EPA-450/3-78-006
April 1978
          STUDY TO SUPPORT
 NEW SOURCE PERFORMANCE
   STANDARDS FOR SURFACE
          COATING OF METAL
                   FURNITURE

  U.S. ENVIRONMENTAL PROTECTION AGENCY
      Office of Air and Waste Management
    Office of Air Quality Planning and Standards
   Research Triangle Park, North Carolina 27711

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                                   EPA-450/3-78-006
          STUDY TO SUPPORT
     NEW  SOURCE PERFORMANCE
STANDARDS FOR SURFACE COATING
         OF METAL FURNITURE
                      by

                Springborn Laboratories, Inc.
                 Enfield, Connecticut 06082
                 Contract No. 68-02-2075
              EPA Project Officer: Vera N. Gallagher
                    Prepared for

           U.S. ENVIRONMENTAL PROTECTION AGENCY
              Office of Air and Waste Management
            Office of Air Quality Planning and Standards
            Research Triangle Park, North Carolina 27711

                    April 1978

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This report is issued by the Environmental Protection Agency to report
technical data of interest to a limited number of readers.  Copies are
available free of charge to Federal employees, current contractors and
grantees, and nonprofit organizations - in limited quantities - from the
Library Services Office (MD-35), U.S. Environmental Protection Agency,
Research Triangle Park, North Carolina 27711; or,  for a fee, from the
National Technical Information Service, 5285 Port Royal Road, Springfield,
Virginia 22161.
This report was furnished to the Environmental Protection Agency by
Springborn Laboratories, Inc. , Enfield, Connecticut, in fulfillment
of Contract No. 68-02-2075.   The  contents of this report are reproduced
herein as received from Springborn Laboratories, Inc.  The opinions,
findings, and conclusions expressed are those of the author and not
necessarily those of the Environmental Protection Agency.  Mention of
company or product names is not  to be considered as an endorsement
by the Environmental Protection Agency.
                     Publication No. EPA-450/3-78-006
                                 11

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                                CONTENTS
2.   INTRODUCTION	     2-1

2.1.      AUTHORITY FOR THE STANDARDS	     2-1

2.2.      SELECTION OF CATEGORIES OF STATIONARY SOURCES  ....     2-4

2.3.      PROCEDURE FOR DEVELOPMENT OF STANDARDS
         PERFORMANCE	     2-6

2.4.      CONSIDERATION OF COSTS	     2-8

2.5.      CONSIDERATION OF ENVIRONMENTAL IMPACTS	     2-9

2.6.      IMPACT ON EXISTING SOURCES	     2-10

3.   THE METAL FURNITURE INDUSTRY	     3-1

3.1.      GENERAL DESCRIPTION	     3-1

3.2.      PROCESSES OR FACILITIES AND THEIR EMISSIONS	     3-5

3.2.1.     The Basic Processes	     3-5

3.2.1.1.   Spray Coating	     3-5

3.2.1.2.   Dip Coating	     3-10

3.2.1.3.   Flow Coating	     3-13

3.2.2.     Equipment Characteristics	     3-14

3.2.3.     Emission Characteristics	     3-15

3.2.4.     Parameters Affecting Emissions	     3-17

3.3.      REFERENCES	     3-19

4.   EMISSION CONTROL TECHNIQUES	     4-1

4.1.      THE ALTERNATIVE EMISSION CONTROL TECHNIQUES	     4-1

4.1.1.     Powder Coating	     4-1

4.1.1.1.   Electrostatic Spray	     4-3

4.1.1.2.   Fluidized Bed	     4-12

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CONTENTS (Continued - 2)
4.1.2.    Water-Borne Coatings	     4-14

4.1.2.1.   Electrodeposition	     4-15

4.1.2.2.   Water-Borne Spray	     4-22

4.1.2.3.   Water-Borne Dip	     4-24

4.1.2.4.   Water-Borne Flow Coating	     4-24

4.1.3.    Higher Solids Coating	     4-25

4.1.4.    Carbon Adsorption	     4-27

4.1.5.    Incineration	     4-34

4.1.5.1.   Thermal Incinerators	     4-34

4.1.5.2.   Catalytic Incineration	     4-39

4.2.      EMISSION REDUCTION PERFORMANCE OF CONTROL
         TECHNIQUES	     4-42

4.2.1.    Powder Coating - Electrostatic Spray	     4-43

4.2.2.    Powder Coating - Fluidized Bed	     4-43

4.2.3.    Electrodeposition of Water-Bornes	     4-43

4.2.4.    Water-Borne Spray	     4-44

4.2.5.    Water-Borne Dip and Flow Coatings	     4-46

4.2.6.    Higher Solids Coatings	     4-47

4.2.7.    Incineration	     4-49

4.2.8.    Carbon Adsorption	     4-49

4.3.      REFERENCES	     4-50

5.  MODIFICATION AND RECONSTRUCTION	     5-1

5.1.      POTENTIAL MODIFICATIONS	     5-2

5.2.      RECONSTRUCTION	     5-5

5.3.      CONSTRAINTS	     5-5

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CONTENTS (Continued -3)
5.4.      REFERENCES	     5-7



6.   EMISSION CONTROL SYSTEMS	     6-1




6.1.      ALTERNATIVE A-2	     6-4



6.2.      ALTERNATIVE A-3	     6-4



6.3.      ALTERNATIVE A-4	     6-4



6.4.      ALTERNATIVE A-5	     6-7



6.5.      ALTERNATIVE B-2	     6-7



6.6.      ALTERNATIVE B-3	•	     6-11



6.7.      ALTERNATIVE B-4	     6-11



6.8.      ALTERNATIVE B-5	     6-11



6.9.      ALTERNATIVE B-6	     6-11



6.10.     REFERENCES	     6-14



7.   ENVIRONMENTAL IMPACT	     7-1



7.1.      AIR POLLUTION IMPACT	     7-1



7.1.1.     State Regulations and Controlled Emissions	     7-3



7.1.2.     Uncontrolled and Controlled Emissions (Alternatives)	     7-5



7.1.2.1.   Spray Coating	     7-5



7.1.2.2.   Dip Coating	     7-6



7.1.2.3.   Estimated Hydrocarbon Emission Reduction in Future Years  ....     7-10



7.2.      WATER POLLUTION IMPACT	     7-17



7.3.      SOLID WASTE DISPOSAL IMPACT	     7-18



7.4.      ENERGY IMPACT	     7-20



7.5.      OTHER ENVIRONMENTAL IMPACTS	     7-23



7.6.      OTHER ENVIRONMENTAL CONCERNS	     7-23



7.6.1.     Irreversible and Irretrievable Commitment of Resources	     7-23

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CONTENTS (Continued -4)


                                                                           Page

7.6.2.    Environmental Impact of Delayed Standards	     7-23

7.6.3.    Environmental Impact of No Standards	     7-24

7.7.      REFERENCES	     7-25

8.   ECONOMIC IMPACT	     8-1

8.1.      INDUSTRY ECONOMIC PROFILE	     8-1

8.1.1.    Introduction	     8-1

8.1.2.    Industry Size	     8-1

8.1.3.    Industry Growth:  Past and Projected	     8-7

8.1.4.    Industry Structure	     8-12

8.1.5.    Channels of Distribution	     8-16

8.1.6.    Industry Markets	     8-17

8.1.7.    Labor and  Materials Costs	     8-17

8.1.8.    Financial Performance	     8-21

8.1.9.    Imports and Exports	     8-21

8.1.10.   Geographic Distribution	     8-24

8.2.      COST ANALYSIS OF ALTERNATIVE EMISSION CONTROL
         SYSTEMS    	     8-27

8.2.1.    Cost Effectiveness Summarized - New Facilities	     8-29

8.2.2.    Reconstructed Facilities	     8-35

8.2.3.    Water Pollution and Solid Waste Disposal	     8-38

8.3.      REFERENCES	     8-39

9.   RATIONALE FOR THE PROPOSED STANDARDS	     9-1

9.1.      SELECTION OF SOURCE FOR CONTROL	     9-1

9.2.      SELECTION OF POLLUTANTS AND AFFECTED FACILITIES ....     9-2

9.3.      SELECTION OF THE BEST SYSTEM OF  EMISSION
         REDUCTION CONSIDERING COSTS	     9-9

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CONTENTS (Continued 5)
9.4.      SELECTION OF THE FORMAT OF THE PROPOSED
         STANDARD	     9-10

9.4.1.    Concentration - Airborne Emissions	     9-10

9.4.2.    Mass/Time - Airborne Emissions	     9-10

9.4.3.    Equipment Standard - Airborne Emissions	     9-11

9.4.4.    Mass of Emissions/Unit of Coating Material Consumed	     9-11

9.5.      SELECTION OF EMISSION LIMITS
         (To be prepared by EPA)

9.6.      VISIBLE EMISSION STANDARDS
         (To be prepared by EPA)

9.7.      MODIFICATION/RECONSTRUCTION CONSIDERATION	     9-14

9.7.1.    Potential Modifications	     9-15

9.7.2.    Substitution of Equipment	     9-17

9.7.3.    Reconstruction	     9-18

9.7.4.    Constraints	     9-18

9.8.      SELECTION OF MONITORING REQUIREMENTS
         (To be prepared by EPA)

9.9.      SELECTION OF PERFORMANCE TEST METHODS
         (To be prepared by EPA)


APPENDIX A.   -   EVOLUTION OF PROPOSED STANDARDS                   A-l

APPENDIX B.  -   INDEX TO ENVIRONMENTAL IMPACT CONSIDERATIONS     B-l
Listing of Tables and Figures follows.

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                        LIST OF TABLES AND FIGURES
TABLES

3-2.       Metal Furniture Trends and Projections in Thousand Dollars             3-3
          at Constant Price (1972)

3-3.       Metal Furniture Establishments                                       3-4

3-4.       Material Balance Metal Furniture Electrostatic Spray Coating           3-8

3-5.       Energy Balance Metal Furniture Coating Process                       3-10

3-6.       Material Balance Metal Furniture Dip Coating                         3-11

3-7.       Energy Balance Dip Coating Metal Furniture                           3-13

3-8.       Average Emissions for the Metal Furniture Finishing Process            3-16
          Liters of Solvent Per 1000 Square Meters (Gallons of Solvent
          Per Square Foot)


4-1.       Examples of Metal Furniture Finishing with Powder Coatings            4-5

4-2.       Overall Weight Percent of Powder Utilized                             4-9

4-3.       Water-Borne Coatings                                                4-16

4-4.       Electrodeposition in the Metal Furniture Industry                       4-17

4-5.       Problem Solvents for Carbon Adsorption                               4-30

4-6.       Percent Emission Reduction for Water-Borne  Coatings Applied          4-45
          by Spray Techniques

4-7.       Reduction of Organic Solvent Emissions                               4-46
          92,400 Square Meters (1,000,000 Square Feet) Sprayed at 65
          Percent Efficiency Approximately 30  Percent Volume Solids

4-8.       Percent Emission Reduction for Water-Borne  Coatings Applied          4-47
          by Dip and Flow Coating


6-1.       Metal Furniture Emission Control Systems                             6-2
          Size of Line: 3,000,000 Square Feet Coated Area Per Year

6-2.       Metal Furniture Emission Control Systems                             6-3
          Size of Line:  22,464,000 Square Feet  Coated  Area Per Year

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LIST OF TABLES AND FIGURES (Continued -2)


TABLES                                                                      Page


7-1.      Metal Furniture Painting Operation Spray Coating Hydrocarbon          7-7
         Emission Factors and Controlled and  Uncontrolled Model Plants

7-2.      Metal Furniture Painting Operation Dip Coating Hydrocarbon            7-9
         Emission Factors and Control Efficiency Controlled and Un-
         controlled Model Plants

7-3.      Comparative Effectiveness of Alternate Control Systems               7-11
         Expressed in Annual Organic Emissions Controls on a Spray
         Coating Operation Assumed Annual Penetration: 5 Percent

7-4.      Comparative Effectiveness of Alternate Control Systems               7-12
         Expressed in Annual Organic Emissions Controls on a Dip
         Coating Operation Assumed Annual Penetration: 5 Percent

7-5.      Comparative Effectiveness of Alternate Control Systems               7-13
         Expressed in Annual Organic Emission Controls on a Spray
         Coating Operation Assumed Annual Penetration: 10 Percent

7-6.      Comparative Effectiveness of Alternate Control Systems               7-14
         Expressed in Annual Organic Emissions Controls on a Dip
         Coating Operation Assumed Annual Penetration: 10 Percent

7-7.      Effectiveness of Alternate Control Systems - Year 1985                7-15
         Expressed in Annual Organic Emissions Controls on a Dip
         Coating Operation Comparative Annual Penetration:
         5 and 10 Percent

7-8.      Effectiveness of Alternative Control Systems - Year 1985               7-16
         Expressed in Annual Organic Emission Controls on a Spray
         Coating Operation Comparative Annual Penetration:
         5 and 10 Percent

7-9.      Energy Balance - On a Spray Coating Operation                         7-21

7-10.    Energy Balance on a Dip Coating Operation                            7-22


8.1-1.    Basic Industry Statistics Metal Household Furniture (SIC 2514)           8-2

8.1-2.    Basic Industry Statistics Metal Office Furniture (SIC 2522)              8-3

8.1-3.    Basic Industry Statistics Public  Building and Related                    8-4
         Furniture (SIC  2531)

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LIST OF TABLES AND FIGURES (Continued  -3)


TABLES                                                                       Page

8.1-4.     Basic Industry Statistics Metal Partitions and Fixtures (SIC 2542)        8-5

8.1-5.     Basic Industry Statistics Metal Furniture Industry (Total Figures         8-6
          for SIC 2514, 2522, 2531, 2542)

8.1-6.     Value of Metal Furniture Industry Shipments in Current and             8-8
          Constant Dollars, 1967, 1975

8.1-7.     Concentration Ratios in Metal Furniture Manufacturing                 8-13

8.1-8.     Percent of Value Added in Metal Furniture Manufacturing by            8-14
          Multiunit and Single Unit Companies, 1972

8.1-9.     Distribution by Firm Size in the Metal Furniture Industry of             8-15
          Establishments, Production Workers and Value Added by Manu-
          facture, 1972 (Share of Total, Percent)

8-1-10.    Metal Furniture Product Mix, 1963  - 1975                              8-18
          (As Percent of Value of Total Industry Shipments)

8.1-11.    Labor and Materials Costs in Metal Furniture Manufacturing             8-19
          Relative to Value of Industry Shipments

8.1-12.    Trends  in Wages and Productivity in the Metal Furniture                8-20
          Industry 1958 - 1975

8.1-13.    Metal Furniture Coating Materials Cost vs. Total Materials Cost         8-22
          and Value of Shipments, 1972 and 1967

8.1-14.    Financial Ratios  for Selected Metal Furniture Manufacturers            8-23

8.1-15.    Geographical Distribution of Establishements and Value Added by        8-25
          Manufacture, Metal Furniture Industry, 1972

8.1-16.    Geographical Distribution of Metal Furniture Industry Establish-         8-26
          ments,  1972 (In Percent of Number of Establishments)

8.2-1.     Case Codes A-l - A-7                                                 8-28

8.2-2.     Case Codes B-l - B-6                                                 8-29

8.2-3.     Alternative Cases - New Facilities  Metal Furniture - Part I              8-31

8.2-4.     Alternative Cases - New Facilities  Metal Furniture - Part II             8-32

8.2-5.     Metal Furniture Coating Solvent Emissions from Affected Facilities     8-34

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LIST OF TABLES AND FIGURES (Continued 4)



TABLES                                                                      Page

8.2-6.    Codes A.l-1 - A.l-3                                                  8-35

8.2-7.    Codes B.l-1 - B.l-3                                                  8-35

8.2-8.    Alternative Cases - Reconstructed Facilities Metal Furniture            8-36
         Parti

8.2-9.    Alternative Cases - Reconstructed Facilities Metal Furniture            8-37
         Part II


FIGURES


3-1.      Electrostatic Solvent Spray Costing System                            3-6

3-2.      Flow Diagram - Material for Electrostatic Spray Solvent-               3-9
         Borne Coating

3-3.      Flow Diagram - Material for Solvent-Borne Dip Coating                 3-12


4-1.      Schematic of Electrostatic Powder Spray Process                       4-4

4-2.      Sophisticated  Recovery System                                       4-8

4-3.      Schematic of Fluidized Bed Apparatus                                 4-13

4-4.      Typical Electrodeposition System Diagram                             4-19

4-5.      Diagram of an Activated-Carbon Adsorber System                      4-28

4-6.      Effluent Concentration Curve of Butane Vapor From an Activated       4-32
         Carbon Bed as Function of Time

4-7.      Forced-Draft  System Eliminating Solvent Vapors from Surface           4-35
         Coating Process

4-8.      Coupled Effects of Temperature and Time on Rate of                   4-38
         Pollutant Oxidation

4-9.      Schematic Diagram of Catalytic Afterburner Using Torch-Type Pre-     4-40
         heat Burner with Flow of Preheat Waste Stream Through Fan to
         Promote Mixing

4-10.    Effect of Temperature on Oxidative Conversion of Organic Vapors       4-41
         in a Catalytic Incinerator

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LIST OF TABLES AND FIGURES  (Continued -5)
FIGURES

4-11.     Emission Reduction Potential (Percent) With Use of Higher Solids       4-48
         Coatings in Place of 28 Volume Percent Solvent-Borne Paint
         (50 Percent Deposition Efficiency)


6-1.      Flow Diagram - Alternative A-2 Application of Solvent-Borne           6-5
         Coating by Electrostatic Spray Base Case with Incinerator on Oven

6-2.      Flow Diagram - Alternative A-3 Application of Solvent-Borne           6-6
         Coating by Electrostatic Spray Base Case with Carbon Adsorber
         on Spray Booth

6-3.      Flow Diagram - Base Case Alternatives A-4 and A-6 Application of      6-8
         Coating by Electrostatic Spray Conventional (Base Case), or  High
         Solids (A-4) Solvent-Borne Coatings or Water-Borne Coatings (A-6)

6-4.      Flow Diagram - Alternative A-5 Application of Powder Coating         6-9
         Electrostatic Spray

6.5.      Flow Diagram - Alternative B-2  Application of Water-Borne  Coating    6-10
         by Electrodeposition (EDP)

6-6.      Flow Diagram - Alternative B-3  Application of Solvent-Borne Dip       6-12
         Coating Base Case with Carbon Adsorber on Dip Tank

6-7.      Flow Diagram - Alternative B-4  Application of Solvent-Borne Dip       6-13
         Coating Base Case with Incinerator on Oven


8.1-1.    Real Gross National Product and Metal Furniture Industry Shipments    8-9
         in Constant Dollars, 1967 - 1975

8.1-2.    Percent Change From Previous Year in Real Gross National Product     8-10
         and Constant Dollar Metal Furniture Industry Shipments

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                               2.  INTRODUCTION

      Standards of performance are proposed following a detailed investigation of air
pollution control methods available to the affected industry and the impact of their
costs on the industry. This document summarizes the information obtained from such
a study.  Its purpose is to explain in detail the background and basis of the proposed
standards  and to facilitate analysis of the proposed  standards by interested persons,
including  those who may not be familiar with  the  many technical  aspects of  the
industry.  To obtain additional copies of this document or the Federal Register notice
of proposed standards, write to EPA Library (MD-35), Research  Triangle Park,  North
Carolina,   27711.   Specify Standards Support and Environmental Impact Statement,
Volume  1:   Proposed Standards  of  Performance  for  Surface Coating of  Metal
Furniture, document number EPA 450/3-78-006 when ordering.
2.1.   AUTHORITY FOR THE STANDARDS
      Standards of performance for new  stationary  sources are established  under
Section 111 of the  Clean Air Act (42 U.S.C. 7411), as amended, hereafter referred to
as the  Act.   Section  111  directs  the  Administrator  to establish  standards  of
performance  for any category of new stationary source of air pollution  which  "...
causes or contributes  significantly  to,  air pollution  which  may reasonably  be
anticipated to endanger public health or welfare."
      The Act requires that standards of performance for stationary sources reflect,
"... the degree of emission limitation achievable through the application of the best
technological  system of  continuous emission  reduction  . .   . the  Administrator
determines has been adequately demonstrated."  In  addition, for stationary sources
whose emissions result from fossil fuel combustion, the standard must also include a
percentage reduction in emissions.  The Act  also provides that the cost  of achieving
the  necessary  emission  reduction,  the  non-air  quality  health and environmental
impacts and  the  energy  requirements all  be  taken into account  in  establishing
standards  of performance.   The  standards  apply only to stationary  sources,  the
construction  or modification  of which commences after regulations are proposed by
publication in the Federal Register.
      The 1977 amendments to the Act altered or added numerous provisions  which
apply to the process of establishing standards of performance.
                                     2-1

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       1.  EPA is  required to list the categories  of  major stationary sources which
have  not already  been  listed  and regulated  under  standards  of  performance.
Regulations must be promulgated for these new categories on the following schedule:
       25 percent of the listed categories by August 7, 1980
       75 percent of the listed categories by August 7, 1981
      100 percent of the listed categories by August 7, 1982
A governor of a state may apply to the Administrator to add a category which is not
on the list or to revise a standard of performance.
       2.  EPA is required to review the standards of performance every four years,
and if appropriate, revise them.
       3.  EPA is  authorized to promulgate a design, equipment, work practice, or
operational standard when an emission standard is not feasible.
       4.   The term  "standards of performance"  is redefined and a  new  term
"technological  system of continuous  emission  reduction"  is  defined.    The  new
definitions clarify  that the control system  must be continuous and may include a low-
polluting or non-polluting process or operation.
       5.  The  time  between  the  proposal and promulgation  of a standard under
Section 111 of the  Act is extended to six months.
       Standards of performance, by themselves, do not  guarantee protection of
health or welfare because they  are not designed to achieve any specific air quality
levels.   Rather, they are  designed to reflect  the degree  of emission limitation
achievable through application  of the  best adequately  demonstrated  technological
system of continuous emission reduction,  taking  into  consideration  the cost of
achieving such  emission  reduction,  any  non-air  quality health and environmental
impact and energy requirements.
       Congress had  several  reasons  for  including these  requirements.   First,
standards with a degree of uniformity are  needed to avoid situations where  some
states may attract industries by relaxing standards relative to other states. Second,
stringent standards enhance the potential  for long-term  growth.   Third, stringent
standards may help achieve long-term cost savings  by  avoiding the need for more
expensive retrofitting when pollution ceilings may be reduced in the future.  Fourth,
certain types of standards for  coal  burning sources can  adversely  affect  the coal
market by driving up the price of  low-sulfur coal or effectively excluding certain
                                     2-2

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coals from the reserve base because their untreated pollution  potentials are high.
Congress does not intend that new source performance standards contribute to these
problems.  Fifth, the standard-setting process should create incentives for improved
technology.
      Promulgation of standards of performance does not prevent  state or local
agencies from  adopting more stringent  emission  limitations for the  same sources.
States are free  under Section  116  of  the  Act  to  establish even  more stringent
emission limits than those established under Section 111  or those necessary to attain
or maintain the National Ambient Air Quality Standards (NAAQS) under Section 110.
Thus, new sources may in some  cases be subject to limitations more  stringent than
standards of performance  under  Section 111, and prospective owners and operators of
new sources should be aware of this possibility in planning for such facilities.
      A similar   situation  may arise  when a  major  emitting facility  is  to  be
constructed in a  geographic area  which falls under  the  prevention  of  significant
deterioration of air quality provisions of Part C of the Act.  These provisions require,
among other things, that major emitting facilities to be constructed in  such areas are
to be subject to best available control technology.  The term "Best Available Control
Technology" (BACT), as defined in the Act, means "...  an emission limitation based
on the maximum degree of reduction of each pollutant subject  to regulation under
this Act emitted  from or  which results from  any major  emitting facility, which the
permitting authority, on a case-by-case basis, taking into account energy, environ-
mental, and economic impacts  and other costs, determines is achievable for such
facility through application of production processes and available methods, systems,
and techniques, including  fuel cleaning or treatment or innovative  fuel combustion
techniques for  control of  each such pollutant. In no event shall application of 'Best
Available Control Technology1 result in emissions of any  pollutants which will exceed
the emissions allowed  by any applicable standard established pursuant  to Section 111
or 112 of this Act."
      Although  standards  of  performance  are  normally  structured  in terms  of
numerical  emission  limits  where feasible,  alternative  approaches are  sometimes
necessary.  In some cases  physical measurement of emissions from a new source may
be  impractical  or  exorbitantly expensive.   Section  lll(h)  provides  that  the
Administrator may promulgate a design or equipment standard in  those cases where it
is not feasible to prescribe or  enforce  a standard of performance.  For example,
                                     2-3

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emissions of hydrocarbons from  storage vessels for  petroleum liquids are greatest
during tank filling.  The nature of the emissions, high concentrations for short  periods
during filling,  and  low concentrations for longer periods during storage, and the
configuration  of storage  tanks  make direct  emission  measurement  impractical.
Therefore, a more practical approach to standards of performance for storage vessels
has been equipment specification.
      In addition,  Section lll(h) authorizes  the  Administrator to grant waivers of
compliance  to  permit  a  source to  use  innovative continuous  emission  control
technology.   In order  to  grant  the  waiver,  the  Administrator must  find:  (1)  a
substantial likelihood that the  technology  will produce greater emission reductions
than the standards  require, or an equivalent reduction at lower economic, energy or
environmental cost; (2)  the proposed system has not  been adequately demonstrated;
(3)   the  technology will not cause or  contribute to  an unreasonable risk  to public
health, welfare or safety;  (4) the governor of the state where the source is  located
consents; and that,  (5)  the waiver will not prevent the attainment or maintenance of
any ambient standard.  A waiver may have conditions attached to assure the source
will not prevent attainment of any NAAQS. Any such condition will have the force of
a performance  standard.  Finally,  waivers have  definite end  dates  and  may be
terminated earlier  if the conditions  are not met or if the system fails to perform as
expected.  In such  a case, the source may be given  up to three  years to  meet the
standards, with a mandatory progress schedule.
2.2.  SELECTION  OF CATEGORIES OF STATIONARY SOURCES
      Section  111   of  the Act directs  the  Administrator  to list  categories of
stationary sources which have not been listed  before.  The Administrator, "... shall
include a category of sources in such list if in his judgement it causes, or contributes
significantly to, air pollution which may reasonably be anticipated to endanger public
health or welfare."  Proposal and promulgation of standards  of performance are to
follow while adhering to the schedule referred to earlier.
      Since passage of the Clean Air  Amendments of 1970, considerable  attention
has been given  to  the  development of a system  for assigning priorities to  various
source categories.  The approach specifies areas of interest by considering the broad
strategy of the Agency  for implementing the Clean Air Act. Often, these "areas" are
actually  pollutants  which are emitted by stationary sources. Source categories which
                                      2-4

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emit these pollutants were then evaluated and ranked by a process involving such
factors as:  (1)  the level of emission control (if any) already required by  state
regulations; (2)  estimated levels of control that might be required from standards of
performance for the source category; (3)  projections of growth and replacement of
existing facilities for the source category; and (4) the estimated incremental amount
of air pollution that could be prevented, in a pre-selected future year, by standards of
performance for the source category.  Sources for which new source  performance
standards were promulgated or are under development during 1977 or earlier, were
selected on these criteria.
       The Act amendments of August 1977, establish specific  criteria to be used in
determining priorities for all source categories not yet listed by  EPA.  These are:  (1)
the quantity of air pollutant emissions which each such category will emit, or will be
designed to emit;  (2)  the extent to which each such pollutant may reasonably be
anticipated  to  endanger  public  health or  welfare;  and  (3)   the  mobility and
competitive nature of each such category  of  sources and  the  consequent need  for
nationally applicable new source standards of performance.
       In some cases, it  may not be feasible to immediately develop a standard for a
source category with a high priority.  This might happen when a program of research
is  needed  to  develop control techniques or  because techniques  for sampling and
measuring  emissions may  require refinement.  In  the  developing of  standards,
differences in the  time required to complete the necessary investigation for different
source categories must also be considered. For example, substantially more time may
be  necessary  if numerous pollutants  must  be investigated from a  single source
category. Further, even  late in the development process the schedule  for completion
of a standard  may change.  For example, inability to obtain emission data from well-
controlled sources in time to pursue the development process in a systematic fashion
may force a change  in scheduling. Nevertheless, priority ranking is, and will continue
to be, used to  establish the  order in which  projects  are  initiated  and  resources
assigned.
       After the source category has been chosen, determining the types of facilities
within the source category to which the standard  will apply must be decided.   A
source category may have several facilities  that cause air pollution and emissions
from  some  of these facilities may  be insignificant  or very expensive to control.
                                     2-5

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Economic studies of the  source category and of applicable control technology may
show that air pollution control is better  served by applying standards to the more
severe pollution  sources.   For  this reason,  and  because  there  is no  adequately
demonstrated system for controlling emissions from certain facilities, standards often
do not apply to all facilities at a source. For the same reasons, the standards may not
apply to all air pollutants emitted. Thus, although a source category may be selected
to be covered by a standard of performance, not all pollutants or facilities within that
source category may be covered by the standards.
2.3.   PROCEDURE FOR DEVELOPMENT OF STANDARDS PERFORMANCE
      Standards of performance must: (1)  realistically reflect the best demonstated
control practice; (2) adequately consider the cost, and the non-air quality health and
environmental impacts and energy requirements of such control; (3)  be applicable to
existing sources that are modified or reconstructed as well as new installations; and
(4)  meet these conditions for all  variations of operating conditions being considered
anywhere in the country.
      The objective of a program  for development of standards is to identify the best
technological system of continuous  emission  reduction which has been  adequately
demonstrated.  The legislative history of  Section 111  and various court  decisions
make clear that the Administrator's judgement of what is adequately demonstrated is
not limited  to systems that  are in  actual routine use.  The search may include a
technical assessment of control systems which have  been adequately demonstrated
but for which there is limited operational experience.  In  most cases, determination
of the "... degree  of emission reduction achievable ..." is based on results of tests
of emissions from well controlled existing sources. At times, this has required the
investigation and measurement of emissions  from control  systems  found in other
industrialized countries that  have developed more effective systems of control than
those available in the United States.
      Since  the  best demonstrated systems  of  emission  reduction  may not be in
widespread use, the data base upon which  standards are developed may be somewhat
limited.  Test data on existing well-controlled sources are obvious starting points in
developing emission limits for new sources.  However,  since the control  of existing
sources generally represents retrofit technology or was originally designed to meet an
existing state or local regulation, new sources may be  able  to meet more  stringent
                                     2-6

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emission standards.  Accordingly, other information  must be  considered before a
judgment can be made as to the level at which the emission standard should be set.
       A process for the development of a  standard  has evolved which  takes into
account the following considerations.
       1.   Emissions from existing well-controlled sources as measured.
       2.   Data on emissions  from such sources are assessed with consideration of
such factors as:  (a) how  representative the tested source is in  regard to  feedstock,
operation, size, age, etc.; (b) age and maintenance of  the control equipment tested;
(c) design uncertainties of control equipment  being considered; and (d) the degree of
uncertainty that new sources will be able to achieve similar levels of control.
       3.   Information from pilot and  prototype installations, guarantees by vendors
of control equipment, unconstructed but contracted projects, foreign technology, and
published literature are also  considered during the standard development  process.
This is especially important for sources where "emerging" technology appears to be a
significant alternative.
       4.   Where  possible,  standards are  developed which  permit the use  of more
than one control technique or licensed process.
       5.   Where possible, standards are developed to encourage or permit the use of
process modifications or new processes as a  method of control  rather than "add-on"
systems of air pollution control.
       6.   In  appropriate cases,  standards  are developed to  permit the  use  of
stystems capable of controlling more than one pollutant.  As an  example, a scrubber
can remove both gaseous and particulate emissions, but an electrostatic precipitator
is specific to particulate matter.
       7.   Where   appropriate, standards  for  visible  emissions  are  developed  in
conjunction with concentration/mass  emission standards.  The  opacity standard is
established  at  a level  that  will require proper operation  and  maintenance of the
emission control system installed to meet the concentration/mass standard on a day-
to-day basis. In some cases, however, it is not possible to develop concentration/mass
standards, such as  with fugitive sources of emissions.  In these cases, only opacity
standards may be developed to limit emissions.
                                      2-7

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2.4.   CONSIDERATION OF COSTS
      Section 317  of the Act  requires, among other things,  an economic impact
assessment with respect to any standard of performance  established under  Section
111 of the Act. The assessment  is required to contain an analysis of:
      1.   the costs  of compliance with the regulation and standard including the
extent to which the cost of compliance varies depending on the  effective date of the
standard or regulation and the development  of less  expensive or more efficient
methods of compliance;
      2.   the potential   inflationary  recessionary  effects  of  the  standard  or
regulation;
      3.   the effects on  competition of the standard or regulation with respect to
small business;
      4.   the effects of the standard or regulation on consumer cost, and,
      5.   the effects of the standard or regulation on energy use.
      Section 317 requires that the economic impact assessment be as extensive as
practical, taking into  account the time and resources available to EPA.
      The economic  impact  of a  proposed standard upon  an industry is usually
addressed both in absolute terms and by comparison with the control costs that would
be incurred as a result of  compliance with typical existing state control regulations.
An  incremental approach  is  taken since both  new and  existing  plants would  be
required to comply with state  regulations in  the absence of a federal standard of
performance.  This approach  requires  a detailed analysis of the  impact upon the
industry resulting from the  cost  differential that exists between  a standard of
performance and the typical state standard.
      The costs for control of air pollutants are not the only costs considered. Total
environmental costs for control of water pollutants as  well as air pollutants are
analyzed wherever possible.
      A thorough study of the profitability and price-setting mechanisms of the
industry is essential to the analysis so that an accurate estimate of potential adverse
economic impacts can be made.  It is also essential to know the capital requirements
placed  on  plants in  the absence of federal standards of performance so that the
additional capital requirements  necessitated by these standards can be placed in the
                                      2-8

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proper perspective.  Finally, it is necessary  to recognize any constraints on capital
availability within an industry, as  this factor also influences the ability of new plants
to generate  the  capital required for installation  of  additional control equipment
needed to meet the standards of performance.
2.5.   CONSIDERATION OF ENVIRONMENTAL IMPACTS
      Section 102(2)(C)  of the National Environmental  Policy Act (NEPA) of 1969
required  federal agencies to prepare detailed environmental  impact  statements on
proposals for legislation  and  other major federal actions significantly affecting the
quality of the  human  environment.   The  objective of  NEPA is  to  build into the
decision-making process  of federal agencies  a careful consideration  of  all environ-
mental aspects of proposed actions.
      In  a  number  of legal  challenges to  standards of  performance  for  various
industries, the  Federal Courts of Appeals  have  held  that  environmental  impact
statements need not be prepared by the Agency for proposed actions under Section 111
of the Clean Air  Act.  Essentially, the  Federal Courts of  Appeals have  determined
that "... the best system of emission reduction, . . . require(s) the Administrator to
take into account counter-productive environmental effects of a proposed standard,
as well as economic costs to the industry .  . ." On this basis, therefore, the Courts" .
.  . established a narrow exemption from NEPA for EPA determination under Section
111."
      In addition to these judicial determinations, the Energy Supply and Environ-
mental  Coordination  Act (ESECA)  of  1974 (PL-93-319)  specifically exempted
proposed actions  under the Clean Air Act from NEPA requirements.  According to
Section 7(c)(l), "No action taken  under the Clean Air  Act shall be deemed a major
federal action significantly affecting  the quality fo the human environment within the
meaning of the National Environmental Policy Act of 1969."
      The Agency has concluded, however,  that the  preparation of  environmental
impact statements  could have  beneficial effects on  certain  regulatory  actions.
Consequently, while  not legally  required to do so  by Section  102(2)(C) of NEPA,
environmental impact  statements will be  prepared  for  various regulatory actions,
including  standards  of performance  developed  under Section  111  of  the Act.  This
voluntary preparation  of environmental  impact statements, however,  in no way
legally subjects the Agency to NEPA requirements.
                                     2-9

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      To implement this policy, a separate section is included in this document which
is devoted  solely to an analysis of the potential  environmental impacts associated
with the  proposed standards.  Both adverse and beneficial impacts in such areas as air
and water pollution, increased solid waste disposal, and increased energy consumption
are identified and discussed.
2.6.   IMPACT ON EXISTING SOURCES
      Section 111 of the Act defines a new source as "... any stationary source, the
construction  or modification of  which is commenced . . ."  after the  proposed
standards are  published.  An existing source becomes a new source if the  source is
modified or is reconstructed.  Both modification  and  reconstruction are defined in
amendments to the general provisions of Subpart A of 40 CFR Part 60 which were
promulagated  in the Federal Register on December 16, 1975 (40 FR 58416).  Any
physical  or operational change  to an existing facility which results in an increase in
the emission rate of  any  pollutant for which  a  standard applies  is considered  a
modification.    Reconstruction, on  the  other hand,  means   the  replacement  of
components of an existing facility to the extent that the fixed capital cost exceeds 50
percent of  the cost of constructing a comparable  entirely new source and that it be
technically and economically feasible  to  meet the applicable  standards.   In such
cases, reconstruction is equivalent  to new construction.
      Promulgation of  a standard  of performance  requires  states to  establish
standards of performance  for existing  sources  in the same industry  under Section
lll(d) of the  Act if the standard for new sources limits  emissions of a designated
pollutant (i.e., a pollutant  for which air quality criteria have not been issued under
Section 108 or which has not been  listed as a hazardous pollutant under Section 112).
If  a state  does not act, EPA must  establish  such standards.   General provisions
outlining procedures for  control  of  existing  sources  under  Section lll(d) were
promulgated on November 17, 1975, as Subpart B of 40 CFR Part 60 (40 FR 53340).
2.7   REVISON OF STANDARDS OF  PERFORMANCE
      Congress was aware that the level of air pollution  control achievable by  any
industry  may improve  with technological advances.  Accordingly, Section 111 of the
Act provides that the Administrator "... shall, at least every four years, review and,
if  appropriate, revise  .  . ."  the standards.  Revisions are made to assure that  the
                                     2-10

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standards continue to reflect the best systems that become available in the future.
Such revisions will not be retroactive but will apply to stationary sources constructed
or modified after the proposal of the revised standards.
                                      2-11

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                    3. THE METAL FURNITURE INDUSTRY

3.1.   GENERAL DESCRIPTION
      In 1972  the metal  furniture industry  consisted of 1,588 companies which
employed 109,600 persons and sold $2.8 billions worth of metal furniture a year.  As
compared  with  the levels in 1967 the number of companies decreased by 5 percent,
employment by  6 percent and shipments increased by 35 percent.
      The  metal  furniture  industry is highly fragmented, including the following
categories of products:
            1.    Household Metal Furniture        SIC 2514
            2.    Office Metal Furniture           SIC 2522
            3.    Public Building Furniture          SIC 2531
            4.    Metal Partitions and Fixtures      SIC 2542
      The  metal furniture industry  consists of many small-scale companies employ-
ing less than 100  employees per company.  During  1972, 85 percent of the metal
furniture manufacturing  industry was  represented by  facilities  with less than 100
employees and 37 percent of the industry involved manufacturing companies with less
than ten employees.
      The employment data for the metal furniture industry is tablulated in Table 3-
1.

