billion square feet of paneling and emission
rates of 18.1 lb/1000 ft for printed panels (75% of production)
2
and 24.2 lb/1000 ft for natural-finish panels (25% of production).
Emissions were reduced about 70 percent while production was
reduced 15 percent. (The decline in production is partly due to
replacement by paper and vinyl laminating products, which are not
covered by this regulation.)
24
-------
From these figures, we can calculate the quantity of emis-
sions from a typical paneling coating plant (thus allowing order-
of-magnitude comparisons to be made with other industries). A
2
large paneling coating plant coats about 12 million ft /mo, or
144 million ft2/yr. At an emission rate of 6.5 Ib VOC/1000 ft
for printed interior panels, 470 tons/yr or slightly less than 2
tons/day are emitted. Natural-finish paneling coating, with an
emission rate of 12 Ib VOC/1000 ft , emits 865 tons/yr or a maxi-
mum of 3.3 tons/day (based on 260 days per year). Small paneling
2 2
plants coat about 5 million ft /mo, or 60 million ft /yr. Using
the same emission rates of 6.5 Ib VOC/1000 ft2 and 12 Ib VOC/1000
2
ft for printed interior panels and for natural-finish panels,
VOC emissions are estimated to be 195 tons/yr (0.5 to 1 ton/day)
and 360 tons/yr (1-1.5 tons/day). These order-of-magnitude
figures are summarized in Table 8.
TABLE 8. ESTIMATE OF VOC EMISSIONS FROM TYPICAL
LARGE AND SMALL PANELING COATING PLANTS
Coated production
Large plant
144 million ft /yr
Small plant
60 million ft /yr
Printed panel emission factor
Printed panel emissions
Natural finish panel emission
factor
Natural finish panel emissions
6.5 Ib VOC/1000 ft
470 tons/yr or
1.5 to 2 tons/day
12 Ib VOC/1000 ft2
865 tons/yr or
3 to 3.5 tons/day
6.5 Ib VOC/1000 ft'
195 tons/yr or
0.5 to 1 ton/day
12 Ib VOC/1000 ft2
360 tons/yr or
1 to 1.5 tons/day
Some of the major coating manufacturers have also supplied
information on the percentages of solvent-based vs. water-based
coatings produced and sold. One major supplier reported that the
coating materials for all flat wood operations (including furni-
ture, exterior siding, etc.) were 76 percent solvent based vs. 24
percent water based in 1976, and 69 percent vs. 29 percent in 1977
25
-------
For paneling only in 1977, this manufacturer estimated the sale
of 36 percent solvent-based coatings vs. 64 percent water-based
coatings. Another coating manufacturer estimated that coatings
sold to paneling operations were 20 percent solvent based vs. 80
percent water based. Other coating manufacturers are selling 45
to 50 percent water-based coatings.
Although we can determine the total gallons of coatings sold
by individual coating manufacturers, amounts of VOC emissions per
gallon cannot be readily calculated. The volatile content of a
coating is highly variable, depending on its type and the coating
manufacturer. Table 9 presents estimates of potential VOC emis-
sions from each kind of operation using conventional coatings.
At plants that apply filler, sealer, base coat, grain ink, and
topcoat, the estimated VOC emission factor may range from 88 to
174 g/m2 (11 to 21 lb/1000 ft2) of flat wood coated.
Because the volatile fraction of the coatings contributes
essentially all of the VOC emissions, the total emissions from a
plant are the product of the weight fraction of volatile organics
in the coatings and of coating usage. Composition of the VOC
emissions depends upon the types of solvents used. The ovens
release practically all of the incoming volatile compounds, and
the fraction of total plant emissions :;hat comes from the dryer
ovens depends on the types of solvents used, or (more specifical-
ly) their relative volatility or evaporation rate.
3.4 GROWTH PROJECTIONS
In the past few years, the number of flat wood plants in
operation (coating and noncoating) has steadily declined (see
Table 10). The industry has, however, experienced increased
production over the same time period (see Table 11). This trend
is true for the surface coating industry as well (including paper
and vinyl laminating). Industry literature predicts that the
factory surface coating of flat wood products will increase as
more prefinished wood is used in the building trade. The market
26
-------
TABLE 9. POTENTIAL VOC EMISSIONS FROM FLAT WOOD OPERATIONS
USING CONVENTIONAL COATINGS
Operation coating
Filler
Sealer
Base coat
Grain ink
Topcoat
Range of VOC emissions
kg/liter
coating
0.26 to 0.53
0.17 to 0.54
0.44 to 1.0
0.36 to 0.84
0.53 to 0.79
( lb/gal\
Vcoating/
(2.2 to 4.4)
(1.4 to 4.5)
(3.7 to 8.6)
(3.0 to 7.0)
(4.4 to 6.6)
Coverage
liters/
103 m2
119
21
56
7
49
(gal/103 ft)
(1.7)
(0.3)
(0.8)
(0.1)
(0.7)
Total
Range of VOC emissions
g/m3 coated
31 to 62
3.6 to 11.3
25 to 56
2.5 to 5.9
26 to 38.7
88 to 174
(lb/103 ft2)
(3.7 to 7.5)
(0.4 to 1.4)
(3.0 to 6.9)
(0.3 to 0.7)
(3.0 to 4.6)
(11 to 21)
Source: Reference 9.
-------
TABLE 10. NUMBER OF PLANTS IN FLAT WOOD
INDUSTRY FROM 1976 TO 1979
Year
1976b
1977d
1978e
1979f
Hardwood
plywood
247C
288C
151
135
Particle
board
86
84
71
61
Hardboarda
panel board
67
NA
26
28
Total
400
NA
266
242
Medium density fiberboard.
Reference 9.
c This number may be inflated due to inclusion of hardwood veneer plants,
Reference 7.
e Reference 10.
Reference 11.
NA = Not available.
28
-------
includes recreational vehicles, home improvement/do-it-yourself,
nonresidential, and industrial construction.
TABLE 11. FLAT WOOD INDUSTRY PRODUCTION
(Square feet)
Year
1976
1977
I978b
Hardwood plywood,
surface measure
1,463,135,000
1,478,000,000
1,675,000,000
Particle board,
3/4-in. basis
3,202,200,000
3,592,210,000
3,610,000,000
Hardboard,
3/4-in. basis
7,066,022,000
7,200,000,000
7,800,000,000
MDF,a
3/4-in. basis
280,036,000
441,354,000
480,000,000
Medium density fiberboard.
Estimated data.
Source: Reference 11.
During this survey, officials at several of the plants
contacted reported that .they had recently shut down either their
coating operations or their entire plant. Many small plants are
being bought by major flat wood producers, and many low-production
coating lines are being shut down. The result is a smaller
number of plants operating at higher production levels.
Some surface coating operations are also being replaced by
paper laminating operations. These products, which require only
top coatings, are not included in the proposed regulations.
Vinyl laminates are also replacing some printed interior paneling
operations. These are not generally topcoated.
These trends will produce a smaller number of larger surface
coating operations, which will reduce the number of emission
sources. Total emissions may also be reduced, because larger <
operations can better afford to buy and develop emission control
equipment, processes, and materials.
29
-------
SECTION 4
CONTROL TECHNOLOGIES
Control technologies addressed in the Control Technique
Guideline can be classified into three groups: add-on devices,
materials changes, and process changes. Add-on devices include
incineration and adsorption. Adsorption methods such as carbon
adsorption are not generally used in the flat wood finishing
industry.
Materials changes include use of water-based coatings and of
high-solids coatings. High-solids coatings have not generally
been used in the paneling industry, but coating suppliers could
develop acceptable products in the future. The wood finishing
industry is using more high-solids coatings, which are defined as
those with 70 percent or more solids. The industry used 25 per-
12
cent high-solids coatings in 1972, 35 to 40 percent in 1977,
and 40 to 45 percent (by volume) in 1978. Much of this in-
crease, however, has been in coatings for wood products other
than paneling, such as furniture. The higher viscosity has led
to several application problems. The coating must often be heat-
ed to reduce viscosity before application. Instead of resembling
natural wood the finish tends to look painted, which is unaccept-
able. Powder coatings, another high-solids product, require a
.higher temperature for curing than is suitable for wood products.
This problem may be solved as coating suppliers expand their
technologies.
Process changes include ultraviolet curing and electron-beam
curing. Both are used to a limited degree in the industry.
30
-------
4.1 PROPOSED REGULATIONS
The EPA guidance document gives emission limits for coating
2
application systems. The VOC standards are as follows:
(a) No owner or operator of a flat wood manufacturing
facility subject to this regulation shall emit volatile
organic compounds from a coating application system in
excess of:
(1) 2.9 kg per 100 square meters of coated finished
product (6.0 lb/1000 sq ft) from printed interior
panels, regardless of the number of coats applied;
(2) 5.8 kg per 100 square meters of coated finished
product (12.0 lb/100 sq ft) from natural-finish
hardwood plywood panels, regardless of the number
of coats applied; and,
(3) 4.8 kg per 100 square meters of coated finished
product (10.0 lb/100 sq ft) from Class II finishes
on hardboard panels, regardless of the number of
coats applied.
(b) The emission limits in paragraph (a) of this section
shall be achieved by:
(1) The application of low solvent content coating
technology; or,
(2) An incineration system that oxidizes at least 90.0
percent of the nonmethane volatile organic com-
pounds entering the incinerator (VOC measured as
total combustible carbon) to carbon dioxide and
water; or,
(3) An equivalent means of VOC removal. The equivalent
means must be certified by the owner or operator
and approved by the Director.
(c) A capture system must be used in conjunction with the
emission control systems in parts (b)(2) and (b)(3).
The design and operation of a capture system must be
consistent with good engineering practice and shall be
required to provide for an overall emission reduction
sufficient to meet the emission limitations in para-
graph (a) of this section.
Emission limits are stated in terms of the amount of VOC per
area of coated surface. This limit is flexible because it allows
31
-------
coaters to make sufficient adjustments anywhere in the line to
meet the requirement; i.e., an operator could reduce the thick-
ness of a coat, use different coatings, or apply different num-
bers of coats to meet the limit. The limits do not apply to a
particular coating, such as filler or topcoat. For printed inte-
rior panels, emission limits are based on the use of both water-
based and solvent-based coatings. For natural-finish paneling,
the limits are based on the use of solvent-based coatings con-
taining less solvent than conventional coatings.
The guidance document applies only to flat wood manufactur-
ing and surface-finishing facilities that manufacture the follow-
ing products:
(1) Printed interior panels made of hardwood, plywood,
and thin particle board;
(2) Natural finish hardwood plywood panels; or,
(3) Hardboard paneling with Class II finishes (as defined
in Voluntary Product Standard PS-59-73 of the American
National Standards Institute).
The regulation does not apply to the manufacture of exterior
siding, tile board, or particle board that is used as a furniture
component.
Emissions from the inks used to print simulated grain or
decorative patterns on printed interior panels are covered in
this CTG category, and should not be considered a Graphic Arts
activity.
4.2 DESCRIPTION AND HISTORY OF CONTROLS
This section discusses the control technologies that can be
used in flat wood paneling: incineration, water-based coatings,
ultraviolet curing, and electron-beam curing. Continuing prob-
lems with these technologies are discussed in Section 6.1.
Incineration was used by two plants in Southern California.
In a new plant in Ohio that uses conventional solvent coatings,
ovens are equipped with afterburners to reduce VOC emissions.
32
-------
Most representatives of the coating industry who were contacted
said that incineration or afterburners were too expensive to
install and to operate because of the extra fuel required.
Water-based coatings have steadily increased in use since
the first water-based fillers were developed in the late 1960's.