                     Table 3-1.  EMPLOYMENT STATISTICS
                              (Number of Persons)
                                              1972
                 Metal household            34,400
                 Metal office                27,600
                 Public building              21,400
                 Partitions and fixtures      26,200
                 Total                      109,600
                                     3-1

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      The metal household furniture industry is comprised of companies manufactur-
ing metal furniture for kitchen, porch, lawn and outdoor usage and others including
metal bed frames, card tables and chairs.   Of the 467 establishments manufacturing
metal household furniture 369 had less than 100 employees in 1972  .
      The metal office industry is established from companies primarily involved in
manufacturing  office  chairs, desks,  cabinets  and  cases  and other  metal  office
furniture  (including bookcases, storage  cabinets, costumers, etc.).   Of  the 192
establishments  manufacturing metal  office furniture,  132 establishments had less
than 100 employees in 1972 .
      Public building furniture may be metal or wood for schools, theaters, assembly
halls, churches and libraries. Companies  manufacturing seats for  automobiles and
aircraft  are also  included  in  this  industry.   Of  the  reported  422  companies
manufacturing public building furniture, 363 companies employ less than 100 persons
in 19721.
      The  industry of  metal  partitions  and  fixtures  comprises establishments
primarily manufacturing  metal shelving,  storage racks,  lockers, office  and  store
fixtures, prefabricated partitions and related fabricated products.
      Of the  507  companies  manufacturing  metal  partitions and  fixtures 443
companies had less than 100 employees.
      The  metal furniture  industry shipments value  has shown an  estimated 10
percent growth  since  1972.  The  growth of the industry  is mainly affected by the
growth in construction  of houses, schools, hospitals, air terminals and office buildings.
The  sales volume of metal furniture was  estimated at  3.2 billion dollars, including
shipments of household furniture,  office and building furniture and metal partitions
and fixtures in 1976. Table 3-2 shows sales of metal furniture by category.
      The growth rates of each segment of the industry from 1972 to 1985 is based
on actual growth excluding inflation of the dollar.  The  household furniture industry
annual average growth rates are:  2.4 percent for 1973  to 1980 and 3.9 percent for
             3
1980 to  1985 .   The other segments of the furniture industry, excluding household
furniture, are showing  the following annual growth rates:  4.4 percent for 1973 to
1980 and 3.0 percent for 1980 to 1985.
      A geographical  break-down of the metal furniture establishments is shown  in
Table 3-3.  The Middle Atlantic and East/North Central states accounted  for almost
50 percent of all establishments.
                                     3-2

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          Table 3-2.  METAL FURNITURE TRENDS AND PROJECTIONS
             IN THOUSAND DOLLARS AT CONSTANT PRICE (1972)
                       1972a   19735   1974b   1975b   1976b   1980b  1985b
Household                890     911     933     956      979   1076    1303

Office                   791     815     851     889     928    1102    1278

Public building           485     506     529     552     576     684     793

Partitions and fixtures     713     744     777     811     847    1006    1167


Total                   2869    2976    3090    3208    3330    3868    4541
Sources:  a  1972 Census of Manufacturers
            BLS Review, November 1976,  p 5
                                  3-3

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               Table 3-3.  METAL FURNITURE ESTABLISHMENTS


                                                      Public      Partitions
                         Household      Office       Buildingsa  and Fixtures

New England                 24             6             19           22
 Maine                      —             -              1
 Massachusetts              17             3             —           12
 Connecticut                 5             -              5

Middle Atlantic             134            55             61         177
 New York                  90            31             24         113
 New Jersey                 15             7             11           29
 Pennsylvania               29            17             26           35

East North Central           76            48            105         118
 Ohio                       12            11             31           32
 Indiana                      9            10             11            7
 Illinois                     43            11             27           42
 Michigan                    8            10             20           30
 Wisconsin                   4             6             16

West North Central          13            17             32           34
 Minnesota                   2            —              6           10
 Iowa                       —2              8           —
 Missouri                     8             8              6           13
 Kansas                     —2              86
 Nebraska                   —            —             —            2

South Atlantic               75            14             48           35
 Maryland                    8
 Delaware                   —             1
 Virginia                     62              91
 North Carolina              16             3             16            5
 Georgia                     63             —            7
 Florida                     36             4             13           11

East South Central           33             9             36           21
 Kentucky                    73             —            3
 Tennessee                  10             2             17            8
 Alabama                   10             3              9            9
 Mississippi                   6             -              5            -

West South Central          25             8             45           28
 Arkansas                    3             -             17            2
 Texas                      17             5             22           20

Mountain Division             7             -             17            5
 Utah                       -                           3            -
 Colorado                    5                           -

Pacific Division              80            34             59           67
 Washington                 —            ~             10
 California                  77            32             43           63


United States Total         467          192            422         507


Source:  The above data were compiled from information given in the 1972 Census
         of Manufacturers, U. S. Department of Commerce.

 aIncludes wood, metal and             ,_,
  plastic furniture

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3.2.   PROCESSES OR FACILITIES AND THEIR EMISSIONS
3.2.1. The Basic Processes
      The  metal  furniture  coating industry includes  all  establishments  which
manufacture metal furniture for office, public building and household use.  Metal
furniture is usually made from low carbon steel sheet, strip or tubing.
      Presently the metal furniture  industry employs mostly solvent-borne coatings
for spray,  dip coating and flow coating processes.  Coating  thickness ranges from 0.5
to 1.5 mils. Powder coating containing less than 5 percent volatiles is becoming more
acceptable for use on  outdoor  and institutional metal furniture.  Coatings for metal
furniture  must  be resistant  to abrasion scuffing  and maintain good appearance.
Institutional furniture  is subjected to a more abusive environment and in addition
must withstand regular cleaning with alkali type cleaners.
3.2.1.1.      Spray Coating
      Spray coating is generally applied by  a combination  of manual and automatic
spray.  Semi-assembled furniture pieces are loaded onto an overhead conveyor moving
at a speed of 8i to 24  feet per minute. The plants usually operate on the basis of one
shift per day (8 hours) for 48 weeks per year  .
      Although finishing lines  may vary from plant to plant, they have some common
characteristics which  allow us to  show  the following major  steps of  such lines
employing organic solvent-borne paint systems.
                          Three-stage or five-stage washer
                          Oven
                          Manual touch-up spray
                          Electrostatic spray
                          Manual touch-up spray
                          Oven
      The block diagram of these consecutive steps of the  metal finishing  process is
presented in Figure 3-1. Looking at each step of  the operation we first examine the
washer. The pieces loaded on a conveyor go through a cleaning process  which occurs
in the following sequence.
                                      3-5

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                                 Figure 3-1.  ELECTROSTATIC SOLVENT SPRAY COATING SYSTEM
CA>
ck
\
^ 	
f







j — j
i IA. \ ^T^ v-5 )
1 ' ' l
1 . 1 1
U A |_^| A A A
1 1 1 Y Y Y

ri,
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(1) Conveyor
(2) Three-stage washer
(3) Oven
(4) Manual touchup spray
(5) Electrostatic booth
(6) Manual touchup spray










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                                                                                                      (1)
                                                                                                     Load
      (7)
             e oven

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                   1.     Alkaline cleaner wash
                   2.     Iron phosphate
                   3.     Hot water rinse
                   4.     Chromic wash
                   5.     Cold water rinse
The alkaline cleaner washes the oil and grease and the phosphate treatment improves
the surface of the metal promoting adhesion of the coating.
      After being washed and treated, the parts pass through a dry-off oven and then
into a touch-up booth, where manual  air spray guns apply a reinforcement coating to
the intricate parts  before  the  topcoat is applied.  This step may be  eliminated, its
inclusion depending  on the configuration of the part being coated.
      The topcoat operation  is  the  most important  step in  the  metal furniture
finishing  process.   This is usually  applied by automatic  or manual electrostatic
spraying technique.  The paint is fed to the application equipment  through a piping
system  from  the paint  room.   Average  percent solids content in the  paint is in the
range of 25 to 35 percent volume basis.
      Because of the length of time that  the item of furniture is in the spray booth
and flash  off area, 70 to 90 percent of the solvent evaporates in  the booth and flash-
off area .
      Color change methods vary depending on  the operation.  In small manual spray
operations the operator purges the line with solvent, wipes the gun and connects the
line to the required  color coating supply. On larger  manual operations alternate spray
guns may be  used each with different colors as required.  Automated operations use
multiple spray guns programmed  for color sequence as scheduled  or in some cases the
line is purged with solvent and the guns are cleaned and set for the next scheduled
color.   Some larger  operations  perform color  mixing compounding with computer
programming  to eliminate  operator  error.  The color ingredients are selected in
accordance with computerized programs designed to meet customer requirements.
      A  material balance  is shown  in  Table  3-4 which  includes the discharge of
emissions at steps in  the  process.   This data is based  on a  model coating line.
Discharge of solvents in the metal furniture finishing process occurs in the following
manner:  75 percent loss at the application and flash-off step and 25  percent loss in
the cure oven step of the operation.  Figure  3-2 is a flow diagram showing  process
steps of the topcoat operation.
                                      3-7

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                        Table 3-4.  MATERIAL BALANCE

             METAL FURNITURE ELECTROSTATIC SPRAY COATING
      Process Steps
  Liters Per
   278,000
Square Meters
 Gallons Per
  3,000,000
Square Feet
                                                                          a
1. Coating applied

2. Material loss in the application
      Solid
      Solvent and trimmer

3. Total coating on furniture item

4. Oven evaporation loss - solvent discharge

5. Net dry solids on furniture item
   31,226
    8,250
3,825
15,223
20,297
5,074
7,104
1,010
4,023
5,363
1,341
1,876
a
   3,000,000 square feet is the annual production figure based on the following:

   (1)  production rate - 1,562.5 square feet per hour
   (2)  time - 1 shift (8 hours per shift) per day; 240 days per year; 1,920 hours
       per year (1,562.5 square feet per hour times 1,920 hours per year equals
       3,000,000 square feet)

   Application includes spray booth and flash-off area. Transfer efficiency of
   electrostatic sprayed coating is 65 percent.

   Water-wash spray booths capture solvents in the water curtain temporarily.
   About 15 percent of the solvent is carried in the recirculated water and
   eventually  is discharged by evaporation into the venting system.

   Coating at  35 percent solids - volume basis  thickness 1 mil, dry.
                                      3-8

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                     Figure 3-2. FLOW DIAGRAM - MATERIAL FOR ELECTROSTATIC

                              SPRAY SOLVENT-BORNE COATING
                                         Stack
                  Stack
Stack
   Load
CO
co
IT Evaporation T Evaporation
(Solvent) (Solvent)
Pretreat 3-Stage
Washer
-^
Pretreat Dry Off
Oven
-^
Solvent-Borne Coat
Spray Booth
-»»
Flash-Off
-^
Dry Off Oven
	 ^- U
                                                                             Unload
                            Paint Thinner
-n
                                               Transfer Loss
                                               (Solid)

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      Energy requirements of the metal furniture coating operation are tabulated in
Table 3-5. This data is based on a model coating line.

                         Table 3-5. ENERGY BALANCE
                    METAL FURNITURE COATING PROCESS


                    Operation Steps      106 BTU Per Yeara

                    Application                  590
                    Cure                       3,905
                    Total                      4,495


      a   Annual energy consumption calculations were based on 3,000,000 feet
          produced per year, working from the following:
          (1)  production rate - 1,562.5 square feet per hour
          (2)  time - a shift (8 hours per shift) per day, 240 days per year; 1,920 hours
               per year (1,562.5 square feet per hour times 1,920 hours per year equals
               3,000,000 square feet)

3.2.1.2.   Dip Coating
      A metal furniture coating application was  observed  to utilize the dip coating
technique.  The percent solids range for dip coating is estimated at 20 to 35 percent
volume basis.  Dip coating may be done manually or automatically, depending on the
size of  the parts  to  be coated.   For  large  pieces of  furniture dipping  is done
manually .
      For dip coating, the washing step may be eliminated.  It is not unusual in some
dip operations for the paint to be contaminated by foreign material on the parts. The
conveyor is  loaded  with  a number of parts  (50 to 100)  and lowered into a dipping
tank. After the parts are coated they pass over a drain board.  Following a  flash-off
period the coated parts are moved into an oven.
                                     3-10

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      A material balance is shown  in  Table 3-6 which  includes the discharge of
emissions at  steps in the process.  Discharge of solvents  in the coating application
occurs in the following manner:  40 to 70 percent loss at the application and flash-off
step and 30 to 60 percent loss in the cure oven step of the operation .
      Figure 3-3 is a flow diagram showing process steps of the dip coating operation
based on a model coating line.
      Process Steps
 Table 3-6.  MATERIAL BALANCE
METAL FURNITURE DIP COATING

                      Liters Per
                      2,086,957
                    Square Meters

                       168,356
                                                                          a
                                                               Gallons Per
                                                               222.5  x 10.
                                                               Square Feet
                                                                 44,480
5,893
65,658
96,805
43,774
53,032
1,557
17,347
25,576
11,565
14,011
1.   Coating applied
2.   Material loss in the application
    Solid
    Solvent discharge
3.   Total coating on wet body
4.   Oven evaporation loss-solvent discharge
5.   Net dry solids on body

   a  2,086,957 square  meters is the annual production figure based on the following:
      (1)  production rate - 108.67 square meter per hour
      (2)  time - 1 shift (8 hours per shift) per day; 240 days per year; 1,920 hours per
           year (109.67  square meters per hour times 1,920 hours per year equals 2,086,957
           square meters per year
      (3)  based on 1 mil dry  weight coating - 35 percent volume solids applied
      Application includes spray booth and flash-off area. Transfer efficiency of  dip
      coating is 90 percent.

         Energy requirements of the primer coat are tabulated in Table 3-7.
                                      3-11

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                 Figure 3-3. FLOW DIAGRAM - MATERIAL FOR SOLVENT-BORNE DIP COATING
Load
                                                          Stack
                        Stack
4 Evaporation
(Solvent)
Pretreat 3-Stage
Washer
— ^
Pretreat Dry Off
Oven
— »•
Solvent-Borne Coat
Dipping Tank
— »•
f Evaporation
(Solvent)
Dry Off Oven
^ Unload
                                     Paint, Thinner
T

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                         Table 3-7.  ENERGY BALANCE
                       DIP COATING METAL FURNITURE

                 Operation Steps          106 BTU PER YEARa

                    Application                  472
                    Cure                      6,725
                    Total                     7,197

      a     Annual energy consumption calculations were based on
            2,086,957 square meters produced per year, working from
            the following model line:
            (1)  production rate - 108.67 square meters per hour
            (2)  time - 1 shift (8 hours per shift) per day; 240 days
                per year
            (3)  conversion factors 3412 BTU/KWH and 1000 BTU per
                1 cubic foot of gas

3.2.1.3.  Flow Coating

      Some manufacturers may use flow coating for finishing metal furniture.  The
flow coating method, in some of its aspects, resembles dipping, particularly since the
process requires liquid coating that will flow out easily.  Viscosity of coating must be
closely controlled to provide satisfactory coverage without excessive runs or sags.
      In flow coating parts are carried by  a horizontal  conveyor  through a flow
coating chamber.  The paint is directed against the parts  from all angles through a
large number of nozzles.  The excess coating drips  off the lower edges of the parts
and leaves no strings and few, if any, congealed drops.
      The  simplest flow-coating equipment has paint nozzles over the work and on
all sides of the tunnel.  Sometimes as many as 100 or more nozzles are used.   The
flow coating method  has less amount  of  solvent emitted than dip  coating.  Flow
coating is done in an enclosed booth, while evaporation takes place over the whole
surface of the dip tank.
                                     3-13

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3.2.2. Equipment Characteristics
      Equipment  of the  metal  furniture finishing  line  associated  with  organic
emissions consists of the  spraying  booths, dip tanks, and ovens. Other equipment
involved in the  metal  furniture  finishing operation  includes  the washer and  the
conveyor for moving the parts to be painted through the process system.
      The metal furniture coating is applied  by either spraying, dipping  or  flow
coating methods.
      Electrostatic  spraying is probably  one  of the  most  widely used  methods
because of its sharp reduction in the overspray.
      Spray booth lengths vary for each facility because of the length of time that
the metal furniture item is in the  spray booth.  The majority of solvents are emitted
in the spraying area. An exhaust fan or blower  is used to draw the contaminated air
out of the spray booths.  To comply with OSHA regulations, a minimum air velocity
for exhaust devices is required to prevent personal breathing of excessive vapors and
paint particulates.  The make-up air  for the spray booth is  usually kept at about
60°F and some relative humidity.
      Water-washed spray booths are coming into use because of the increased effort
required to keep the  spray booths clear of overspray particulate.
      In a typical water-wash spray booth, the overspray paint particles are removed
by means of a curtain of water flowing down the side surfaces of the booth enclosure.
      A dry-style spray booth uses a  filter to remove the overspray paint particles
from the exhaust.
      Bake oven temperatures  range  from 300 to 325 F.  Solvent concentration in
the oven, usually measured as  a  percentage  of the lower explosive limit (LEL)  of
solvent  in the  air, is  about 10 to 25 percent.
      For some  large  parts and  parts that do not need a perfect painting finish,
dipping  and flow coating are the coating methods that will apply satisfactory coating
within a reasonable  cost range.  The  dipping system  consists  of a tank to hold the
paint and a drain board to collect the dripped paint.  Required air volume in the dip
tank area is less than that  needed  for spraying paint since there is less solvent lost in
transfer of the coating.  Flow coating  consists of a cabinet having nozzles on the top,
sides and bottom which directs  the paint at the work from all angles.  An improved
flow coating sytem eliminates all nozzles on top and sides of the cabinet and streams
of paint only from the bottom are directed against the  work.
                                      3-14

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3.2.3.  Emission Characteristics
       The two types of organic solvent-borne coatings used in the metal furniture
industry are enamels and lacquers.
       "Enamel is a type of paint consisting of an intimate dispersion of pigments in a
varnish or resin  vehicle.   The vehicle may be  an  oil-resin  mixture,  or an entirely
synthetic  resin. Those containing drying oils are converted to film by oxidation; those
comprised wholly of synthetic resins may be converted by either heat or oxygen  or
both."8
       Lacquers in  contrast to enamels, do not undergo a chemical  reaction when
exposed to heat.  Applied lacquers are dried by evaporation of the solvent to form the
coating film.
       The traditional coating materials used in the metal furniture coating industry
are organic solvent-borne compositions. Alkyd resins account for the largest portion
of all resins used in finishing  metal furniture.  Others include acrylics, amines, vinyls
and cellulosics. Some metallic coatings are used in finishing metal office furniture.
       The solvents used in coatings for metal  furniture are mixtures of aliphatics,
xylene, toluene and other aromatics, MEK and other solvents.
       According to a recent survey by the National Paint and Coatings Association in
1975, the  metal furniture and fixtures consumed 116 million pounds of solvents or 6
                                                 Q
percent of the total industrial coating solvent usage .
       Based on our survey the average  solvent emission for an electrostatic spray
operation  was  calculated to be 2.10 gallons per 1000 square feet.   Assuming  that a
metal  furniture finishing line operates at a production rate of 1562.5 square feet an
hour for one  shift  (8  hours per day), this  will  mean  that  12,500 square feet are
produced per day and that  approximately 26.25 gallons of solvent are discharged daily
from  the  metal furniture  spray  coating  operation.   Loss  from  overspray  was
                                               o
calculated to be 15 kilograms per 1000 meters based on data collected from the
industry.
       Average solvent emission for  a dip coat operation was calculated to be 1.37
gallons per 1000 square feet.  Assuming that a metal furniture dip line  operates at a
production rate of 11,700 square feet per hour for  eight hours per day, it will mean
that 93,000 square feet are produced per day and approximately 128 gallons of solvent
are discharged daily from the line.
                                       3-15

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      Calculations  of  solvent emissions from plants  visited result in  the  following
emission factors for the spray and dip coat operations (Table 3-8).
                   Table 3-8.  AVERAGE EMISSIONS FOR THE
                    METAL FURNITURE FINISHING PROCESS
                     Liters of Solvent Per 1000 Square Meters
                      (Gallons of Solvent Per Square Foot)
                                              a                   b
                 Coatings           Application     Cure     Total
           Spray
             Solvent-borne coat         64.50       21.50     86
                                       (1.57)      (0.53)     (2.10)

           Dip
             Solvent-borne coat         31.35       25.65      57
                                       (9.75)      (9.62)     (1.37)
            a Application includes spray booth and flash-off area

              Data presented as unconfirmed data reported from  field surveys
      Effluents from water wash  in spray  booths contain  contaminants  from
overspray of coatings. The water used in the spray booth curtain may be discharged
into a sludge tank where solids are removed and the water is recirculated. Immiscible
solvents captured by water curtains in spray booths evaporates from the water as it
recirculates and leaves at the booth  vent.  Solid waste discharge by the landfill
method may be the most appropriate for the metal furniture finishing operations.
                                     3-16

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3.2.4.  Parameters Affecting Emissions
       Metal furniture industry solvent emissions are directly related to the types of
coating materials used.  Naturally the greater the quantity of solvents in the coating
compositon the greater will be the  air emissions.  Lacquer having 15 to  17 volume
percent solids are higher in organic solvents than enamels which have 30 to 35 volume
percent solids.   The usage of add-on equipment such as  incinerators and carbon
adsorbers will also affect the  solvent emissions.   Springborn Laboratories' survey of
the metal furniture  industry however, did not discover any add-on pollution control
equipment for treating solvent  emissions.
       The advance of powder coating materials in the metal furniture operations will
affect the emission discharge  of the industry.  Powder coating was found to be a
popular method in outdoor furniture    and institutional furniture  .
       The advance of powder  coating materials  in the metal furniture  industry has
been attributed to  achieving better  performance coating a slightly higher cost over
solvent-borne systems.  Environmental improvement was an additional benefit.
       Water-borne coatings have not penetrated  the  furniture industry in  significant
                                                       12
volume because  they are  relatively  new in  this  industry   .   This technique will no
doubt develop when  more pressure to reduce emissions from solvent-borne coating is
applied to the industry.
       Higher solids coatings  are  making  inroads.   In  one  case  an  institutional
furniture  manufacturer  used higher solids  coating to minimize air pollution  and
                                                           41
provide a coating with minimum solvent content on its product  .
       Emissions  are also influenced by the  thickness of the coating and transfer
efficiency of the coating technique used. There are minor transfer problems involved
with the use of dip  coating; essentially, all of the paint solids are transferred  to the
part.   The dipped paint is normally  returned  to the dip tank.  Coating loss with non-
electrostatic spraying ranges from 40 to 70  percent;  with electrostatic spraying the
                               13
range  is from 13 to 32 percent .   In this industry a loss of 35 percent is probably
more  realistic as an average because of the variety of parts coated. Flow coating
transfer efficiency is about 90 percent.
       Emissions  are also influenced by state or intrastate regulations. Only thirteen
states  had statewide regulations in effect;  but  eight other  states with  a total of
twelve districts  within  these  states, had  promulgated  individual  district, non-
statewide regulations.  Some states do not have limits on the  amounts of exempt or
                                      3-17

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non-photochemically reactive solvents that can be emitted.  Connecticut on the other
hand is more stringent in this regard, allowing only 800 pounds per day versus the
3000 pounds per day specified by Rule 66.
                                      3-18

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 3.3.   REFERENCES
 1.     1972 Census of Manufacturers, Volume II, Industry Statistics, U. S. Department
       of Commerce
 2.     U. S. Outlook 1977 - p 305
 3.     BLS Review - November 1976 - p 5
 4.     Springborn Laboratories' (formerly  DeBell & Richardson, Inc.) survey of the
       metal furniture companies.
 5.     Air Pollution Engineering Manual.  U. S. Department of Health, Education and
       Welfare; Cincinati, Ohio  1967 p 711.
 6.     Oge, M.T. Trip  Report - Lyon Metals, Aurora, Illinois.   Springborn  Labora-
       tories, Inc., (formerly DeBell & Richardson, Inc.) Enfield, Connecticut.  Trip
       Report 91, March 12, 1976.
 7.     Industrial Finishing Journal - July  1976 - p 22
 8.     The Condensed Chemical Dictionary by VanNostrand Reinhold Company 1971,
       p346
 9.     Bruce Ocko, Modern Paint and Coating Magazine, March 1977 - p 61.
10.     Oge,  M.T.  Trip  Report  -  Bunting Company,  Philadelphia, Pennsylvania,
       Springborn Laboratories, Inc. (formerly  DeBell &  Richardson, Inc.)  Enfield,
       Connecticut. Trip Report 86, March 8,  1976.
11.     Oge M.  T.  Trip  Report - Goodman  Brothers  Manufacturing  Company,
       Philadelphia, Pennsylvania, Springborn  Laboratories, Inc. (formerly DeBell &
       Richardson, Inc.) Enfield, Connecticut.  Trip Report  85, March 8, 1976.
12.     Telephone Conversation,   William  Holley of  Springborn  Laboratories, Inc.
       (formerly DeBell  & Richardson,  Inc.) with  John  Dunhan,  Hanna Chemical
       Coatings Company, August 25,1977.
13.     Waste Disposal from paint systems.  Discussed at Detroit, Michigan. American
       Paint and Coating  Journal.  February 23, 1976 - pp 35-36.
                                      3-19

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                     4.   EMISSION CONTROL TECHNIQUES

        This chapter  and Chapter 6 are both analyses of available emission control
technology for the metal furniture finishing industry. The purpose of this chapter is
to define the  emission  reduction performance of specific  control techniques,  while
Chapter 6  evaluates  complete systems which include finishing processes in combin-
ation with one or more emission reduction techniques.
        The purpose  of  the control techniques as referred to in  this chapter is to
minimize emissions of  volatile  organic compounds  to the air.  These  compounds -
ketones, alcohols, esters, saturated and unsaturated  hydrocarbons, and ethers -make
up the  major  portion of solvents used for paints,  thinners, and cleaning materials
associated with industrial finishing processes.
        There  are several types of control techniques either presently  in use within
the metal furniture industry or which would have utility based on technology transfer
from related industries.  These methods  can be broadly  categorized as either "add-
ons" or "new  coating"  systems.  Add-ons  are  used to reduce  emissions by either
recovering or  destroying the  solvents before they  are emitted into  the air.  Such
techniques include thermal and catalytic incinerators and carbon adsorbers.  New
coatings refers  to  application  methods  which  use coating  materials  containing
relatively low levels  of organic solvents.   Such  methods  include electrodeposition,
spray, dip or flow coating of water-borne paints and electrostatic spray of high solids
and powder coatings.   Because of the lower solvent content of the "new"  coating
materials,  these application  methods are  inherently less polluting than processes
which use "conventional" organic solvent-borne coatings.
        The following discussion characterizes the control techniques and defines the
emission reduction performance associated with each technique as  applied  to  the
metal furniture industry.
4.1.  THE ALTERNATIVE EMISSION CONTROL TECHNIQUES
4.1. L Powder Coating
        On the control techniques presently in use  in the metal furniture finishing
industry, powder coating is the most common.  Most of the powder is being used for
outdoor furniture  with lesser  amounts being applied to shelves, bed and chair frames
and miscellaneous parts.
                                      4-1

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        While powder is generally suitable for painting metal furniture, there can be
problems  of  color matching.    For  example,  there  can be difficulties  where
merchandise is made for resale from one manufacturer to another, particularly if one
is  using a solvent-borne paint.   This problem may not  exist,  however, where both
finishers are using the same coating.
        Powder coating, although considered here as a new coating method, has been
in   use  for  decades ,  fluidized-bed coating beginning in the  early  1950's  and
electrostatic  spray in  the early 1960's.   Powder coating, regardless of  process,
involves the application of nearly 100 percent solid materials in dry powder form: no
solvents are used, although small percentages of organics can be driven off from the
resins during curing.
        Powder coating is being  used throughout the industrial finishing industry for
such diverse painting applications as wire goods (baskets, racks, and shelves),  piping
                             2                                 34
and tubing,  fencing and posts ,  garden  tractors, lawn equipment  , and bicycles ; in
                                                                 c C <7
the automotive industry powder coating is being used for topcoats ' '  , under-the-
                                            8 9
hood parts such as oil filters and air cleaners '  as well as bumpers, trailer hitches,
and emergency brake cable guides  '  '   .
        Powder coating has made significant penetration into the metal furniture
finishing industry primarily in  outdoor and  patio  furniture.    One industry expert
estimates that approximately 60 companies in the metal furniture, display shelving
and office equipment industries are presently using electrostatically sprayed powder
            13
for finishing  , representing approximately 15 percent of the total number of powder
                  14
spray installations  .  It has been estimated  that by 1980, the metal furniture and
architectural metal industries will consume  approximately 12 percent  of the 113
million  kilograms (250 million pounds) of powdered resin that will be used annually for
                                               13
both fluidized bed and electrostatic spray coating  .
        The use of powder in the metal furniture finishing industry can in general be
divided into  two categories:    thin-film  thermosetting  polymers  applied  from
electrostatic  spray and to  a  lesser  extent,  thick-film  thermoplastic  materials
deposited by the fluidized bed technique.
        The  leading thermoset  powder coating  materials,  are  the  epoxies  and
         14 15
polyesters   '  .   these materials provide hard, smooth surfaces that  have excellent
adhesion to most metallic substrates.  The coatings are tough, with good resistance to
abrasion and chemicals. Thermosetting  acrylic is of lesser importance but is growing
in usage.
                                       4-2

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        These powdered thermosets are used in the metal furniture industry for such
general decorative applications  as chair  and bed  frames,  tubular  metal furniture,
patio and casual furniture, office furniture, and shelving.  Examples of the use of
powder in the furniture industry appear in Table 4-1.
        Thermoplastic powders comprise polymers such as polyvinyl chloride ("vinyl"),
various nylons, and cellulose acetate butyrate.  These materials are normally applied
in thick films typically 5 to 15 mils to heavy wear areas such as chair legs, bases and
arms; and miscellaneous parts such as springs and handles.
        The three significant application techniques in use commercially for powder
coatings are:  electrostatic spray, fluidized bed, electrostatic fluidized bed; the first
two are in evidence in the metal furniture industry.
4.1.1.1.  Electrostatic Spray
        The electrostatic powder spray process is shown schematically in Figure 4-1
                             35
and can be described as follows   :
            Powder is drawn  from  the hopper and  carried to  the  gun by
        compressed air.  As the powder passes through the gun, it picks up an
        electrostatic  charge from the electrodes  in the tip  of  the gun.  The
        part  to be coated is grounded and at  a lower potential than the
        powder particles.  When an electrostatic field is generated  between
        the tip of the gun and the part, the powder particles are attracted to
        the  part and adhere.   As  the  coating  forms, the  part becomes
        insulated  and  the deposited  powder begins  to   repel  additional
        particles.  The result is a uniform film relatively free of voids.
            The powder adheres to the part until it  is fused  to the surface
        and heat-cured in the oven.  Film  thickness normally varies from 1.5
        to  6  mils  (0.038  to  0.127  mm),  depending on the  preheated
        temperature  of the  part,  the particle  size  of  the  powder,  the
                                                      oc
        electrical potential, and the duration of the spray  .

        Electrostatic  spray units range from relatively small manually operated job-
shop, touchup models up to large production units with several automatic reciprocat-
ing guns and complex  powder recovery systems. The basic components of all units are
         37
as follows  :
                                      4-3

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                 Figure 4-1   SCHEMATIC OF ELECTROSTATIC POWDER SPRAY PROCESS
                                                                              38
                                                        d.
a.     Powder hopper
b.     Compressed air control
c.     Powder injector and tube
d.     Spray gun with integral high-
       voltage generator
e.    Deflector plate
f.    Part to be coated
g.    Ground
h.    Power supply
i.    Electrode

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           Table 4-1. EXAMPLES OF METAL FURNITURE FINISHING

                         WITH POWDER COATINGS
Product Process
Stadium seating
Hospital beds
Indoor and outdoor
furniture
Hospital bed
frames and parts
Chair frames
Tubular metal
furniture
Steel tubing for
furniture
Library shelves
Metal chairs
Dinette tables
Metal furnishing parts
Patio and casual
furniture
Hospital beds
Office furniture
Shop furniture
Chair base and arms
Chairs
Hospital furnishing parts
Hospital bed handles
Process
Manual ESa
ES
Automatic
ES
Automatic
ES
Automatic
Manual
ES
Automatic
ES
Automatic
ES
Automatic
ES
ES
Manual
ES
Automatic
ES
ES
Automatic
ES
ES
FBb
FB
FB
FB
Type of Powder Reference
Thermoplastic
polyester
Nylon 11
Epoxy and Poly- 18
ester
Epoxy
Epoxy
Epoxy and thermo-
plastic polyester
Polyvinyl chloride
thermosetting polyester
Epoxy
Polyester 25
Cellulose acetate
butyrate
Epoxy 27
Polyester
Epoxy
Epoxy
Cellulose acetate
butyrate
Nylon 66
Polyvinyl chloride/
polyester
Nylon
Polyvinyl chloride
163
17
, 19
20
21
22
23
24
, 26
19
,28
29
30
31
51
21
32
28
33
Thickness
3 mils
—
1-3 mils
2-4 mils
2-3 mils
1.5 mils
2.5 mils
1.0 mils
2.2 mils
1.5 mils
—
2.5-4.0 mils
1-5 mils
—
3-8 mils
3.5-4.0 mils
6-7 mils
15 mils total
—
—
a ES - electrostatic spray
b FB- fluidized bed
                                   4-5

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(a)  Basic Console
    The console or cabinet contains the power supply which converts
line current to high-voltage direct current; the air supply with drier;
the powder reservoir  with vibrator and  air fluidizer to keep the
powder fluidized so that it will flow through the hose to the gun; and
the control module for regulating  air volume and  pressure,  voltage,
amperage,  vibrator frequency in  the  powder reservoir, and  powder
flow rate.
(b)  Powder Spray Gun
    A trigger switch  on the  gun activates both  powder flow and
transfer of voltage.  A deflector  mounted in the nozzle of the gun
controls the spray pattern.   Connected to the gun are the material
hose and high-voltage cable.
    Automatic guns are similar in design construction and operation,
but are turned on and off by a master switch on the control panel.
Automatic guns are often mounted on variable-speed/variable-stroke
                    39
vertical reciprocators   .
    The number of guns in a unit generally varies from one to  twelve,
and is dependent on the size and complexity of the parts to be  coated,
the extent and rate  of travel of the reciprocating  guns,  and the
conveyor speed. It is better to use several guns at a moderate output
since excessive output from a gun will lower deposition efficiency,
                                   40
increase overspray, and clog the guns  .
(c)  Spray  Booth
    Powder spray booths are  much simpler in  design  than  normal
paint  booths  with floors  sloped  in order  to recover oversprayed
powder. Guns are normally  mounted  in the side walls of the booth;
openings are kept small to minimize powder loss.  The interior walls
are vertical and free  of projections in order to minimize hang-up of
powder  .
    The dimensions of the  booth are governed by  the  part size,
conveyor size, conveyor speed, and the number of guns.
                               4-6

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    Figure  4-2.  shows a typical booth  with  recovery system  and
reciprocating gun.  Air flow from top to bottom in  the booth helps
scavenge oversprayed powder and carry it through the bottom of the
booth.
(d)  Recovery System
    A recovery  system  is  also shown  in Figure 4-2.  Recovery of
oversprayed powder is the key to economical powder coating.  Most
systems comprise a bag  or  tube  filter, with or without one or more
cyclones.   The  powder goes  through the cyclones first, where  the
centrifugal  action  spins  the heavier particles to the outside  and
recovers them.  Recovery in the cyclone is often in the range of 75 to
                           n be
                           ,186
                 185
85 weight percent,    but can be as high as 90 to 95 weight percent if
high efficiency units are used
     Powder  which passes through  the cyclone  contains primarily
smaller particles which are collected on the filter.  The  filter plus
cyclone remove a  total of greater than 99 weight percent of the
oversprayed powder.  If an additional "absolute" filter is used, a total
of approximately 99.97 percent of the  powder can be removed from
             186
the air stream
     In paint operations  where a  single color is used, powder from
both the  cyclone  and bag filter can be reused and overall powder
                                                  42
utilization for such operations is 98 percent or better  . Where color
changes are  occasionally  made, however, powder  from  the  filters
must be discarded in order to prevent color contamination.  For such
operations overall powder  utilization is dependent on a combination
of the  efficiency of the powder recovery unit and the initial transfer
efficiency of powder from the  gun to the part.  The effect of these
two variables on powder utilization has been shown in Table 4-2.
                              4-7

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Figure 4-2.   SOPHISTICATED RECOVERY SYSTEM41
 a.    Reservoir and controls
 b.    Elevator-mounted industrial spray gun
 c.    High-voltage electrode and deflector plate
 d.    Part being coated
 e.    Grounded conveyor
 £.    Powder tube and high-voltage cable
 g.    Spray booth
 h.    Powder recovery unit
 i.    Exhaust fan
 j.    Exhaust line for powder recovery
 k.    Clean air returned to booth
 1.    Clean air exhausted to atmosphere
                   4-8

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Table 4-2. OVERALL WEIGHT PERCENT OF POWDER UTILIZED
                                                            a
   Weight Fraction
   Powder  Recovery
         a
Weight Fraction Transfer
  50
65
80
80
85
90
82.5
85.7
89.2
90.1
91.8
94.6
95.2
96.4
97.5
           Assuming color changes, with powder in bag filters discarded

           Weight fraction deposited on the part to be painted
       Normal operating parameters for powder spray units used for
                                      49 41 4.4 4"; 4.R
   metal furniture finishing are as foUows  ' '  '  '  :
   Preheat


   Conveyor speed




   Electrical output


   Polarity


   Compressed air output




   Powder output


   Powder cure
      None


      1.52-13.7 meters/minute

      (5-45 feet/minute)26'34'22'20'18


      70-90 KV DC (maxiumum)


      Positive or negative


      1416-7080 cu cm/sec at 146-488 kg/sq

      meters (30-100 psig)


      0-36 KG (0-80 lb)/hour/gun


      171-232°C (340-450°F) for 4-30

      minutes18'20*22'24'26
                                 4-9

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        The voltage on most units is variable up to 90 KV, which permits control of
              42
film thickness  .   A low voltage  will allow penetration into holes and recesses.
Although  polarity is  often variable, most powders are sprayed successfully  with a
negative charge.  An adjustable deflector on the gun also controls the spray pattern.
A  narrow  pattern aids  penetration while  broad clouds are  useful  for large flat
     47
areas  .
        Powder  deposition on the parts can reach 85 percent on  large flat surfaces,
                                                               40
but irregularly shaped objects result in reduced transfer efficiency  .  Deposition can
be as low as 30 percent on wire products such as racks and baskets, but of course this
                                   40
overspray is almost always recovered  .
        The following is a generalized process description based on an investigation of
several  lines   presently  in  operation   in   the   metal  furniture   finishing  in-
dustry18'20'24'26'28'29'31.   Such systems are used for finishing metal shelves, bed
frames, chairs, springs, etc.
        Most systems  are nearly fully automated with the exception of loading and
unloading of conveyors, and occasional manual-spray touchup.
        (1)  Conveyor
            All  electrostatic powder spray systems  investigated  use con-
        veyors, generally overhead types, which carry the parts to be painted
        through  the pretreatment and dry-off sections, paint booth, and bake
        oven to  the unload area.  Although conveyors are  used at speeds of
        from 1.52 to 13.7 meters per minute (5 to 45  feet per minute) they
        generally travel in the range of from 3.05 to 4.57  meters per minute
        (10  to 15 feet per  minute).  Parts are hung on  hooks  at uniform
        intervals as governed by the size of the parts; 0.305 or 0.610 meter
        (one or two foot) spacing is  common.  Conveyors are normally loaded
                                              24
        by hand, but automatic loaders are in use  .
        (2)  Pretreatment
            The metal parts are generally cleaned and phosphated in  a three
        stage washer.  The treatment is normally done by spraying the parts,
        as they  are conveyed, but batch type pretreatment can be used prior
                                           29
        to placing the parts  on the  conveyor   .  For heavy-duty cleaning a
        wheel-o-brator can be used prior to conventional treatment.
                                      4-10

-------
    The first stage  is a phosphate wash, followed by a water rinse,
and then an  acid rinse,  generally chromic.  The wet parts are run
through a "dry-off oven for 5 to 15  minutes at temperatures of from
93 to 260°C (200 to  500°F), followed by a cool-off period.  The parts
are cooled  by allowing them to travel along the conveyor in the open
room  for 5  to 15 minutes.
(3)  Powder Spray
    After  the  cool-off period,  the  parts are conveyed through the
spray booth where the powder is applied from spray guns.  The spray
booths,  sometimes called tunnels or chambers depending on their size
and shape,  are often designed especially to accommodate the type of
part to  be  coated. Long booths with large wide openings are used to
coat large  items with complicated shapes or are used where the mix
of part  sizes and shapes  varies.  Where the parts are narrow, such as
in the case of metal  shelves, the booth can be correspondingly narrow
(e.g. 3.65 meters long by 3.05  meters high by one meter wide or  12
                                     O-l
feet by  10 feet by 3 feet, 4 inches wide  ).
    Powder coating  is best suited to the finishing of flat exterior
surfaces or open frames. Due to a Faraday caging phenomenon, it is
often difficult to coat parts with recesses which are surrounded  by
metal, such as interior corners of desks or cabinets. This problem can
be overcome in part  by preheating the substrate, coating at a reduced
voltage, or focusing the spray directly at the problem recess.
    The powder is normally applied with from  two to six guns; but
                                       04
booths with as many as 16 guns are in use  .  Automatic guns are the
most common, often  mounted on verticle reciprocaters.
    Some  operations use a smaller touchup booth  after the  main
                                                     18 29
booth where unpainted areas are covered by manual spray   '  .
    Most operations recover  oversprayed powder for reuse, using
cyclones and bag filters.  One rather unique booth draws the exhaust
air  from the  top of the booth rather than from the bottom  as is
commonly  done.  This  exhaust system  plus electrically charged
precipitator plates  which repel powder away from  the booth walls
                                                24
permit  an  overall 85 per cent transfer efficiency  .  No  powder is
recovered on this powder spray line.
                              4-11

-------
       (4)  Baking
            Baking time and  temperature are governed by the mass of the
       coated part  and  the  nature of  the powdered polymer.    Baking
       schedules vary from 4 to 30 minutes at temperatures of from 171 to
       232°C (340 to 450°F).
4.1.1.2. Fluidized Bed
       Fluidized bed coating involves the dipping of a preheated metal part into a
tank of powder which has been  intimately mixed with air to a relatively low bulk
density.   The process is analogous to the conventional organic solvent-borne paint
dipping technique.
       The powder is kept fluidized by passing a stream of air up through the bottom
of the tank.  The  bed when fluidized has the  appearance of boiling water, and if the
tank is tipped, the powder bed flows like a liquid .
       The powdered resin fuses and adheres  to the heated part; coating thickness is
governed by the temperature and  mass of the part and the dwell time in the bed.
       Fluidized  bed coating  is generally used where a heavy  durable coating is
desired with thicknesses between 6 and 60 mils.  Typical applications include chain
link  fence;  wire  baskets and  shelves   for  use  in  appliances  such  as  freezers,
refrigerators  and dish  washers; handles  for  tools  and  small  appliances;  and
        48
furniture   .
       With the exception of the bed itself, fluidized bed powder  coating is done
with conventional finishing equipment.  The bed is a relatively simple  apparatus as
illustrated in Figure  4-3, consisting of a tank of suitable size separated into  an upper
and lower chamber by a porous divider. Air generally from a compressor or blower, is
introduced into the  lower chamber  where it passes  uniformly through the porous
divider and into the  powder bed.  The powder in the upper chamber  is aerated and
suspended into a "fluidized bed".
       Air flow through the bed  is approximately 15.2  to 61.0 cubic meters  per hour
                                                                            49
per square meter of plate (50 to 200 cubic feet per hour per square foot of plate).   A
vibrator is generally used to keep the expansion of the bed uniform and to prevent air
from channeling through the powder.
       The tank should be of sufficient  size so that the parts to be coated can be
dipped below the level of the expanded powder.
                                      4-12

-------
              PREHEATED       ,—L
              PART TO BE
               COATED
         POROUS
         PLATE
               f   I
                 J
       R.UIOSED «S«.