Use of water-based fillers, base coats, and groove coats is wide-
spread in the industry, resulting in significantly less solvent
use and fewer VOC emissions from coating plants. The technology
of water-based inks and topcoats, however, particularly clear
topcoats, is still being developed. Some suppliers and coaters
estimated that full development of these products is still 1 to
3 years away (as of January 1980).
People in the industry commented that conversion to water-
based products is desirable for several reasons:
Water-based coatings emit fewer fumes, thus making the plant
environment more pleasant. Workers experience much less
discomfort from eye, nose, and throat irritations when low-
solvent products are used.
The presence of fewer solvents and fumes in the plant sig-
nificantly reduces fire hazards. Fire insurance costs and
equipment replacement costs decrease as a result. Fires had
occurred monthly at one plant, but they became infrequent
when water-based coatings were adopted.
Emissions are fewer. Plants converting to water-based
coatings are more likely to meet local or state emission
standards.
Cleanup, when done promptly, is easier when water-based
coatings are used. When wet, the equipment can be hosed
down or washed with water.
Some of the problems that arose when plants first tried
water-based fillers, sealers, and other coatings have since been
corrected. These problems included blocking, mudcracking, roping,
and defects in appearance. Some early water-based coatings were
thermoplastic, meaning that they would soften and fuse when heat-
ed and would harden again when cooled. Panels and doors coated
with thermoplastic coatings would be cured in an oven and then
stacked. The warm coatings on each wood product would then fuse
33
-------
and a banded stack would become a fused blocki Early temporary
solutions consisted of spreading all the panels or doors out to
dry and cure completely for 24 hours before stacking. Since
then, new coatings and more complete drying and curing in the
process line have reduced the probability of blocking.
Other problems were roping and mudcracking. Roping, an
uneven finish caused by the absence of tail solvents to smooth
the application, has been avoided by new coating formulations and
sometimes by the application of two thin coats rather than one
thick coat. Improvements are still being made in this area.
Mudcracking, or fine cracks in the finish, has been alleviated by
altering the drying process; conventional ovens are commonly fol-
lowed by high-intensity infrared ovens.
Many finishers commented, particularly about earlier coat-
ings, that the appearance was not as clear or smooth as solvent
coatings. This problem continues with topcoats and inks, for
which satisfactory water-based coatings are not yet developed.
The inks tend to block the pyramids in the metal gravure printing
rollers, creating a less distinct pattern. The topcoats have not
been clear enough, and some discoloration or cloudiness has been
experienced. Solvent coatings are reported to have better adhe-
sion and more gloss. Water-based topcoats are reportedly diffi-
cult to cure.
Ultraviolet and electron-beam curing, both of which use
radiation-cured finishes, are process changes that can be used in
flat wood finishing. Ultraviolet curing is gaining acceptance as
an option for finishing lines, especially to coat particle board,
where water-based coatings are less successful. Ultraviolet-cur-
able coatings are a combination of resin, prepolymers, monomers,
and a photosensitizer that serves as a catalyst, with no solvents.
The coatings are applied as a liquid; the material hardens and
cross-links upon exposure to ultraviolet light, forming a tough,
solid coating within seconds. Less than 1 percent of the coating
is emitted as VOC; the ultraviolet-cured coatings are thus con-
sidered nearly 100 percent solids. Small amounts of ozone are
emitted. Ultraviolet-cured coatings are generally more expensive
34
-------
per gallon ($8 to $15/gallon) than conventional coatings, but us-
age costs are competitive because greater mileage is possible.
Ultraviolet ovens used to cure the coatings are usually smaller
than conventional ovens because these coatings cure very quickly;
as a result, less floor space is needed. The ovens run on elec-
tricity rather than natural gas, and energy consumption is re-
portedly 5 to 80 times less than with conventional coatings.
Radiation-cured coatings are most suitable for flat wood
panels because the radiation must reach all coated areas uni-
formly without benefit of heat or reflection.
A plant visited in Oregon used ultraviolet-cured fillers and
topcoats on particle board and fiberboard for furniture and cabi-
net parts. Most of these coatings are clear to semitransparent
fillers and topcoats; opaque ultraviolet-cured coatings have not
yet been developed. The Oregon plant used conventional solvent
based coats between the ultraviolet-cured filler and topcoat be-
cause topcoats do not adhere well to ultraviolet-cured base
coats. This adhesion problem limits the number of finishes that
can be applied over ultraviolet-cured coatings. Usage is ex-
pected to increase, however, as the technology progresses.
Electron-beam curing is a new technology for flat wood fin-
ishing. ' Particle board, fiberboard, or hardboard are coated
with an opaque, acrylic coating and passed under a beam of accel-
erated electrons in a low-oxygen, high-vacuum atmosphere. Nitro-
gen is pumped across the panel to maintain an inert environment.
The coating cures rapidly to a very durable, smooth finish com-
parable in some respects to plastic laminates. Electron-beam-
cured products are currently used for furniture and cabinet
components, although the technology can be applied to paneling
products as well.
*
The electron-beam curing system has several advantages.
Emissions of VOC are virtually eliminated because the liquid
coatings are almost entirely converted to solids upon curing.
Because expensive heating is not required, less electricity or
other energy is used. A third advantage is the wider range of
colors available in comparison with plastic laminate products.
35
-------
Disadvantages of electron-beam-curable coatings are cost and
safety precautions required. Because electron-beam curing emits
radiation while it is operating, the vaults must be heavily
shielded to protect workers from radiation exposure. The Oregon
plant has a 2-ft-thick concrete wall around the accelerator and a
1-ft-thick wall around the entries and exits to the vault. The
electron-beam line at this plant cost $500,000 to install. The
acrylic coatings used in the system are also expensive, ranging
from about $25 to $30/gallon.
Although radiation curing is expensive, its use, especially
of ultraviolet cures, is expected to increase in the future.
36
-------
SECTION 5.