-t   <   '
                     •or
        AIR CHAMBER	







       LOW PRESSURE AIR
Figure 4-3. SCHEMATIC OF FLUIDIZED BED APPARATUS
                                                       49
                          4-13

-------
        As with most metal finishing, the process begins with a thorough cleaning and
phosphating as described on  page 4-10 after which  parts  are  normally hung  on an
overhead  conveyor.   For some applications requiring high adhesion with the use of
thermoplastic powders, primers  are employed.  These are generally organic solven-
                                                           52
borne materials applied either by  dip, spray or flow  coating  .  After leaving the
pretreatment section parts enter a dry-off/preheat oven, where the metal  is heated
approximately 40 C  above the melting point of the polymer, or higher if the part has
a small mass and is apt to cool rapidly between  preheat and dipping   .  The time and
temperature of the preheat are dependent on the polymer being used and the mass of
the part.  A heavy cast iron valve to be coated  with epoxy might require 45 minutes
at 200°C  ,  while a chair  arm might require only 4.5 minutes at 330°C to fuse a
            21
nylon coating  .
        To apply the powder, the preheated part is dipped into  the fluidized bed; this
is done as soon as the part exists the oven in order  to minimize heat losses.
        Adequate dwell time and motion of the part in the bed are required in order
to obtain a satisfactory coating,  free  from pin  holes and an "orange  peel-like"
surface. Coating thickness is goverened by the  dwell time in the bed; the longer the
dwell time, the thicker the coating.  Typical immersion  times range  from 3 to 20
      . 53
seconds  .
        Depending on the size of the operation,  parts are dipped either automatically
or are removed from the conveyor on exiting the oven and dipped manually.  Excess
powder is  often  removed from the  coated  parts by  a  blast  of air,  prior to post-
                            49
heating, or cooling of the part  .
        If the powder is a thermoset, or if a more uniform coating is desired with a
thermoplastic powder, the part is given a final bake.
4.1.2.   Water-Borne Coatings
        Of the control techniques  presently in  use in the metal furniture industry,
water-borne coatings next  to powder are the  most common.  Most  of the  water-
bornes for furniture  are being applied by  electrodeposition  (ED or EDP) for use as
one-coat finishes.  Water-borne spray is being used to a lesser extent.
        The terminology for water-borne coatings tends to  be confusing; the names of
the various coating types are often misused or used synonymously.  The term water-
bornes as discussed here refers to any coating material which uses water primarily as
the carrier, and  is  meant to distinguish such  coatings  from  organic solvent-borne
paints.

                                      4-14

-------
        There are three types of water-borne coating materials:  latex or emulsion
paints,  partially solubilized  dispersions, and water-soluble  coatings.  Table 4-3 lists
the significant characteristics of these three types of coating materials.
        The  majority  of  water-borne industrial  finishes  are based on  partially
                                      4                        54
solubilized resins in the 3.5 to 8.0 x 10  molecular weight range   and are applied by
electrodeposition (EDP).   Emulsions are growing in  interest for some applications,
however,  because  of their  ability to build relatively  thick films  without causing
      e c                                                              ec
blister  . They also require  no noxious amine solubilizers and no solvents  .
        Most  of  the  solubilized water-borne  coatings  used  are based  on alkyd,
polyester, acrylic, modified silicone, and epoxy resins - often made crosslinkable with
                                                     57
amine  resins  such  as hexamethoxymethyl melamine   .   A  common  method  of
solubilizing is to incorporate carboxyl-containing materials  such as maleic anhydride
and acrylic acid into the polymer backbone. The acids are then  "solubilized" with low
molecular weight amines such as triethylamine, or to a lesser extent with potassium
         57
hydroxide   .
        After application,  solubilized coatings are baked and the amine, solvent, and
water evaporate to leave a cured film that closely resembles an  organic solvent-borne
finish58.
      Although the use of  water-borne coatings in the metal furniture  industry is
limited  at  this time it will probably increase.  One  industry consultant feels that the
market  for water-borne finishes for  office, home, and institutional furniture "should
                                                               59
grow  well - both as ED coatings and as sprayedor dipped coatings"  .
      Current usage in the metal furniture and related fields includes office and shop
        fifl fi1 fil          fi9                   fi1^  fifi             R7
furniture   '', shelving  , computer cabinets  '   , metal doors  , card table legs
          55                                          68
and chairs   , and other tubular folding table frameworks  .
4.1.2.1.   Electrodeposition
      Many of the finishes  used for institutional and office furniture are applied in
                                     _o                     ce CQ
very  thin  coats, generally  2.5 x  10   cm  (1  mil)  or less   '   .   The  fact  that
electrodeposition is limited to one coat application of thin films in  one color makes it
an attractive  finishing method for certain  products in the  metal  furniture  industry.
Examples where EDP is in use on metal furniture finishing lines  can be found in Table
4-4.
                                       4-15

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                     Table 4-3.  WATER-BORNE COATINGS
   Properties


Resin particle size

Molecular weight

Viscosity


Viscosity control



Solids at application

Gloss

Chemical resistance

Exterior durability

Impact resistance

Stain resistance

Color retention on
oven bake

Reducer


Washup
Latex or Emulsion
      Paints
0.1 micron

up to 1 million
Partially Solubilized
     Dispersions
Ultrafine

50,000 - 200,000
Low-not dependent   Somewhat dependent
on molecular weight  on molecular weight

Require thickeners   Thickened by addition
                     of cosolvent
High

Low

Excellent

Excellent

Excellent

Excellent

Excellent


Water


Difficult
Intermediate

Low to medium-high

Good to excellent

Excellent

Excellent

Good

Excellent to good


Water
Water-Soluble
   Coatings
20,000-50,000

Very dependent
on molecular weight

Governed by molecu-
lar weight and solvent
percent

Low

Low to highest

Fair to good

Very good

Good to excellent

Fair to good

Good to Fair
Water or water/
solvent mix
 Moderately difficult     Easy
Source:  Industrial Finishing (July 1973) p 13
                                      4-16

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      Table 4-4.  ELECTRODEPOSITION IN THE METAL FURNITURE INDUSTRY
Application/Product
Topcoat/shop
furniture
Topcoat/shelves
Topcoat/shop
furniture
Topcoat/institu-
tional furniture
Primer/outdoor
furniture
Topcoat/office
furniture
Tank
Capacity Paint
Liters Concentration
(Gallons) Percent Solids
37,900 10
(10,000)
53,000 7.5-8.0
(14,000)
106,000 —
(28,000)
68,100 7.9-8.1
(18,000)
79,500 —
(21,000)
9,500 —
(2,500)

Dwell Time Film Thickness
Min. cm x 10~3(mils)
2 2.54-3.05
(1.0-1.2)
2 2.54-3.05
(1.0-1.2)
3.5 2.54 (1)
— 1.78-2.03
(0.7-0.8)
— —
— —

Reference
60, 61
62
63
64
60
60
                                       4-17

-------
        Autophoretic coating, similar  in nature to EDP, is not being used  for metal
furniture, since the  color for this paint technique is limited to black at the present
time193.
        Electrodepostion is  limited to waterborne coatings. During application,  the
parts are immersed  in a bath of low-solids water-borne coating solution; the tank or
grids on the periphery of the tank are  subjected to a negative charge while the parts
are grounded. The process is analogous to electroplating; negatively charged polymer
                                                                              70
is  attracted  to the  metal  item  and  is deposited  as a  highly uniform coating  .
Systems of the opposite polarity can also be used.
        Figure 4-4 shows a typical closed-loop electrocoating line.
        In a typical EDP operation, parts are loaded on a conveyor which carries them
first  through  a  conventional cleaning and pretreating section.  An additional rinse
with  deionized  water is  often  used,  but  since EDP is an aqueous  system dry-off
between pretreatment and finishing is not required. The washed and treated parts are
lowered automatically into  the  EDP tank containing the water-borne paint, normally
                                              71 62 64
a 7 to 10 percent dispersion  of a colloidal polymer   '   '  .  The body or part becomes
the  anode  of the  electrical system  while the tank  or grids mounted  in the tank
become the cathode.  To avoid stripping the coating the DC current is not applied
until the part is totally submerged. Current  flow through the bath  causes the paint
"particles" to be attracted to the metal  surface, where  they deposit as a uniform
film. The  polymer film that builds up tends to insulate the part and prevent further
                                                          R1 B2 71 72
deposition. Dwell  time in the tank is typically li to 2 minutes   '   '   '   .
        The current  is then  shut off and the parts  are raised out of the bath, allowed
to drain, rinsed  in  deionized water to remove  "dragout", and then baked.  Solids from
the dragout are collected in the rinse water and usually are returned to the EDP tank.
                                                                 67 73
This recovery can result in  a paint savings of from 17 to 30 percent  '   , with paint
                                        74
solids utilization approaching 100 percent   .   Excess water removed from the paint
                       74
bath  with an ultrafilter  , is generally used for rinsing and eventually dumped to the
sewer to control the buildup of impurities.
        The  conveyors, pretreatment  section, and  bake  oven used for  EDP  are
                                                          70 75
conventional items; the critical components of the system are  '   :
                                      4-18

-------
                                  Figure 4-4.   TYPICAL ELECTRODEPOSITION SYSTEM DIAGRAM 159
>**.

t-1
CO
                                                                       Deionized Water
Llectrodeposition
    Dip Tank
                        Paint Supply
                             Rinse Tank »2
                                                                       Rinse Tank  S3
                                        Paint  Return
                    I— Ultrafiltration
                    Ultrafiltrate
                                                             Holding Tank
                                                                          h-€T
                                                                                                   Drain

-------
(1)  Dip Tank
    The  dip tank is a  large rectangular container generally with  a
capacity  of 37,850 to  113,550 liters  (10,000  to 30,000  gallons),
                      61 fi2 fi"? fi4
depending on part size  '  '  '  .  The tanks are coated internally
with a dielectric material such as epoxy and are electrically grounded
          CO "71 <7C
for safety  '  '  . Shielded cathodes are  submerged and usually run
along both sides of the tank.
(2)  Power Supply
    Direct  current electrical power is supplied by a rectifier with  a
capacity of approximately 30 to 300 volts and 300 to 750 amperes,
depending on the number of square feet per  minute to be finish-
ed62'63'64.
(3)  Heat Exchangers
    Paint drawn from the dip tank is passed through a heat exchanger
to dissipate heat which is developed during the "painting" operation.
The temperature is normally main
24°C (+ 2°F of 68 to 75°F)62'71'76.
The  temperature is normally maintained  at  within +  1°C of 20  to
(4)  Filters
    An "in-line" filter is also  placed  in the recirculating system  to
remove dirt and polymer agglomerates from the paint.
(5)  Pumps
    Circulating pumps are used to keep the paint solution moving.
(6)  Paint Mixing Tanks
    Paint  mixing tanks are used to premix and store paint solids for
addition to the dip tank as needed.
(7)  Control Panel
    The electrodeposition  process is generally  controlled  from  a
central control console.  This  panel contains all start-stop switches
plus instruments for monitoring voltage,  amperage, paint tempera-
ture, and pH.
                               4-20

-------
        Proper pretreatment can be critical to paint performance - particularly if the
substrate has  grease  or  oil  on the surface.  Solvent-borne  paints  will generally
                                                        77 78
"dislodge" an occasional oil spot, but water-bornes will not  '  .  Cleaners developed
for conventional systems are generally adequate for EDP, however.
        Painting in the dip tank is affected by voltage, current density, temperature,
                                79
dwell time, pH, and solids content  .
        By increasing  the voltage or the  temperature in the bath, the film thickness
can  be  increased.   Excessively high voltage will cause holes in  the films due to
gassing,  however.   Too high  a temperature is  also undesirable;  some  paints will
flocculate at temperatures approaching 90°C.
        At high pH, there  is a reduction  in the depostion; if the  pH drops below the
isoelectric point, the entire tank of paint can coagulate.
        If the solids content in the tank is too high, the voltage cannot "wring" the
moisture from  the deposited film; if the bath is too dilute, then the film will be thin,
             _o
below 2.54x10  mm  (one mil).
        For successful operation of an EDP system it is necessary to monitor on a
regular  basis:  voltage, amperage, pH,  temperature, and solids and organic solvents.
For  satisfactory  appearance of the  final finish,  it is important to rinse the parts
thoroughly after painting; the final rinse should be with deionized water.
            Ultrafiltration Rinsing
               A portion of the bath  is pumped through an Ultrafiltration
            membrane to provide permeate for rinsing of parts  emerging
            from  the  tank.  The permeate collects into a tank of suitable
            capacity.   Permeate is  delivered from the holding tank #3 for a
            final rinse.
            Waste Treatment
               The liquid in the waste treatment tank is monitored for pH.
            Such a  system treats accumulated  wastes from  the ultrafilter
            rinses and drains and raises their pH to precipitate the resin prior
            to dischaging  to  drain.   The precipitate  forms  a  rubber-like
            material in a chamber that is readily cleaned.  The remaining
            solution passes into the plant's waste  system.
                                       4-21

-------
        Furniture parts painted with EDP are  normally baked from 15 to 30 minutes
at 135 to 205°C (275 to 400°F).
        Solvent  emissions are related to  both  paint composition and production rate.
The greater the quantity of solvent in the water-borne coating, the  greater the air
emissions.  Solvents used are high molecular weight alcohols, added  to aid in fusing
the paint particles into a continuous film.
        Production  in terms of square meters per hour has an influence on emissions:
the higher the rate, the greater the emissions.  This rate depends on  the  area of the
parts, their spacing on the conveyor, and the conveyor speed.
        Emissions are also influenced by coating thickness; thicker coatings will carry
a greater amount of  solvent.  The  thickness depends  on the "throwing power"  used
during the deposition - i.e., the voltage and amperage applied across the electrodes.
Normally there  are no transfer efficiency problems with electrodeposition;  with the
                                                                        74
use of ultrafilters nearly all of the  paint solids are transferred to the part  .  There
can be dripping associated  with dragout, but this material is recovered in the rinse
water and returned  to the dip tank.
        The emission reduction capacity  of EDP is related to the solvent content of
the paint, and the percent solids of the paint as the  part emerges from the bath, both
of which influence  the weight of  solvent associated with applying a given weight of
dry paint solids.  Of  course  the  percent emission reduction is also  related  to the
emission level  for the  solvent-borne paint being replaced, which  can  also vary,
depending on the percent solvent in the paint and the transfer efficiency.
4.1.2.2. Water-Borne Spray
        While spray painting with water-bomes has found relatively little use in the
metal furniture industry  to date, there is fairly widespread use of  this  technology
throughout much of  the industrial  finishing industry.  Typical  applications include
.   ,  ^ . ,    .      ,.80        ..,  ,.      ^ 81.82,83    •   84    j    .  85,86 .
industrial equipment   ; automobile topcoats   '  '  , engines  , and parts  '   ; farm
          87      88                    89 90                    91
machinery  ; cans  ; computer  cabinets  '  ; business  machines   ;  and  air  con-
        92                          68
ditioners  ; as well as metal furniture  .
        A recent  survey  of  100 major appliance;  air conditioner; and business,
vending, and commercial machinery firms indicates that,  15 were using water-borne
              93
spray painting  , compared to 11 using electrodeposition and 8  using either flow or
dip coating.
                                       4-22

-------
        Most of the solvent-borne paint presently being used for indoor home, office,
                                                                            94 95
and institutional furniture is alkyd and  to a lesser extent acrylic and polyester  '  .
It  is  likely that  in  converting to water-borne finishes,  these same  binders will
continue to be used.
        Since  water-borne paints are readily atomized, they can  be applied  by air,
airless, or electrostatic spray or electrostatic disc, using either manually operated or
                93 96
automatic  guns  '   .    With  both  water-borne  and solvent-borne  paints,  being
relatively low viscosity fluid systems with approximately the same solids content, few
if  any modifications are generally required in order to convert from the use of one
paint to the other. Some water-bornes are corrosive due to high pH, requiring the use
of stainless steel or plastic pipes and  pumps   '  ,  and stainless steel  or aluminum
spray nozzles.
        Electrostatic spray presents no problems, but for  safety reasons  because a
highly conductive fluid is being used, pumps, lines, guns and paint  supply tanks  must
                                54
generally be insulated or isolated  . One unique gun design allows for changing of the
paint particles  at the gun, obviating  the  need for isolation  of  the  rest  of the
system
        Water-borne  paints are generally water-reducible coatings with some emul-
sions being used.  The water reducible materials are thermosetting paints with 25 to
                        54 57
40 volume  percent solids  '    and a ratio of 82/8 to  88/12 water to organic solvent in
the volatile portion of the paint.
        With water-borne paints, as with any solvent containing paint, the emission of
volatile organics into the air is dependent on the percent solvent in the paint and the
thickness of the coating that is applied.
        In addition, the emissions are influenced by the number of units  produced per
hour and the surface area of each unit.
        One critical  factor in any spray operation,  a factor that can have a serious
effect  not only  on  emissions but on  cost  and  secondary  pollutants, is transfer
efficiency  -  that percentage  of the spray paint that actually  deposits on the  part.
With  conventional spray being  used, transfer efficiencies are normally in the range of
30 to 60 percent.  If electrostatic spray is  used,  transfer  can increase to 70 to  90
        29
percent  . The variation in percent transfer for a given spray technique is influenced
by part geometry and in the case of manual spray, by the spray gun operator.
                                       4-23

-------
4.1.2.3  Water-Borne Dip
        Water-borne dip  coating  has  also  found relatively little use  in  the metal
furniture industry to date, but as  with water-borne spray coating there is increasing
use of this technology  throughout the industrial finishing industry.   Reports from a
recent symposium on water-borne coating systems indicate that water-borne dipping
enamels are finding use as  primers  and  one coat finishes  in industrial  finishing
                                    -3                                 98
applications where a nominal 2.5 x 10   cm (1 mil) thick finish is desired  .  Present
use of  dip  coating includes  applications  such  as primers  for bicycles  and au-
,.  99,100,101  ^     x  .      .     ,.         ,93
tos  '    '    , topcoats for major appliances, etc.  .
        Most of the solvent-borne finishes  for metal furniture are applied by either
                    £C
spray or dip  coating   .   Therefore for a finisher already  applying  dip coatings,
conversion to water-borne paint should  be  relatively simple,  requiring the  replace-
ment of the dip tank with a tank of stainless steel or other inert material.
        One  industry  expert feels that water-borne  dip coats should  make good
                                                    59
penetration into the metal furniture and  fixture market   , but  the occasional problem
                                                               1 no
of poor appearance due to runs and drips may slow this penetration    .
        The water-borne  dip process is nearly identical to  that for solvent-borne
materials, the major difference coming in the dry and bake schedule.  As with water-
bornes applied by other methods a longer slower drying schedule is required in order
to prevent blistering of the coatings.
        The factors governing emission of solvents are the same as for spray coatings
discussed above.  In the  case of  dip coating, the transfer  efficiency is nearly 100
percent with only some small losses due to dripping in some operations.
4.1.2.4. Water-Borne Flow Coating
        Flow coating is a finishing technique that is used for painting a wide variety
of products  including,  farm equipment,  appliances,  machinery, electrical equipment,
                   93  189 190
and air conditioners  '    '    , as well as furniture.
        In flow coating, paint is made to flow  or cascade over the part to be painted,
by squirting the paint  onto the part through small nozzles.  These nozzles are often
mounted in  the bottom of the coating cabinet, where they create a  column of paint
through which the  parts must pass. Excess paint flows to the bottom of the cabinet
where it is collected and reused.
                                       4-24

-------
        Since  flow  coating involves the use of a fluid paint, conversion from organic
solvent-borne  to water-borne materials is logical; such conversions have been made in
                                   92 93                      187
the major appliance, air conditioner  '  , and trailer industries   , as well as in the
                       188
metal furniture industry
        Once  again, the factors governing emission of solvent vapors to the air are
the same as for spray coating discussed  above.  In the case of flow  coating,  the
transfer efficiency is in the range of 75 to 90 percent.   Hollow articles may receive a
coating inside where it is unnecessary - and therefore result in low effective transfer
efficiency.
4.1.3.   Higher Solids Coatings
        Higher solids coatings  hold the potential of being able to  apply  the  same
weight  of  paint  solids  with reduced emissions of  volatile organic  solvent.   Such
coatings fall  in  the general categories of radiation  curable systems,  "high-solids
coatings",  and powder coatings.   Powder coatings  have  already  been  discussed
(Section 4.1.1. - page  4-1).  Radiation-cured coating involves the  photocuring of
mixtures of low molecular weight polymers or oligomers dissolved in low molecular
weight  acrylic monomers.  These  formulations contain no solvent  carriers and  can
cure using either electron beam  or ultraviolet light sources to essentially  100 percent
solids coatings   '    '    .  These coatings have generated little interest in the metal
furniture industry, presumably because of the health hazard associated with the  spray
application of these relatively toxic monomer mixtures and the difficulties involved
in obtaining adequate cure of the paint when applied to irregularly shaped substrates.
        High-solids coatings are a relatively new family of materials that is currently
being developed and investigated in the automotive, can, coil, appliance, and metal
furniture industries.  The attraction of such  coatings seems based  on a low solvent
content, the promise of application with modified conventional finishing equipment,
and  the promise  of energy  savings through the  use of more reactive systems.
Although the traditional definition of high solids as specified in "Rule 66" indicates no
less than 80 volume percent solids    , most of the people in industry are considering
everything from 50 percent to 100 percent.
        There will  very likely be no radically new resin binders associated with high-
solids coatings; most are modifications of their low-solids counterparts. The coatings
can  be  categorized  as  either   two-component/ambient-curing   or   single-com-
ponent/heat-converted materials.
                                       4-25

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        The  coatings  that  are  of the  most immediate  interest  are  the  two-
component/ambient-cure materials; they offer  not only a reduced solvent content but
also a tremendous energy savings  since  they require little or no baking.   Resin
systems   being  investigated   include  epoxy-amine,  acrylic-ure thane,   and  ure-
thane106'107'108'109.
        The  heat-converted,  high-solids  coatings being  developed  include  epoxy,
acrylic, polyester, and alkyd    .  Most contain reactive hydroxyls or carboxyls which
allow crosslinking  with amino compounds  such as  hexamethoxy  methylmelamine.
There  coatings  are  baked  at temperatures  similar  to  low-solids  counterparts -
nominally 150 to 175°C (300 to 350°F).
        The  most significant problem  with high-solids coatings is  the  high working
                                                                108
viscosity of the high-solids solution (i.e., 60 to  80 volume percent)    .  The viscosity
can  be  controlled  to some  degree by  reducing the  molecular  weight of the base
polymer or by using reactive diluents,  but  these techniques  can result in a greatly
altered product  with inferior  properties.   A  more  effective  means of  reducing
                                                  108
viscosity is to heat the coating during the application
        Heated high solids can  be applied as airless, air, or electrostatically sprayed
                               1 C A
finishes from heated equipment   , and can be roll-coated. One new type of coating
apparatus, the high-speed turbine disc or bell,  seems particularly well  suited to the
application of  high-solids  coatings since the coatings can be  applied without heating
of the paint160'161.
        While it  is generally agreed that high-solids  coatings hold a great deal of
promise, they are still an  emerging technology and must be considered to be  still in
                                                                    on  §
                                                                      163
             1 fi2
their  infancy   .  Of the approximately 1514  million liters (400 million  gallons) of
industrial finishes consumed in 1975, less than 1 percent were high solids
        Principal  uses  for high-solids  coatings  are  presently  in coil  and  can
coating   .  While there has been a great deal of interest in high-solids coatings in
                              95
the industrial finishing industry  , there are only a f
furniture industry at the present tjme95.160>165'166.
                              95
the industrial finishing industry  , there are only a few production lines in the metal
        The current  usage of high solids paints in  the  industrial  finishing industry,
including the  metal furniture industry, generally involves the application of "higher
                                                                              i fis
solids" or intermediate solids materials, that is 40  to 55 volume  percent solids
While the use of high solids coatings (i.e. 70 to 80 volume percent solids) is feasible
and  has been  demonstrated  on at least one institutional metal  furniture finishing
                                       4-26

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    166
line   , "higher solids" coatings of 65 volume percent solids are generally considered
to  be  the practical  upper limit  at the present time  for industrial finishes.  For
materials above  65  volume percent solids there are often adhesion and application
problems resulting from the high viscosity and low solvent content of these paints.
4.1.4.   Carbon Adsorption
        Carbon  adsorption  as a  technique for solvent  recovery has  been  in use
commercially for several decades.  Applications include recovery of solvent from dry
cleaning,  metal degreasing, printing operations, and rayon manufacture   .   While
adsorbers have not been used in the metal furniture finishing industry they have been
used in other industrial finishing industries   '   '   ,  and although the recovery of
coating solvents from industrial finishing operations using adsorption is not without
some technical problems, the  process is essentially no different from any other being
used for solvent recovery.
        The  adsorption process  is  made possible through the  use  of  specially
"activated"  carbon,  which has a fine pore structure and therefore a  tremendous
surface area per unit weight - as great as 1,000,000 square meters per kilogram    .
Through secondary bonding and  capillary  action, this  carbon  can adsorb onto  its
surface large quantities of volatile organics.
        A typical adsorption unit  is shown  in Figure 4-5.  Air containing the organic
vapors is passed through a filter to remove particulates and then through a  cooler to
reduce  the  temperature of the gas  to no  greater than  38°C.  A blower forces the
vapors through one of two adsorbers, packed with activated carbon.  Two  units are
normally adequate for continuous operation; one unit can be operated while the other
is being regenerated.
        During the course  of operation, the carbon  becomes saturated with organics,
and it  is necessary to  regenerate.   The organics are desorbed from  the carbon by
                                               11B
passing either steam or hot gases through the bed    .  The revolatilized organics are
then recovered downstream in a condenser. The regenerated gas can also be directly
incinerated, which is always the case for hot gas regeneration.
        For most industrial applications, adsorption is  used to recover solvents for
reuse.   Coating solvents used in industrial finishing, however, are  normally complex
                                                              118 119
mixtures of aliphatics,  aromatics, esters, ketones, alcohols, ect.   '    . To recover
such solvents  with  sufficient purity  for reuse  would  require  costly fractional
                                       4-27

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                            Figure 4-5.   DIAGRAM OF AN ACTIVATED-CARBON ADSORBER SYSTEM
to
oo
                        Vapor laden
                        air inlet
Stripped air
to atmosphere
           Condenser


            Decanter
                     Filter
                      and
                     Cooler
                                                                                                  Recovered
                                                                                                     solvent
                       Water
    Stripped air
    to atmosphere
                                             Low-pressure
                                                steam
                    From Adsorption,  by Mantell.  Copyright 1945, 1951 by the
                    McGraw-Hill Book  Company, Inc.  Used with permission of the
                    McGraw-Hill Book  Company.

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distillation, which is probably not economically feasible.  The most practical use for
these solvents, since they are all flammable, is incineration.  The heat generated can
                                                                            120
be used to produce some of the steam necessary for regeneration of the adsorber
        There are several variables which effect the performance of carbon adsorbers
and  most are related to the  adsorptive capacity of  the carbon.  This adsorptive
capacity, the weight of solvent that can be retained on a given weight of carbon, can
                      121 122
be expressed as follows   '    :

                                               V
            Adsorptive capacity             -
                g solvent
            in  —	
                g carbon
   Where   V     =    liquid molar volume of pollutant at normal boiling point
            T     =    absolute temperature
            CQ    =    concentration of saturated vapor
            C.    =    initial pollutant vapor concentration into adsorber

        The liquid molar  volume of a given solvent is related to both its molecular
weight and density at the boiling point.  In general,  the greater the V  of the solvent
the higher the molecular weight and therefore the boiling point.  In other words,
carbon will generally have a greater adsorptive capacity for higher boiling solvents.
        For these compounds with relatively  high  V  , adsorption will occur, but
because  of their  low  vapor pressures desorption  becomes  difficult.   Generally,
                                                       3
solvents with  a molar volume of between  80 and 190 cm /mole present no problems
                                 123
with adsorption and  regeneration   .   Fortunately most  of  the  solvents used in
industrial finishing fall within  this  range.   Table  4-5  lists  some  of the  problem
solvents for carbon adsorption.  Of the solvents listed, nonane  (a component of most
grades of mineral spirits) is  commonly used in metal  furniture finishing.  Mineral
spirits are used in substantial  proportions  in  many alkyd  and acrylic  enamels but
                                                                     124
should be effectively desorbed with either super heated steam or hot gas
                                       4-29

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Table 4-5. PROBLEM SOLVENTS FOR CARBON ADSORPTION

                                          Boiling Point

 Solvent                  Vmcm3/mo1      F
 Dodecane                    274          421     (216)
 Undecane                    251          383     (195)
 2-ethylhexyl acetate           238          390     (199)
 Decane                      229          345     (174)

 Butyl carbitol                213          448     (231)
 Nonane                      207          302     (150)
 2,6-dimethyl4-heptanone      207          345     (174)
 Diethyl cyclohexane           207

 Butyl cyclohexane             207          345     (174)
 1-methyl pentyl acetate        194
 Diethyl cyclopentane          192          307     (152)

 Nitroe thane                   75          239     (116)
 Propanone                     74          133     (  56)
 Dichloromethane               65          104     (  40)

 Ethanol                       61          173     (  78)
 Nitromethane                  53          214     (101)
 Methanol                      42          149     (  66)
 Source:  Stern, A.C. Air Pollution.  Academic Press, New
          York. Vol. II, Second Edition, Chapter 16 (1968)
                          4-30

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       Temperature  of  the  inlet gas stream  also affects adsorptive  capacity; the
higher the temperature the lower the adsorptive capacity.  At temperatures in excess
of approximately 38°C,  solvents which are normally adsorbed and desorbed  with no
difficulty will be poorly retained by the carbon   '   .  Low inlet vapor concentra-
                                                    127
tion also has an adverse effect on adsorptive capacity   ,  and  of course capacity is
also affected  by the  surface area of the carbon as influenced by particle size and
degree of porosity.
        Although adsorption will generally remove 90 percent or more of the volatile
organics from a gas stream, this performance tends to deteriorate with time  as the
active sites on the carbon surface are depleted.  This is shown graphically in Figure 4-
6. Although the performance begins to deteriorate after 500 minutes (i.e., effluent
concentration starts to increase), the carbon is not completely exhausted until 1000
minutes  have elapsed.   The overall performance  of an adsorber, then,  is  largely
dependent on  when and  how completely the unit is regenerated.  If  the unit in the
example given is regenerated after every 500  minutes, the overall performance will
be quite high, but the cost of treatment will also be higher than with longer cycle
times as a result of more frequent regeneration. Normally  there will be some trade-
off between cost and performance.
        The size of a given adsorber is determined by the adsorptive capacity of the
carbon and the quantity of volatile organic to be removed.  Of course the  adsorptive
capacity will depend on the V  of the solvent or solvent blend.  In the case of mixed
solvents, the bed depth necessary to adsorb each of the vapors can be estimated from
the sun-
stream
the sum of the bed depths necessary to remove each vapor if it were alone in the air
      .128
       The cross-sectional area of each bed is  determined from  the  volume of air
that must flow through the unit.  A face velocity (defined as flow rate in CFM or
cubic meters per minute divided by the cross-sectional area) of 9.1 to  30 meters per
minute (30 to 100 feet per minute) is normally used to avoid excessive pressure drop
      1 the
      ,130
               129
through the bed    and to get an effective utilization of the equilibrium capacity of
the bed
       In the  metal furniture  industry the solvent emissions of greatest concern
come from two general areas, the application and flash-off area, and the bake oven.
                                      4-31

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                             Figure 4-6.    EFFLUENT CONCENTRATION CURVE OF  BUTANE VAPOR

                                       FROM AN ACTIVATED CARBON BED AS FUNCTION OF TIME
                                                                      135
                     100
                      80
CO
to
                a
                a
c
o
•l-t
-p
n)
M
4J
c

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        In the case of spray booths, adsorbers must be designed  to handle air with a
high water vapor content.  This high humidity results from the use of water curtains
on  both  sides  of  the  spray  booths  to  capture  overspray.    Although  carbon
preferentially adsorbs organics, water will compete for available sites on the carbon
surface. Generally the relative humidity should be kept below 80  percent to minimize
           131
the problem
        The  exhaust  from the  spray  booths, particularly  during  periods of  cool
                                                         132
ambient temperatures, can reach saturation with  moisture    .   One solution to this
problem would be to preheat the  moisture-laden air to lower  the  relative humidity to
                         _                           1 ^1
below 80 percent; a 4 to 5  C heating would be sufficient
        Prior to adsorption, particulates from oversprayed paint  have to be removed
from the air streams,  since this material will coat the carbon or  plug the interstices
between carbon particles.  Such plugging will destroy efficiency and increase pressure
drop through the bed.  Such  particulates can be  removed by using either a fabric
     131
filter    or the combination of a centrifugal wet separator plus prefilter and bag
filter134.
        Another variable  which  should  be considered in designing an adsorber for
metal  furniture finishing  application  is  the  potential  variability  of  the  solvent
systems between different grades  or types of paint.  Although all conventional low
solids paints contain the same families of solvents (i.e., glycol ethers, esters, C0 and
                                                                            o
Cg  aliphatics,  etc.),  the  various paints employed can differ widely  with  regard to
specific compounds and relative proportions.  Solvent systems therefore could differ
in their adsorptive  capacity  and,  as a result, their  ability to  be removed by the
adsorber.  On  lines where different grades of paint  are used  from  time to time,
adsorbers will probably have to be over designed in adsorptive capacity.
        Ovens  are  the second important source of solvent emissions;  it  has been
estimated that approximately 10 percent of the volatiles from a solvent-based paint
                       132
are emitted in the oven    ; the remaining  90 percent goes off in the application area.
        The individual solvents in an application area  tend to evaporate at different
rates.   The 90 percent of the solvent that is emitted in  the application  area  will
comprise a large percentage of 'low boilers" such as acetone, butanol, toluene,  etc.
The 10  percent which  remains in the film as it enters the oven contains primarily less
volatile solvents.  Therefore,  adsorbers for ovens  will have to be  designed to handle a
different solvent mix  than is  found with the application areas. High-boiling solvents
                                       4-33

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may not be consistently and completely stripped during regeneration, in which case
more frequent replacement of the carbon would be likely.   In any  case, hot gas or
                                                        124
super heated steam regeneration would probably be required
        In the oven, high temperatures and flame contact with the volatiles can cause
polymerization of degradation products into high molecular weight resinous materials
which can deposit on and foul the carbon bed.  Various high molecular weight volatiles
in the coatings such as oligomers, curing agents, or plasticizers could cause a similar
problem.  Filtration and/or condensation of the oven exhaust air would be necessary
prior to adsorption in order to remove  these materials.
        In order to  get satisfactory performance,  it will also be necessary to cool the
oven exhaust to a temperature no greater than 38°C.  Without cooling, many of the
                                                                    125 126
more volatile organics will not adsorb but will pass through the adsorber   '
4.1.5.   Incineration
        Incineration is  the  most universally suitable  technique for  reducing the
emission of volatile organics from  industrial processes;  in  the  industrial finishing
industry these volatile organic  emissions  consist mostly of solvents  made  up of
carbon,  hydrogen,   and  oxygen,  which can  be  burned  or  oxidized  in  specially
constructed incinerators into carbon dioxide and water vapor.
        Industrial incinerators or afterburners  are  either  noncatalytic (commonly
                                          136
called thermal or direct fired) or catalytic   , with sufficient  differences between
the two to warrant  a separate discussion for each.
4.1.5.1. Thermal Incinerators
        Direct-fired units  operate  by  heating  the  solvent-laden  air  to near  its
combustion temperature and  then bringing  it  in  direct contact  with a flame.   A
typical unit is shown schematically  in Figure 4-7. In general, high temperature and
organic  concentration  favor  combustion;  a  temperature  of  760°C  (1400°F)  is
generally sufficient for near complete combustion.
        To prevent a fire hazard, industrial finishing ovens are seldom operated with
a concentration of solvent vapor in the air greater than 25  percent LEL, and some
operations - particularly ovens - in  the automobile and light duty truck industry can
achieve concentrations of only  5 to 10 percent LEL.  These low concentrations are
the  result  of high air flows necessary in order to prevent escape of oven gas at oven
openings and to prevent condensation  of high-boiling organics on the inner surfaces of
        137
the oven
                                       4-34

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Figure 4-7..  FORCED-DRAFT SYSTEM ELIMINATING SOLVENT VAPORS

                    FROM SURFACE COATING PROCESS140
Process
 Fumes
 Coicbustor
                    Fan
                   Hot Clean
                     Gas
                                    \
                                                        Cooled
                                                        Clean
                                                          Gas
                   I
Single-Pass

Heat Exchanger
Stack
      Preheated Process Fumes
                          4-35

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       Since  the solvent emissions  are  below  the  combustible limit,  auxilliary
heating of the air is necessary for incineration.  The quantity of heat to be supplied is
dependent  on the concentration of the organic in the air  stream;  the higher the
concentration the lower the auxiliary heat requirement because of the  fuel value of
the organic.
       For most solvents, the fuel value is equivalent  to 4.45 gram-kilocalories per
cubic meter (0.5 BTU/scf), which translates into a temperature rise of approximately
15.3°C (27.5°F) for every percentage point of LEL that is incinerated.  For an air
stream with an organic solvent content of  25 percent of LEL, the contribution  from
the heat of combustion  of the solvent would be approximately 115 gram-kilocalories
per cubic meter (13 BTU/scf)    , equivalent to a temperature rise of 345°C (620°F).
       If  the  desired exhaust temperature  is 816°C  (1500°F),  then  the  inlet air
stream would have to be heated to only 471°C (880°F). On the other hand, if the
process air contains  only 10 percent LEL, as is  the  case  with the exhaust  from
automobile bake ovens, then  the solvent would  contribute only 135°C  (275 F) and the
air entering the incinerator would have to be preheated to 681 C (1225  F) in order to
attain the same final temperature, 816°C (1500°F).
       To make thermal incineration less costly, heat transfer devices are often used
to recover some  of this heat of combustion.  Primary heat  recovery  is often in the
form  of  a  recuperative heat exchanger, either tube or plate type, which is used to
                                                           140
preheat the incoming process fumes as illustrated in Figure 4-7    .  Units of this type
are capable  of recovering 50  to  70 percent  of  the  heat  from  the  original fuel
input140'141.
       A more satisfactory type of heat recovery device and one  that finds wide use
in fume  incineration equipment is the regenerative heat exchanger,  both refractory
                     140
and rotary plate types   . Units of this type are capable of heat recoveries of  75 to
           142 143 144
90  percent   '   '   .   In some cases  secondary recovery  is also used to convert
                                                                            140
additional exhaust heat into process steam or to warm "make-up" air for the plant
       There are several operating parameters which affect  the  emission reduction
potential of thermal incinerators; following are  the most significant ones:
                                      4-36

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            For efficient combustion of the hydrocarbons in the air stream it
       is necessary to have sufficient temperature and residence time in the
       incinerator.   Figure  4-8. shows the  combined  effect  of these two
       parameters. Insufficient residence time results in incomplete combus-
       tion and the generation of carbon monoxide.  A residence time of 0.3
       to 1.0 seconds is typical.
            If the air  stream to the incinerator contains sulfur-, nitrogen-or
       halogen-containing  organics there  will be  a  secondary  pollution
       problem.   Incineration of  these  materials will produce sulfur and
       nitrous oxides  and  acids such  as  hydrochloric and  hydrobromic.
       Fortunately  none of  the  solvents used  for metal furniture finishing
       contain these elements.
            Solvent type can also influence incinerator performance.  While
       593  to 677°C  (110-1250°F) is adequate to  combust  most  solvent
       vapors, certain organics require temperatures of 760 to 816°C (1400 to
           s\                              1 Q C
       1500 F) for nearly complete oxidation
        On a finishing line in the metal furniture industry, the two potential areas for
the use of incinerators are again on the application section and on the ovens used for
baking.
        Although  a survey  of  the metal  furniture  finishing  industry  found  no
incinerators in use on bake ovens, such an application presents no significant problem.
Thermal incinerators are in place on ovens  in several automotive assembly  plants,
                        145  146 147                              148     149
particularly in California   '   '    , as well as in plants in the paper    , can   , and
coil coating industries    '   . Typical emission reductions with such units is over 90
percent. Since  the air  exiting the ovens  is generally  at a temperature  of  120 to
150°C (250 to 300°F),  the air preheating requirements are less than they would be for
incoming air at ambient temperature.
        Incinerators on the bake ovens are controlling  approximately 10 percent of
the solvent emissions;  the remaining 90 percent of the volatiles are emitted in the
application and flash-off areas.
        Although incineration of the air from application areas is possible, our survey
revealed no applications in  the  metal furniture finishing industry.  Because of the
relatively large  air flow in spray booths, and the resulting low solvent concentration
                                       4-37

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CO
oo
       •M
       C
       0)
       o
       M
       0)
       cm
       o
       •H
       -p
       o
       en
       at
       a

       -p
       c
        o
        CM
                    Figure 4-8.   COUPLED EFFECTS OF TEMPERATURE AND TIME ON RATE OF POLLUTANT .OXIDATION 135
          100
           80
           60
40
           20
           0
                  Increasing

                  Residence

                     Time
             600
              800
1000
                                           Increasi
1200         1400


      mperature,
1600
1800
2000
                                        nagBte

-------
of the air stream, large quantities of natural gas or equivalent fuel would be required
to heat  the vapor-laden air from near ambient to the 700 to 760°C (1300  to 1400°F)
necessary to effect near complete combustion.
4.1.5.2.  Catalytic Incineration
        This add-on control method  makes use  of a metal catalyst to promote  or
speed combustion  of volatile organics.  Oxidation takes place at the surface  of the
                                                                           1 *^fi
catalyst to convert organics into carbon dioxide and water; no flame is required
        A schematic of a typical catalytic afterburner is shown in Figure 4-9.  The
catalysts, usually noble metals such as platinum  and  palladium, are supported in the
hot gas stream  in such a way that  a high surface  area is presented to the waste
organics.  A variety of designs are available  for the catalyst,  but  most units use a
noble metal electrodeposited on  a high  area support  such  as  ceramic rods  or
                           136 152
honeycomb or alumina pellet   '
        As  with  thermal  incinerators,  the performance of  the catalytic  unit  is
dependent on the temperature of the gas passing across the catalyst and the residence
time. In addition, the efficiency of the afterburners varies with the type of organic
              152
being oxidized    .  These effects of temperature and organic type are  illustrated
graphically in Figure 4-10.  While high temperatures  are  desirable for good emission
                                        3 649°C  (
                                        ,136,152
reduction, temperatures in excess of 593 to 649°C (1100 to 1200°F) can cause serious
erosion of the catalyst through vaporization
       The use of a catalyst permits lower operating temperatures than are used in
direct-fired units; temperatures are  normally in the range of 260 to 316°C (500  to
600°F) for the  incoming air  stream and 399 to  538°C (750-1000°F) for the exhaust.
The  exit  temperature  from  the  catalyst  depends on  the  inlet  temperature, the
concentration of organic, and the percent combustion.  The increase in temperature
results from the heat of combustion of the organics being oxidized.
       As with thermal  incinerators, primary  and secondary heat recovery can be
used to  minimize auxiliary  heating  requirements for the inlet air stream and  to
reduce the overall energy needs for the plant (see page 4-36.  Although catalysts are
not consumed  during  chemical reaction, they do  tend to deteriorate with  time,
causing a gradual loss  of  effectiveness in burning the organics. This deterioration is
caused by poisoning with chemicals such as phosphorous and arsenic, which react with
the catalyst; by coating the catalyst with  particulates  or condensates; and  by high
                                      4-39

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                      Figure 4-9.

   SCHEMATIC DIAGRAM OF CATALYTIC AFTERBURNER USING

    TORCH-TYPE PREHEAT BURNER WITH FLOW OF PREHEAT

    WASTE  STREAM THROUGH  FAN TO PROMOTE  MIXING 135
                        Clean Hot Gases
Catalyst
Elements
                                          Oven Fumes
                                          Preheater
                       4-40

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             Figure 4-10.  EFFECT OF TEMPERATURE  ON
             OXIDATIVE CONVERSION OF ORGANIC VAPORS
                 IN A CATALYTIC INCINERATOR
                                            135
100
                      Temperature,  C  ( F)
                            4-41

-------
operating temperatures,  which tend to  vaporize  the  noble metal.   In  most cases
                                                              153
catalysts are guaranteed  for one year by the equipment supplier   ,  but  with proper
filtration, cleaning, and attention  to moderate operating temperatures the catalyst
should have a useful life of two to three years   ''.
        Although catalytic incineration has the potential for reducing  volatile organic
emissions, our survey  found no units in regular use in the  metal furniture  finishing
industry.
        While  catalytic incinerators can probably be adapted to baking ovens with
relatively little  difficulty,  the  use of  these  add-ons  for controlling spray booth
emissions will present the same design considerations that were discussed for thermal
incinerators.  These factors include high air flow, low vapor  concentration, and the
need to incorporate a  highly efficient heat recovery system in order to minimize the
need for auxiliary heating of inlet air.
4.2.     EMISSION REDUCTION PERFORMANCE OF CONTROL TECHNIQUES
        Emissions can  be  controlled either through the use of "new coatings" or "add-
on" control  devices. The  emission  reduction associated with add-ons is related to the
ability of the technique to either capture or destroy the organic solvent emissions.
        The emission reduction potential for new coatings, however, is related to the
quantity of volatile organic material in  the "paint" before application and cure.  The
emissions of any paint can be expressed quantitatively  in terms of the amount  of
solvent or other volatile  organic emitted per unit  of dry coating resin applied to the
substrate.   These relative  solvent emissions (RSE) can be  derived from the weight
                                              108
percent solids of the coating materials as follows    :
                         RSE = % Organic Solvent/% Solids
        It can  be shown  that the  relative organic solvent emissions are  not only
dependent  on the  solids  content of the paint but  rise  exponentially as the solids
                 108
content is lowered
        The RSE of any paint/application method is also related to the deposition  or
transfer efficiency; that is, the percentage of the paint used that actually deposits on
the substrate.  For spray application, 30 to 60 percent  is  normal when  using air  or
airless spray, while the electrostatic spray techniques will permit depositions of 60  to
90 percent. The RSE then can be expressed as:
               RSE =  % Organic Solvent/(% Solids) (% Deposition)
                                       4-42

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4.2.1.   Powder Coating - Electrostatic Spray
        There is a tremendous emission reduction potential associated with the use of
powder coating materials which are nearly 100 percent solids.
        Some powders emit  small  percentages  of volatile organics during fusion or
cure, and the type and amount tends to vary with the generic type of binder used.
For  thermosetting powders,  the  emission of  organic volatiles for  various resins in
weight percent is as follows:  Epoxy - 0.5% to 3.0%; polyester (urethane type) 2.0% to
4.0%;  polyesters  (other  types)  - generally less than 1%;  and acrylics  -  0.5%  to
1.0%   '    .   For thermoplastic powders  such as  polyvinyl  chloride and cellulose
acetate butyrate, organic volatile  emissions  can run as high as  5 to 10% due  to
                                                     184
evaporation of plasticizers from the powders during cure
        With electrostatic spray of  powder  coatings, the  powder  which does  not
deposit on the part to  be painted is  mostly contained in  the spray booth.  With
properly designed equipment, the  oversprayed  powder can  be recovered, providing
overall transfer efficiencies  in the range of 83  to 98 percent.  See Table 4-2,  page
9.    The  RSE when adjusted for  transfer efficiency becomes 0.021 to  0.134; and
when compared against  conventional solvent-borne lacquers and enamels, there is a
potential emission reduction in the range of 94 to 99%.
4.2.2.   Powder Coating - Fluidized Bed
        The same basic  emission reduction considerations that were  presented  for
electrostatic spray of powder coatings apply to fluidized bed coating.
        In general, the powder, other than that deposited on the parts, is contained in
the bed. A small amount of unfused powder is generally carried with the coated part,
however.  This powder is usually blown-off and recovered.
        Overall  emission reduction then is again high, in  the range of 94 to  99
percent.
4.2.3.   Electrodeposition of Water-Bornes
        The electrodeposition process, as described  on page 4-15 has  three possible
sources of organic solvent emission: the painted substrate as it is baked, evaporation
from the surface of the  EDP tank, and evaporation of  organic solvent from  the
cascading rinse water and the drain.
                                      4-43

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       The paint films on the substrates are approximately 95 percent solids as they
emerge from the bath.  The remaining 5 percent is primarily water with only 3 to 5
                                        1 *\fi
percent of the volatiles as organic solvent
       Another more likely  source  of  fugitive emissions is  escape of the  organic
solvent into the rinse water.  During operation, a portion of the paint from the EDP
tank is pumped through an ultrafilter; the permeate is generally is used for rinsing
purposes,  while  the paint concentrate is returned to the tank.  Since ultrafiltration
                                                        157 158
will  remove nothing smaller than  500  molecular  weight   '   ,  a portion of the
                                                                  1 ^fi
water-miscible organic solvents such as alcohols  and glycol  ethers   , which have
molecular weights under 150, will likely end up in the permeate.
       The permeate is  then used  for spray rinsing where the high surface  area of
the spray  is conducive to evaporation. Depending on the water requirements for the
closed loop system, some of  the permeate is  sent to  the  drain.  It is possible that
much of the organic solvent may be lost in this manner.
       Since the quantities of organic solvent involved with EDP are quite small by
comparison with organic solvent-borne  finishes, there has  been  no  effort to our
knowledge to quantify these fugitive emissions.
       The RSE,  regardless  of  the  source  of the emissions, can  be  related to the
organic solvent content of the paint.  Most EDP paints are supplied with an  organic
solvent to  solids  ratio  of 0.06 to  0.12  by weight.   Since  transfer efficiency  is
essentially 100  percent,  the  RSE is also 0.06 to  0.12.  These RSE  translate into
percent  emission  reductions of  97.7  to  98.8  percent when  compared  against
conventional enamels.
4.2.4.  Water-Borne Spray
       In  considering  emission  reduction  for water-borne  spray  coatings,  it  is
necessary to assess the effect of organic solvent  content and solids content of the
paint as well as transfer efficiency for not only the water-borne but also the  organic
solvent-borne paint which it is replacing.
       For spray painting the  transfer efficiencies  cover a broad spectrum, going
                      191
from 30  to 95 percent    .  These efficiencies are influenced by  the  type of spray
method; i.e. conventional air or airless  spray, electrostatic  air or airless spray or
centrifugally  atomized  electrostatic  spray   using  either  a  disc  or bell,  with
electrostatic techniques giving much greater transfer efficiencies than the conventio-
nal techniques.  Transfer is also influenced by the geometry of the parts to be coated,
                                       4-44

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with  higher  efficiencies  for  large  flat surfaces and  lower efficiencies for open
structures such as chairs or bed frames.  Finally, the efficiency can be influenced by
the individual operator in those cases where manual spray is employed.
       Table 4-6 shows the combined effects of solids content, transfer efficiency
and solvent content of the paint on the emission reduction potential of water-borne
spray coatings when compared against their  organic solvent-borne counterparts.
Emission reductions  are shown for two types of water-bornes, containing a volume
ratio  of either 88/12 or 82/18 water to solvent in the  volatile portion of the paint.
These  paints are compared   against a 35  volume  percent  solids content  organic
solvent-borne paint applied at  both 65 and 80 percent transfer efficiency. In the case
of both the  water-borne and solvent-borne  paints,  a  solids content of  35  volume
percent as applied from the gun was assumed.

                 Table  4-6.PERCENT EMISSION REDUCTION FOR
          WATER-BORNE COATINGS APPLIED BY SPRAY TECHNIQUES


                     Percent Emission Reduction by Type of Water-Borne Coating
                     Versus Organic Solvent-Borne   Versus  Organic Solvent-Borne
                              Paint at 65%                  Paint at 80%
   Water-Borne             Transfer Efficiency            Transfer Efficiency
Transfer Efficiency      88/12 (1)       82/18 (1)      88/12 (1)       82/18 (1)
	%	   Water/Solvent  Water/Solvent  Water/Solvent  Water/Solvent

      50                  84.4           76.6           80.8           71.3
      65                  88.0           82.0           85.2           77.9
      80                  90.2           85.4           88.0           82.0
      90                  91.3           87.0           89.3           84.0
(1) Volume ratio of water to solvent in the volatile portion of the paint with 35 volume
    percent solids as applied in both water-borne paints.
        One paint supplier estimates that an emission reduction in the range of 72 to
84  percent will result from substituting water-bornes  for  organic  solvent-borne
enamels in spray applications. See Table 4-7.
                                      4-45

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           Table 4-7.  REDUCTION OF ORGANIC SOLVENT EMISSIONS
                   92,400 Square Meters (1,000,000 Square Feet)
                        Sprayed at 65 Percent Efficiency
                     Approximately 30 Percent Volume Solids
                                      Liters (Gallons) of
                                       Organic Solvent           Percent
            Coating Type                 Emitted             Reduction
       Convention enamel             10,931  (2,888)

       Water base, 33 percent
       organic solvent                  2,861  (  756)              72

       Water base, 18 percent
       organic solvent                  1,560  (  412)              84
       Source:  SME Technical Paper FC74-639, 1974. Page 3
4.2.5.  Water-Borne Dip and Flow Coatings
       As with water-borne  spray coatings,  the emission reduction potential  is
influenced by  the solids content and solvent content of both  the water-borne paint
and  the   solvent-borne material  which it is replacing  as  well  as the  transfer
efficiences for both.
       The transfer efficiencies for dip coating are in the range of 70 to 80 percent
                                            191 192
compared to 90 to 95 percent for flow coating       .  The effect  of these transfer
efficiences on emission reduction  for two types  of  water-borne coatings compared
against an organic-solvent-borne paint, is shown in Table 4-8.  For both water-borne
and solvent-borne paints, we have  assumed 25 volume percent solids as applied. We
have also assumed  80 percent transfer efficiency for solvent-borne dip coating and 95
percent efficiency  for solvent-borne flow coating.
                                     4-46

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Transfer
Efficiency
%
70
80
90
95
88/12 (2)
Water/Solvent
86.3
88.0
87.3
88.0
82/18 (2)
Water/Solvent
79.4
82.0
81.0
82.0
                Table 4-8. PERCENT EMISSION REDUCTION FOR
        WATER-BORNE COATINGS APPLIED BY DIP AND FLOW COATING
                                                 Percent Emission
                                            Reduction by Coating Type (1)
           Coating Process

              Dip

              Flow
           (1)   Compared against a 25 volume percent solids organic solvent-borne
                enamel at 80 percent transfer efficiency for dip and 95 percent for
                flow coating.
           (2)   Volume ratio of water to solvent in the volatile portion of the paint
                with 25 volume percent solids in both water-borne paints.
4.2.6.  Higher Solids Coatings
       To determine the emission reduction potential associated with higher solids
coatings, the RSE of various solids content paints in the range of 30 to 80 volume
percent were compared against the RSE organic solvent-borne paint with 28 volume
percent solids. In preparing these estimates, the deposition or transfer efficiency was
also  taken into consideration.  Application by  air spray (50 percent deposition) and
electrostatic spray (80 percent  deposition)  was  compared  against  application of
conventional solvent-borne paints with air spray.
       Figure 4-11  shows that if 28  volume  percent  solvent-borne coatings were
replaced  by higher solids  coatings of  60 volume percent solids, then an  emission
reduction of 74 to 84 percent would be possible.
       If the same 28 volume percent paint were replaced by an 80 volume percent
solids high solids coating then there would be an emission reduction of greater than 90
percent.
                                      4-47

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                      Figure 4-11. EMISSION REDUCTION POTENTIAL (PERCENT) WITH USE OF

                HIGHER SOLIDS COATINGS IN PLACE OF 28 VOLUME PERCENT SOLVENT-BORNE PAINT

                                   (50 PERCENT DEPOSITION EFFICIENCY)
                100
rfk

oo
              C
              O
              •H
              •P
              O
              3
              •O
              c
              O
              •H
              Ul
              01
              •H
              a
              (U
              O
              M
              0)
              a.
80 -
                                 %  Deposition Efficitincy
                               30         40        50         60         70         80


                                   Volume Percent  Solids Content  of Paints

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4.2.7.   Incineration
        Incineration is currently being  used to control solvent emissions  in  such
finishing industries  as paper148,  fabric174, wire175'  176,  can149'177, coil150'151
coating, and auto finishing   5»146.   Field investigations indicate that incineration,
both thermal and catalytic, is capable of removing at least 90 percent of the solvents
from exhaust air streams142'146'175'176'178'179'180.
4.2.8.  Carbon Adsorption
                                                                    169 170 171
        Carbon  adsorption is being  used  successfully  in  the paper   '    '   and
      172
fabric    industries for controlling solvent emissions,  and has been  evaluated  on a
pilot scale in the automobile industry where is is acknowledged to be capable of  85
percent or greater emission  reduction  when used for solvent emissions from spray
booths181'182'183.
                                       4-49

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                                       4-50

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18.    Oge,  M.T. Trip Report-Bunting  Company,  Philadelphia, Pennsylvania. Spring-
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                                       4-52

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52.    Pegg, F.E. Applying Plastic Coatings with the Fluidized Bed Process. Plastics
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67.   Schrantz, J. UF  Benefits Conveyorized, Batch-Type EDP Systems. Industrial
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                                       4-54

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83.    Gabris, T.  Trip  Report  -  Ford  Motor Company Plant, Oakville,  Ontario.
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123.   Cavanaugh, E.G., G.M. Clancy, and R.G. Wetherold. Evaluation of a Carbon
       Adsorption/Incineration Control  System for  Auto Assembly Plants.  Radian
       Corporation;  Austin, Texas. EPA Contract 68-02-1319, Task 46. May, 1976,  26.
124.   Cavanaugh, E.G., G.M. Clancy, and R.G.  Wetherold. Evaluation of a Carbon
       Adsorption/Incineration Control  System for  Auto Assembly Plants.  Radian
       Corporation;  Austin, Texas. EPA Contract 68-02-1319, Task 46. May 1976.  27.
125.   Grandjacques, B.  Air Pollution  Control  and Energy Savings  with Carbon
       Adsorption Systems. Calgon Corporation Report APC 12-A, July 19, 1975.
126.   Lee, D.R. Activated Charcoal in Air Pollution Control. Heating, Piping and Air
       Conditioning. 76-79, April 1970.
127.   Lund, H.F. Industrial  Pollution Control Handbook. New York.  McGraw-Hill,
       1971, 5-20.
128.   Cavanaugh, E.G., G.M. Clancy, and R.G.  Wetherold. Evaluation of a Carbon
       Adsorption/Incineration Control  System for  Auto Assembly Plants.  Radian
       Corporation;  Austin, Texas. EPA Contract 68-02-1319, Task 46. May 1976.  28-
       29.
                                       4-57

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129.    Package  Sorption Device  Systems Study.  MSA Research Corporation; Evans
       City, Pennsylvania. EPA-R2-73-202. April 1973.
130.    Lund, H.F. Industrial Pullution Control Handbook.  New  York.  McGraw-Hill,
       1971, 5-21.
131.    Cavanaugh,  E.G., G.M.Clancy,  and R.G. Wetherold. Evaluation of a  Carbon
       Adsorption/Incineration  Control System  for  Auto  Assembly Plants.  Radian
       Corporation; Austin, Texas. EPA Contract 68-02-1319, Task 46. May 1976.  32.
132.    Sussman, Victor H. Ford Motor Company, Dearborn,  Michigan. Letter  to R.G.
       Wetherold, Radian Corporation,  dated March 15, 1976.
133.    Handbook of  Chemistry  and  Physics.  Weast, R.C.  (ed.)  Cleveland,  The
       Chemical Rubber Company. 1964. E-26.
134.    Roberts,   R.E.  and  J.B.  Roberts. An Engineering Approach to  Emission
       Reduction in  Automotive  Spray  Painting. Proceedings  of  the 57th APCA
       Annual Meeting. 26(4):353, June 1974.
135.    Stern,  A.C.  Air  Pollution. New York.  Academic Press. Volume II,  Second
       Edition, Chapter 16, 1968.
136.    Lund, H.F. Industrial Pollution Control Handbook.  New  York.  McGraw-Hill,
       1971, 5-27 to 5-32.
137.    Conversation between Fred Porter, Ford Motor Company, Dearborn, Michigan,
       and EPA-CTO, Research Triangle Park, North Carolina.
138.    Stern, A.C. Air Pollution; Vol. Ill,  Sources of  Air Pollution and Their Control.
       New York. Academic Press, 1968.
139.    Benforado, D.M.  Air Pollution  Control by Direct Flame Incineration in  The
       Paint Industry. Jurnal of Paint Technology. 39_(508):265, May  1967.
140.    Lund, H.F. Industrial Pollution Control Handbook.  New  York.  McGraw-Hill,
       1971, 7-8, to 7-11.
141.    Heat Recovery Combined with Oven Exhaust Incineration. Industrial Finishing.
       52(6): 26-27.
142.    Re-Therm Thermal Oxidation Equipment. Product Bulletin REE-1051-975-15M.
       Reeco  Regenerative  Environmental Equipment Company, Inc., Morris Plains,
       New Jersey.
143.    Young, R.A.  Heat Recovery: Pays for Air Incineration and  Process  Drying.
       Pollution Egineering. 7X9):60-61, September 1975.
144.    Can Ceramic  Heat  Wheels Do  Industry a Turn? Process Engineering. 42-43,
       August 1975.
                                       4-58

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145.   Gabris,  T.  Trip Report -  Ford  Motor  Company, Truck  Plant,  Milpitas,
       California.  Springborn Laboratories (formerly DeBell 
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159.   Loop,  P.M.  Automotive Electrocoat.   Preprints,  NPCA  Chemical Coatings
       Conference, Electrocoat Session. 81, April 22, 1976.
160.   Holley, William  H., Springborn Laboratories, Inc. (formerly DeBell & Richard-
       son, Inc.),  Enfield,  Connecticut.  Memo to Robert Diehl,  Springborn Labora-
       tories,  covering phone conversation  with J.A.  Scharfenberger,  Ransburg
       Corporation, Indianapolis, Indiana, August 29, 1977.
161.   Sames Discatron PPH 405, Technical Leaflet PPH 405, Interred Corporation,
       Stamford, Connecticut, February 1977.
162.   Price, M.B. High Solids Coatings - Where Can They Be Used.  Preprints, NPCA
       Chemical Coatings Conference, High Solids Session. 37, April 22, 1976.
163.   Mazia,  J.  Technical Developments in  1976.  Metal Finishing. 75(2):74-75,
       February 1977.
164.   Scharfenberger, J.A.   New  High  Solids  Coating  Equipment  Offers  Ecolo-
       gy/Energy Advantages. Modern Plastics.  53(2):52-53, February 1976.
165.   LeBras, L.R. - PPG Industries  Inc., Pittsburgh, Pennsylvania.   Letter to W.H.
       Holley, Springborn  Laboratories, Inc. (formerly DeBell &  Richardson), dated
       September 16, 1977.
166.   Oge,  M.T. - Trip Report - Simmons Company,  Munster, Indiana.  Springborn
       Laboratories, Inc. (formerly DeBell <5c Richardson, Inc.), Enfield, Connecticut.
       Trip Report 41.  January 28, 1976.
167.   Holley, William H.  -  Springborn  Laboratories,  Inc.  (formerly  DeBell  &
       Richardson, Inc.), Enfield, Connecticut.  Memo to Robert Diehl,  Springborn
       Laboratories, Inc., covering phone conversation with George Wilhelm, Ashland
       Chemical Company, Columbus Ohio, August 24,1977.
168.   Holley, W.H.  Springborn Laboratories, Inc. (formerly DeBell 
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172.    McCarthy,  R.A.   Trip  Report  -  Raybestos-Manhattan,  Inc.,  Mannheim,
       Pennsylvania.  Springborn Laboratories, Inc. (formerly  DeBell <5c Richardson,
       Inc.), Enfield, Connecticut. Trip Report 77.  February 26, 1976.
173.    Gabris, T.  Trip Report - American Can Company,  Lemoyne,  Pennsylvania.
       Springborn Laboratories, Inc.  (formerly DeBell  & Richardson, Inc.),  Enfield,
       Connecticut. Trip Report 89.  March 11, 1976.
174.    McCarthy, R.A.  Trip Report - DuPont Corporation, Fabric and  Finishes
       Department; Fairfield, Connecticut.  Trip Report 130. April 30, 1976.
175.    Kloppenburg, W.B.  Trip  Report - Phelps   Dodge Magnet Wire; Fort Wayne,
       Indiana.   Springborn Laboratories, Inc.  (formerly DeBell &  Richardson, Inc.),
       Enfield, Connecticut.  Trip Report 113.  April 7, 1976.
176.    Kloppenburg, W.B.    Trip Report -  General Electric Company; Schenectady,
       New York. Springborn Laboratories, Inc. (formerly DeBell 
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184.   Holley,  William  H.  -  Springborn  Laboratories,  Inc.  (formerly  DeBell  &
       Richardson, Inc.).  Enfield  Connecticut.  Memo to Robert Diehl,  Springborn
       Laboratories,  Inc.,  covering telephone conversations with Jim Pfeifer,  Pratt
       and Lambert,  Buffalo, New York and Tim Birdsall, Warsaw Indiana.  October
       18, 1977.
185.   Miller,  E.P. and  Taft, D. D.  Fundamentals of Powder Coating.  Dearborn,
       Society of Manufacturing Engineers, 1974. p 95.
186.   Holley,  William  H.  -  Springborn  Laboratories,  Inc.  (formerly  DeBell  <5c
       Richardson, Inc.).  Enfield, Connecticut.  Memo  to  Robert Diehl, Spingborn
       Laboratories,  Covering  conversation  with Richard   Hammel.    Interred
       Corporation. Stamford Connecticut. November 1, 1977.
187.   Switching to a Water-Borne Flow Coat System. Finishing Highlights, p 16-19,
       March/April 1976.
188.   Flow  Coating Water  Base Paint.  Data Sheet  F-52.  George Koch Sons, Inc.
       Evansville, Indiana.
189.   Oscicator Flow  Coating System.  Data Sheet  F-27.  George Koch Sons, Inc.
       Evansville, Indiana.
190.   Flow-Coating  Process of Paint Application.  Data Sheet F-24.  George Koch
       Sons, Inc. Evansville, Indiana.
191.   Brewer, G.E.F.   Painting  Waste  Loads Associated with  Metal Finishing.
       Journal of Coatings Technology. 49(625) : 50, February 1977.
192.   Automatic Air Electrostatic Gun For Applying Water-Borne Coatings—Without
       System Isolation. Products Finishing. 39(11):  98, August 1975.
193.   Gabris, T. Springborn Laboratories, Inc.  (formerly DeBell <3c Richardson, Inc.),
       Enfield, Connecticut.   Memo to  Robert  Diehl, Springborn  Laboratories
       covering  phone  conversation  with  Fred Henning, Amchem  Products, Inc.
       November 15, 1977.
                                      4-62

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                   5.  MODIFICATION AND RECONSTRUCTION

      Proposed standards apply to all affected facilities constructed  or  modified
after the  date of  proposal of  the  proposed  standards.   Provisions  applying  to
modification and reconstruction were  originally  published in the Federal Register on
December 23, 1971.  Clarifying amendments were proposed in the Federal Register on
October  15, 1974 (39  FR  36946),  and final  regulations were promulgated in  the
Federal Register on December 16, 1975 (40 FR 58416).
      Modification is defined as "any  physical change in, or change in the method of
operation of, an existing facility which increases the amount of any air pollutant (to
which a  standard applies) emitted  into  the  atmosphere  by that facility or which
results in the emission of any  air pollutant  (to which a standard applies) into  the
atmosphere not previously emitted".  Reconstruction occurs when components of an
existing facility are replaced to such an extent that:

      (1)      The  fixed  capital cost  of  the  new components  exceeds 50
               percent of  the  fixed  capital cost  that would be  required to
               construct a comparable entirely new facility, and
      (2)      It  is technologically and economically feasible to  meet the
               applicable standards.

      There are certain circumstances under which an increase in emissions does not
result in a modification.  If a capital expenditure that is less than  the most recent
annual asset guideline  repair allowance published  by  the Internal Revenue Service
(Publication 534) is made to increase capacity at an existing facility and also results
in an increase in emissions to the atmosphere of  a regulated pollutant, a modification
is not considered to have occurred.
      An increase in working hours - i.e., from one  to two-shift operation - or  an
extension from 8 hours  to 10 hours per shift would also increase solvent emissions per
day.  This situation,  however,  is  also  not  considered  a  modification under  the
definitions set forth in 40 FR 58416, December 16, 1975.
                                      5-1

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      The  purpose  of  this  chapter is  to  identify  potential  modifications and
reconstructions  of affected facilities,  and any  exemptions or  special allowances
covering changes in existing facilities that should be considered. Exemptions from
the regulations  may be  based on  availability  of technology  and economic con-
siderations.
      As will be seen,  many of the possible changes do not qualify as modifications
by  strict definition.   They are, however, potential  causes of increased  solvent
emission and as such should be discussed.
5.1.   POTENTIAL MODIFICATIONS
      The following changes  in  materials  or  formulations could cause  increased
solvent  emissions  but would qualify primarily  as alternate raw  materials, not  as
modifications, under the above definition unless capital expenditures are required to
effect the change so as  to qualify as a reconstruction.
      (1)  Lower Solids Coatings
           If a change  is made from a higher solids to  a lower solids coating-
      e.g., from an enamel to a lacquer - more material, hence more solvent,
      will be used to maintain the same  dry coating thickness. While a change
      in the direction  of lower solids is unlikely; it could  occur in  any one
      plant as a result of changing paint systems or colors.  It is unlikely,
      however,  that any major capital  expenditures to equipment would be
      required.
      (2)  Use of Higher Density Solvent
           Regulations  normally  restrict the number  of pounds of  solvent
      which can be emitted.  A change in the density of the  solvents used,
      even if the volumetric  amounts  used  were the same, would result in
      more pounds or kilograms being emitted.  Again, this could be construed
      as a raw-material  substitution  and hence not  a modification, as no
      major capital expenditures would  be involved. Such substitutions might
      come about as a result of solvent shortages, attempts to cut paint costs,
      or efforts to incorporate less photoreactive solvents.
                                      5-2

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       (3)  Increased Thinning of Coatings
           A change to a higher viscosity coating could result in an increased
       use  of  solvents for thinning the coating to  proper application consis-
       tency.
       While these three cases can be considered as raw material substitutions, they
are not of themselves considered to be modifications.  The phrase "bubble concept"
has been used  in Title 40 FR 58416, to refer to a trade-off of emission increases from
one facility undergoing  a physical or operational  change with emission reductions
from another  facility in order to achieve no net increase in the amount of any air
pollutant (to which a standard applies) emitted into the atmosphere by the stationary
source as a whole.
       Title 40 FR 58416 states: "In those cases where utilization of the exemptions
under  Paragraph 60.14 (e)  (2),  (3), or (4) as promulgated herein would effectively
negate the compliance measures originally adopted, use of those  exemptions will not
be permitted."
       Other changes  that  could be  made that could result in increased  solvent
emission include:
       (4)  Change to Larger Parts
           If  part sizes were increased  and  the same production rates were
       maintained, more coating materials would be used.  With  the  diversity
       of products produced by the metal furniture industry, it  is somewhat
       difficult  to  see why this could  occur  unless  a manufacturer began
       production  of large  parts such as desks or panels that  he  had not
       produced before.
           Coating lines in this industry, however, are generally equipped  to
       handle  many size  parts  hence such a change would  not  qualify  as  a
       modification  per se.  If  extensive capital expenditures were involved,
       such a change could be classified as a reconstruction.
       (5)  Change to Thicker Coatings
           A  change to  a thicker  coating, other factors  remaining constant,
       could result  in increased solvent emission.  Such a change could result
       from a desire to increase durability or resistance to outdoor exposure.
       Most metal furniture manufacturers,  especially of  office furniture,
       apply as thin a coating as possible, however.
                                      5-3

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(6)  Reduced Deposition Efficiency
    Increased overspray because  of  a process  modification  such as a
switch from  electrostatic  spray to conventional spray would result in
increased emission.  For economic reasons if for nothing else, however,
a switch in such a direction  is unlikely except possibly as a temporary
measure.
(7)  Additional Coating Stations
    If for any reason additional coating stations were added, emissions
would be increased.  It is possible that new paint systems could result in
such a change.  This could involve a reconstruction or a new facility
and, as such, would be subject to regulation.
(8)  Substitution of Equipment
    There can  be  cases  where  in  existing  sources,  coating line
configurations are of a temporary nature to perform a custom coating
job.   Certain custom coaters in the  metal furniture industry perform
metal  coating  services only.  These  services are  offered   to  metal
furniture  manufacturers on a contract basis.  In the course of this type
of business,  the  coating line configuration may  be changed to meet
requirements of a specific job.  For example, existing line components
such as spray booths and dip tanks may be interchanged to accomodate
different jobs.  As another example,  existing ovens may be lengthened
or shortened for each  job.   The aforementioned  changes will  not  be
considered to constitute a modification.  It is  the intent to allow the
custom  coater to make changes of this nature for short-term contract
business without invoking compliance with  new  source  performance
standards.
    Installation of a line or affected  facility previously used at another
plant  site, however, will require  compliance with new source perfor-
mance standards.
                               5-4

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5.2.    RECONSTRUCTION
       Spray booths and bake ovens used in coating metal furniture last ten to twenty
     o
years  and are not replaced before that time unless process changes dictate it.  In
some cases  a line may be moved to another location within the plant and booths  or
ovens may fall apart necessitating some rebuilding.
       Reconstructions would include replacement of spray booths either  because  of
deterioration or  because of more  advanced  design such as the  addition of  more
automatic spraying or electrostatic spraying, if not already being used.
       A line could be made longer or faster to permit  increased production.   This
would  be considered a  reconstruction as long as the requirements  outlined in the
beginning of this chapter are met.
       Ovens could be replaced with  more efficient models or to accomodate new
energy sources such as electricity.
       Changing coating application methods such as from dip coating to electrostatic
spray would qualify as a reconstruction, again if requirements were  met.
       It should be noted that according to 40 FR 58416 that an existing facility, upon
reconstruction  becomes  an affected facility  and  hence  subject to  regulation
irrespective of any change in emission rate.
       It should also be noted that according to 40 FR 58416, Part 60, the  decision  as
to whether a reconstructed  facility can meet applicable standards both technologic-
ally  and  economically  rests  with the  EPA Administrator.   For example, if the
equipment being  replaced does not emit  air pollutants, it  may be determined  that
controlling the  components  that do emit  air pollutants is not reasonable considering
cost, and standards of performance for new sources should not be applied.   As another
example,  if  there is  insufficient space after the  replacements at an  existing facility
to install the necessary air pollution  control  system to comply with standards  of
performance, then reconstruction would not be determined to have occurred.
5.3.    CONSTRAINTS
       Probably the greatest physical constraint to switching to new  coating systems
with lower solvent emissions in existing facilities is the added space  requirements  of
some of the  systems. The seriousness of this constraint will, of course, vary from line
to line or plant to plant.   Plants with very tight space  requirements  might find  it
difficult  to  fit  in the longer oven and flash-off  area required by water-borne spray
systems.  Electrodeposition  tanks are long to allow the necessary immersion time and
rinse area.