COMPLIANCE SCHEDULE
5.1 SCHEDULE
The EPA guidance document has separate compliance schedules
depending on the VOC control method used. Those plants .using
water-based (low-solvent) coatings must comply with the regula-
tions by July 1, 1982. Plants using incineration with heat
recovery must also comply by that date. If incineration without
heat recovery is used, the plant must comply by July 1, 1981.
Alternative compliance schedules can be submitted to the EPA
Director, subject to approval. The details of the compliance
schedule from the guidance document are included here for refer-
ence.
The owner or operator of a source of volatile organic com-
pounds subject to this regulation shall meet the applicable
increments of progress in the following schedules:
(1) Sources utilizing low solvent content coatings to
comply with the emission limitations in §XX.9330 shall:
(i) Submit final plans for the application of low
solvent technology before October 15, 1980;
(ii) Complete evaluation of product quality and com-
mercial acceptance before April 1, 1981;
(iii) Issue purchase orders or contracts for low solvent
content coatings before June 1, 1981;
(iv) Initiate process modifications before July 1,
1981; and,
(v) Complete process modifications and begin use of
low solvent content coatings before July 1, 1982.
37
-------
(2) Sources utilizing process equipment changes or add-on
control devices, including incineration with heat re-
covery, to comply with the emisson limitations in
§XX.9330 shall:
(i) Submit final plans for the emission control sys-
tem, or process equipment, or both, before October
15, 1980;
(ii) Award contracts or purchase orders for the emis-
sion control systems, or process equipment, or
both, before December 15, 1980;
(iii) Initiate onsite construction or installation of
the emission control system, or process equipment,
or both, before June 1, 1981;
(iv) Complete onsite construction or installation of
the emission control system or process equipment,
or both, before June 1, 1982; and,
(v) Achieve final compliance, determined in accordance
with §XX.9350, before July 1, 1982.
(3) Sources utilizing incineration without heat recovery or
process modifications not requiring purchase orders, to
comply with the emission limitations in §XX.9330,
shall:
(i) Submit final plans for the emission control system
or process modification, or both, before September
15, 1980;
(ii) Award contracts or purchase orders for the emis-
sion control system or process modification, or
both, before November 1, 1980;
(iii) Initiate onsite construction or installation of
the emission control system or process modifica-
tion, or both, before January 15, 1981;
(iv) Complete onsite construction or installation of
the emission control system or process modifica-
tion, or both, before May 15, 1981; and,
(v) Achieve final compliance, determined in accordance
with §XX.9350, before July 1, 1981.
The owner or operator of a source of volatile organic com-
pounds subject to this regulation may submit to the Direc-
tor, and the Director may approve, a proposed alternative
compliance schedule provided:
38
-------
(1) ,The proposed alternative compliance schedule is sub-
mitted before September 15, 1980;
(2) The owner or operator provides information showing the
need for an alternative schedule;
(3) The alternative compliance schedule contains increments
of progress;
(4) Sufficient documentation and certification from appro-
priate suppliers, contractors, manufacturers, or fabri-
cators is submitted by the owner or operator of the
volatile organic compound source to justify the dates
proposed for the increments of progress; and,
(5) Final compliance is achieved as expeditiously as pos-
sible and before the photochemical oxidant attainment
date.
The owner or operator of a volatile organic compound source
subject to a compliance schedule of this section shall
certify to the Director within 5 days after the deadline for
each increment of progress, whether the required increment
of progress has been met.
i
5.2 INDUSTRY REACTION AND COMMENTS ON COMPLIANCE SCHEDULE
The flat wood finishing industry has participated in the
review of proposed VOC regulations within the last several years,
and has thus had the opportunity to review and comment on the
emission limits as they were being developed. Coatings suppliers
have also participated in the process. The result of the indus-
try participation is that, with some exceptions, the industry
accepts the proposed compliance schedule for the emission limits
stated.
PEDCo contacted representatives at all the paneling coating
plants in the survey. About half of the plant representatives
contacted said that the compliance schedule as written is realis-
tic. Some of these added that costs for compliance might be high
for some plants, however, mainly because of the need to purchase
and install new ovens.
About one-third of the plant representatives who commented
on the compliance schedule said that they thought it was realis-
tic, but with some qualifications. Some stipulated that it would
39
-------
depend on whether the coatings suppliers could meet the demand,
particularly for low-solvent, water-based coatings. Several fin-
ishers commented that the schedule is easier to meet in some
plants than others. They emphasized that each plant is different
and that coating suppliers must develop products for each line
because of differences in wood substrate, equipment type and age,
and amounts of coatings to be applied in various coating lines.
Some plants apply more coatings than other plants; decreasing
coating thickness may adversely affect product quality- Some
finishers thought that the schedule was realistic for printed
lauan, but that it might take more time for hardboard and parti-
cle board.
About 17 percent of the plant representatives who commented
on the compliance schedule said that 2 years was too short a time
for conversion to water-based coatings. Some plants have taken 3
to 4 years (sometimes longer) to convert to a water-based system,
because many trials and adjustments are necessary before accept-
able products are found for a particular plant. The time should
decrease, however, as suppliers expand the water-based coating
technology.
The most common response about the compliance schedule was
that most plants could meet it if they spent enough money and ef-
fort. The plant would also have to be committed to making the
changes within the allowable time frame.
40
-------
SECTION 6
ENFORCEMENT OF PROPOSED REGULATIONS
6.1 PROBLEMS IN MATCHING RACT AND PROCESSES: INDUSTRY COMMENT
Conversion to low-solvent, water-based coatings is the most
commonly chosen RACT option in the flat wood paneling industry.
Ultraviolet- and electron-beam-curable coating are increasing in
use at a slower rate. Incinerators are quite limited in use at
this time. Most of the industry comments about experiences with
RACT options, therefore, concern water-based coatings. Table 12
summarizes the comments about the control options.
Like most materials changes in an industry, conversion to
water-based coatings involves a period of experimentation during
which suitable coatings must be developed. Although many of the
earlier problems (see Section 4.3) have been solved, problems
still arise whenever a new coating is tried in a plant. Coatings
suppliers and coating plants must experiment until a satisfactory
finish is obtained for a particular line. A water-based filler
that works on one line may not work on another because of differ-
ences in wood substrate, equipment, and other coatings used. The
time and money required to develop coatings for a particular line
is a substantial problem in the use of water-based coatings.
Flat wood finishers most frequently commented that water-
based coatings are more difficult to dry, requiring more heat,
longer drying times, or different types of ovens. New ovens, a
considerable capital expense, might be required in some plants.
Another option is to slow down the line that decreases produc-
tivity.
The second most frequent comment about water-based coatings
concerned their tendency to raise the grain in the wood, due to
41
-------
TABLE 12. PANELING INDUSTRY PROBLEMS WITH VOC CONTROL METHODS
Control method
Problem
Water-based coatings
Ultraviolet- and electron-
beam-curable coatings
Incineration
Experimentation period required for conversion
Increased oven capacity required for drying and
curing
Grain raising; more buffing required
Metal equipment parts must be modified to
minimize corrosion
Changes in rolls may be necessary
Costs
Coatings must be protected from freezing
Lack of adhesion to other coatings
Cost
Cost
42
-------
the waiter swelling the fibers. Grain raising is particularly
troublesome on fiberboard and particle board. The finish is not
as smooth and may need sanding or buffing. The water-based coat-
ing on particle board and fiberboard may have to be thicker; more
coating must be used, resulting in more emissions.
Besides the new ovens, conversion to water-based coatings
requires several lesser modifications. Plates, trays, and other
metal parts that come into contact with the water-based coating
must be covered with a metal that will resist corrosion. Stain-
less steel and cadmium have been used. The rolls (on the roll-
coaters) may need to be changed more often. Changes may also be
necessary in pump and bearing materials.
Several finishers commented that the profit margin in panel
finishing is small, and that small finishers cannot afford large
capital outlays for new ovens and other equipment changes.
Water-based and solvent-based coatings have different han-
dling and storage requirements. Water-based coatings are far
more susceptible to freezing, and they must be stored in a heated
area in cold climates. Solvent-based coatings are more of a fire
hazard, and must be stored away from plant operations. Explo-
sion-proof equipment is also needed for solvent materials, but
not for water-based coatings.
One finisher commented that the flame spread rating on his
panels was less desirable when using water-based coatings. Other
finishers reported no change in flame spread rating.
Mixed comments were made about the cost, mileage, and dura-
bility of the different coatings. Some users stated that price
per gallon was greater for water-based coatings, while others
said that the prices were comparable. Some finishers expected
solvent coatings to become more expensive as petroleum prices
increase. Mileage derived from water-based coatings was greater
for some users and less for others. Some finishers reported that
water-based coatings are harder and more durable than solvent-
based coatings, as long as they are cured completely. Other
finishers disagreed.
43
-------
Although use of ultraviolet- and electron-beam-curable coat-
ings is expected to increase in the future, there are impedi-
ments to their widespread use at this time. First are the tech-
nical problems of adhesion to radiation-cured coatings. This
situation will improve as coating suppliers advance the technol-
ogy in this area. The second impediment is price. Both the
coatings and the equipment used to cure them are expensive. The
finishers at the plant visited are pleased with the results of
their radiation-cured coatings, and they plan to expand their
operations. Speed of curing was cited as one advantage.
Most finishers who commented on incineration said that it
was not a desired option. Incinerators are expensive, and the
finishers prefer to work with water-based coatings. The one
plant that had an afterburner used conventional solvent coatings.
Incineration is not expected to gain acceptance as a means of
reducing VOC emissions.
6.2 FACTORS AFFECTING ENFORCEMENT
Most of the finishers visited stated that they have been
converting to water-based coatings wherever possible; as a result,
many plants have reduced VOC emissions significantly over the
last decade. The reduction in fumes—bringing greater worker
comfort and lessening the fire hazard—is a compelling reason for
the conversion. It is reasonable, therefore, to expect the trend
to continue. Most finishers stated that they could meet or near-
ly meet the emission limits within the 2 years allowed for com-
pliance. Particle board finishers may have trouble meeting the
limits because this product requires heavier coatings. The in-
dustry as a whole, however, should be able and willing to meet
the standards for VOC.
Enforcement efforts should be minimal. The number of fin-
ishers is small (57), and few plants are located in nonattainment
areas. The advantages of conversion to water-based coatings will
aid the enforcement effort.
44
-------
Plants in California are generally ahead of other plants
with respect to VOC emission reduction. California has had VOC
regulations for several years, and the current regulations (for
1981) are more strict than those in the EPA guideline document.
Enforcement in that State should be easier than elsewhere.
The guidance document states (page 56) that plants are to
show compliance with emission limits by following specified VOC
emission test procedures, or by submitting a "composition of the
o
coating, if supported by actual batch formulation records." It
is a straightforward task to compute VOC emissions, given the
percentages of solids and volatiles and the amount of solvent
used. Use of plant records to determine compliance or noncom-
pliance may create a legal problem in some states, such as Cal-
ifornia. This problem should be evaluated by DSSE.
Few add-on controls will be encountered in the paneling
finishing industry. The guidance document specifies that moni-
toring is required for add-on control equipment (page 56).
Incinerators must have continuous monitors for exhaust gas tem-
perature, and catalytic incinerators must have continuous moni-
tors measuring temperature rise. (Carbon adsorption beds are not
currently used by the industry.) The guidance document also says
(page 58) that recorders should be used at "larger installations,"
or those emitting 100 tons or more of VOC per day. If this
provision is adopted into state laws, continuous monitors will
only be installed on larger plants. Enforcement effort will be
minimal in this area.
Particulate emissions are generated from the sanders used in
the finishing operations. In all the plants visited, the par-
ticulates were ducted in an enclosed system to cyclones and/or
baghouses. Collection efficiencies were more than 90 percent.