                                     5-5

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       Add-on controls for controlling bake oven emissions such as incinerators or
carbon adsorbers are relatively small and usually can be mounted on top of the oven.
It could be difficult if space were tight  to  find room for a large carbon adsorber to
handle spray booth emissions.
       Incinerators,  especially  if used for controlling  spray  booth emissions, use a
great  deal  of fuel even with  heat recovery  in  many cases.  This  constraint  is
considered very sensitive in this era of energy shortages.
                                      5-6

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5.4-   REFERENCES
1.     Holley, W. Springborn Laboratories, Inc. (formerly DeBell & Richardson, Inc.),
      phone call to PPG Industries, Inc.  August 25, 1977.
2.     Oge, M.T. Springborn Laboratories, Inc. (formerly DeBell <5c Richardson, Inc.),
      Trip Reports and Guidelines 41,72,86,100,103, and  108.
                                     5-7

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                        6. EMISSION CONTROL SYSTEMS

        The purpose of this chapter is to identify alternative emission control systems
and finishing processes for typical metal furniture  finishing lines.  In Chapter 4 the
performance of available emission control technology for coating  operations in the
metal furniture industry was discussed and evaluated.
        Eleven alternatives (A-2 through A-7, and B-2 through B-6) for controlling or
reducing emissions for  metal furniture  coating operations have been  identified and
are listed in Tables 6-1 and 6-2.
        There are  a  variety  of sizes of  coating lines used in the metal  furniture
industry and therefore it would be impossible to show  these systems in place for all
sizes of lines.  To illustrate the application of these  systems it  was necessary to
design  model coating lines where emission reductions could be quantified in terms of
percent relative to base cases using organic solvent-borne coatings.  In one base case
a solvent-borne coating spray method was used and in another base case a  solvent-
borne coating dip method was used.
        The two model lines discussed in this chapter are; a line with a yearly output
of 333,333  metal shelves, spray coated, and another  line  with a  yearly  output of
2,496,000 metal  shelves dip coated.  The 333,333  metal shelves represent a yearly
coated surface area of 3,000,000 square feet (278,707  square  meters), the 2,496,000
metal shelves represent 22,464,000 square feet of coated area.
        It was assumed for all cases  that  the coating lines for metal shelves  were
operating 1920 hours per year (240 days,  1 shift).
        It is the task of  this chapter  to  select a realistic .number  of alternative
emission control systems in order to analyze the range of environmental (Chapter 7)
and economic (Chapter 8)  impacts associated with  various alternative controls.  For
this reason, several of the  most viable of the  various alternatives have been selected
for further consideration.  These are presented - in  order of decreasing emission
reduction -in Table 6-1 for  the  smaller  line producing  333,333 metal shelves per
annum, and in Table 6-2 for  the line  with an output of 2,496,000 metal shelves per
year.
                                      6-1

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         Table 6-1. METAL FURNITURE EMISSION CONTROL SYSTEMS
            Size of Line: 3,000,000 Square Feet Coated Area Per Year
           Process

Powder coating, electrostatic spray

Conventional solvent-borne coating,
electrostatic spray

       Carbon adsorber on spray booth,
       and incinerator on cure oven (in-
       cinerator with primary heat re-
       covery)

High solids coating, electrostatic spray

Water-borne coating, electrostatic spray

Conventional solvent-borne coating
electrostatic spray

       Carbon adsorber on spray booth

       Incinerator  on  cure oven
       (with primary heat recovery)

       No control  (base case)
Alternative
  (Case)
  Number


    A-5
                                                                 a
    A-3


    A-2

    A-l
 Solvent
 Emitted
  Metric
Tons/Year
   5.5


  13.2

  17.1
Reduction
 Percent
                 95-991
                                                                                a
A-7"
A-4
A-6
1.7
2.8
3.6
90
83
79
    68


    22

    0
       a
            With the add-on controls it was assumed that all the solvents emitted
            from the application areas and flash-off and ovens went through the control unit.

            For practical purposes, emission can be  considered  as zero; however,

            minute emissions can be caused (0.5 to 3.0 percent) by plasticizers from
            vinyl materials, and by curing agents used in conjunction with thermo-

            setting type resins.
            This is actually a combination of A-2 and A-3.
                                         6-2

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            With the add-on controls it was assumed  that all the  solvents emitted

from application areas and ovens went through the control unit.  Most  water wash

spray booths have recirculating water systems. Any solvent from overspray that is
                                                                             34
captured by the  water curtain is eventually evaporated  into the air exhaust system  .

Both incinerators and carbon  adsorbers  were figured as operating  at  an average

efficiency of 90  percent.
        Table 6-2.  METAL FURNITURE EMISSION CONTROL SYSTEMS
            Size of Line:  22,464,000 Square Feet coated Area Per Year
             Process

Water-borne electrodeposition

Solvent-borne dip coating with carbon
adsorber on dip tank, and incinerator
on cure oven

Water-borne dip coating
Solvent-borne dip coating
  Carbon  adsorber on  dip tank

   Incinerator on cure oven
   (with primary heat recovery)

  No control (base  case)
 Solvent
Alternative
  (Case)
 Number


   B-2
   B-5

   B-6


   B-3


   B-4

   B-l
Solvent
Emitted*
Metric
Tons/Year

   6.24
   9.18

  18.40


  42.23


  58.75

  91.80
Reduction
 Percent


   93



   90

   80


   54


   36

    0
                                                                                a
       a
            With the add-on controls it was assumed  that all the solvents emitted

            from the application areas and flash-off and ovens went through the con-
            trol unit.
            This is actually a combination of B-3 and B-4.
                                     6-3

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       The decreased emissions and percent reduction are from the base cases (A-l
and B-l respectively), which are uncontrolled organic solvent-borne coating systems.
6.1.    ALTERNATIVE A-2
       In  this system, emissions from  the curing oven  of  the  model line (which
amount to only about 20  to  30 percent of the total emissions) are  discharged to an
incinerator. Incineration is a process where compounds are combusted and reduced to
other compounds.   Organic solvents used in the  industrial finishing industry, in
general, can be converted  by the incinerator into carbon dioxide and water vapor.
       Incineration  is the most universally accepted technique for  reducing solvent
emissions  from  industrial  processes.   The  value  of this  technology  has  been
                                                 1234
demonstrated  in  the  can manufacturing industry '  ' '  , in the  coil coating in-
      56789                          10 11
dustry '  '  ' '  and the automotive industry  '  , etc.
       By discharging the emissions of  the curing oven  to an  incinerator, the
emissions of the  model line A-l can  be reduced to 13.2  metric tons per year - a
reduction of 22 percent.
       A flow diagram of this system is shown in Figure 6-1.
6.2.    ALTERNATIVE A-3
       Activated carbon  gained  some  attention  mostly in  the paper and  fabric
coating industry  for the  removal of  organic compounds  from gaseous streams by
adsorption12'13'14'15.
       In alternative system A-3, emissions from the spray booth and flash-off of the
model line (which amount to about 70 to 80 percent of the total emissions  and  flash-
off)  are  discharged  to a carbon adsorption unit.   A flow  diagram of  this system  is
presented in Figure 6-2.
       By the use of this technology, the  emissions of the model  line are reduced
from 17.1 metric  tons per year  to 2.8 tons - a reduction of 68 percent.
6.3.    ALTERNATIVE A-4
       In this alternative, the conventional  solvent-borne paint is replaced with a
high solids coating material.  Otherwise,  the  process is identical with  the base case
(A-l).  Due to the  high  solids content  of the coating composition (therefore, low
solvent content) the  emissions are reduced.
                                     6-4

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                            Figure 6- 1.  FLOW DIAGRAM - ALTERNATIVE A-2

                 APPLICATION OF SOLVENT-BORNE COATING BY ELECTROSTATIC SPRAY

                                BASE CASE WITH INCINERATOR ON OVEN
                    Stack
           Overspray
           (Solvent)
Ware
 Paint,
               Spray   Booth

Thinner
                    Stack
                       Solvent Emission
                   Flashoff
                    of
                   Solvents
Overspray
(Solids and Organic Solvent)
                                                                        Stack
                                                                         I
                                                                       Incinerator
                                                                      90 Percent
                                                                       Efficient
                                                                               Evaporation Loss
                                                                                  (Solvent)
Cure
Oven
Coated
Product

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                            Figure 6- 2 .   FLOW DIAGRAM - ALTERNATIVE A-3

                  APPLICATION OF SOLVENT-BORNE COATING BY ELECTROSTATIC SPRAY

                         BASE CASE WITH CARBON ADSORBER ON SPRAY BOOTH
Ware-
Paint,
Thinner
                     Stack
                      I
               Carbon  Adsorber
                  90 Percent
                   Efficient
                         Evaporation
                           (Solvent)
                 Spray  Booth
J
                                                                              Stack
                                                           Solvent Emission
                              Flashoff
                                of
                              Solvents
                                                                 Evaporation
                                                                   (Solvent)
                                                  Cure
                                                  Oven
Coated
Product
Overspray
(Solids and Organic Solvent)

-------
        High solids coatings are  currently investigated  in the  coating  industry,
(including the metal furniture industry, for the reasons of energy savings and pollution
control)16'17.
        By the use  of high solids coating material, the emission of the model line (A-
1) can be  reduced  from  17.1 metric tons  per year to  2.8 tons - a reduction of 83
percent.
        A flow diagram of this process (see base case) is shown in Figure 6-3.
6.4.     ALTERNATIVE A-5
        In  this alternative the  solvent-borne coating  material is replaced  on the
model line by powder coating. The reduction is 95 to 99  percent with a minimum emis-
sion  (minute emissions can be  caused by plasticizers  from  vinyl materials,  and by
some of the curing agents used in conjunction with thermosetting resins).
        Of the  control techniques presently in use  in  the metal  furniture finishing
                                              18 19 20 21 22 23 24
industry,  powder coating is the  most common  ''''  »*"»*' on outdoor and
institutional  furniture.  Also, other coating industries,  like the automobile industry
                                                  25
investigate this technology on large scale production  .
        A flow diagram of this process is shown in Figure 6-4.
6.5.     ALTERNATIVE B-2
        Of the  control techniques presently in use  in the metal  furniture  industry,
water-borne  coatings are in widespread use.  Most  of the water-borne coatings are
applied by electrodeposition (EDP)26.27,28,29,30,31,32,33<

        Changing from  an uncontrolled organic solvent-borne coat to an EDP  system
for the  metal furniture model line (base case or case B-l) would reduce the  solvent
emissions from 91.8 metric tons per year to 6.24 tons - a reduction  of 93 percent.
        A typical electrodeposition system diagram is shown in Figure 4-4 of Chapter
4. A simplified flow diagram of this system is presented in Figure 6-5.
                                      6-7

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                         Figure 6- 3.   FLOW DIAGRAM - BASE CASE, ALTERNATIVES A-4 AND A-6
                    APPLICATION OF COATING BY ELECTROSTATIC SPRAY CONVENTIONAL (BASE CASE),
                    OR HIGH SOLIDS (A-4) SOLVENT-BORNE COATINGS OR WATER-BORNE COATINGS (A-6)
01
CO
st
Ware 	 ^ Spray
Paint, 1
Thinner
ick St
Evaporation
(Solvent)

Flas


ack
Solvent Emission
hoff
»f
/ents
Overspray
(Solids and Solvent)


Sta
i
ck
Evaporation
(Solvent)
Cure (
Oven ^ 1

                                                                                         Coated
                                                                                         Product

-------
                                   Figure 6- 4 .   FLOW DIAGRAM - ALTERNATIVE A-5

                              APPLICATION OF POWDER COATING - ELECTROSTATIC SPRAY
en
to
                         Ware
Booth to Apply
 Electrostatic
 Powder Spray
                             Powder
                                           I
Cure
Oven
Coated Product
                                                    Overspray
                                                     (Solids)

-------
                                      Figure 6-5. FLOW DIAGRAM - ALTERNATIVE B-2

                         APPLICATION OF WATER-BORNE COATING BY ELECTRODEPOSITION (EDP)
                              Stack
                   Stack
Stack
I—'
o
           Ware
           EDP Coating
1
i
Transfer Loss
(Solvent)
EDP Dip Tank
•
*


Rinse
Solvent Loss

1 Evaporation Loss
1 (Solvent, Water)
Cure
Oven
^ Coated
Product
*Lose solvents into the sewer through
 purging the ultrafiltrate liquid residue

-------
6.6.    ALTERNATIVE B-3
       Activated carbon is  used  in paper and  fabric  coating industries for the
removal  of  organic  compounds from gaseous  streams by adsorption.   Applications
include recovery of solvent  from various industrial operations, including  industrial
finishing  operations (see Chapter 4 and also the references listed under A-3).
       In this system, emissions (which amount to  approximately 50 percent of the
line) from the dip tank and  flash-off of  the model line are discharged to a carbon
adsorption unit.  A flow diagram is shown in Figure 6-6.
       This control system reduces dip tank emissions of the  metal furniture  model
line (B-l) from 91.8 metric  tons per year to 42.23 metric tons - a reduction of 54
percent.
6.7.    ALTERNATIVE B-4
       In this system, emissions from the curing oven  of  the model line (which
amount to about 40 to 50 percent of the total line emissions) are discharged to an
incinerator.    Incineration process  was  already  discussed  under  alternative  A-2.
Therefore, no details are discussed here.
       By  discharging the  emissions  of the curing oven  to  an incinerator, the
emissions of the model line B-l can be  reduced to 58.75 metric tons  per year - a
reduction of 36 percent.
       A flow diagram illustrating this  system is shown in Figure 6-7.
6.8.    ALTERNATIVE B-5
       This alternative is actually  a combination  of alternatives B-3 and B-4:  the
emissions from the dip tank and flash-off are discharged to a carbon adsorption unit,
and the emissions of the curing oven are  chanelled to an incinerator.  This combined
carbon adsorber/incinerator system reduces total emissions from the model line (B-l)
to 9.18 metric tons per year - a reduction  of 90 percent.
6.9.    ALTERNATIVE B-6
       In this system, the solvent-borne dip coating material is replaced by a water-
borne composition.  By this, the emissions of the model line B-l can be reduced to
18.4 metric tons per year - a reduction of  80 percent.
                                      6-11

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                                       Figure 6-6. FLOW DIAGRAM - ALTERNATIVE B-3

                                       APPLICATION OF SOLVENT-BORNE DIP COATING

                                     BASE CASE WITH CARBON ADSORBER ON DIP TANK
                             Stack
to
          Ware
          Paint,
          Thinner
                               t
                        Carbon Adsorber
                          90 Percent
                            Efficient
                                                                                   Stack
                                   Evaporation
                                     (Solvent)
Dip  Tank
  J
                                    Solvent Emission
Flashoff
  of
Solvents
                                Evaporation
                                 (Solvent)
Cure
Oven
Coated
Product

-------
                              Figure 6-7.  FLOW DIAGRAM - ALTERNATIVE B-4

                              APPLICATION OF SOLVENT-BORNE DIP COATING

                                 BASE CASE WITH INCINERATOR ON OVEN
                     Stack
                                 Stack
Ware
Paint,
Thinner
                          Evaporation
                           (Solvent)
                   Dip Tank
J
                                     Solvent Emission
                               Flashoff
                                  of
                               Solvents
                                                                          Stack
                                                                        Incinerator
                                                                        90  Percent
                                                                        Efficient
     Evaporation Loss
         (Solvent)
Cure
Oven
Coated
Product

-------
 6.10.    REFERENCES
 1.       Gabris, T.    Springborn  Laboratories, Inc.  (formerly  DeBell <5c Richardson,
         Inc.). Trip Report 5. December 2, 1975.
 2.       Gabris, T.  Springborn Laboratories, Inc.  Enfield, Connecticut. Trip Report
         6.  December 2, 1975.
 3.       Gabris, T.   Springborn Laboratories, Inc. Enfield, Connecticut. Trip Report
         80.  February 24, 1976.
 4.       Gabris, T.  Springborn Laboratories, Inc.  Enfield, Connecticut. Trip Report
         128.  March 24, 1976.
 5.       Gabris, T.   Springborn Laboratories, Inc. Enfield, Connecticut. Trip Report
         16.  December 18, 1975.
 6.       Fisher, R.  Springborn Laboratories, Inc.  Enfield, Connecticut. Trip Report
         27.  December 12, 1975
 7.       Fisher, R.  Springborn Laboratories, Inc.  Enfield, Connecticut. Trip Report
         31.  December 12, 1975
 8.       Gabris, T.  Springborn Laboratories, Inc.  Enfield, Connecticut. Trip Report
         35.  January 8, 1976.
 9.       Gabris, T.  Springborn Laboratories, Inc.  Enfield, Connecticut. Trip Report
         76.  February 9, 1976.
10.       Gabris, T.  Springborn Laboratories, Inc.  Enfield, Connecticut. Trip Report
         112.  March 12, 1976.
11.       Gabris, T.  Springborn Laboratories, Inc.  Enfield, Connecticut. Trip Report
         120.  March 12,1976.
12.       Gabris, T.  Springborn Laboratories, Inc.  Enfield, Connecticut. Trip Report
         89.  February 27, 1976.
13.       Oge, M.   Springborn Laboratories, Inc.  Enfield,  Connecticut.  Trip Report
         139.  July 19, 1976.
14.       Oge, M.   Springborn Laboratories, Inc.  Enfield,  Connecticut.  Trip Report
         140.  July 20, 1976.
15.       Oge, M.   Springborn Laboratories, Inc.  Enfield,  Connecticut.  Trip Report
         141.  July 21, 1976.
16.       Oge, M.   Springborn Laboratories, Inc.  Enfield,  Connecticut.  Trip Report
         41.  January 14, 1976.
17.       Gabris, T.  Springborn Laboratories, Inc.  Enfield, Connecticut. Trip Report
         36.  January 16, 1976.
                                       6-14

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18.     Schrantz, J.    Automatic  powder systems coat lawn furniture.   Industrial
        Finishing.  April 1975, pp 32-38.
19.     Oge, M.   Springborn Laboratories, Inc.  Enfield, Connecticut.  Trip Report
        86.  February 25, 1976.
20.     Oge, M.   Springborn Laboratories, Inc.  Enfield, Connecticut.  Trip Report
        57.  December 10, 1975.
21.     Oge, M.   Springborn Laboratories, Inc.  Enfield, Connecticut.  Trip Report
        108.  March 8,1976.
22.     Oge, M.   Springborn Laboratories, Inc.  Enfield, Connecticut.  Trip Report
        72.  February 4,1976.
23.     Oge, M.   Springborn Laboratories, Inc.  Enfield, Connecticut.  Trip Report
        85.  February 25, 1976.
24.     Oge, M.   Springborn Laboratories, Inc.  Enfield, Connecticut.  Trip Report
        100.  March 23, 1976.
25.     Gabris, T.   Springborn Laboratories, Inc.  Enfield, Connecticut.  Trip Report
        38.  January 15, 1976.
26.     Oge, M.   Springborn Laboratories, Inc.  Enfield, Connecticut.  Trip Report
        103.  March 9,1976.
27=     Gabris, T.   Springborn Laboratories, Inc.  Enfield, Connecticut,  Trip Report
        9. December 9, 1975.
28.     Gabris, T.   Springborn Laboratories, Inc.  Enfield, Connecticut.  Trip Report
        102.  March 10, 1976.
29.     Gabris, T.   Springborn Laboratories, Inc.  Enfield, Connecticut.  Trip Report
        110.  March 11, 1976.
30.     Gabris, T.   Springborn Laboratories, Inc.  Enfield, Connecticut.  Trip Report
        112.  March 12, 1976.
31.     Gabris, T.   Springborn Laboratories, Inc.  Enfield, Connecticut.  Trip Report
        120.  March 12, 1976.
32.     Gabris, T.   Springborn Laboratories, Inc.  Enfield, Connecticut.  Trip Report
        13.  December 12, 1975.
33.     Gabris, T.   Springborn Laboratories, Inc.  Enfield, Connecticut.  Trip Report
        73.  February 10, 1976.
34.      Holley, W.H.  Springborn Laboratories, Inc. Enfield, Connecticut.  Telephone
         conversation with Binks Manufacturing Co., New Jersey, November?, 1977
                                        6-15

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                          7.  ENVIRONMENTAL IMPACT

7.1.     AIR POLLUTION IMPACT
        Metal furniture manufacturing lines are sources of organic solvent emissions.
The bulk of these emissions is  due to the solvent-borne coating materials used to
protect and decorate  the low  carbon steel  sheets, strips  and tubings used in the
manufacture of the furniture.
        Coatings for metal furniture must resist abrasion scuffing and maintain good
appearance. Institutional furniture is subjected to a more abusive environment and in
addition must  withstand regular  cleaning with alkali type  cleansers.
        Presently, the  metal furniture industry employs mostly organic solvent-borne
coatings for spray, dip  and flow coating processes.  However, different techniques are
available today  for reducing organic solvent  emissions from  metal furniture coating
facilities.
        As an example  for the  use of conventional organic solvent-borne coating
material,  the  following  figures  are of interest.   A metal  furniture line producing
22,464,000 square feet coated area per year, and applying said coating material by dip
coating, causes an uncontrolled emission of approximately 92 metric tons per year. A
line  producing  3,000,000  square feet  of coated areas per year, and using the
electrostatic spray technique to apply the coating material, causes an  uncontrolled
emission of approximately  17 metric tons per year.
        In 1973  (a very high  production  year), United States  consumption of solvents
                                                                       1 2
in paints and  coatings was 1,902,273 metric  tons or 4,185,000,000  pounds ' .  From
these 4,185  million pounds, 805  million were used directly in  the manufacture of the
coating materials,  while 1,365  million pounds of solvents were used as thinners and
                                2
for some other miscellaneous uses .
        In 1973, the  metal furniture industry (including fixtures)  consumed 71,136
                                                     2
metric  tons or 156.5 million pounds  of organic solvents  . These 156.5 million pounds
                                                                 2
of organic solvents were used with  79.4  million  pounds of resins   and 56 million
                  o
pounds of pigments  to make  coating materials.  Thus, the total paint consumption of
the metal  furniture (and  fixtures)  industry  in 1973  must have been  291.9 million
pounds  or  132,681 metric   tons  (a  total  of   the  solvent, resins   and  pigment
consumption).
                                      7-1

-------
       If we examine these figures, the average organic solvent content as computed
is 54 percent by weight or 36 percent  by volume.  (We used 35 percent by volume for
our base case).
                                                                              o
       According to a recent survey  of the National Paint and Coating Association  ,
the metal furniture (and fixture)  industry consumed 116 million pounds of organic
solvents in 1975.  The 116  million pounds exclude thinners.  The survey also states
that the solvent/resin weight ratio of these coating materials was 1.8.
       It is also apparent from said  survey that thinner  and miscellaneous solvents
accounted to 32  percent of total solvents consumed.  According to  this,  the  total
solvent consumption of the 1975 metal furniture industry must have been close to 170
million pounds.
       Based on the earlier cited solvent/resin weight ratio of 1.8, the  170 million
pounds  of solvent should  have  required  some  94  million  pounds of  resin  as
compounding ingredients.   Based  on the 1973 consumption  figures of the  metal
                 o
furniture  industry ,  the pigment/resin  ratio  was 0.7.  This ratio  is now used for
estimating the 1975 consumption.
       In view of the above, the 1975 consumption of the metal furniture industry is
estimated as follows:
                         Millions          Percent by         Percent by
                         of Pounds          Weight            Volume
           Organic
           Solvent          170               52                62
           Resin             94               28 >               38
           Pigment           66               20 J          included in resin
              Total         330              100               100
        The estimates for 1976, our base year for this study, are discussed under 7.1.2.3.
Estimated Hydrocarbon Emission Reduction in Future Years.
                                      7-2

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       The objectives of  New Source  Performance Standards  are  to limit the
emission  of organics by imposing standards which reflect  the  degree of emission
reduction achievable through the application of the  best adequately  demonstrated
system(s) of emission reduction, taking into consideration the cost of achieving such
reduction.  Several alternative organic solvent emission control systems (hereinafter
referred  to as "Alternative") have been identified as candidates for the best system of
emission  reduction.
       In assessing the environmental impact  and the degree  of emission control
achieved by each  alternative which could  serve as  the basis for standards, these
alternatives need to be compared. Also, other facets  of environmental impact -such
as potential water pollution and  solid waste generation  -  needed to be  assessed.
Similarly, state regulations and controlled emissions should be considered.  These are
discussed in the following sections.
7.1.1.  State Regulations and Controlled Emissions
       In August of 1971, Los Angeles County in California adopted Rule 66, Section
C, specifying  that  effective August  31,  1974,  the  maximum  allowable organic
nonphotochemical  emissions per paint facility was  to  be 3,000 pounds per day. The
rule  allows only 40 pounds per day from  sources using  photoehemically reactive
solvent and 15 pounds per day from ovens.  Emissions beyond this limit  would require
control.
       The regulations also  provided an  exemption for water-borne coatings where
the volatile content consists of 80 percent water and  the organic solvent was a non-
photochemically reactive solvent.
       There  are   very few coating users other  than  automobile and some truck
assembly plants which  could  consume  enough coating  product  to  aggregate 3,000
pounds of total  organic solvent emission in a day. This is  the  reason why the Air
Resources Board of the State of California scheduled some consultation meetings for
            4
October  1976  to gather information for developing a  model rule to limit emissions of
volatile organic compounds from automotive coating operations.
                                     7-3

-------
        Based on preliminary discussions with  coating  manufacturers,  the Organic
Solvent Regulation Study Group, composed of staff  members of the California Air
Resources Board and several local  Air Pollution Control Districts has developed for
discussion purposes, the  following organic solvent content limits to be  effective by
October 1, 1980:
                                                       Maximum Organic
                                                        Solvent Content
                                                           As  Applied
                   Coating Use                             (by Volume)
       Original Equipment Manufacture
         Undercoats
         (primer, primer-surfacer, sealer, etc.)                 30%
         Top coat
         (by October 1, 1980)                                  37.5%
         (by October 1, 1982)                                  30%
         Final  Repair
         Metallic Color                                       55%
         Solid Color                                          45%

       These specifications are proposed for automotive coating lines only.  However,
this thinking could serve  as the guide line for the other industries.
       Today only thirteen  states have statewide regulations covering  hydrocarbon
emissions. Approximately half of these states have regulations that  are  the same as,
or similar to, Rule 66 of Los  Angeles.  Such standards carefully limit the  amount of
photochemically reactive (PCR) solvent  volatiles  which may be emitted within  a
given time  period from  both  baking ovens and  curing operations and from coating
applications in any plant.
       There are difficulties in understanding and interpreting Rule 66.  While many
states have  Rule 66 regulations, many have variations such as no maximum limit per
day.  Even those states that have the same regulation  seem to interpret it differently.
The interpretation of the definition  of the affected facility has a great impact on the
stringency of the standard.  The situation is  complicated even more by the current
activity in rewriting state regulations.
       As to stringency,  the Connecticut regulation is the most stringent in terms of
total daily  organic  solvent emission restrictions.  The oven  discharges  of organic
materials are limited to  15  pounds per day, unless the discharge of the oven has been
reduced by at least 85  percent.
                                     7-4

-------
      There are ten states in which state  regulations are  in force  in designated
counties only.  There twenty-two states where no hydrocarbon emission controls are
required on stationary sources.  And, there are five states in which state regulations
are in the process of formulation.
7.1.2. Uncontrolled and Controlled Emissions  (Alternatives)
      The objective of this chapter is to discuss and determine what control methods
coupled with which processes will allow substantial reductions in solvent  emissions
over the base line situation without an extreme adverse effect on secondary pollution
such as water and solid waste.  This chapter should help  to identify  those control
methods/processes which can result in significant emission reduction and should guide
the selecting of candidates for NSPS.
7.1.2.1. Spray Coating
      For our base case, we  have assumed that the coating line, which produces
metal shelves, has a yearly output of 3 million square feet coated area.  It was also
assumed that the coating line was operating 1920 hours per year by being on one shift
(8-hour  shift, 240 work days per year). The base case is representative of what might
be found in the industry.  This model line is using traditional organic  solvent-borne
finishes.
      Our base case indicates that the uncontrolled organic solvent-borne coating
operation results in a yearly emission  of 17.1 metric tons  (37,620 pounds).  This
translates into 157 pounds per day.
      The following alternatives represent control technologies that could be used to
reduce  the emission of volatile  organic solvents.  Typical emissions from  such
alternative lines  have been discussed and have been compared against the base case.
With the add-on controls  it was assumed  that all  the  solvents  emitted  from  the
application areas and ovens went through the control unit.
      (1)    Incinerator on Cure Oven
             Alternative A-2 (Table 7-1)
      In this case an incinerator is treating the emissions from the cure oven (which
amount to about  25  percent of  the total line  emissions) of the model line, which can
reduce  the yearly emission (17.1  metric tons) by 22 percent, yielding a yearly
emission of 13.2 tons or 29,040 pounds.  Converting  this into daily  emissions, the
result is 121 pounds per day.
      (2)    Carbon  Adsorber on Spray Booth and Flash-off
             Alternative A-3 (Table 7-1)
                                      7-5

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      In this Alternative a carbon adsorber is put on the spray booth and flash-off
area of the model line.  A reduction of 68 percent in emission is observed, bringing
the 17.1 metric tons of emission down to 5.5 tons.  This amounts to 50 pounds per day.
      (3)    High Solids Coating
             Alternative A-4  (Table 7-1)
             In  this Alternative, the conventional solvent-borne  paint is replaced
with a high solids coating material.  Due to the  high solids content of the coating
composition (therefore, low solvent content) the emissions are reduced by 83 percent,
yielding a yearly emission of 2.8 metric tons or 25  pounds per day.
      (4)    Powder Coating
             Alternative A-5  (Table 7-1)
             In this Alternative the solvent-borne coating material is replaced on the
model line by powder coat.  The reduction is 95 to  99 percent with an emission of 1 to
5 percent.
      (5)    Water-Borne Coating
             Alternative A-6  (Table 7-1)
             In  this example, a  water-borne coating  material  is substituted for the
solvent-borne coating.  This Alternative reduces  the  emission  by  79 percent to 3.6
metric tons per year, or 33 pounds per day.
      (6)    Carbon Adsorber on Spray Booth and Flash-off
             and Incinerator on Cure Oven
             Alternative A-7  (Table 7-1)
             This is a combination of Alternatives A-2 and A-3. The reduction is 90
percent (22 percent for  A-2 and 68  percent for A-3  or  90  percent  total).  The
emissions are reduced  from the uncontrolled 17.1 metric tons to 1.7 tons. Converting
this into daily emissions, the model line has an emission of 16 pounds per day.
7.1.2.2.   Dip Coating
      For our base case, we have assumed that the coating line has a yearly output
of 22,464,000 square feet coated area.  Similarly to the spray  coating line (7.1.2.1),
the line operates on one (8-hour) shift,  240 days per year. This  amounts to  1920 work
hours per annum.
                                      7-6

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          Table 7-1. METAL FURNITURE PAINTING OPERATION
       SPRAY COATING HYDROCARBON EMISSION FACTORS AND
          CONTROLLED AND UNCONTROLLED MODEL PLANTS
                                                            Percent
        Model Plant            Alternative   Tons/Year      Reduction

Uncontrolled                      (A-l)      17.1  (19.2)
Controlled
  Incinerator on cure oven          A-2       13.2  (14.5)        22
  Carbon adsorber on spray booth    A-3        5.5  ( 6.0)        68
  High solids coating               A-4        2.8  ( 3.0)        83
  Powder coating                  A-5         Ob             95 - 99
  Water-borne coating              A-6        3.6  ( 3.9)        79
  Carbon adsorber on spray
  booth and flash-off and in-
  cinerator on cure oven            A-7        1.7(1.9)        90
a Units are metric tons; U.S. tons shown in parentheses.  With add-on controls
  it was assumed that all the solvents emitted from the application areas and
  ovens went through the control unit.
  For practical purposes,  emission can be considered as zero; however, minute
  emissions (0.5 to 3.0 percent) can be caused by plasticizers from vinyl materials
  and by curing agents used in conjunction with thermosetting type resins.
                                7-7

-------
      Our base  case  (B-l)  indicates that  the  uncontrolled  organic solvent-borne
coating operation results in  a yearly emission of 91.8 metric tons (201,960 pounds).
This amounts to 841 pounds per day.
      The following alternatives represent control technologies that could be used to
reduce the emission of this  line.   Typical emissions from such alternative lines are
compared against the base case and presented in Table 7-2.
      (1)    Water-Borne - Electrodeposition
             Alternative B-2 (Table 7-2)
             In this  Alternative,  a water-borne coating  material is  applied  by
electrostatic deposition.  By  using this technology, the emission of the line is reduced
by 93 percent.  Thus, from the 91.8 metric tons of yearly emission to 6.24 tons.  This
amounts to 57  pounds  per day.  (The uncontrolled line produces an emission  of 841
pounds per day).
      (2)    Carbon Adsorber on Dip Tank and Flash-off
             Alternative B-3 (Table 7-2)
             In this system, emissions  from the dip  tank  of the  model line are
discharged to  a  carbon  adsorber  unit.   Emissions  of  the  line  are reduced by 54
percent, or to 42.2 metric tons per year.  This corresponds to 387 pounds per day.
      (3)    Incinerator on Cure Oven
             Alternative B-4 (Table 7-2)
             In this example, an incinerator  is treating the emissions from the cure
oven (approximately 40 percent of the total  line) of the model line.  This can  reduce
the emission by 36 percent.   Thus the yearly emissions are  reduced to  58.75  metric
tons, or 538 pounds per day.
      (4)    Carbon Adsorber on  Dip Tank  and Flash-off
             and Incinerator on Cure Oven
             Alternative B-5 (Table 7-2)
             This is a combination of Alternatives B-3 and Alternative  B-4.   The
achievable emission reduction is 90 percent.   The yearly emission of  the  line is
reduced to 9.1 metric tons, or 83 pounds per day.
      (5)    Water-Borne Dip Coating
             Alternative B-6 (Table 7-2)
      A water-borne coating material is replacing the solvent-borne material in the
dip tank.  The achievable emission reduction is  80 percent.  The yearly emission of
the line is reduced to 18.4 metric tons, or 168 pounds per day.
                                      7-8

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             Table 7-2.  METAL FURNITURE PAINTING OPERATION

DIP COATING HYDROCARBON EMISSION FACTORS AND CONTROL EFFICIENCY

             CONTROLLED AND UNCONTROLLED MODEL PLANTS
                                                             Percent
         Model Plant             Alternative   Tons/Year     Reduction
   Uncontrolled                     (B-l)      91.8  (100.9)


   Controlled

   Water-borne - electrodeposition     B-2        6.2  (  6.8)      93

   Solvent-borne dip coating

       Carbon adsorber on dip tank     B-3       42.2  (  46.4)       54
       Incinerator on cure oven
        and flash-off                 B-4       58.7  ( 64.6)      36

      Carbon adsorber on dip tank
      and incinerator on cure oven     B-5        9.1  ( 10.0)      90

      Water-borne dip coating         B-6       18.4  ( 20.2)      80
a Units are metric tons; U.S. tons shown in parentheses.

  With the add-on controls it was assumed that all the solvents emitted from the
   application areas and ovens went through the control unit.
                                  7-9

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7.1.2.3. Estimated Hydrocarbon Emission Reduction in Future Years
       The household furniture industry from 1973 to 1980 is expected to grow at an
annual rate of 2.4 percent .  Other branches of the furniture industry, like office
metal furniture, public building furniture, and metal partitions and fixtures, expect to
grow at a rate of 4.4 percent  . Growth rates predicted for the period of 1980  to 1985
are 3.9  percent for household  furniture , and  3.0 percent per  annum for other
furniture  .
       Employment statistics, and sales projections presented in Chapter 3, indicate
that approximately  30  percent  of the total furniture  industry is constituted by
household furniture.  The  remaining 70 percent are made up from  furniture  sold to
offices, public buildings, and  sold  as  partitions and fixtures.   Since the predicted
growth rates for these industries are not significantly  different, it is reasonable to
take proportional averages for our work.
       In view of the above, the metal furniture industry in the period of 1973  to 1980
is  expected to grow at a rate of 3.8 percent per year  (0.3 times 2.4 plus 0.7 times
4.4), and from 1980 to 1985, at an average rate of 3.3 percent.
       We  have  estimated (see  earlier pages  of  this  chapter)  that  the  solvent
consumption of the  metal furniture industry in 1975 was 170 million pounds  (77,272
metric tons).   Based on this figure, and the discussed  estimated growth rates, the
hypothetical emissions  from uncontrolled metal furniture coating operations in the
United States are estimated under A-l in the tables which follow.
       The adoption by the metal furniture industry of programs for the reduction of
emissions is a long-range  consideration.  In 1973,  from  the 79.4  million pounds of
resins  consumed by the metal furniture industry, only 2  percent was used  of  new
technology  coating  materials:   0.5 million pounds in water-borne, and 1.1  million
                      o
pounds in powder coats  .
       Six  control options for spray coating, and  five  options for dip coating are
available to the industry to control emissions over a projected growth period up to the
year 1985.  Tables  7-3 and  7-4  encompasses the effectiveness of alternate  control
options on the reduction of annual emissions assuming that each year 5 percent of the
industry  would be affected by the use of pollution control systems. Tables 7-5 and 7-
6 show the effectiveness at 10 percent yearly penetration.
                                      7-10

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Table 7-3.  COMPARATIVE EFFECTIVENESS OF ALTERNATE CONTROL SYSTEMS
              EXPRESSED IN ANNUAL ORGANIC EMISSIONS
             CONTROLS ON A SPRAY COATING OPERATION
             ASSUMED ANNUAL PENETRATION: 5 PERCENT
Emissions, Metric Tons/Year

Year
1976
1977
1978
1979
1980
1981
1982
1983
1984
1985
A-l
Uncontrolled
Emissions
80,208
83,256
86,420
89,704
93,113
96,186
99,360
102,639
106,026
109,525
A-2
Incinerator
on Cure Oven
80,208
82,339
84,518
86,742
89,016
90,894
92,802
94,734
96,694
98,681
A-3
Carbon Adsorber
on Spray Booth
and Flash-off
80,208
80,425
80,543
80,553
80,449
79,834
79,090
78,210
77,186
76,009
A-4
High Solids
Coating
80,208
79,800
79,247
78,535
77,655
76,226
74,619
72,882
70,824
68,616
A-5
Powder
Coating
80,208
79,093
77,778
76,248
74,490
72,139
69,552
66,715
63,615
60,238
A-6
Water-Borne
Coating
80,208
79,967
79,593
79,073
78,400
77,188
75,811
74,259
72,521
70,588
A-7
Carbon Adsorber
on Spray Booth
_ and Flash-off
Incinerator on Oven
80,208
79,509
78,642
77,593
76,352
74,543
72,532
70,307
67,856
65,166

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Table 7-4. COMPARATIVE EFFECTIVENESS OF ALTERNATE CONTROL SYSTEMS EXPRESSED

      IN ANNUAL ORGANIC EMISSIONS CONTROLS ON A DIP COATING OPERATION

                   ASSUMED ANNUAL PENETRATION:  5 PERCENT
                            Emissions, Metric Tons/Year
  B-l
B-2
B-3
                           Carbon Adsorber
B-4
       B-5
Carbon Adsorber on
    Dip Tank
B-6

Year
1976
1977
1978
1979
1980
1981
1982
1983
1984
1985
Uncontrolled
Emissions
80,208
83,256
86,420
89,704
93,113
96,186
99,360
102,639
106,026
109,525
Water-Borne
Electrodeposition
80,208
79,384
78,383
77,190
75,793
73,822
71,638
69,229
66,584
63,688
on Dip Tank
and Flash-off
80,208
81,007
81,753
82,437
83,056
83,200
83,263
83,239
83,123
82,909
Incinerator
on Cure Oven
80,208
81,756
83,309
84,859
86,408
87,528
88,629
89,706
90,757
91,781
and Flash-off
Incinerator on Oven
80,208
79,509
78,642
77,593
76,352
74,543
72,532
70,307
67,856
65,166
Water-Borne
Dip Coat
80,208
79,925
79,506
78,939
78,214
76,948
75,513
73,899
72,097
70,095

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Table 7-5. COMPARATIVE EFFECTIVENESS OF ALTERNATE CONTROL SYSTEMS
              EXPRESSED IN ANNUAL ORGANIC EMISSIONS
             CONTROLS ON A SPRAY COATING OPERATION
             ASSUMED ANNUAL PENETRATION:  10 PERCENT
                                Emissions, Metric Tons/Year


Year
1976
1977
1979
1981
1983
1985
A-l

Uncontrolled
Emissions
80,208
83,256
89,704
96,186
102,639
109,525
A-2

Incinerator
on Cure Oven
80,208
81,423
83,783
85,605
86,832
87,838
A-3

Carbon Adsorber
on Spray Booth
and Flash-off
80,208
77,602
71,404
63,482
53,783
42,495
A-4

High Solids
Coating
80,208
76,345
67,368
56,269
43,006
27,709
A-5

Powder
Coating
80,208
72,187
58,471
47,362
38,363
31,073
A-6

Water-Borne
Coating
80,208
76,678
68,444
58,192
45,880
31,652
A-7
Carbon Adsorber
on Spray Booth
and Flash-off
Incinerator on Oven
80,208
75,762
65,484
52,902
37,976
20,809

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Table 7-6. COMPARATIVE EFFECTIVENESS OF ALTERNATE CONTROL SYSTEMS EXPRESSED
      IN ANNUAL ORGANIC EMISSIONS CONTROLS ON A DIP COATING OPERATION
                  ASSUMED ANNUAL PENETRATION: 10 PERCENT
                                 Emissions, Metric Tons Per Year


Year
1976
1977
1979
1981
1983
1985
B-l

Uncontrolled
Emissions
80,208
83,256
89,704
96,186
102,639
109,525
B-2

Water-Borne
Electrodeposition
80,208
75,512
64,677
51,459
35,801
17,852
B-3

Carbon Adsorber
on Dip Tank
and Flash-off
80,208
78,759
75,172
70,216
63,841
56,295
B-4

Incinerator
on Cure Oven
80,208
80,258
80,016
78,872
76,774
74,038
B-5
Carbon Adsorber on
Dip Tank
and Flash-off
Incinerator on Oven
80,208
75,762
65,484
52,902
37,976
20,809
B-6

Water-Borne
Dip Coat
80,208
76,595
68,175
57,711
45,161
30,666

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  Table 7-7. EFFECTIVENESS OF ALTERNATE CONTROL SYSTEMS - YEAR 1985

                 EXPRESSED IN ANNUAL ORGANIC EMISSIONS

                  CONTROLS ON A DIP COATING OPERATION

          COMPARATIVE ANNUAL PENETRATION: 5 AND 10 PERCENT
                                           Emissions, Metric Tons/Year
  Control System
By Add-On Equipment
Carbon adsorber on dip tank
and flash-off
Incinerator  on cure oven
Carbon adsorber on dip tank
and flash-off and incinera-
tor on cure oven

By Coating Composition
Alternative
 Number    Uncontrolled
                                                  a
  B-3
  B-4
  B-5
               Annual       Annual
             Penetration   Penetration
                5%           10%
109,525


109,525




109,525
82,909
91,781
65,166
56,295
74,038
20,809
Water-borne coating
electrodeposition

Water-borne dip coating
B-2
B-6
109,525
109,525
63,688
70,095
17,852
30,666
 a
   No add-on equipment with conventional solvent-borne coating material.
                                   7-15

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 Table 7-8. EFFECTIVENESS OF ALTERNATIVE CONTROL SYSTEMS - YEAR 1985

                 EXPRESSED IN ANNUAL ORGANIC EMISSIONS

                CONTROLS ON A SPRAY COATING OPERATION

          COMPARATIVE ANNUAL PENETRATION:  5 AND 10 PERCENT
                                    Emissions, Metric Tons/Year
  Control System


By Add-On Equipment


Incinerator on cure oven

Carbon adsorber on
spray booth and flash-off

Carbon adsorber on spray
booth and flash-off and
incinerator on cure oven


By Coating Composition


High solids coating


Powder coating


Water-borne coating
Alternative
 Number    Uncontrolled
                                                 a
   A-7
   A-4
   A-5
   A-6
              Annual
             Penetration
                5%
   A-2       109,525



   A-3       109,525
109,525
109,525
109,525
109,525
65,166
68,616
60,238
70,588
            Annual
           Penetration
               10%
               98,681       87,838



               76,009       42,495
20,809
27,709
31,073
31,652
  No add-on equipment with conventional solvent-borne coating material
                                   7-16

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7.2.     WATER POLLUTION IMPACT
        When solvent-borne coatings are applied by spraying, the spraying operation is
carried out in  the spray booth.  With  the increased attention to air  pollution,  the
efficiency  of particulate removal from the spray booth is of great importance to  the
metal  furniture coating lines.  As a result, water-wash spray booths of advanced
design are  coming into use.  These booths have a grid in the floor through which  the
overspray is drawn before being exhausted.
        In a spray booth, typically  used in the industrial finishing industry,  95 percent
of the paint participates are captured by the water  curtain, but most of the  solvent
escapes to the atmosphere, either up the stack  due to evaporation  from the water
                                                                           >7
curtain, or as fugitive emissions by evaporation from the water collection tank . For
most  paints used, the solvents  are immiscible in the water  which facilitates their
                    7
discharge into the air .
        Water-borne  electrodeposition  coats  are  prepared  by neutralizing  highly
acidic polymers with an alkali (like  amines) so that these polymers  can be dissolved or
suspended in water.  Small amounts of solvents are  also added to  increase the water
            g
dispersibility .
        In  the  coating  process  the paint  solids  coat the metal ware,  leaving alkali
coalescing  solvents behind in the tank.  These products must be removed.  In  modern
installations, ultrafiltration is used to automatically remove  the  water-solubles and
chemical agents which are left behind during the process (see details in Section 7.3. -
Solid Waste Disposal).
        If the effluent water originates from  properly operating  ultrafiltration only
and is treated properly, it can be adequately handled in municipal  or in-house  sewage
treatment  facilities.   On the other hand, if the  electrocoating systems allows rinse
water  and/or paint to drip or be spilled on the  floor and  the rinsing and clean-up
water is not automatically placed in a reservoir for treatment, this painting operation
could cause pollution.
        Especially important in this instance is the  matter of "dragout."  At the end
of the coating  operation the dipped ware  becomes coated with an additional  film of
adhering paint called dragout.  This film is more  porous  than the  plated coating;
therefore,  it is usually rinsed  off.  Also, a dragout takes place as the ware leaves the
tank  for the next location.   This dragout is  reclaimed through an  ultrafiltration
system.
                                      7-17

-------
        Water-borne spray-coating  materials, in the metal furniture industry, do not
represent demonstrated  technology  as yet.   Nevertheless,  water-borne  coating
                                                            8 9 10
materials are  used  by spraying both in the automotive industry ' '  . and in  the  can
industry  .    Water-borne spray-coat  materials,  however,  are  made  with  water-
miscible solvents to assure good suspension of the resin binder in  the water phase of
the coating material.   These various water-miscible solvents (glycols,  and  certain
esters  and  alcohols) found  in  the water-borne  coating materials are extremely
miscible with  water wash and actually act as coupling agents between the suspended
particles and the water.
        The problem with organic solvent in effluent water is the chemical oxygen
demand  (COD).  COD  is not a pollutant in  itself; it is  a  problem only  if it is
discharged to  a stream in sufficient concentration and quantity to deplete the oxygen
in the stream  and thereby affect fish life and other water life.
        There  are no water pollution  impacts associated with the  other alternative
emission control systems; however, incineration or adsorption of spray booth  exhaust
- although technically  feasible - have not been used at any plant.  As far  as  carbon
adsorption is  concerned, it is to be noted that some solvents used  in solvent-borne
coating systems are sufficiently water-miscible to pose a water pollution problem if
regeneration steam is condensed and discharged without being treated.
7.3.     SOLID WASTE DISPOSAL IMPACT
        Water-borne electrodeposition operations can have an impact on solid waste
disposal.  In older installations the dragout and rinse were discarded, resulting in a
waste disposal problem.  This also causes a paint loss. Improvements have been made,
however, to reduce paint cost through the inclusion of some means of  reusing  this
paint by returning it to the tank.
        In modern  operations, ultrafiltration  is used to automatically  remove  the
amine(s), solvents, and water-solubles which are left behind during the electrocoating.
Consequently, it is possible to set up a completely closed system with practically no
waste problem.
        Once  a year there is a regular cleaning  of the filter system.  Otherwise
cleaning is not needed except on occasions such as, for example, when a paper cup or
other foreign  object is accidently dropped into the  tank. Such a minor cleaning  job,
however, does not involve more paint than a few gallons.
                                      7-18

-------
        There  are  no  serious  solids  waste  disposal problems  associated  with
electrocoating.   Sludge may develop in the tank, leading to a  minor solid waste
disposal  problem; however,  sludge is  generally  a result  of improperly  controlled
chemistry of the electrocoating tank or poor housekeeping  (such as allowing parts to
accumulate in the tank). In any case, the amount of such solid waste is not  excessive.
        While water-borne electrodeposition type coatings no longer  present any
serious sludge and solid waste problems, water-borne spray coats  are more prone to
do so.  Water-borne spray coat materials, because they are partial or full  suspension
systems just as are dispersions and/or emulsions, display considerably less mechanical
and storage stability than do  organic solvent-borne topcoat  materials, which are often
actually true solutions. In a dispersion, fine particles (of the binder) are suspended in
a continuous liquid phase, like water.  In an emulsion the solids are liquified with the
help of solvent(s), and droplets of this are  suspended in a continuous liquid phase like
water.
       The stability of these suspension  (also referred to as colloidal) systems is
much dependent on the water-to-sol vent ratio used.  This is especially true when the
water-to-solvent ratio of the water-borne  topcoat material is disturbed, as it is  when
the overspray of the water-borne topcoat material hits the  water wash. In the water
wash the  major portion of  the  water-borne topcoat  overspray  is thrown out of
suspension,  forming lumps consisting of agglomerated  solids with locked-in water.
                                                              9 10
This can seriously increase the amount of sludge formed in a plant  '   .
        For example,  an automobile plant reported that the sludge tank  had to be
cleaned only once a year when using solvent-borne topcoats, and as the plant switched
                                                                          12
to water-borne topcoats, the sludge tank had to be cleaned every three months   .
        As  a result  of the  above  situations  -  the  water  being  filtered  at and
recirculated from the sludge tanks to the  spray booths  of  coating lines  -  the water
must contain significant  amounts of  water-miscible  solvents  as well  as colloidal
particles of the coagulated binder and pigment. Particles which are of ultrafine size
are impossible to filter out by conventional filtering methods.
        As to the exact amounts  and  compositions of  the sludge, estimates of the
various industry spokesmen vary over a wide spectrum.
                                      7-19

-------
       There are some basic differences between the treatment of sludge from
solvent-based coatings and that of water-borne spray coating materials. Sludge from
water-based  spray coat materials,  in  order  to break the suspension system and  to
remove the particles, is treated with slightly acidic compounds like calcium acetate
                       13
at an actual pH  of  3-4  .   Ultrafiltration could be used eventually to remove the
colloidal particles; but this method  is labeled  as an  expensive  approach to the
problem   .
       There is  little  solid waste  impact associated with alternatives other than
water-borne  coatings.  In the case of carbon adsorption  (because  of the high cost  of
the carbon),  the carbon is returned  to the supplier  for regeneration. In the case  of
powder coats (because of the high cost of the powder), the oversprayed powder is
recovered by means of cyclone(s) - with the possible additional help of tube or bag
filters.  Virtually no solid by-product is produced by incineration.
7.4.    ENERGY IMPACT
       With  the exception of high solids, powder and water-borne spray-coat systems
- all alternative emission control systems require  some additional energy.
       In contrast to the necessary exhausting method  used for solvent-borne paint
systems, the  exhaust from a powder coating application  booth usually can be filtered
and  returned to the room.  This  makes possible a considerable  energy reduction -
attributable  to less  makeup  air,  less oven  exhaust  no flashoff zone,  and the
                                      14
elimination of heat-up zones in the oven  .
       The energy impact  associated with each of the alternative emission control
systems outlined in Chapter 6 and discussed in this chapter is summarized in Tables 7-
9  and 7-10;  these tables are a  compact representation and summary of energy
balances prepared for the purpose of comparing  the energy required for a base case
finishing model with the energy required when pollution  reduction coatings or add-on
emission controls are utilized.
                                      7-20

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      Table 7-9.  ENERGY BALANCE - ON A SPRAY COATING OPERATION
                                 Energy Requirements Per Line
Model Description


Base case

Incinerator on cure
oven

Carbon adsorber on
spray booth and flash-off

High solids coating

Powder coating

Water-borne coating

Carbon adsorber on
spray booth and flash-
off and incinerator on
cure oven
                                                              Total Energy
Alternative
Number
A-l
A-2
f A-3
A-4
A-5
A-6
Electricity a
KWH/Year
192,000
203,500
306,600
192,000
192,000
230,400
Gasb
MCF/Year
3,840
6,048
3,820C
2,690
2,400
2,572
PerRYear
10° BTU
4,495
6,743
4,867
3,345
3,055
3,359
A-7
318,100
6,331
7,417
   a
     Conversion factor:  KWH = 3,415 BTU

     Conversion factor:  1 cubic foot = 1,000 BTU

     Adjusted for energy credit (303 MCF/year) due to solvent recovery
                                    7-21

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        Table 7-10. ENERGY BALANCE ON A DIP COATING OPERATION
                                 Energy Requirements Per Line
Model Description
                                             a
Alternative    Electricity        Gas
 Number        KWH/Year     MCF/Year     10" BTU
                          Total Energy
                            Per Year
Base Case               B-l

Water-borne coating
electrodeposition         B-2

Solvent-borne dip
coating -

  Carbon adsorber on
  dip tank and flash-off   B-3
                153,600
                960,000
                210,900
              6,720
              4,500
              6,670
               7,244
               7,778
               7,390
  Incinerator on
  cure oven
   B-4
176,640       10,560
              11,163
  Carbon adsorber on
  dip tank and flash-off
  and incinerator on
  cure oven             B-5
                233,940
             11,320
              12,119
Water-borne dip
 coating
    B-6
153,600
4,503
5,027
   a
     Conversion factor:  KWH - 3,415 BTU

     Conversion factor:  1 cubic foot = 1,000 BTU

     Adjusted for energy credit (810 MCF/year) due to solvent recovery
                                  7-22

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7.5.    OTHER ENVIRONMENTAL IMPACTS
       Electrodeposition  (EDP) coatings contain  amines that are  driven off during
the curing step.  Some plants have found it necessary to incinerate the oven exhaust
gas to eliminate the visible emission and mal odors associated with these amines  ;
                                                           1 fi
some other plants have installed scrubbers for the same purpose  .
       No environmental impacts other than those discussed above  are likely to arise
from  standards of  performance  for metal  furniture painting (coating) operations,
regardless of which alternative emission control system is selected as the  basis for
standards.
7.6.    OTHER ENVIRONMENTAL CONCERNS
7.6.1.  Irreversible and Irretrievable Commitment of Resources
       The alternative control systems will require the installation  of additional
equipment, regardless of which alternative emission control system is selected.  This
will  require the additional use of steel and other resources. This commitment of
resources is small compared to the national usage of each resource. A good quantity
of these  resources  will ultimately be salvaged and recycled.  With the exception of
carbon adsorption, there are not expected to be significant amounts  of space (or land)
required  for  the  installation  of  control equipment and/or new coating technology
because  all control systems can  be located  with little additional space required.
Therefore,  the commitment of land on which to locate additional control devices
and/or application equipment is expected to be minor.
       The  increase  in  the  use of  activated  carbon  is  also  expected  to  be
insignificant. In many cases the carbon can be regenerated and reused.
       As  can be  noted, the use of  primary and secondary heat recovery would
enhance  the value  of incineration; here it is reasoned that without heat  recovery,
significant energy would be lost.
7.6.2.  Environmental Impact of Delayed Standards
       Delay of proposal of standards for  the  metal furniture industry  will have
major negative environmental effects on emission of hydrocarbon to the atmosphere
and minor or no positive impacts on water and solid waste. Furthermore, there does
not appear to be any emerging emission control technology on the horizon that could
achieve greater emission reductions or result in lower costs than that represented by
                                     7-23

-------
the emission control alternatives under consideration here.   Consequently, delaying
standards to allow  further technical developments appears to present no "trade-off"
of higher solvent emissions in the near future against lower emissions in the distant
future.
7.6.3.   Environmental Impact of No Standards
        Growth projections have been presented in earlier sections.  It is obvious that
the increased production of metal furniture will add to the national solvent emissions.
        There are  essentially no adverse  water  and solid  waste  disposal impacts
associated with either  of  the alternative emission control systems proposed in this
chapter.  Therefore, as in the case of delayed standards, there is no trade-off  of
potentially adverse impacts in these areas against the negative result on  air quality
which would be inherent with  not setting standards.
                                      7-24

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7.7    REFERENCES
 1.    Tess, Roy  W. Chemistry and  Technology of Solvents; Chapter 44 in Applied
      Polymer Science.  American Chemical Society, Organic Coatings and Plastics
      Division. 1975.
2.     Sources and Consumption of Chemical Raw Materials in Paints and Coatings -
      by Type and End-Use. Stanford Research Institute. November 1974.
3.     Bruce Ocko.  Modern Paint and Coating Magazine.  March 1977.  p 61.
4.     Air  Resources Board,  State  of California,  Sacramento, California  95812.
      Ronald  A.  Friesen, Chief Industrial Project Evaluation and Control Strategy
      Development Branch.   Public Consultation  Meeting on Methods to Reduce
      Solvent  Emissions from  Automotive  Coatings.    Meeting  announcement,
      September 16, 1977.
5.     Monthly Labor Review, U.S. Department of Labor.  November 1976.  p 5.
6.     Jones, F.N. What Properties Can You Expect from Aqueous Solution Coatings.
      SME Technical Paper, FC74-641:3-4, 1974.
7.     Holley,  William   H.    Springborn  Laboratories,  Inc.  (formerly  DeBell  <5c
      Richardson, Inc.)  and Andreola, M., Binks Manufacturing Company.  Telephone
      conversation.
      November 7, 1977.
8.     Gabris, T.  Springborn Laboratories, Inc. (formerly DeBell & Richardson, Inc.)
      Trip Report 56. February 5, 1976
9.     Gabris, T.  Springborn Laboratories Inc. (formerly DeBell <5c Richardson, Inc.).
      Trip Report 102.  March 10, 1976.
10.    Gabris, T.  Springborn Laboratories, Inc.  (formerly DeBell & Richardson, Inc.).
      Trip Report 110.  March 11, 1976.
11.    Gabris, T.  Springborn Laboratories, Inc. (formerly DeBell & Richardson, Inc.)
      Trip Teport 5. December 2, 1975.
12.    Gabris, T.  Telephone conversation with one of the California General Motors
      plants.  October 29,1976.
13.    Gabris, T.  Telephone conversation with Gerwert, Phil. General Motors Water
      Pollution Section. November 2, 1976.
14.    Product Finishing. June 1976.  p 166
15.    Gabris, T.  Springborn Laboratories, Inc. (formerly DeBell & Richardson, Inc.).
      Trip Report 112.  March 12, 1976.
16.    Gabris, T.  Springborn Laboratories, Inc. (formerly DeBell 
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                             8.  ECONOMIC IMPACT

8.1.    INDUSTRY ECONOMIC PROFILE
8.1.1   Introduction
       The  metal  furniture  industry  as defined  here includes all establishments
engaged in the manufacture of metal household furniture.
                    1.  Metal Household Furniture      SIC 2514
                    2.  Metal Office Furniture         SIC 2522
                    3.  Public Building and
                       Related Furniture              SIC 2531
                    4.  Metal Partitions and Fixtures   SIC 2542
       Major products in  the  metal household classification include indoor dining and
breakfast furniture,  and  porch, patio  and  outdoor seating and tables;  main office
furniture products  are chairs, desks, and filing and storage cabinets.  Public building
and related furniture covers furnishings purchased by schools and institutions such as
hospitals.  Room dividers, shelves, lockers and storage bins are classified under metal
partitions and fixtures.
8.1.2.  Industry Size
       Tables 8.1-1 through 8.1-5 present a time series of basic statistics on the indus-
try stretching  from  1958  to 1975.a    fables  8.1-1  through  8.1-4 include  metal
household furniture, metal office  furniture,  public building and related furniture, and
metal  partitions and fixtures, respectively.   Table 8.1-5 presents total statistics for
the four classifications.
       In  1975, the industry  shipped products worth  $3.4 billion, employing 71,400
production  workers  and  22,900  other  employees.   Production workers earned  an
average annual salary of $8,209 in 1975 or $4.21  per hour for an average work week of
38 hours.  Other employees earned an average annual wage of $13,332.
a   Data for 1958 is not available for metal partitions and fixtures, until 1963 metal
    and wood partitions and fixtures were classified as one industry.
                                      8-1

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                                           Table 8.1-1.  BASIC INDUSTRY STATISTICS


                                               METAL  HOUSEHOLD FURNITURE


                                                          (SIC 2514)
oo
 I
to
All Employees
Year
1975
1974
1973
1972
1971
1970
1969
1968
1967
1963
1958
Establish-
ments
(Number)
NA
NA
NA
467
NA
NA
NA
NA
486
517
626
Number
(Thousands)
28.1
35.4
36.9
34.4
31.5
32.4
32.8
32.1
31.0
29.3
30.3
Payroll
(Million
Dollars)
233.5
257.5
253.6
222.5
194.2
188.1
181.4
169.4
155.5
128.8
124.6
Production Workers
Number
(Thousands)
22.5
28.8
30.6
28.6
25.8
26.7
27.6
26.5
25.8
24.3
24.6
Man-Hours
(Millions)
41.5
53.8
58.9
53.7
49.7
50.4
52.4
51.2
50.3
47.9
48.2
Wages
(Million
Dollars)
155.4
176.9
177.9
157.6
133.7
131.3
132.6
120.5
109.6
92.0
89.2
Value
Added by
Manu-
facture
(Million
Dollars)
436.6
483.6
508.8
447.2
386.3
365.8
346.2
333.9
291.3
247.0
218.7
Cost of
Materials,
Fuel
(Million
Dollars)
478.2
529.4
506.6
452.4
380.4
360.7
352.8
333.2
312.0
280.7
274.7
Value of
Industry
Shipments
(Million
Dollars)
930.6
1,003.0
999.8
890.4
763.9
724.9
697.1
664.3
605.3
524.3
496.1
Gross
Capital Value of
Expendi- Fixed
tures, New Assets
(Million
Dollars)
14.7
18.2
25.5
16.9
10.8
13.8
12.9
10.1
10.1
6.8
6.3
(Million
Dollars)
NA
199.2
193.7
174.3
146.6
148.6
129.2
127.6
125.8
91.7
NA
    Source:   U.S.  Census of Manufacturers,  1972: Annual Survey of Manufactures,  1973, 1974,  and 1975.

    NA   - -  Not Available

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                                       Table 8.1-2. BASIC INDUSTRY STATISTICS
                                             METAL OFFICE FURNITURE
                                                     (SIC 2522)
All Employees
Year
1975
1974
1973
1972
1971
1970
1969
1968
1967
1963
1958
Establish-
ments
(Number)
NA
NA
NA
192
NA
NA
NA
NA
187
170
151
Number
(Thousands)
25.2
31.1
30.1
27.6
25.0
27.6
30.5
27.1
27.0
19.9
17.5
Payroll
(Million
Dollars)
272.0
313.3
286.4
248.2
201.8
205.6
219.4
186.3
178.5
112.1
86.0
Production Workers
Number
(Thousands)
18.5
24.1
22.7
20.6
18.1
20.4
23.1
20.9
21.1
15.8
13.9
Man-Hours
(Millions)
36.5
49.0
46.5
42.6
37.5
42.4
46.5
42.7
42.9
31.5
26.9
Wages
(Million
Dollars)
183.1
221.1
192.4
166.7
134.2
136.3
151.7
128.3
125.3
81.4
62.7
Value
Added by
Manu-
facture
(Million
Dollars)
589.5
645.2
638.9
508.6
415.5
425.2
478.6
398.9
389.3
228.3
173.7
Cost of
Materials,
Fuel
(Million
Dollars)
399.4
436.4
394.8
349.8
263.7
254.2
304.2
262.6
239.5
160.1
109.7
Value of
Industry
Shipments
(Million
Dollars)
981.9
1,069.4
1,023.7
853.7
682.5
682.1
764.5
654.2
622.9
390.0
286.0
Gross
Capital Value of
Expendi- Fixed
tures, New Assets
(Million
Dollars)
23.9
25.2
39.6
24.5
14.2
14.2
20.3
32.6
31.5
14.2
5.3
(Million
Dollars)
NA
304.4
302.4
261.5
251.2
248.8
252.9
231.4
207.7
151.5
NA
Source:   U.S. Census of Manufacturers,  1972; Annual Survey of Manufactures,  1973, 1974, and 1975
NA - -    Not Available

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                                      Table 8.1-3.  BASIC INDUSTRY STATISTICS
                                     PUBLIC BUILDING AND RELATED FURNITURE
                                                     (SIC  2531)
All Employees
Year
1975
1974
1973
1972
1971
1970
1969
1968
1967
1963
1958
Establish-
ments
(Number)
NA
NA
NA
422
NA
NA
NA
NA
438
429
390
Number
(Thousands)
20.0
21.6
22.2
21.4
21.0
23.1
23.4
21.0
22.6
16.9
16.0
Payroll
(Million
Dollars)
173.6
186.1
169.1
157.8
135.5
149.9
154.5
127.7
132.2
83.4
69.3
Production Workers
Number
(Thousands)
15.6
16.9
17.4
16.3
16.3
18.2
18.3
16.4
17.5
13.3
12.6
Man-Hours
(Millions)
28.0
31.7
33.0
31.6
30.9
36.0
37.0
33.1
36.3
26.8
25.8
Wages
(Million
Dollars)
115.8
124.5
112.0
103.8
89.0
101.2
104.6
83.1
89.2
57.4
48.4
Value
Added by
Manu-
facture
(Million
Dollars)
330.3
338.7
299.6
295.9
254.5
255.3
267.4
241.3
233.6
141.8
112.9
Cost of
Materials,
Fuel
(Million
Dollars)
317.1
305.8
265.6
245.9
218.5
214.2
214.2
191.3
194.7
127.9
98.0
Value of
Industry
Shipments
(Million
Dollars)
657.5
643.1
564.9
535.3
471.8
462.6
468.5
432.3
421.2
268.6
208.4
Gross
Capital Value of
Expendi- Fixed
tures, New Assets
(Million
Dollars)
15.8
15.6
13.0
13.0
8.8
18.1
12.1
7.6
10.0
4.4
4.9
(Million
Dollars)
NA
154.8
150.5
143.6
121.3
126.5
109.5
96.4
94.5
66.3
NA
Source:    U.S. Census of Manufactures,  1972; Annual Survey of Manufactures,  1973, 1974, and 1975
NA -  -    Not Available

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                                           Table 8.1-4.  BASIC INDUSTRY STATISTICS
                                              METAL PARTITIONS AND FIXTURES
                                                          (SIC 2542)
oo
All Employees
Year
1975
1974
1973
1972
1971
1970
1969
1968
1967
1963
1958
Establish-
ments
(Number)
NA
NA
NA
507
NA
NA
NA
NA
500
513
NA
Number
(Thousands)
21.0
25.6
26.3
26.2
22.2
22.7
25.2
23.4
22.7
20.3
NA
Payroll
(Million
Dollars)
212.3
237.9
231.3
215.7
167.7
166.0
177.4
163.9
152.9
119.3
NA
Production Workers
Number
(Thousands)
14.8
18.4
19.5
19.9
16.7
16.8
18.8
17.6
17.0
14.9
NA
Man-Hours
(Millions)
29.6
37.6
38.7
38.5
30.9
32.7
37.5
35.7
35.1
31.7
NA
Wages
(Million
Dollars)
131.8
150.1
149.1
143.1
107.0
105.8
110.1
102.0
96.0
79.2
NA
Value
Added by
Manu-
facture
(Million
Dollars)
448.2
546.8
444.8
412.4
328.5
324.9
334.6
309.6
302.5
214.3
NA
Cost of
Materials,
Fuel
(Million
Dollars)
406.2
458.3
367.8
326.3
256.8
.257.4
251.0
220.2
213.0
165.7
NA
Value of
Industry
Shipments
(Million
Dollars)
868.3
987.6
805.6
734.5
580.1
579.0
583.8
524.1
512.0
377.8
NA
Gross
Capital Value of
Expendi- Fixed
tures, New Assets
(Million
Dollars)
21.6
22.2
22.7
19.4
13.3
14.9
12.5
13.4
19.9
8.5
NA
(Million
Dollars)
NA
239.3
242.7
237.5
NA
NA
172.5
156.6
150.6
117.8
NA
     Source:   U.S.  Census of Manufactures,  1972; Annual Survey  of Manufactures,  1973,  1974, and 1975
     NA - -   Not Available

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                                       Table 8.1-5.  BASIC INDUSTRY STATISTICS
                                            METAL FURNITURE INDUSTRY
                                    (TOTAL FIGURES FOR SIC 2514, 2522, 2531, 2542)
All Employees
Year
1975
1974
1973
1972
1971
1970
1969
1968
1967
1963
1958
Establish-
ments
(Number)
NA
NA
NA
1,588
NA
NA
NA
NA
1,611
1,629
NA
Number
(Thousands)
94.3
113.7
115.5
109.6
99.7
105.8
111.9
103.6
103.3
86.4
NA
Payroll
(Million
Dollars)
891.4
994.8
940.4
844.2
699.2
709.6
732.7
647.3
619.1
443.6
NA
Production Workers
Number
(Thousands)
71.4
88.2
90.2
85.4
76.9
82.1
87.8
81.4
81.4
68.3
NA
Man-Hours
(Millions)
135.6
172.1
177.1
166.4
149.0
161.5
173.4
162.7
164.6
137.9
NA
Wages
(Million
Dollars)
586.1
672.6
631.4
571.2
463.9
474.6
499.0
433.9
420.1
310.0
NA
Value
Added by
Manu-
facture
(Million
Dollars)
1,804.6
2,014.3
1,892,1
1,664.1
1,384.8
1,371.2
1,426.8
1,283.7
1,216.7
831.4
NA
Cost of
Materials,
Fuel
(Million
Dollars)
1,600.9
1,729.9
1,534.8
1,374.4
1,119.4
1,086.5
1,122.2
1,007.3
959.2
734.4
NA
Value of
Industry
Shipments
(Million
Dollars)
3,438.3
3,703.1
3,394.0
3,013.9
2,498.3
2,448.6
2,513.9
2,274.9
2,161.4
1,560.7
NA
Gross
Capital Value of
Expendi- Fixed
tures, New Assets
(Million
Dollars)
76.0
81.2
100.8
73.8
47.1
61.0
57.8
63.7
71.5
33.9
NA
(Million
Dollars)
NA
897.7
889.3
816.9
NA
NA
664.1
612.0
578.6
427.3
NA
Source:    Derived From Data in U.S.  Census of Manufactures,  1972, and in Annual Survey of Manufactures,
          1973,  1974,  and 1975.
NA -  -    Not Available

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      In 1972, the last year  for which data is available, 1,588  establishments were
listed  by  the  U.S. .Census  of  Manufacturers  as engaged  in  metal  furniture
manufacturing.  The number of establishments devoted to metal furniture manufactu-
ring has  declined, but only slightly, from the 1967 level of 1,611 establishments for
the industry as a whole.  The number of establishments involved in metal  household
and public  building and related furniture manufacturing decreased slightly from 1967
to 1972, and increased slightly for metal office  furniture and metal partitions and
fixtures. Generally, the number of establishments in the metal furniture industry has
been relatively stable with only moderate rates of exit and new entry.

8.1.3. Industry Growth: Past and Projected

      The  metal furniture industry, as a manufacturer of capital goods and consumer
durable goods, is quite volatile relative to changes in the United States economy as a
whole.   Table 8.1-6 presents the  value of metal furniture  industry  shipments  in
current and  constant 1972 dollars, as well  as real  gross  national  product,  also
expressed in 1972 dollars.  Figure 8.1-1 presents the industry's shipments in constant
dollars and real GNP  graphically.  As is  readily  evident,  activity  in  the metal
furniture industry expands more rapidly than  GNP during the growth  phase of the
business  cycle, and contracts more quickly during a period of decline (or even slow
growth).  Figure 8.1-2 presents a graph of a more direct  measure of this phenomenon:
annual percentage changes in real GNP and real shipment of metal furniture.

      In addition to the volatility  of the metal furniture industry, Figure  8.1-2 also
illustrates  a lag in the industry's reaction to shifts  in the economy.   In 1971, GNP
grew  at a real  rate of  increase  of  3.0 percent,  but metal  furniture shipments
continued  the  decline of  the economic downturn  in  1970;  in  1972,  however, the
industry  made  up for lost  time  by growing by almost  19 percent over 1971.  The
industry  did  not  lag the  arrival of  the  recession  of  1974 to 1975,  however,  as
shipments dropped by more than 7 percent in  1974.
                                      8-7

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             Table 8.1-6. VALUE OF METAL FURNITURE INDUSTRY

              SHIPMENTS IN CURRENT AND CONSTANT DOLLARS,

                                  1967 - 1975
       Value of Industry   Wholesale Price    Value of Industry  Gross National
           Shipments      Index for Com-       Shipments         Product
       (Millions of Cur-   mercial Furniture    (Millions of 1972  (Billions of 1372
Year     rent Dollarsa     (1972=100)°         Dollars)6         Dollarsr
1975
1974
1973
1972
1971
1970
1969
1968
1967
3,438.3
3,703.1
3,394.0
3,013.9
2,498.3
2,448.3
2,513.9
2,274.9
2,161.4
138.7
126.8
107.7
100.0
98.3
95.3
89.9
86.4
83.2
2,478.9
2,920.4
3,151.3
3,013.9
2,541.5
2,569.4
2,796.3
2,633.0
2,597.8
1,191.7
1,210.7
1,233.4
1,171.1
1,107.5
1,075.3
1,078.8
1,051.8
1,007.7
a

b
c

d
Source:    Table 8.1-5.

Source:    U.S. Bureau of Labor Statistics, Wholesale Prices and Price Indexes.

          Note:  This index is published with 1967=100. It has been converted

          to 1972=100 to facilitate comparison with constant dollar GNP.

Equals value in current dollars divided by (Index '-  100).