The particulates tend to be large particles that are easy to
collect and that settle out of the air quickly. Because of these
controls, the plants visited were relatively dust-free. Further,
75 percent of the coating plants are located in attainment areas
45
-------
for particulates. Enforcement efforts for particulate emissions
will be largely confined to those plants having adequate collec-
tion systems.
The applicability section of the guidance document lists
2
(page 49) the products covered by the regulations. They are:
Printed interior panels made of hardwood, plywood, and thin
particle board
Natural-finish hardwood plywood panels
Hardboard paneling with Class II finishes
Products not covered are exterior siding, tile board, or particle
board that is used as a furniture component.
Paper and vinyl laminated products are not covered, and the
survey of paneling coaters did not include these products. A few
of the wood paneling finishing plants visited were also making
vinyl and paper overlay panels. These panels closely resemble
the printed panels, and may be made in the same plants on the
same lines. Paper-laminated panels may have a groove coat and a
topcoat application similar to the wood panels. An adhesive is
also used to laminate the paper to the board. Vinyl-laminated
panels do not usually have a topcoat.
It would be reasonable to include these operations in the
regulations because they are so similar to wood panel finishing.
Emissions are expected to be lower because no fill coats, base
coats, or printing inks are used. The adhesives, groove coats,
and topcoats that are used would be sources of VOC emissions. A
water-based topcoat, with few emissions, was used at one plant
that was visited.
6.3 RECOMMENDATIONS
Emissions of VOC from factory surface coating of flat wood
paneling are being reduced by the gradual conversion to water-
based coatings. The 57 plants located in our survey emitted a
total of about 11,000 tons/year from coating operations. The
DSSE should rank the magnitude of these emissions, and thus
46
-------
determine their relative importance, in relation to the other in-
dustries for which VOC emission guidelines have been written.
A small enforcement effort is expected, for the following
reasons:
The small number of plants in nonattainment areas
The relatively small amounts of VOG and TSP emissions from
the industry
The reduction of VOC emissions due to conversion to water-
based coatings
The slow growth of the industry
Vinyl and paper laminated panels are not included among the
applicable products covered in the EPA guidance document. It is
reasonable to include the paper and vinyl laminated panels under
the same regulations as the printed interior panels because they
are often made in the same plants and with similar coatings. The
list of coaters in the appendix does not include those who re-
sponded only as paper or vinyl laminators. If these plants are
later included in the regulations for wood paneling coating, the
survey would have to be expanded to include them.
47
-------
REFERENCES
1. Control of Volatile Organic Emissions From Existing Sta-
tionary Sources - Volume VII: Factory Surface Coating of
Flat Wood Paneling. EPA-450/2-78-032, OAQPS No. 1.2-112,
June 1978.
2. U.S. Environmental Protection Agency. Guidance to State and
Local Agencies in Preparing Regulations To Control Volatile
Organic Compounds From Ten Stationary Source Categories.
EPA-450/2-79-004, 1979.
3. Directory of Panel Plants - USA. Forest Industries, April
1979.
4. U.S. Department of Commerce. Bureau of Census. County
Business Patterns. U.S. Government Printing Office, Wash-
ington, D.C., 1976 and 1977.
5. Directory of Hardwood Plywood Prefinish Industry. Hardwood
Plywood Manufactures Association. Reston, Virginia, Septem-
ber 19, 1979.
6. U.S. Department of Commerce. Bureau of Census. Compliance
Data System. Quick Look Report. SIC 2435 and 2492. Novem-
ber 28, 1979.
7. U.S. Department of Commerce. Bureau of Census. 1977 Census
of Manufactures. Vol. II, Industry Statistics, Part I. SIC
2000-2600, 2435, 2436, 2492, 2499.
8. Hardboard Plants in the United States. American Hardboard
Association. Park Ridge, Illinois, October 1979.
9. Guidance for Lowest Achievable Emission Rates From 18 Major
Stationary Sources of Particulate, Nitrogen Oxides, Sulfur
Dioxide, or Volatile Organic Compounds. Prepared for U.S.
Environmental Protection Agency by PEDCo Environmental,
Inc., under Contract No. 68-01-4147, April 1979.
10. Panel Outputs in '77 Reflected Rebounds, Some New Records.
Forest Industries, 105(3) : 26-32, 1978.
11. Panel Products Shared in the Remarkable Market of 1978.
Forest Industries, 106(4):34-38, 1979.
48
-------
12. Farnsworth, E. What's New in Finishing? Wood and Wood
Products, 82(12), December 1977.
13. Changes Swirl Over the Coatings World. Chemical Week, June
14, 1978.
14. EB Curing Goes Commercial. Wood and Wood Products, 82(5):65-
66, 1977.
15. Blackman, T. Electron Beam System Cures Coated Particle-
board Panels. Forest Industries, 105 (3):70-71, 1978.
16. Attainment Status Designations. 40 CFR 81 Sect. 107.
December 7, 1979.
49
-------
APPENDIX A
TABULAR DATA ABOUT
FLAT WOOD PANELING PLANTS
51
-------
TABLE A-l. DIRECTORY OF FLAT WOOD PANELING PLANTS
WITH SURFACE COATING OPERATIONS
Plant name and address
County
Located in attainment area
16
for VOC (03)
for TSP
Region I
Weyerhaeuser Co.
Wood Products Division
Hancock, VT 05748
Region II
Predco Precision Panels
3900 River Road
Pennsauken, NJ 08110
U.S. Veneer Co., Inc.
888 Longfellow Avenue
Bronx, NY 10474
Region III
Masonite Corporation
Box 311
Towanda, PA 18848
Champion Building Products
Highway 304, Drawer 250
South Boston, VA 24592
Lane Co., Inc., The
E. Franklin Street
AltaVista, VA 24517
Masonite Corporation
Box 378
Waverly, VA 23890
Plywood Panels, Inc.
3747 Village Avenue
Norfolk, VA 23502
U.S. Gypsum Co.
Box 3327
Danville, VA 24541
Weyerhaeuser Co.
Box 1188, 201 Dexter St. W
Chesapeake, VA 23324
Addison
Camden
Bronx
Bradford
Halifax
Campbel1
Sussex
No
No
No
No
Yes
Yes
Yes
No
Yes
No
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
52
-------
TABLE A-l (continued)
Plant name and address
County
Located in attainment area
16
for VOC (03)
for TSP
Region IV
Champion Home Builds Co.
Box 248
Plains, GA 31780
Georgia-Pacific Corp.
Box 386
Monticello, GA 31064
Georgia-Pacific Corp.
Box 367
Savannah, GA 31402
Jasper-American Mfg. Co.
Box 378, Priesh Rd.
Henderson, KY 42420
Masonite Corp.
Box 488
Laurel, MS 39440
Abitibi Corp.
Box 98
Roaring River, NC 28669
Broyhill Industries
Pacemaker Division
Lenoir, NC 28645
Georgia-Pacific Corp.
Southern Division
Box 950
Whiteville, NC 28472
Masonite Corp.
Fiberboard Div.
Box 369
Spring Hope, NC 27882
Vanply, Inc.
Prefinished Prod. Div.
Box 8289
900 N. Hoskins Rd.
Charlotte, NC 28208
Sumter
Jasper
Chatham
Henderson
Jones
Wilkes
Caldwell
Columbus
Nash
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Mecklenburg No
Yes
Yes
No
No
No
Yes
Yes
Yes
Yes
Yes
53
-------
TABLE A-l (continued)
Plant name and address
Region IV (continued)
Champion Bldg. Products
Div. of Champion Int1 1.
238 E. Bay Street
Charleston, SC 29403
Champion Bldg. Products
Div. of Champion Int'l.
Box 1087, 5 Chop Road
Orangeburg, SC 29115
International Paneling Prod., Inc.
Box 7031, North Station
705 Corrine Avenue
Memphis, TN 38107
Region V
Abitibi Corporation
416 Ford Avenue
Alpena, MI 49707
Iron Wood Products
Yale Avenue
Bessemer, MI 49911
Superwood Corporation
Box 6267
Duluth, MN 55806
Abitibi Corporation
Building Prod. Div.
2900 Hill Avenue
Toledo, OH 43607
Eggars Plywood Co.
1819 E. River St.
Two Rivers, WI 54241
Pluswood, Inc.
11450 Oshkosh Avenue
Oshkosh, WI 54903
Superior Fiber Products
Box 365
Superior, WI 54880
County
Charlestor
Orangeburc
Shelby
Alpena
Gogebic
St. Louis
Lucas
Manitowoc
Winnebago
Douglas
Located in attainment area
for VOC (03)
i No
i Yes
No
Yes
Yes
Yes
No
Yes
Yes
No
for TSP
No
Yes
Yes
Yes
Yes
No
Yes
Yes
No
No
54
-------
TABLE A-l (continued)
Plant name and address
Region V (continued)
Superwood Corporation
P.O. Box 138
Phillips, WI 54555
Warvel Products, Inc.
Box 266, 160 Park Street
Gillett, WI 54124
Region VI
Singer Co. , The
Main Street
Trumann, AR 72472
Superwood Corporation
Box 3151, Hwy. 130
N. Little Rock, AR 72117
AFCO Industries
Box 5085, 3400 Roy Avenue
Alexandria, LA 71301
Plywood Paneling Co.
100 Napolean Avenue
New Orleans, LA 70130
Ponderosa Products
Box 25506
1701 Bell amah Avenue N.W.
Albuquerque, NM 87125
Champion Building Prod.
Div. Champion International
Box 186, 3902 Port Industrial Rd.
Galveston, TX 77551
Region VII
Region VIII
Louisiana-Pacific
Intermountain Div.
Box 407, 3300 Raser Dr.
Missoula, MT 59806
County
Price
Oconto
Poinsett
Pulaski
Rap ides
Orleans
Bernalill
Galveston
Missoula
Located in attainment area
for VOC (03) for TSP
Yes Yes
Yes Yes
No Yes
No Yes
Yes Yes
No Yes
o No No
No No
Yes No
55
-------
TABLE A-l (continued)
Plant name and address
County
Located in attainment area
16
for VOC (OJ
for TSP
Region IX
Collins Pine Co.
Box 796
Chester, CA 96020
Davidson Panel Co.
1551 E. Babbit Avenue
Anaheim, CA 92805
Forest Products
4315 Dominguez Rd.
Rocklin, CA 95677
Masonite Corporation
Hardboard Div.
300 Ford Rd.
Ukiah, CA 95482
National Plywood, Inc.
Box 9340
2870 El. Presidio Street
Long Beach, CA 90810
Pacific Finishing Co.
Box 474, 16200 Illinois Avenue
Paramount, CA 90723
Western States Plywood
12848 E. Firestone Blvd.
Santa Fe Springs, CA 90670
Weyerhaeuser Co.
11355 Arrow Hwy.
Rancho Cucamonga, CA 91730
Region X
Champion Home Builders Co.
Weiser Prod. Div.
Box 551
Weiser, ID 83672
Champion Building Prod.
Div. Champion Int'l.
Box 1166
Hood River, OR 97031
Plumas
Orange
Nevada
Mendocino
Yes
Yes
Yes
Yes
Los Angeles No
Los Angeles No
Los Angeles No
San Bernadino No
Washington Yes
Hood River Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
No
Yes
Yes
56
-------
TABLE A-l (continued)
Plant name and address
Region X (continued)
Champion Building Prod.
Div. Champion Int'l.
Box 547
Lebanon, OR 97355
Evans Products Co.
Fiber Products Group
Box E, 1115 S.W. Crystal Lake Dr.
Corvallis, OR 97330
Georgia-Pacific Corp.
Box 869
Coos Bay, OR 97420
Roseburg Lumber
Plants #1 and #2
Oil lard, OR 97432
(Mailing address: Box 1088
Roseburg, OR
97470
States Veneer Co.