Source:    Statistical Abstracts of the United States, 1976.
                                     8-8

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               Figure 8.1-1.   REAL GROSS NATIONAL PRODUCT AND METAL

                FURNITURE INDUSTRY SHIPMENTS IN CONSTANT DOLLARS,

                                        1967 - 1975
             1500 -
Gross National
Product (Billions
of 1972'Dollars)
             1000 -
                        I      I       I      I      I      I      I      I      I
                       1967  1968   1969   1970  1971  1972   1973   1974   1975
             3000 H

 Value of Metal
 Furniture Industry
 Shipments (Millions
 of 1972 Dollars)
             2500 -
            2000 -
                        I       1     I       I      I      I      I      I      I
                       1967  1968  1969  1970  1971  1972  1973   1974   1975


              Source:  Table 8.1-6.
                                          8-9

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               Figure 8.1-2. PERCENT CHANGE FROM PREVIOUS YEAR
               IN REAL GROSS NATIONAL PRODUCT AND CONSTANT
                 DOLLAR METAL FURNITURE INDUSTRY SHIPMENTS
         20 -
         10  -
Percent   0  -
                                                        GNP
                                                 	Metal Furniture
                                                         Shipments
        -10 -
                                                       \
                                                        \
                  I      I     I      i     i      >     i      i
                 1968  1969  1970  1971  1972  1973   1974  1975
                                  8-10

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      In an industry which exhibits such volatility, calculating historic growth rates
can yield vastly different results depending on the span of years chosen for analysis.
Specifically, growth correlations for the  most recent available data for  1974 and 1975
probably understates the secular growth trend.a  To avoid this difficulty, the annual
compound growth rate may be calculated between the two  most recent shipment
peaks, 1969 and 1973.   During those four years, real shipments growth averaged 3.0
percent per year.
      We estimate long-term growth of real industry shipments will average  2 to 3
percent per year.  While data for  the entire industry  is not yet available for 1976,
statistics  for  one  segment of the industry indicate  the industry is  repeating  its
traditional pattern  of recovering from a dip in the economy with growth faster than
the economy as a whole, and in line with  historic growth rates.
      According to the Business and Institutional Furniture  Manufacturer's Associa-
tion, office furniture shipments increased at a real rate of  12 percent in 1976 over
the 1975 level.   And during the first eight months of 1977,  shipments in real terms
were 24 percent above  1976 levels.  Applying those growth rates to the industry as a
whole for  1976  and 1977   implies shipments  for 1977  (in  1972 dollars) of $3,443
million.  Growth of shipments from the 1973 peak to 1977, using  that  assumption,
averaged 2.2 percent per year.  Thus the recovery of the metal furniture industry
sales from  the most recent recession tends to support a secular growth trend of 2 to 3
percent, following the trends of the last decade.
    For example, a least squares fit of real industry shipments versus time, using a
    constant growth rate model, results in a 1.4 percent annual real growth rate from
    1967 to 1975. The latest years are  heavily weighted in this model.
    From 1969 to 1973,  metal office furniture shipments grew at almost exactly the
    same rate as the metal furniture industry as a whole.
                                     8-11

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8.1.4.  Industry Structure
      The metal furniture  industry  is  quite  fragmented.   Table  8.1-7  presents
concentration ratios for the four appropriate SIC classifications and none of the four
shows enough concentration  in the top four firms to indicate market dominance by
one or even a few firms.
      Metal  office furniture  (SIC 2522)  is  the most  concentrated  of the  four
classifications, with the  top  four firms having accounted  for 37 percent of the value
of shipments in  1972.  Concentration  increased slightly from 1967 to 1972, but not
enough to imply a trend.
      Some increase in concentration  has also occurred in metal household furniture,
but the  increase  is very  small.  In public building and related furniture and in metal
partitions and fixtures, concentration has actually decreased.
      Table  8.1-8 offers a look at the role of small  firms  in  the  metal furniture
industry.  In the economy as a whole, single-unit firmsa accounted for only 19 percent
of the  value of shipments  by  all manufacturing establishments.   But in  metal
household furniture, public building and related furniture,  and metal partitions and
fixtures, single-unit  firms accounted for at least double that  proportion of the value
of shipments, 38, 44 and 42 percent respectively.  Only in metal office  furniture did
the 17  percent  of  single-unit  firms fall near  the level of single-unit  firms  in the
economy as a whole. Small  manufacturers play a  more important role  in the metal
furniture industry than in the economy  as a whole.
      A view of the economics of plant size in the metal  furniture  industry can be
obtained from Table 8.1-9,  which lists the percent of  number of  establishments,
production worker man-hours, and value added by manufacture for establishments of
various  sizes, classified  by the number of employees per establishment.  Establish-
ments with less than 20 employees account for more than 50 percent of the number of
establishments in metal household furniture, public building  and related furniture, and
metal partitions  and fixtures.  The smaller establishments, of course, account for a
much lower percentage of the  value added by  manufacture by the industry than for
the number of establishments.
    The U.S. Bureau of the Census defines single-unit firms as one  with a single
    establishment for both manufacturing and administration.
                                     8-12

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                  Table 8.1-7.  CONCENTRATION RATIOS IN

                    METAL FURNITURE MANUFACTURING
                                     Percent of Value of Shipments
                                     	Accounted for by;	

                             4 Largest   8 Largest   20 Largest  50 Largest
                            Companies   Companies  Companies  Companies
Metal Household Furniture
    (SIC 2514)	
      1972                     14
      1967                     12
      1963                     12
      1958                     12

Metal Office Furniture
    (SIC 2522)	
      1972                     37
      1967                     32
      1963                     29
      1958                     33

Public Building and Re-
lated Furniture
    (SIC 2531)	
      1972                     18
      1967                     18
      1963                     21
      1958                     24

Metal Partitions and Fixtures
    (SIC 2542)	
      1972                     13
      1967                     19
      1963                     19
      1958                     (NA)
 23
 21
 18
 19
 49
 45
 45
 49
 26
 30
 32
 34
 22
 27
 26
(NA)
 41
 35
 31
 33
 70
 69
 69
 73
 40
 46
 45
 47
 39
 43
 41
(NA)
 65
 56
 53
 52
 88
 88
 88
 89
 59
 64
 62
 65
 59
 64
 61
(NA)
Source:   U.S. Census of Manufactures, 1972, Concentration Ratios in Manufacturing.
NA —  Not Available
                                    8-13

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       Table 8.1-8.  PERCENT OF VALUE ADDED IN METAL

       FURNITURE MANUFACTURING BY MULTI-UNIT AND

                 SINGLE-UNIT COMPANIES, 1972
                                   Multi-Unit
                                   Companies
             Single-Unit
             Companies
                                            Percent
All Manufacturing Establishments


Metal Household Furniture
(SIC 2514)	


Metal Office Furniture
(SIC 2522)	


Public  Building  and Related
Furniture  (SIC  2531)	


Metal Partitions and Fixtures
(SIC 2542)
81
62
83
56
58
19
38
17
44
42
Source: U.S. Census of Manufactures, 1972, Type of Organization.
                            8-14

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                      Table 8.1-9.  DISTRIBUTION BY FIRM SIZE IN THE METAL FURNITURE INDUSTRY

                           OF ESTABLISHMENTS, PRODUCTION WORKERS AND VALUE ADDED

                                               BY MANUFACTURE, 1972

                                                (Share of Total, Percent)
                                  Metal Household Furniture
                                         (SIC 2514)
                                                                        Metal Office Furniture
                                                                             (SIC 2522)
oo
 I
  Firm Size
 (Number of
Employees per
Establishment)

    1 to 19
   20 to 49
   50 to 99
  100 to 249
  250 to 499
  500 to 999
1,000 to 2,499
2,500 or More
            1 to 19
           20 to 49
           50 to 99
          100 to 249
          250 to 499
          500 to 999
        1,000 to 2,499
        2,500 or More

Number of
Establishments
(Percent)
50.7
18.0
10.3
13.1
6.2
1.3
0.4

53.8
20.9
11.4
10.2
2.8
0.7
0.2
Production Value Added
Worker by
Man-hours Manufacture
(Percent) (Percent)
4.9 5.0
8.2 7.3
10.3 10.6
29.7 30.5
31.3 29.2
15.7 17.5
(NA) (NA)
Public Building and Related
Furniture
(SIC 2531)
6.6 6.8
13.6 11.1
18.0 16.2
30.9 31.1
18.3 19.0
12.6 15.7
(NA) (NA)
Production
Number of
Establishments
(Percent)
39.1
14.1
15.6
18.2
6.3
4.2
2.1
0.5
Metal


52.3
22.5
12.0
8.9
2.4
1.4
Worker
Man-hours
(Percent)
1.3
3.5
7.7
19.7
16.9
21.5
29.3
(NA)
Partitions
Fixtures
(SIC 2542)
7.3
14.0
17.7
31.2
13.8
16.1
Value Added
by
Manufacture
(Percent)
1.3
2.7
7.4
16.2
17.7
20.6
34.1
(NA)
and


7.1
13.3
14.6
29.4
16.5
19.2
        Source: U.S. Census of Manufactures, 1972
        NA = Not Available

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      In the case of all four industry segments, the very largest plants in the industry
have the greatest labor productivity.  For instance,  in metal office furniture, in the
largest plants, 29.5 percent of production workers man-hours are able to produce 34.1
percent of the value added by manufacture.  (See Table 8.1-9.)  However, just because
one plant is larger than another does not necessarily mean that the larger plant is
more   efficient;  a  threshold  effect is  evident.   Some  intermediate  sizes  of
establishments, for example, those with 100 to 249 or 500 to 999 employees in metal
office furniture, account for a lower percentage of value added by  manufacture than
of production worker man-hours.  At present, no economies of scale  are evident in the
metal  furniture  industry  which prohibit a  small  manufacturer  from  competing,
especially in regional  markets  where lower labor productivity may be overcome by
lower distribution costs.
8.1.5.  Channels of Distribution
       The four segments  of the industry market through different outlets; the one
common denominator  is that a  large number of outlets sell to end-users.  The 1972
Census of Retail Trade reported that 32,987 establishments marketed furniture and
sleep equipment. One  manufacturer estimated that 25,000 outlets handle metal office
furniture; another manufacturer of outdoor furniture estimated that 30,000 to 60,000
retail outlets offer outdoor furniture.  No single manufacturer is represented in the
majority of end-user outlets.
       Furniture marts play a major role in the marketing of metal household, metal
office and public  building and related furniture.  At these martsa buyers gather to
examine the  products  of a large number  of manufacturers. Such marts are extremely
competitive.  The furniture mart provides a mechanism for smaller manufacturers to
compete  without  maintaining regional showrooms which  are characteristic of  some
larger manufacturers.
       Metal partitions and fixtures are marketed  primarily through locally owned
distributors  who  usually carry  or  offer  the  products  of  a  large  number of
manufacturers. Price competition  in this market is therefore particularly keen, as
end-users can compare prices of various manufacturers in one location.  The number
of such distributors is quite large;  in addition to shelves,  lockers, storage bins and
other  fixtures, such outlets often carry related products such as  material handling
equipment.
 a   Two key marts are in Chicago and High Point, North Carolina.

                                      8-16

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8.1.6. Industry Markets
      Table  8.1-10  presents the  product mix of the metal furniture industry as a
percent of the value of total industry shipments.  No major changes in product  mix
have occurred since  1967.
      The most important development in metal  furniture marketing of the  last
decade has occurred in the office furniture market, which includes  not only  metal
office furniture (SIC 2522) but also metal partitions and fixtures (SIC 2542).  With the
growing importance  of white collar and service workers in the American economy,
managers have turned  their attention more and more to white collar productivity. A
major  issue   has  been,  of course,  the  office  environment.    Metal  furniture
manufacturers have responded  to this change in the marketing environment with
increased attention  to the need for systems — not just desks and chairs and room
dividers, but  modular  units that  can  be  fitted together in a number of ways.   As
Hauserman Inc., stated in its 1977 annual report,  "Our strategy has  been to broaden
our opportunities in  the office furniture market by improving user productivity.  We
accomplish this through easy movability, our ability to reorganize  the wiring, lighting,
communications, and other services of the building, and our  accommodating individual
furniture needs of office people."  Herman  Miller Inc., in its 1977 10-K report to the
Securities and Exchange  Commission, also address the issue of  systems marketing:
"The  principal  business  of  the  company is  the  research,  design, development,
manufacture   and  sale of modular  space division, storage and  materials handling
furniture  systems and other furniture products  such  as chairs, tables, desks  and
general purpose seating.   Most of these products and systems  are coordinated in
design so that they may be used  together and interchangeably."
8.1.7. Labor  and Materials Costs
      Labor  and materials and  fuel costs have represented roughly constant share of
the value of  industry  shipments during the past decade.a   No  major changes in the
industry's cost structure are apparent. Table 8.1-12 offers a detailed view of labor
productivity  in the  industry.  With  one exception - - the  most recent period in the
metal household furniture industry - - labor productivity has grown more  rapidly than
the average hourly earnings of  production workers during the periods analyzed.  The
productivity gains in metal office furniture and metal partitions  and fixtures in the
1972 to 1975  period are particularly noticeable.
p
    Table  8.1-11  reveals  a decline in labor costs to 1975, but this  is difficult to
    interpret correctly due to the recession of that year.

                                      8-17

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          Table 8.1-10.  METAL FURNITURE PRODUCT MIX, 1963 - 1975

                 (As Percent of Value of Total Industry Shipments)
Metal Household  Furniture
(SIC 2514)	

Dining,  breakfast
Kitchen
Porch, lawn,  outdoor
Other

Metal Office Furniture
(SIC 2522)	

Office seating
Desks
Cabinets, cases
Other

Public Building and Related
Furniture (SIC 2531)	

School furniture
Non-school furniture
Other

Metal Partitions  and Fixtures
(SIC 2542)	

Partitions
Shelving  and  lockers
Storage racks,  accessories
Fixtures
Other
                                 1975    1974   1973   1972    1967   1963
28.1   28.1   29.9    30.1   28.3    33.9
9.2
1.7
6.8
10.5
27.8
7.0
4.5
10.9
5.4
19.5
7.2
11.8
0.5
24.7
3.4
8.0
4.7
6.6
1.9
8.9
1.7
6.8
10.7
29.5
7.7
5.5
11.2
5.1
17.4
6.7
10.1
0.6
25.0
3.1
7.8
5.5
6.6
2.1
8.5
2.7
6.1
12.5
28.9
7.5
5.5
11.4
4.5
17.3
6.3
9.7
1.3
24.0
2.5
8.2
3.4
8.3
1.5
8.6
2.5
6.2
12.8
27.4
6.8
5.4
10.5
4.8
17.4
6.4
9.8
1.2
25.0
2.8
8.3
3.3
7.6
3.0
7.9
2.7
5.3
12.4
28.2
6.4
7.3
9.6
4.9
18.8
7.6
10.1
1.0
24.7
(NA)
(NA)
(NA)
(NA)
(NA)
9.4
4.2
6.8
13.5
23.9
4.9
5.9
9.6
3.6
17.6
7.9
9.0
0.7
24.6
(NA)
(NA)
(NA)
(NA)
(NA)
Source:  Annual Survey of Manufactures, U.S. Census of Manufactures.

NA —  Not Available
                                 8-18

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Table 8.1-11.  LABOR AND MATERIALS COSTS IN METAL
FURNITURE MANUFACTURING RELATIVE TO VALUE OF
              INDUSTRY SHIPMENTS
                  As % of Value of Shipments
Year
1975
1974
1973
1972
1971
1970
1969
1968
1967
1963
1958
Production
Workers'
Wages
17.0
18.2
18.6
19.0
18.6
19.4
19.8
19.1
19.4
19.9
20.2
Cost of
Materials,
Fuel
46.6
46.7
45.2
45.6
44.8
44.4
44.6
44.3
44.4
47.1
48.7
        Source: Derived from Table 8.1-5.
                     8-19

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                                   Table 8.1-12.  TRENDS IN WAGES AND PRODUCTIVITY

                                          IN THE METAL FURNITURE INDUSTRY,

                                                        1958 - 1975
oo
                Metal Household Furniture
                      (SIC 2514)
                                       Metal Office Furniture
                                            (SIC 2522)
Public Building and
 Related Furniture
    (SIC 2531)
Metal Partitions and Fixtures
        (SIC 2542)
Average
Hourly
Earnings of
Production
Year
1975
1974
1973
1972
1967
1963
1958
Average
Annual
Compound
Growth
Rates from:
Percent
1958-1975
1967-1975
1972-1975
Workers
3.74
3.29
3.02
2.93
2.18
1.92
1.85



4.20
7.00
8.50
Value Added
per Man-hour
of Production
Workers
10.52
8.99
8.64
8.32
5.79
5.16
4.54



5.10
7.70
8.10
Average
Hourly
Earnings of
Production
Workers
5.02
4.51
4.14
3.91
2.92
2.58
2.33



4.60
7.00
8.70
Value Added
per Man-hour
of Production
Workers
(Dollars)
16.15
13.17
13.74
11.94
9.08
7.24
6.45



5.50
7.50
10.60
Average
Hourly
Earnings of
Production
Workers
4.14
3.93
3.39
3.28
2.46
2.14
1.88



4.80
6.70
8.10
Value Added
per Man-hour
of Production
Workers
11.80
10.68
9.08
9.36
6.44
5.29
4.38



6.00
7.90
8.00
Average
Hourly
Earnings of
Production
Workers
4.45
3.99
3.85
3.72
2.73
2.50
(NA)



(NA)
6.30
6.20
Value Added
per Man-hour
of Production
Workers
15.14
14.54
11.49
10.71
8.61
6.77
(NA)



(NA)
7.30
12.20
NA -
                   of Manufactures, Annual Survey of
                 Available

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       Coating materials cost varies in importance among the four segments analyzed
here, as shown in Table 8.1-13.  Cost is relatively higher for metal office furniture
and  metal partitions and fixtures, as it to be expected, for in  major,  high-volume
products in these segments, e.g.,  file and storage cabinets and industrial shelving,
coating is more important in the manufacturing process, and metal processing is less
important than in the production of, for example, wrought iron lawn chairs.

       The relative importance of  coating material costs detailed in Table 8.1-13 is
borne out by direct industry estimates of total coating costs as a percentage of total
manufacturing costs.  A  manufacturer of hospital beds (public building and related
furniture) reports that  coating costs, including both materials and the cost of  their
application, run about 4 percent of total manufacturing costs;  a company specializing
in industrial shelving, office desks and file cabinets  reports that total coating costs
average 10 to 12 percent of total manufacturing costs.

8.1.8.  Financial Performance

       A wide  range  of financial performance is  to  be expected in an industry  as
fragmented as metal furniture. Table 8.1-14 bears out this expectation for some of
the largest  manufacturers' of  metal furniture.  There is a wide range of profitability
even among these firms.

8.1.9.  Imports and Exports

       Imports and exports are extremely small in the  metal  furniture industry, and
do not play a significant role in industry conduct in the United States.
                                      8-21

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         Table 8.1-13.  METAL FURNITURE COATING MATERIALS COST

           VS. TOTAL MATERIALS COST AND VALUE OF SHIPMENTS,

                                1972 AND 1967
                                           Coating Materials Costs
                                     1972
                             Percent of
                              Cost of
                             Materials
          Percent of
           Value of
           Industry
          Shipments
                                  1967
           Percent of
            Cost of
            Materials
          Percent of
           Value of
           Industry
          Shipments
Metal Household Furniture
(SIC 2514)	


Metal Office Furniture
(SIC 2522)	
1.7
3.2
0.8
1.0
2.1
4.1
1.0
1.3
Public Building and
Related Furniture
(SIC 2531)	
1.9
0.8
1.9
0.8
Metal Partitions and Fixtures
(SIC 2542)
3.6
1.4
4.7
1.8
Source:  Census of  Manufactures
                                   8-22

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to
GO
                Table 8.1-14.  FINANCIAL RATIOS FOR SELECTED METAL FURNITURE MANUFACTURERS

                                          (Date Indicates End of Fiscal Year)


               G. F. Business                                                          Lyon Metal          Virco
              Equipment Inc.   Hauserman Inc.   Herman Miller Inc.   Hon Industries Inc.   Products Inc.   Manufacturing Corp.

              12/76    12/75   6/77     6/76   5/77        5/76   12/76      12/75   12/76  12/75  1/77        1/76


Cost of Sales
as Percent of
Net Sales      83.4     80.1   77.3     77.9   59.2        56.5   65.0       66.2    68.5   69.5   71.1        69.2


Net Income
as Percent of
Net Sales       0.0      0.8    1.7      4.1     5.1         5.3    7.2        6.6     5.0    4.2    2.4         2.7


Return on
Equity
Percent        0.0      1.8    5.9     14.3   19.6        15.5   23.3       20.6     7.5    6.0    14.9       15.9
Source: Annual reports, 10-K filings with the Securities and Exchange Commission.

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8.1.10.   Geographic Distribution
         The metal furniture  industry is not concentrated  in any  single area of the
country, as Table 8.1-15 indicates. It should be noted that for metal office furniture,
public building and related furniture, and metal partitions and fixtures, a preponder-
ance of larger establishments are located  in the North Central states.  These states
account  for a much larger share of the value added by manufacture than  for number
of establishments.  These states contain the largest manufacturing plants. Table 8.1-
16 presents a more detailed breakdown on  the location of establishments throughout
the United States.a
a    Data in Table 8.1-16 on the geographical distribution of the establishments must
     be used with care; as data in Table 8.1-15 on the North Central states indicates,
     percent  of establishments do  not necessarily coincide with  percent of value
     added by manufacture  (and thus with percent of employment).  Due to the need
     to maintain  confidentiality  from census  surveys, data  on  value  added  by
     manufacture and percentage of production workers is often not available for the
     finer geographic breakdowns in Table 8.1-16.
                                      8-24

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                Table 8.1-15.  GEOGRAPHICAL DISTRIBUTION OF

           ESTABLISHMENTS AND VALUE ADDED BY MANUFACTURE,

                      METAL FURNITURE INDUSTRY, 1972
                                             Share of
                                         Establishments
                                            (Percent)
                 Share of
              Value Added
             by Manufacture
                (Percent)
Metal Household Furniture
(SIC 2514)	

North East
North Central
South
West

Metal Office Furniture
(SIC 2522)	
North East
North Central
South
West

Public Building and Related Furniture
(SIC 2531)	
North East
North Central
South
West

Metal Partitions and Fixtures
(SIC 2542)	

North East
North Central
South
West
33.8
19.1
28.5
18.6
33.2
32.6
15.8
18.4
19.0
32.5
30.6
18.0
39.3
30.0
16.6
14.2
(NA)
(NA)
 35.2
 17.2
 27.7
 51.8
 12.6
  7.9
 14.7
 43.5
 28.7
 13.0
 27.5
 49.5
 15.3
  7.7
Source:  Derived from U.S. Census of Manufactures, 1972.

Note:   North East includes New England and Middle  Atlantic states; North Central
        states  in East North  Central and West North Central; South states in  the
        South Atlantic, East South Central, and West  South Central; and West states
        in the Mountain and Pacific regions. Individual states within the divisions are
        listed in Table 8.1-16.

NA - - Not Available
                                    8-25

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              Table 8.1-16.  GEOGRAPHICAL DISTRIBUTION OF METAL
                   FURNITURE INDUSTRY ESTABLISHMENTS, 1972
                       (In Percent of Number of Establishments)
New England
Middle Atlantic
East North Central
West North Central
South Atlantic
East South Central
West South Central
Mountain
Pacific
                      Metal
                     Household
                     Furniture
                     SIC 2514
                     (Percent)
             Metal
            Office
           Furniture
           SIC 2522
           (Percent)
          Public Building
           and Related
            Furniture
            SIC 2531
           (Percent)
5.1
28.7
16.3
2.8
16.1
7.1
5.4
1.5
17.1
3.1
28.6
25.0
8.9
7.3
4.7
4.2
0.5
17.7
4.5
14.5
24.9
7.6
11.4
8.5
10.7
4.0
14.0
                   Metal
                 Partitions
                and Fixtures
                 SIC 2542
                (Percent)
              Total
            Industry
            SIC 2514,
              2522,
              2531,
              2442
            (Percent)
4.3
34.9
23.3
6.7
6.9
4.1
5.5
1.0
13.2
4.5
26.9
21.9
6.0
10.8
6.2
6.7
1.9
15.1
Total Establishments
(Number)
467
192
422
507
1,588
Source: 1972 Census of Manufactures.

Note: The above classifications contain the states indicated below:
      New  England:   Main,  New Hampshire,  Vermont, Massachusetts,  Rhode  Island,
      Connecticut; Middle Atlantic:  New York, New Jersey,  Pennsylvania; East North
      Central:   Ohio,  Indiana,  Illinois,  Michigan,  Wisconsin;  West  North  Central:
      Minnesota, Iowa, Missouri, North Dakota, South Dakota,  Nebraska,  Kansas; South
      Atlantic:  Delaware, Maryland, District of Columbia, Virginia, West Virginia, North
      Carolina,  South  Carolina,  Georgia,  Florida;  East   South  Central:   Kentucky,
      Tennessee,  Alabama,  Mississippi;  West  South  Central:    Arkansas,  Louisiana,
      Oklahoma, Texas; Mountain:  Montana, Idaho, Wyoming, Colorado,  New Mexico,
      Arizona, Utah, Nevada; Pacific: Washington, Oregon, California, Alaska, Hawaii.
                                       8-26

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8.2.   COST ANALYSIS OF ALTERNATIVE EMISSION CONTROL SYSTEMS
      Cost models were prepared as guides to show average costs for coating lines
subject to new source performance regulations. A wide variety of coating line sizes
and  outputs are used in the metal furniture  industry.  To adequately  cover this
industry it was decided to construct two basic and distinct cost  models. A relatively
small line coating 3000,000  square feet per year (278,707 square meters), was chosen
to compare solvent-borne,  water-borne,  high solids and  powder  coating all by
electrostatic spray, and add-on controls.   A larger output line capable  of coating
approximately 23,000,000 square feet per year (2,086,957 square meters) was selected
to compare  solvent-borne  and  water-borne  dip  coatings, electrodeposition  and
appropriate add-on controls. Such lines are used for high volume coating where  high
quality is not  a  prerequisite and where few colors are involved or for long runs of a
single color .  It is not the intent to show any cross comparisons between these two
line sizes but to compare each on its own merits on a separate  basis.  The choice of
lines  should not be construed as limiting spray coating only to small lines or dip
coating to very  large lines.  It is merely an attempt  to  show actual  production
situations.
      Metal  furniture  manufacturers  normally  apply  only  one  coat varying in
thickness from .005" to .0015" depending on the product and the color -lighter colors
tend to be applied thicker because of less hiding power. It is difficult to apply powder
coatings  much less than .002" in commercial production and get an acceptable finish.
(See  Table  4-1,  Chapter  4 for typical thicknesses.)  High solids coatings, because of
their higher viscosities, also tend toward thicker coatings and are normally applied in
                        o
the .001" to .0015" range .  For the smaller electrostatic spray lines, a dry coating
thickness of .001" was assumed  for  the  conventional solvent-borne and water-borne
coating models.   For high solids coating, a thickness of .00125" was assumed and for
powder coating,  a thickness of .002" was assumed.  For the dip coat and EDP lines, a
coating thickness of .001" was assumed for the costing models.  The majority of firms
visited worked only one shift.  The  costing models, therefore,  were based on one 8
hour shift, 240  days per year or  1920 hours per  year.  Capital costs include all
equipment used  in the coating operations except washing or other metal pretreatment
equipment.  Building space  is included at  30
-------
      Capital costs used in the models reflect  a typical installation  where normal
color changes are  programed  within  the  production  cycle for efficient operation.
Facilities requiring rapid color changes would have to be treated on an  individual
basis.
      With the  add-on controls it was assumed that all the solvents  emitted from
application areas and ovens went through the control unit.  Most water wash spray
booths  have recirculating  water  systems.   Any solvent from overspray  that is
                                                                               3
captured by the water curtain is eventually evaporated into the air  exhaust system .
Both  incinerators and  carbon  adsorbers were  figured as  operating at  an average
efficiency of 90  percent.
      For  the  smaller  line, two add-on  controls and three  alternative painting
methods were considered. Cost models are as follows:

                      Table 8.2-1.  CASE CODES A-l  - A-7
            Code
            A-l         Base Case - Solvent-borne coating
                        electrostatic spray - no controls
            A-2         Base Case - thermal incinerator on oven only
            A-3         Base Case - carbon adsorber on spray booth
                        and flash-off area
            A-4         High solids coating - electrostatic spray
            A-5         Powder coating - electrostatic spray
            A-6         Water-borne coating - electrostatic spray
            A-7         Base Case - carbon adsorber on spray booth
                        and flash-off area and incinerator on oven
       For the larger line, two add-on controls and two alternative coating methods
were selected as follows:
                                     8-28

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                      Table 8.2-2.  CASE CODES B-l  - B-6


            Code
            B-l         Base Case - solvent-borne coating - dip coat
            B-2         Water-borne coating - electrodeposition (EDP)
            B-3         Solvent-borne dip coat - carbon adsorber on dip
                        tank exhaust and flash-off area
            B-4         Solvent-borne dip coat - thermal incinerator on
                        oven exhaust.  Primary heat recovery.
            B-5         Solvent-borne dip coat - carbon adsorber on dip
                        tank and flash-off area and  incinerator on oven.
            B-6         Water-borne coating - dip coat

      Pertinent cost and emission data as developed from the cost models are shown
in Table 8.2-3, Part I and Table 8.2-4, Part II, in order of increasing emission.
8.2.1. Cost Effectiveness Summarized -New  Facilities
      For  new facilities the two most cost effective  systems for the lower output
lines are powder coating and high solids coating.   The latter system achieves high
emission reduction  with  no annual cost penalties in the model costed. The powder
coating showed  only a modest increase in annual costs (about  2  percent) over the
conventional solvent-borne base case.
      Powder coating of metal furniture  is already  an accepted  practice, being used
by many manufacturers for applying coating thicknesses of .0015" and above.  Six of
the metal furniture companies visited by Springborn  Laboratories in the course of this
study used  powder coating for at least part of their  coating operations. The majority
of applications were by electrostatic spray although fluidized beds were also used for
smaller parts  and where heavy coating thicknesses (.006" and  over) were desired.
High solids coatings also  show potential as a non-polluting, cost saving alternative to
conventional coating methods.  Although  most work has been done  in the medium
solids range of 50 to 60 percent NVV, higher solids  coatings are in use. The costing
model was  based on  80 percent solids. While considered high by many  in the industry,
                                     8-29

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a major company visited  by Springborn Laboratories is  commercially applying an
                                                                              2 4
alkyd based  coating at 80  percent solids after several years of  development ' .
Despite considerable interest in high solids coatings, there are very few lines in the
                                                  c c
metal  furniture  industry  in  commercial operation ' .   Materials and  application
techniques are still undergoing development.
       Water-borne  coatings applied by electrostatic spray achieve a high emission
reduction  but  are  potentially  more  expensive  than  conventional  solvent-borne
coatings.   Typical alkyd coatings in a water-borne  formulation cost about $1.00 per
                                                  7
gallon  more  than their solvent-borne  counterparts .  Coating lines are also more
expensive as stainless steel is used in some areas to prevent rusting.  There is very
                                                                       B 8 9
little action in the metal furniture industry with water-borne spray coatings  ' ' .
       As  for  control equipment,  both  carbon  adsorption  and  incineration  are
expensive in  proportion to amount of emission reduction  and are more likely to be
used in retrofit situations than in new facilities.
       For the larger output line models, electrodeposition (EDP) is considerably more
cost effective in terms of dollars per ton of  reduced emissions than control options
such as incineration or carbon adsorption. It  is also more cost effective than water-
borne  dip  coating primarily because of  the cost of coating  materials.   Capital
investment for EDP is higher than for dip coating, however. It should be noted that
no  water-borne dip coating operations were observed by  Springborn Laboratories
during industry visits.   Water-borne  coating materials  suitable  for dip coating,
however,  are available from major  suppliers. Costs range  10 to 15 percent higher
than for solvent-borne counterparts.
       In  the case  of both the large  and  small lines  controlling  emissions  by
incineration  on the  oven is more expensive than by carbon adsorption on application
and flash-off areas on a cost per ton of solvent removed basis.
       Although both spray booth and dip tank emissions  are below the 3000 pounds
per  day  (assuming  exempt solvents)  allowed by  the  Los  Angeles  Rule 66  type
regulations adopted by many states (as long  as  oven emissions are controlled), cost
models were prepared controlling both application emissions  and oven emissions of
the solvent-borne spray line and dip coating  line.  As can be seen  from Table 8.2-3,
Case A-7  and  B-5, emissions going into the control device  can be reduced  by 90
percent by these combinations but costs per ton of emissions reduced is considerably
more than alternative coating methods.
                                      8-30

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                                                                       EraSI
oo

CO
Case
No.


A-5  Powder coating

A-7  Base - adsorber on
     spray booth, in-
     cinerator on oven

A-4  High solids

A-6  Water-borne

A-3  Adsorber on spray
     booth

A-2  Incinerator  on oven

A-l  Base case - solvent
     spray
               B-2   EDP dip

               B-5   Base - adsorber on
                     application, incinera-
                     tor on oven

               B-6   Water-born dip

               B-3   Adsorber on
                     application

               B-4   Incinerator on oven

               B-l
     Base case - solvent
     dip
                           Table 8.2-3.  ALTERNATIVE C^SES - NEW FACILITIES

                                        METAL FURNITURE - PART I

                                 Model Size - Coating Capacity 3000,000 Square Feet
                                         (278,707 square meters) Per Year
Incremental
KG VOC
Annual Cost Total Coating Increased Cost Emitted Per
Total Annual Over Base Cost Over Base Case Liter Coating
Cost Case $/Sq. Meter $/Sq. Meter (minus water)
2S3.070
288.280
243,810
278.080
276. ISO
260.740
248,610
Model
517.200
572,940
559.590
538,180
548,060
4,460
39,670
(4,800)
29,470
27.540
12,130
—
.910
1.03
.870
.997
.990
.935
.892
.02
.14
(.02)
.11
.10
.04
—
.01*
.0545
.1678
.2272
.1773
.4226
.5457
Cost Per
Metric Ton
of VOC
Percent Controlled
Reduction $/Metric Ton
99* 261
90 2,576
83 0
79 2,195
68 2,347
22 3.110
—
Size - Coating Capacity 22,464,000 Square Feet
(2,086,957 square meters) Per Year
3,900
59,640
46,270
24,880
34,760
.248
.275
.268
.258
.263
.002
.029
.022
.012
.017
.0987
.0348
.2272
.2508
.3490
93 45
90 722
80 630
54 502
36 1,052
                                          513,300
.246
.5457
               a
                  Some volatile organics can be emitted on the order of 0.5 to 3 percent from plasticizers or other
                   additives. Thermoset resins which comprise the bulk of the market generally emit less than 1 percent.

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              Table 8.2-4. ALTERNATIVE CASES - NEW FACILITIES

                         METAL FURNITURE - PART II
               Model Size:  Coating Capacity 3000,000 Square Feet
                        (278.707 square meters) Per Year
Case
A-5
A-7
A-4
A-6
A-3
A-2
A-l
Total Capital
Investment
370,000
531,410
350,000
496,000
495,750
439,410
403,750
Increased Capital
Over Base
(33,750)
127,660
(53,750)
92,250
92,000
35,660
—
Solvent
Metric Tons
Per Year
<0.19a
1.7
2.86
3.67
5.5
13.22
17.1
Emitted
Pounds
Per Day
<1.7a
15
26
34
51
121
157
               Model Size: Coating Capacity 22,464,000 Square Feet
                       (2,086,957 square meters) Per Year
B-2
B-5
B-6
B-3
B-4
B-l
629,200
689,420
525,000
570,420
670,420
488,420
140,780
201,000
36,580
82,000
119,000
—
6.2
9.18
18.4
42.23
58.75
91.8
57
84.3
169
388
540
843
Cases correspond to codes on Tables 8.2-1 and 8.2-2
a See footnote on Table 8.2-3
                                    8-32

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      Only thirteen states  currently have statewide regulations controlling organic
solvent  emissions  from stationary sources,  but  eight  other  states  with  a total of
twelve  districts  within  these states have  promulgated  individual, non-statewide
regulations.  Most of these  regulations are based on or are similar to Rule 66  of the
Los Angeles Country Air Pollution Control District.
      This regulation limits oven emissions to 15 pounds per day per oven and all
emissions  of photoreactive  solvents  from  any   machine,  equipment,  or  other
contrivance to 40 pounds per day. The limit  on "exempt" solvents is  3000 pounds per
day.  The law permits, however,  these limits  to be exceeded if the total emissions
have been reduced by 85 percent  or more.   Most of the state and local regulations
follow these limits closely.
      The affected  facilities in  the  coating line are  assumed to be the application
and flash-off area and the  oven.  As can be seen  from Table 8.2-5 oven  emissions
from  the smaller line are  controlled to below the  15 pounds per  day limit  by
incineration, high-solids coating  and  powder coating.   Water-borne spray coatings
exceed the 15 pound limit if one assumes that 50 percent of the solvents are emitted
from  the oven.   This has found  to be so in other  industries (automotive) because
higher boiling solvents are generally used in water-borne coatings than in convention-
al solvent-borne coatings where 10 to 30 percent of emissions are from the oven   .
The use of water-borne coatings with  a solvent content of not over 20 percent  of the
liquid contents,  however, provides exemption from  most  state  and local emission
control laws.
      For the large dip coat line  only EDP coatings fall below the 15  pound level.  As
stated above, however, the Rule 66 type laws allow this limit to be exceeded provided
emissions are reduced by at least  85 percent which is the case with incineration.
      Four states and  four districts have upper limits on the  amounts of exempt
(non-photoreactive) solvents emitted from sources other than ovens.  These generally
follow Rule 66, which places a limit of 3000 pounds per day - except for Connecticut,
which has a limit of 800 pounds per day. In all of  the model cases shown, these limits
were  not exceeded even with no  controls, assuming of course, that exempt solvents
are being used.  It is the latest EPA purpose, however, to place limits on all solvent
                                                    11 12
emissions not just those that are avtively photoreactive  '  .
                                     8-33

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               Table 8.2-5. METAL FURNITURE COATING
           SOLVENT EMISSIONS FROM AFFECTED FACILITIES
                    Model Size: Capacity 3,000 Square Feet
                       278,707 square meters) Per Year
      Model Case No.
          A-l
          A-2
          A-3
          A-4
          A-5
          A-6
          A-7
Application Area
Metric Tons
Per Year
12.83
12.83
1.28
2.15
0
1.84
1.28
Pounds
Per Day
118
118
11.8
19.7
0
16.87
11.8
Oven
Metric Tons
Per Year
4.27
.43
4.27
0.72
<0.19a
1.84
.43
Pounds
Per Day
39
3.9
39
6.6
<1.7f
16.9
4
      a
              Model Size: Coating Capacity 22,464,000 Square Feet
                      (2,086,957 square meters) Per Year
          B-l
          B-2
          B-3
          B-4
          B-5
          B-6
55.08
5.62
5.51
55.08
5.51
11.04
506
52
51
506
51
101
36.72
0.62
36.72
3.67
3.67
7.36
337
  6
337
 34
 34
 68
Cases correspond to codes on Tables 8.2-1. and 8.2-2.
a
  See footnote on Table 8.2-3.
                                   8-34

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8.2.2.  Reconstructed Facilities
       Add-on controls for all intents and purposes will cost about the same as on new
facilities providing space is available especially for large carbon adsorbers on spray
booths and providing emissions are similar to a new facility using solvent-borne spray
or dip  coating. Since the latter could vary depending on the coating system chosen, it
was assumed for costing purposes that the reconstructed lines had the same outputs
and solvent emissions as the new facilities in Cases A-l and B-l.
       Add-on controls used are the same as those used in the new facilities as shown
in Tables 8.2-6 and 8.2-7.
       As for alternative coating systems  such, as  water-borne or high solids, it is
possible that a reconstructed facility could be altered to  accomodate these.  Each
case will be different, however, depending on  the degree of reconstruction.  For
example, it might be possible to  switch  to a high solids coating just by adding new
guns at a cost of $10,000 to $20,000. A  switch to powder coating on the other hand
would  require a recovery system  as  well as  a new spray  booth at considerable
expense. Since costs to convert to a different coating system will be so variable only
the add-on controls will be considered in this analysis.

                       Table 8.2-6. CODES A.l-1  -  A.l-3

            For smaller line:
            Code
            A.l-1       Thermal incinerator on oven exhaust
            A.l-2       Carbon adsorber on spray booth exhaust
            A.l-3       Incinerator on oven plus carbon adsorber
                        on spray booth
            For larger line:
                        Table 8.2-7. CODES B.l-1  -  B.l-3

            Code
            B.l-1       Carbon adsorber on dip tank exhaust
            B.l-2       Thermal incinerator on oven exhaust
            B.l-3       Carbon adsorber on dip tank plus incin-
                        erator on oven
       Pertinent cost and emission data as developed  from cost models are shown in
Tables 8.2-8 and 8.2-9.  Costs shown are those for the control option only and are
incremental to the cost of reconstructing  the facility.