Box 7037, 95 Foch St.
Eugene, OR 97401
Weyerhaeuser Co.
Box 9
Klamath Fall, OR 97601
Willamette Industries
Duraflake Div.
Box 428
Albany, OR 97321
Vanport Industries
Box 1089, 8th St.,
Terminal #2
Vancouver, WA 98666
County
Linn
Benton
Coos
Douglas
Lane
Klamath
Linn
Clark
Located in attainment area
for VOC (03)
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
for TSP
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
57
-------
TABLE A-2. FLAT WOOD PANELING PLANTS WITH
SURFACE COATING OPERATIONS
Region I
Vermont
Region II
New Jersey
New York
Region III
Pennsylvania
Virginia
Region IV
Georgia
Kentucky
Mississippi
North Carolina
South Carolina
Tennessee
Region V
Michigan
Minnesota
Ohio
Wisconsin
Region VI
Arkansas
Louisiana
New Mexico
Texas
Region VII
Region VIII
Montana
Region IX
California
Region X
Idaho
Oregon
Washington
Total
Hardwood
plywood
1
1
1
3
2
1
2
1
1
2
2
1
6
1
1
1
27
Particle
board
2
1
1
1
1
1
1
2
10
Hardboard ,
panel board3
1
1
1
1
3
1
1
1
3
1
1
5
20
Production (No. of companies)
>200 million
~ ftz/yr
1
1
1
1
1
1
5
2
13
<200 million
ft2/yr
1
1
1
5
2
1
1
5
1
1
1
1
5
2
2
1
1
1
3
1
6
1
44
Medium density fiberboard.
58
-------
TABLE A-3. SUMMARY OF PANEL PLANT INFORMATION SUPPLIED
IN FOREST INDUSTRIES MAGAZINE (APRIL 1979)
Region I
Maine
New Hampshire
Vermont
Region II
New Jersey
New York
Region III
Pennsylvania
Virginia
West Virginia
Region IV
Alabama
Florida
Georgia
Kentucky
Mississippi
North Carolina
South Carolina
Tennessee
Region V
Indiana
Michigan
Minnesota
Wisconsin
Region VI
Arkansas
Louisiana
New Mexico
Oklahoma
Texas
Region VII
Region VIII
Montana
Region IX
California
Region X
Idaho
Oregon
Washington
Total
Hardwood
plywood
Coat
1
1
2
1
2
1
2
1
1
1
12
No coat
1
1
2
1
1
1
7
1
4
1
5
2
2
21
12
5
4
2
3
12
3
1
2
7
2
3
3
110
Partlclt
board
Coat
2
1
1
1
1
1
1
2
10
No coat
1
1
4
3
4
1
1
1
1
1
1
3
1
1
3
6
1
8
1
43
Hardboard,
fiber-board
Coat
1
1
1
1
3
1
1
2
1
1
5
18
No coat
1
1
1
1
2
2
1
2
1
1
1
1
2
4
1
22
Production (No. of companies)
>200 million
ft2/yr
1
1
1
1
1
2
1
1
2
11
<200 million
ft2/yr
1
1
3
1
2
2
9
1
7
1
9
1
6
19
11
6
3
4
3
15
4
5
2
4
2
14
3
18
5
162
Not
known
1
5
2
2
2
8
5
1
1
2
3
2
1
2
2
3
42
59
-------
TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing]
REPORT NO.
2.
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
Enforceability Aspects of RACT for Factory Surface
Coating of Flat Wood Paneling
5. REPORT DATE
1QRD
M4
-ORMII
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
Catherine E. Jarvis, Cathie L. Gardinier,
Thomas C. Ponder. Jr.
8. PERFORMING ORGANIZATION REPORT NO.
P/N 3570-3-L
9. PERFORMING ORGANIZATION NAME AND ADDRESS
PEDCo Environmental, Inc.
11499 Chester Road
Cincinnati, Ohio 45246
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-01-4747. Task No. 129
12. SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental Protection Agency
Division of Stationary Source Enforcement
Washington, D.C. 20460
13. TYPE OF REPORT AND PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
DSSE Project Officer: John R. Busik, EN-341, (202) 755-2560
16. ABSTRACT
Revised State Implementation Plans must include controls for emissions of
volatile organic compounds (VOC's) from factory surface coating of flat wood paneling.
This report identifies 57 coaters to which the VOC regulations apply. Sixty-one per-
cent of these plants are located in attainment areas for oxidants; 75 percent are in
attainment areas for particulates. According to information from coating suppliers,
factory surface costing of flat wood paneling emitted a total of 11,000 tons VOC's in
1978. Emissions in 1970 were estimated at 34,000 tons VOC's. These figures show an
emission reduction of approximately 70 percent with a production decrease of 15 per-
cent.
Methods currently used to control VOC emissions are: use of water-based coatings,
use of ultraviolet-curable and electron-beam curable coatings, and incineration. Use
of water-based coatings, the most widely applied method, is significantly reducing VOC
emissions.
Enforcement of standards for coating plants in the paneling industry is not ex-
pected to require a major effort due to the small number of plants, the relatively
small amounts of VOC and TSP emissions, the increasing use of water-based coatings,
and the slow growth of the industry.
17.
KEY WORDS AND DOCUMENT ANALYSIS
a.
DESCRIPTORS
^IDENTIFIERS/OPEN ENDED'TERMS c. cos ATI Field/Group
Air Pollution Control
Organic Compounds
Coatings
Wood Products
Volatile Organic Com-
pounds (VOC's)
Oxidants
Surface Coatings
Flat Wood Paneling
13B
07C
11C
111
18. DISTRIBUTION STATEMENT
Unlimited
:fPA Form ZiJi- 1 • ' 3)
19. SECURITY CLASS (This Report)
Unclassified
2). NO. OF PAGES
66 p.
20. SECURITY CLASS (Thispage)
Unclassified
22. PRICE
------- |