                                      8-35

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       Table 8.2-8. ALTERNATIVE CASES - RECONSTRUCTED FACILITIES

                        METAL FURNITURE - PART I
               Model Size:  Coating Capacity 3000,000 Square Feet
                       (278,707 square meters ) Per Year
Case
A.l-3
A. 1-2
A.l-1
Incremental Incremental Kg VOC Percent
Annual Cost Emitted Per Reduction
Cost $/Sq. Meter Liter Coating Total VOC
39,670 .14
27,542 .10
12,130 .04
.0545 90
.1773 68
.4226 22
Cost Per
Metric Ton
of VOC
Controlled
2,560
2,374
3,110
Model Size: Coating Capacity 22,464,000 Square Feet
(2,086,975 square meters) Per Year
B.l-3
B.l-1
B.l-2
59,640 .03
24,880 .01
34,760 .02
.0348 90
.2508 54
.3490 36
722
502
1,052
Cases correspond to codes on Tables 8.2-6 and 8.2-7
                                   8-36

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       Table 8.2-9. ALTERNATIVE CASES - RECONSTRUCTED FACILITIES

                        METAL FURNITURE - PART II
               Model Size: Coating Capacity 3000,000 Square Feet
                        (278.707 square meters) Per Year
Case
A. 1-3
A. 1-2
A. 1-1
Capital Investment
of Add-on Controls
92,000
56,340
35,660
Solvent
Metric Tons
Per Year
1.7
5.5
13.22
Emited
Pounds Per
15
50
121

Day



              Model Size:  Coating Capacity 22,864,000 Square Feet
                       (2,086,957 square meters) Per Year
          B.l-3        201,000              9.18             84

          B.l-1        82,000             42.23            388

          B.l-2       119,000             58.75            540
Cases correspond to codes on Tables 8.2-6 and 8.2-7
                                    8-37

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8.2.3.  Water Pollution and Solid Waste Disposal
       Control measures such as incineration and carbon adsorption do not contribute
to  solid  waste  disposal  problems.   Spent  carbon  is  usually  returned  to  the
manufactures and reprocessed. If steam is used to regenerate the carbon bed in the
adsorber unit, any water miscible solvents remaining in the water can be dumped into
the sewer. This can be avoided by incinerating the steam-solvent mixture.
       In the electrodeposition process, water  pollution and  waste disposal of sludge
was initially a problem but in today's modern operation a closed loop  recirculating
system is used whereby paint is filtered out using ultrafiltration methods and returned
to the tank.  The filtrate is used to rinse off  excess paint  from the part.  A small
amount of filtrate  containing excess salts and solubilizers is normally dumped to the
sewer and replaced with deionized water to keep the bath chemistry in balance. In a
                                                                 13
typical installation, this can amount to around 0.5 gallons per minute
       With water-borne spray coatings sludge disposal problems increase compared
to solvent-borne  coatings.  In the water wash  the major portion of  the overspray is
thrown out of suspension forming gummy  agglomerates requiring more  frequent  and
more difficult cleaning of settling tanks.  Based on information from the automotive
industry,  tanks had to be  cleaned  four times as  often  compared to solvent-borne
coatings.   In the cost model, liquid and sludge disposal costs were increased  by 50
percent to reflect this.  Disposal costs, however,  play a relatively small part in the
overall coating operation costs.
                                      8-38

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8.3.   REFERENCES
 1.   Oge, M.T.  Trip Report - Lyon Metal Products, Inc., Aurora, Illinois. Springborn
      Laboratories,  Inc. (formerly DeBell & Richardson, Inc.).  Enfield, Connecticut.
      Trip Report 91.  March 12, 1976.
2.     Oge,  M.T.  Springborn Laboratories,  Inc., Enfield, Connecticut.  Telephone
      Conversation  with Simmons  Company, Charlotte,  North Carolona.  October
      1977.
3.     Holley, W.H.  Springborn Laboratories, Inc.  Telephone conversation with Binks
      Manufacturing, New Jersey.  November 7,1977.
4.     Oge, M.T.  Trip Report - Guidelines.  Springborn Laboratories,  Inc. Simmons
      Co., Munster,  Indiana. Trip Report 41. January 28, 1976.
5.     Holley, W.H.   Springborn Laboratories, Inc.   Telephone conversation with
      Ashland Chemical, Columbus, Ohio.  August 24,1977.
6.     Holley, W.H.   Springborn Laboratories, Inc.   Telephone conversation with
      Hanna Chemical Coatings, Columbus, Ohio.  August 25, 1977.
7.     Holley, W.H.  Springborn Laboratories, Inc.  Telephone conversation with Lilly
      Industrial Coating, Indianapolis, Indiana.  August 20, 1977.
8.     Holley, W.H.   Springborn Laboratories, Inc.   Telephone conversation with
      Ransburg Corporation. Indianapolis,  Indiana. August 29,  1977.
9.     Holley, W.H.  Springborn Laboratories, Inc.  Telephone conversation with Lilly
      Industrial Coatings, Indianapolis, Indiana.  August 24, 1977.
10.   Air Pollution Engineering Manual, U.S. Department HEW  1967, p  711.
11.   EPA declares exempt solvents will not be solution to air pollution. Industrial
       Finishing (magazine) April 1976, p 20.
12.   EPA Solvent Game Plan, Industrial Finishing. December  1976, p 20.
13.    Schrantz, W.  UF Benfits Conveyorized Batch-Type EDP  Systems,  Industrial
      Finishing (magazine).  November 1972, p 26.
                                     8-39

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                9.  RATIONALE FOR THE PROPOSED STANDARDS

       This chapter presents the rationale for the selection of the emission sources,
pollutants, and emission control systems for use in recommendations for an air quality
standard for stationary sources in  the  metal furniture  industry.  Also discussed are
modification and reconstruction considerations.  The references for much of the data
contained here are  included in Chapters 3 through 8, which chapters develop the data
for these recommendations.
9.1.    SELECTION OF SOURCE FOR CONTROL
       Section III of the Clean Air Act of 1970 and 1974 extends authority to EPA to
regulate emissions by developing standards of performance for new stationary sources
based on the degree of emission limitations achievable through the application of the
best systems of emission reduction.
       Section III (b), which allows EPA to limit emission of pollutants for which air
quality criteria have been prescribed, is appropriate for the metal furniture industry a
major source of hydrocarbon  (HC) emissions.   Hydrocarbon  emissions  from metal
furniture finishing lines depend on the ratios of organic  solvents to nonvolatile solids
in the coatings used, the  transfer efficiency of the method of applying the coatings
and the quantities of coating materials used on the products. For example, lacquers
having 15  to  17 volume percent solids are higher in organic solvents than enamels
consisting of 30 to  35 volume percent solids.  Powder coatings have volume percent
volatiles ranging from  less than 1 percent to  5 percent and water-borne  coatings
contain organic solvents in the range of 12 to 15 percent.
       The sources studied are metal furniture and fixture assembly plants where the
products of production are coated in a finishing  operation.  The coatings are applied
to metal furniture or fixture pieces which  will be assembled with other metal, wood,
fabric, plastic or glass parts to form  a furniture or fixture assembly. Included in this
category are household furniture, office furniture, institutional furniture and fixtures.
Household  and office furniture includes tables, chairs, beds, desks, lockers,  benches,
shelving, file cabinets,  lamps, room  dividers and  others.  Institutional  furniture is
made  for  hospitals, schools,  athletic  fields,  restaurants,  governments   offices,
laboratories and other types of institutions.
                                      9-1

-------
        Metal furniture assembly plants are generally medium to small in size with
most of the companies employing  100  employees or less.  The categories household,
office furniture, institutional and fixtures employ nearly equal numbers of people. In
terms  of  value  of shipments,  50  largest  companies had  65 percent of the  metal
household furniture market and in the metal office furniture 50 largest companies had
88 percent of the  market.   The location of about 3000 plants is distributed in the
continental United States in this proportion: 43 percent in the East, 29 percent in the
East Central Region, 12 percent in the West Central Region and 16 percent in the
West and Pacific Coast Regions. Figure 9.1-1 shows this distribution.
        The markets of the  metal furniture  industry are varied.  Some companies sell
directly to consumers through  retail stores.  Other companies  do contract  jobs for
other manufacturers. Some companies specialize in certain functional furniture and
purchase other pieces from outside sources which they  provide  to customers as an
integrated suite  of furniture.
        Typical  coating  lines operate  at speeds of 8 to  24 feet  per minute  at a
continuous rate  or  intermittently.   A  plant may  have  more than one line.  Plants
operate single  and multiple shifts depending on  work loadings.    Applications of
coatings is done by the techniques of spray, dipping  and  flow coating which are
described in detail in Chapter 4.
        The major objective of new source performance standards is to obviate future
air pollution problems rather than to correct them after the fact. The most practical
time, from  both an economic and  technical  viewpoint, to  install pollution control
equipment is during the construction  phase of a  new facility.  Add-on  systems or
devices are more costly than those incorporated in the plant design, and they  may not
represent the application of the best technology due to constraints placed on  them by
existing structures  and process considerations.  Pollution control equipment, designed
as an integral part  of a process or operation, is the most effective means of reducing
emissions at the least possible expense  over  add-on controls.  New sources planned for
the use of coatings low in organic solvents will  avoid  delays  in production as the
result of change-over from higher solvent systems avoiding  economic benefits.
9.2.     SELECTION OF POLLUTANTS AND AFFECTED  FACILITIES
        The  pollutants  for  which  New Source  Performance Standards  are being
prepared are airborne organic solvents emitted from stationary sources such as metal
furniture and fixture finishing lines.
                                     9-2

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   100% = 3,036 Plants


               Percent
                     50
                     25 -
CD
 I
CO
                                      Figure 9-1.  DISTRIBUTION OF 3000 PLANTS

                                         MANUFACTURING METAL FURNITURE

-------
        The  metal  furniture  industry  uses  two  types  or  organic solvent-borne
coatings:  enamels and lacquers. Enamel is a type of paint consisting of an intricate
dispersion of pigments in a varnish or resin vehicle. The vehicle may be an oil-resin
mixture, or  an entirely  synthetic resin.  The  enamels containing  drying oils are
converted to film by oxidation; those comprised wholly of synthetic resins may be
converted by either heat or oxygen or both.
        Lacquers in contrast  to enamels, do not undergo a chemical reaction  when
exposed to heat.  Applied lacquers are dried by evaporation of the solvent to form the
coating film.
        The metal furniture industry uses organic solvent-borne coatings of quantity
estimated to be  279 million pounds in 1975.  The  most widely used resins in these
coatings are alkyd,  others include acrylics, epoxies, polyesters, amines, vinyls and
cellulosics.  The use of powder coatings is relatively small at this time.  The organic
solvents used in coatings for  metal furniture are aliphatics, xylene, toluene ketones,
and other aromatics.  Solvents  consumption of 170 million pounds annually in this
industry amounts to  6 percent of the total industrial coating solvent usage.
        The  functions of coatings  in  the  metal  furniture industry are corrosion
protection  for  the metal and esthetic decoration of the product.  To provide these
functions, coating films  must be continuous with good adherence to the surface and
they must be available in a variety of colors and glosses.
        The process of finishing metal furniture may vary in detail  from one plant to
another, however, there are many features common to all plants.  The application of
coatings is done  by  spray coating, dip coating or flow coating. The process usually
involves the  following steps.  The parts to  be coated, unassembled, sub-assemblies
and/or total assemblies,  are loaded on a conveyor as they leave the metal fabricating
shop. The parts are conveyed through a cleansing and degreasing station to prepare
the surface for coating.  These preparation steps are alkaline cleaning to remove light
mill scale and  oils,  hot  water rinsing, iron phosphatizing bath or  spray to improve
coating adhesion  and prevent  rusting during the process, and cold water rinsing.  The
parts are dried by passing them through an oven  at temperatures of 121 C to 177 C
(250°F to 350°C).
        Some operations  use  a  sandblasting  chamber to remove  mill scale, rust and
other dirt and do  not use the washing step.
                                      9-4

-------
        The parts are  next conveyed  to  the coating stations.   Some  parts, when
required, are prime coated by one of the spray techniques applied in a spray booth or
by dip or flow coating techniques.  The spray booth, dip tank or flow coat nozzle
enclosure are vented to the atmosphere to eliminate accumulation of organic solvents
released from the coating.
        The part is conveyed from the application station through an open area on its
way to the bake oven.  The area called the flash-off area is often  necessary to allow
time for the solvents in the coating to escape slowly from  the wet film before it is
cured.  This step in the process avoids blistering  the film  from entrapped solvents
during the bake cycle. This area is usually vented through roof fans.
        The part is baked  in an  oven at temperatures ranging from 149°C to 204°C
(300°F to 400°F).
        The topcoating is applied next. In some cases this coating is the only coating
applied  when prime coats are not required.  The  topcoat is applied in a preferred
color  and in some plants many color changes are made which are best applied by one
of the spray techniques.  Flow coating and dip coating is usually restricted to the use
of one or two colors where changes are infrequent.
        The part to be topcoated is conveyed through the spray booth as described in
the prime coat. In the case of dip coating and flow coating,  conveyors carry multiple
parts  on  holding  fixtures  through the application station at high  unit  rates of
production.
        Flash-off areas are in the process stream as previously described. The coated
parts  are baked in an oven at temperature ranges of 149° C to 232°C  (300°F to 450°F).
        A touch-up area may be  located at  the end of a line where repair of coatings
is made. This work is usually done by spray  application and air drying.
        The affected facilities  in the metal furniture coating lines are the coating
application  station such  as a spray booth, dip  tank or flow coating station which
includes the flash-off area, and the curing station or bake oven or air drying location.
The latter is  used when ovens  are not required.   The touch-up  area  may  not be
considered an affected facility  as the volume of solvents involved is expected to be
very low.
                                      9-5

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        The technology for controlling emissions at affected facilities was studied by
visiting plant  sites and gathering information  from other metal coating operations.
Emission reduction capabilities of various techniques and systems were compared for
cost effectiveness. These systems are tabulated in Chapter 8.2.  Such systems were
selected for study on  the  basis that the technology to implement them was available
or demonstrated to be in  use  in the industry or related metal fabricating industries.
Emission reduction capability  of add-on controls or coating systems, when compared
to a  model base  case  plant  using organic solvent-borne coatings,  ranges  from 22
percent to nearly 100  percent.
        The cost analysis of  systems  with these  capabilities  of  emission reduction
included all  direct and indirect  manufacturing costs, including  an allowance  for
capital investment depreciation with interest charges on the capital.  These  emission
reduction systems are based on two model plants scaled to produce, at an annual rate,
3,000,000 square  feet and 22.4 million square feet of coated furniture. The smaller
capacity plant model  utilizes a spray application system and the larger plant model is
a dip coating operation.
        Cost effectiveness is  measured in  terms  of annulized cost per metric ton of
organic solvent emissions controlled.  Energy  effectiveness is measured in  terms of
British  Thermal Units  (BTUs) per metric ton of  reduced  emissions.   Comparative
values for control options studied are shown  in Table 9.2-1 for a model operation
using spray coatings and in Table 9.2-2 for a model operation using dip coatings.
        The metal furniture  industry  organic  solvent  usage is  estimated to be 80
thousand metric tons  in 1976. The protected industry growth rate average per year is
3.8 percent for the period 1973 to 1980 and 3.3 percent for the period 1980 to 1985.
If no controls on the discharge of organic solvents in the air are used over the growth
forecast the organic solvent discharge could increase by approximately 37 percent in
1985  over the base year 1976.  Fortunately, technology  does exist that offers a means
to reduce these  emissions over  the  years  to be  applied  to  new  or  significantly
modified sources as they become available each year in  the industry.
                                      9-6

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               Table 9.2-1. COMPARATIVE ENERGY AND COSTS

                     OF POLLUTION CONTROL SYSTEMS

                     FOR SPRAY COATING OPERATION


Code
A-5
A-4
A-6

A-3

A-2



Case
Powder coating
High solids coatinga
Water-borne coating
Base
Carbon adsorber
on spray booth
Incinerator on cure
oven

Total
Energy Usage
106BTU
3,055
3,345
3,359
4,495

4,867

6,743
Percent
Increase or
(Decrease)
Over Base
(32)
(26)
(25)
—

8

50
Ratio BTUxlO"
Per Metric Ton
of Reduced
Emissions
178
235
251
—

420

1,728
Cost
$/Metric Ton
Reduced
Emissions
261
nil
2,195
—

2,374

3,110
A-7  Carbon adsorber on
     spray booth and in-
     cinerator on oven
7,417
65
482
2,576
   Estimated on high solids, 80 percent solids/volume coating used in a metal furniture.

   Reference 1 in Chapter 8.2. Costs are lower in energy use and floor space.
                                   9-7

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               Table  9.2-2. COMPARATIVE ENERGY AND COSTS

                     OF POLLUTION CONTROL SYSTEMS

                       FOR DIP COATING OPERATION
Code
Case
               Percent
  Total       Increase or
Energy Usage   (Decrease)
  106BTU     Over Base
 Ratio BTUxlO
Per Metric Ton
  of Reduced
  Emissions
   Cost
$/Metric Ton
  Reduced
  Emissions
B-6  Water-borne dip
     coating                5,027

B-l  Base                  7,244
B-3  Solvent-borne dip
     coating, carbon ad-
     sorber on dip tank

B-2  Water-borne coating
     electrodeposition

B-4  Incinerator on
     cure oven
B-5  Carbon adsorber on
     dip tank and in-
     cinerator on oven      12,119
                               (31)
                                 68
                     630
7,390
7,778
11,163
2
7
54
149
91
338
502
45
1,052
                                67
                                147
                     722
                                   9-8

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9.3.  SELECTION OF THE BEST SYSTEM OF EMISSION
     REDUCTION CONSIDERING COSTS
    (To be prepared by EPA.)
                                9-9

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9.4.     SELECTION OF THE FORMAT OF THE PROPOSED STANDARD
        The  format  for  writing  a  standard  is  needed  to  uniformly measure
performance of compliance to  that standard.  The term "format" is defined,  for the
purposed ot this Chapter,  as a ratio of emissions to a prescribed unit. The  format
could be chosen from any of  the following approaches:  concentration, mass/time,
mass/unit  of production,  equipment  standard,  or mass/unit  of  coating material
consumption.   Each  of  these  approaches has advantages as  well as some disad-
vantages; however,  most  provide no  long-range  incentive  to  the  user for  energy
reduction as required to abate emissions.
      A brief discussion of each of these approaches will indicate why the best format
for a standard is based on the mass/unit of coating material consumption.
9.4.1.   Concentration - Airborne Emissions
        The standards written in terms of concentration allowable in parts per million
or whatever units by definition  would govern the  quantity  of organic emissions
discharged  from the affected facility in terms of the quantity of air exhausted to the
atmosphere from  the affected  facility.  To enforce this  format-standard would
require constant  monitoring  of the discharge,  which  can be done  with  present
technology.  However,  to  reduce significantly the organic emissions from solvent-
borne  coatings, the use of add-on  control equipment such  as carbon adsorbers or
incinerators is required.  This is also possible within the present technology.
        For compliance,  another alternative would be to change coating formulation;
but unless  organic solvents were significantly reduced, the emission problem would
persist.
        The reduction in the use of energy by means of add-on controls required to
abate organic emissions  would  most likely take place over a long period  of time.  This
constitutes an  indirect approach to  the long-range solution  of  the organic emission
problem.
9.4.2.   Mass/Time - Airborne Emissions
        This  format  suggests  that a limitation be placed on the  mass of organic
emissions from an affected facility  within a time period which is now in  use within
many states  and localities  within the states. The  format is enforceable and requires
monitoring equipment, as stated above. Also, add-on equipment involving the same
                                     9-10

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energy excesses for total abatement will be required to abate emissions from organic
solvent-borne coatings.  This format, as with the previous one, does not get at the
root of the problem of providing an incentive to reduce the  use of organic solvents
and thinners in the coating.
9.4.3.   Equipment Standard - Airborne Emissions
        This format suggests  that equipment  used in the  coating process be designed
to meet an emission limitation.  The burden of this requirement would fall on the
equipment manufacturer, who probably could not comply without qualifying the  type
of coatings to be used with such equipment.  The performance of  the coating would
dictate its selection by the end  user, and the  equipment manufacturer would want to
place restrictions that would probably not be compatible with the performance of the
coating.    An  unwieldy  situation would develop and, as  in  the  previous formats
discussed,  the long-range aspects of energy  reduction in emission abatement would
not be directly approached.
9.4.4.   Mass of Emissions/Unit of Coating Material Consumed
        The standards  written  in the  format  of  liters or  kilograms of organic
emissions per liter of coating materials used by an affected facility is the most direct
approach to a long-range solution to the problem of control of organic emissions from
stationary sources.   A programed approach to the 'application of this format to  the
industry  will  consider present  technology  availability in  coatings.  Each year or
designated period the emission standards may be made more stringent according to a
program for the industry to reduce emissions over a reasonable length of time.  As a
matter of  interest graphic presentation of the effect on  emission  reduction through
the use  of higher  solids coatings will be found in Chapter  4 -  Emission Control
Techniques - Figure 4-11, page 4-48
       The energy consumption for  emission abatement  from  present organic
solvent-borne  coatings will increase over  the short-term in new stationary sources
that must comply with performance standards.  The  use of incineration or adsorption
techniques may have  to be  considered  until higher solids  coatings  are used.   The
pressure  to provide high solids coatings will be on the coating manufacturer who will
respond to the industry.  In the long-term, there will be in effect the incentive to use
coatings with less volatiles in order to reduce energy costs of emission abatement.
                                     9-11

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       There are some areas where some interpretation will be required in the use of
this format.   Also the format  does not take into account volatile organic emissions
caused by the reaction products during the curing of the coating, however, coating
manufacturers may be able to supply this data.
       A limitation  of this format is possible  under conditions  where a coating
facility is converted  from, as an example,  a  conventional  spray system  to  an
electrostatic spray system  improving transfer efficiency  of the coating operation
thereby using less coating material over a time  interval resulting in less emissions.
Another example of a limitation of this format would be when a different coating is
used having better hiding power resulting in  the  use  of thinner coating say  changing
1.2 mils to 0.8 mils  thickness.  There is definitely a  percentage reduction of organic
emissions possible in these two  examples that would not be recognized in this format.
The latter case may be more prevelant in the modified or reconstructed facilities.
       For the  cases  found  in  new  sources and  the majority  of modifications
reconstructions, the  format will  provide a straight forward means of measuring
organic solvent emissions.  The format will be easily measurable at the source, and
the quantities of coating, volatiles, or organic solvents used per time period can  be
reported by the user and trade organizations.  Routine monitoring tests and plant
surveys will confirm  compliance with new source performance standards.
                                      9-12

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9.5.    SELECTION OF EMISSION LIMITS
       (To be prepared by EPA.)
9.6.    VISIBLE EMISSION STANDARDS
       (To be prepared by EPA.)
                                  9-13

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9.7.   MODIFICATION/RECONSTRUCTION CONSIDERATION
      Modifications and reconstructions are discussed in Chapter 5 and are repeated
here.
      Proposed standards apply to all  affected  facilities constructed or modified
after the  date of  proposal  of the  proposed standards.    Provisions applying  to
modification and reconstruction were  originally published in the Federal Register  on
December 23, 1971.  Clarifying amendments were proposed in  the Federal Register  on
October  15, 1974 (39  FR  36946),  and  final  regulations  were  promulgated  in the
Federal Register on December 16, 1975 (40 FR  58416).
      Modification is defined as "any  physical  change in, or change in  the method of
operation of, an existing  facility which increases the amount of any air pollutant (to
which a  standard applies) emitted  into the atmosphere by  that facility or which
results in the emission of any  air pollutant (to which a standard applies) into the
atmosphere not previously emitted".  Reconstruction occurs  when components of  an
existing facility are replaced to such an extent  that:

      (1)      The  fixed capital cost  of  the new components  exceeds 50
               percent of  the  fixed  capital cost  that would be  required to
               construct a comparable entirely new facility, and
      (2)      It is technologically and economically feasible  to meet  the
               applicable standards.

      There are certain circumstances under which an increase in emissions does not
result in a  modification.  If a capital expenditure that is less than the most recent
annual asset guideline  repair allowance published by the Internal Revenue  Service
(Publication 534) is made to increase capacity  at an existing  facility and also results
in an increase in emissions to the atmosphere of a regulated pollutant, a modification
is not considered to have occurred.
      An increase in working hours - i.e., from one  to two-shift operation - or  an
extension from 8 hours  to 10 hours per shift would also increase solvent emissions per
day.  This situation,  however,  is  also  not   considered a modification  under the
definitions set forth in 40 FR 58416, December  16, 1975.
                                     9-14

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      The  purpose of  this  Chapter  is  to  identify potential  modifications  and
reconstructions  of affected  facilities,  and any  exemptions  or special  allowances
covering changes in existing  facilities that should be considered.  Exemptions from
the regulations may be based on availability of technology and  economic considera-
tions.
      As will be seen, many  of the possible changes do not qualify as modifications
by  strict definition.   They  are,  however, potential causes of increased solvent
emission and as such should be discussed.
9.7.1. Potential Modifications
      The following changes in  materials  or formulations could cause increased
solvent  emissions but  would  qualify primarily as alternate raw materials,  not as
modifications, under the above definition unless capital expenditures  are required to
effect the change so as to qualify as a reconstruction.

      (1)  Lower Solids Coatings
           If a change  is made from a higher solids to a lower solids  coating-
      e.g., from  an enamel to a lacquer - more material,  hence  more solvent,
      will be used to maintain the same dry coating thickness. While a change
      in the direction of lower solids is  unlikely, it could occur in  any one
      plant as a result of changing paint systems or colors.   It is unlikely,
      however, that any  major capital expenditures to equipment would be
      required.

      (2)  Use of Higher Density Solvent
           Regulations normally  restrict  the number of pounds  of  solvent
      which can be emitted.  A change in the  density of the solvents used,
      even if the  volumetric amounts used  were the same, would result  in
      more pounds or kilograms being emitted. Again, this could be construed
      as  a raw-material  substitution  and hence not a  modification, as no
      major capital expenditures would be involved.  Such substitutions might
      come about as a result of solvent shortages, attempts to cut paint costs,
      or efforts to incorporate less photoreactive solvents.
                                      9-15

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      (3)  Increased Thinning of Coatings
           A change to a higher viscosity coating could result in an increased
      use  of  solvents for thinning  the  coating to proper application consis-
      tency.

      While these three cases can be considered as raw material substitutions, they
are not of themselves considered  to be  modifications.  The phrase "bubble concept"
has been used in Title 40 FR 58416, to refer to a trade-off of emission increases from
one  facility undergoing  a physical  or operational change  with emission reductions
from another  facility in order to achieve no net increase  in the amount of any air
pollutant (to which a standard applies) emitted into the atmosphere by the stationary
source as a whole.
      Title 40 FR 58416 states: "In those cases where utilization of the exemptions
under Paragraph 60.14 (e)  (2),  (3),  or (4) as promulgated  herein would effectively
negate the compliance measures originally adopted, use of those exemptions will not
be permitted."
      Other changes  that  could  be  made  that could result  in increased solvent
emission include:

      (4)  Change to Larger Parts
           If  part sizes were increased  and  the same production rates were
      maintained, more coating materials would be used.  With the diversity
      of products produced by the metal furniture  industry, it is somewhat
      difficult  to  see why this  could  occur  unless a manufacturer began
      production  of  large  parts  such as desks or  panels that he had not
      produced before.
           Coating lines in this industry, however, are generally equipped  to
      handle  many size  parts  hence such a change would not qualify as a
      modification per se.  If  extensive capital expenditures  were involved,
      such a change could be classified as a reconstruction.
                                      9-16

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      (5)  Change to Thicker Coatings
           A change to a thicker coating, other factors remaining constant,
      could result in increased solvent emission.  Such a change could result
      from a desire to increase durability or resistance to outdoor exposure.
      Most metal  furniture manufacturers, especially of office  furniture,
      apply as thin a coating as possible, however.a

      (6)  Reduced  Deposition Efficiency
           Increased overspray because of a process modification  such as a
      switch  from electrostatic spray to conventional spray would result in
      increased emission. For economic reasons if for nothing else, however,
      a switch in such a direction is unlikely except possibly as a temporary
      measure.

      (7)  Additional Coating Stations
           If for any reason additional coating stations were  added, emissions
      would be increased. It is possible that new paint systems could result in
      such a  change.  This could involve a reconstruction or a new facility
      and, as such, would be subject to regulation.
9.7.2. Substitution of Equipment
      There can be  cases where in existing sources coating line configurations are of
a temporary nature  to perform custom jobs.  Certain custom coaters in this metal
furniture industry perform metal coating services only. These services are offered to
metal furniture manufacturers  on a contract  basis.  In the  course of this  type of
business  the coating line configuration may be  changed to meet requirements  of a
specific contract job.  For example, existing coating line components such as spray
booths and dip tanks  may be  interchanged to accomodate different jobs.  Another
example,  existing  ovens  may be  lengthened  or shortened  for each job.   The
aforementioned changes do not constitute a modification. It is the intent to allow the
custom  coater to make  changes of  this nature  for  short-term contract business
without invoking compliance with new source performance standards.
      Installation of a line or affected facility previously used at another plant site
however will require compliance to new source performance standards.
a Chapter 5
                                      9-17

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9.7.3. Reconstruction
      Spray booths and bake ovens used in coating metal furniture last ten to twenty
     2
years  and are not replaced before that time unless process changes dictate it.  In
some cases a  line may be  moved to another location within the plant and booths or
ovens may fall apart necessitating some rebuilding.
      Reconstructions would  include replacement of spray booths either  because of
deterioration  or  because of more  advanced  design such as the  addition of  more
automatic spraying or electrostatic spraying, if not already being used.
      A line  could be made longer or faster to permit  increased production.   This
would be considered a reconstruction as long as  the requirements  outlined in  the
beginning of this chapter are met.
      Ovens  could be replaced with  more efficient models or to accomodate new
energy sources such as electricity.
      Changing coating application methods such as from dip coating to electrostatic
spray would qualify as a reconstruction, again if requirements were met.
      It should be noted that according to 40 FR 58416 that an existing facility, upon
reconstruction becomes  an  affected  facility  and  hence  subject to  regulation
irrespective of any change  in emission rate.
      It should also be noted  that according to 40 FR 58416, Part 60, the  decision as
to whether a reconstructed facility can  meet applicable standards both technologic-
ally  and  economically  rests  with the  EPA  Administrator.   For example, if  the
equipment being  replaced  does not emit air pollutants, it may be determined  that
controlling the components that do emit air pollutants is not reasonable considering
cost, and standards of performance for new sources should not be applied.  As another
example, if there is insufficient space after the replacements at an  existing  facility
to install the necessary air pollution control system  to comply  with standards of
performance,  then reconstruction would not be determined to have occurred.
9.7.4. Constraints
      Probably the greatest physical constraint to switching to new  coating systems
with lower solvent emissions is the added space requirements of some of the systems.
The  seriousness  of this constraint  will, of course, vary from line to line or plant to
                                     9-18

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plant.  Plants with very tight space requirements might find it difficult to fit in the
longer oven and flash-off area required by water-borne spray systems. Electrodeposi-
tion tanks are long to allow the necessary immersion time and rinse area.
        Add-on controls for controlling bake oven emissions such as incinerators are
relatively small and usually can be mounted on top of the oven.  It could be difficult
if space were tight to find  room for a large carbon adsorber to handle spray booth
emissions.
        Incinerators, especially if used for controlling spray booth emissions, use a
great deal of fuel  even with heat  recovery.  This constraint  is considered very
sensitive in this era of energy shortages.
                                       9-19

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9.8.  SELECTION OF MONITORING REQUIREMENTS
     (To be prepared by EPA.)
9.9.  SELECTION OF PERFORMANCE TEST METHODS
      (To be prepared by EPA.)
                                9-20

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            APPENDIX A.   EVOLUTION OF PROPOSED STANDARDS

June 27. 1975
       EPA authorized Springborn Laboratories, Inc. (formerly DeBell <5c Richardson,
Inc.) to conduct an Air Pollution Control Engineering and Cost Study on the General
Surface  Coating  Industry  including  the  Metal  Furniture Industry.   Springborn
Laboratories Program Manager:  Dr. Bernard Baum.  EPA Contract Project  Officer:
David Patrick.
August 11, 15, 20, 1975
       Springborn Laboratories conducted  an  equipment survey  to  review coating
equipment, contacting manufacturers by telephone.
August 25, 1975
       Springborn Laboratories visited  Nordson Corporation  in  Amherst, Ohio to
discuss powder coating application in the industrial coating industry.
August 27, 1975
       Springborn Laboratories visited Interred Corporation in Stamford, Connecti-
cut to discuss powder coating technology and equipment.
August 28, 1975
       Springborn Laboratories met with  EPA  representatives  in Durham,  North
Carolina, to discuss progress of the study.
September 26. 1975
       Office  of Management and Budget approved the  EPA  questionnaire  for
distribution in the industrial finishing industry.
January 28, 1976
       Springborn  Laboratories  visited  the Simmons  Company  plant  in Munster,
Indiana to observe the high solids coating operation and to obtain related data.
February 11, 1976
       Springborn Laboratories visited  Virco  Manufacturing  Corporation  plant in
Gardena, California. The  purpose of the  visit was to observe a powder coating metal
                                     A-l

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furniture line and a solvent coating metal furniture line with an incinerator.  Data on
powder coating operations were obtained.
February 24, 1976
       Springborn Laboratories visited the Steelcase  Company plant in Grand Rapids,
Michigan to observe the metal furniture coating operation.  Information on powder
coating was obtained.
March 8, 1976
       Springborn Laboratories visited  Goodman Brothers  Manufacturing Company
plant in Philadelphia, Pennsylvania to observe the powder coating operation.
March 8, 1976
       Springborn Laboratories visited  the  Bunting  Company plant in Philadelphia,
Pennsylvania  to observe   the  powder   coating  of  outdoor  household  furniture.
Information on powder coating was obtained.
March 12, 1976
       Springborn Laboratories visited  Lyon Metal  Products,  Inc. plant in  Aurora,
Illinois to observe the solvent-borne coating  of metal office furniture  and to collect
related data.
April 2, 1976
       Springborn  Laboratories visited  Herman Miller,  Inc.  plant in  Zeeland,
Michigan.  The purpose of the visit was to observe the powder coating operation of
metal furniture and to  obtain related data.
April 5, 1976
       Springborn  Laboratories  visited  Angel Steel  Company plant  in Plainwell,
Michigan to observe the electrodeposition coating operation for metal furniture and
to obtain related data.
April 6, 1976
       Springborn Laboratories visited  U.S. Furniture Industries, Blacksmith  Shop
Division  in  Highpoint, North  Carolina to observe the powder  coating operation of
metal furniture.
                                      A-2

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April 21, 22, 23. 1976
        Springborn Laboratories attended Chemical Coatings Conference in  Cincin-
nati, Ohio.
September 26. 1976
        Springborn Laboratories visited Georg Koch <5c Sons, Inc., Evansville,  Indiana
to review available finishing technology.
July 15, 1976
        The first interim report on Air Pollution Control Engineering and Cost Study
of the Surface Coating Industry was  sent  to EPA, Triangle Park, North  Carolina.
Metal Furniture Coating Industry was included.
August 23, 1976
        The second interim report on Air Pollution Control Engineering and last study
of the Surface Coating Industry was  sent  to EPA, Triangle Park, North  Carolina.
Metal Furniture Coating Industry was included.
May 19, 1977
        Springborn Laboratories met with EPA  in  Triangle Park, North  Carolina to
discuss general surface coating projects.
June 14, 1977
        Springborn Laboratories was authorized to continue and complete the study to
support New Source Performance Standards  for metal furniture coating.
August 23, 1977
        Springborn Laboratories made a telephone survey to resin suppliers to discuss
present status of high solids coating for metal furniture.
August 25, 1977
        Springbom Laboratories made a telephone survey to resin suppliers to discuss
present status of powder coatings and water-borne coatings for metal furniture.
                                      A-3

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    APPENDIX B. INDEX TO ENVIRONMENTAL IMPACT CONSIDERATIONS
Agency Guidelines for Preparing Regulatory
Action Environmental Impact Statements
(39 FR 37419)
Location Within the Standards Support
and Environmental Impact Statement
Background description of the domestic
metal furniture industry (number of plants,
location, production, trends, etc.).

General procedures, basic processes.
Processes or facilities and their emissions


Affected facilities and types of sources.



Modifications and reconstructions.

Emission control technology.
Environmental impacts of suggested alterna-
tive control systems.
Chapter 3, pages 3-1 through 3-4. Data
are found also on pages 7-1 and 7-2.
Chapter 3, Sections 3.2.1.1 and 3.2.1.2;
pages 3-5  through 3-13.

Chapter 3, Section 3.2.3; pages 3-15
through 3-16.

Chapter 4, Sections 4.1.1 through 4.2.8;
pages 4-1  through 4-49. Chapter 9,
Section 9.1.  and 9.2; pages 9-1 through 9-8.

Chapter 5, pages 5-1 through 5-5.

A discussion of the alternative emission
control systems and their effectiveness
is presented in Chapter 6; pages 6-1
through 6-13.

The various relationships between these
alternatives are tabulated in Tables 6-1,
and 6-2; pages 6-2 and 6-3.

Flow diagrams illustrating these alterna-
tive systems are presented in Figures 6-1
through 6-7; pages 6-5, 6-6, 6-8 through
6-10, 6-12 and 6-13.

A discussion of the suggested alternative
control systems is presented in Chapter 7.

Estimated hydrocarbon emission reduction
in future years  is discussed in Section 7.1.3.
These are  shown also in a tabulated form for
1976 through 1985 in Tables 7-3 through 7-8;
pages 7-11 through 7-16.
                                        B-l

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Agency Guidelines for Preparing Regulatory
Action Environmental Impact Statements
(39 FR 37419)
Location Within the Standards Support
and Environmental Impact Statement
Secondary impacts associated with the
suggested alternative control systems.
Other environmental impacts and concerns.
Extension of time and effective date of
standards.
Energy requirements for alternative
control systems.
Economic impacts of alternative control
systems.

Capital and operating costs for alternate
control systems

Affected facilities and energy requirements.
Cost effectiveness for emission reduction

State regulations and controlled emissions.


Uncontrolled emissions.
Secondary impacts are discussed under
Chapter 7, Section 7.2 (water); pages 7-17
through 7-18.  Section 7.3. (solid waste dis-
posal); pages 7-18 through 7-20.  Section 7.4.
(energy); pages 7-20 through 7-22.

Tables 7-9 and 7-10 show energy balances and
energy requirements of the various suggested
alternative control systems.

Chapter 7, Sections 7.5 and 7-6 discuss impacts
other than primary and secondary impacts
associated with the suggested alternative con-
trol systems; pages 7-23 and 7-24.

Chapter 7, Sections 7.6.2 and 7.6.3, deal with
impacts of delayed and no standards; pages
7-23 and 7-24.

Chapter 7, Section 7.4, Tables 7-9 and 7-10
show energy balances  in tabulated form;
pages 7-21 and 7-22.

Chapter 8, Section 8.1 and 8.2; pages 8-1
through 8-38.

Chapter 8, Section 8.1 and 8.2; pages 8-1
through 8-38.

Chapter 9, Section 9.2; pages 9-2 through
9-8.

Chapter 9, Section 9.

Chapter 7, Section 7.1.1, pages 7-3 through
7-5.

Chapter 7, Section 7.1.2; page 7-5.
                                       B-2

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                                      TECHNICAL REPORT DATA
                               (Please read Instructions on the reverse before completing)
   1. REPORT NO.
      EPA-450/3-78-006
                                 2.
                                                               3. RECIPIENT'S ACCESSION* NO.
     TITLE ANOSUBTITLE
      tudy to Support  New Source Performance Standards  for
      iurface Coating of Metal Furniture
                                                         5. REPORT DATE
                                                             April 1978
                                                         6. PERFORMING ORGANIZATION CODE
   7. AUTHOR(S)
                                                               8. PERFORMING ORGANIZATION REPORT NO.
     Springborn Laboratories, Inc.
   9. PERFORMING ORGANIZATION NAME AND ADDRESS

     Springborn Laboratories, Inc.
     Enfield, Connecticut   06080

     (Formerly DeBell  & Richardson.  Inc.}
                                                               10. PROGRAM ELEMENT NO.
                                                         11. CONTRACT/GRANT NO.
                                                           EPA 68-02-2075
   12. SPONSORING AGENCY NAME AND ADDRESS
     Environmental Protection Agency
     Office of Air Quality Planning &  Standards
     Emission Standards & Engineering  Division
     Research Triangle  Park. N.C.  27711	
                                                               13. TYPE OF REPORT AND PERIOD COVERED
                                                                       Final
                                                         14. SPONSORING AGENCY CODE
                                                                  200/04
   15. SUPPLEMENTARY NOTES
   16. ABSTRACT
         The purpose  of this report  is  to provide the  information for EPA to establish
         Standards of Performance for New Stationary Sources under Section 111 of the
         Clean ^Air Act as amended.   Included are descriptions of the industry, organic
         emission control techniques and their costs.
   17.
                                   KEY WORDS AND DOCUMENT ANALYSIS
                     DESCRIPTORS
                                                 b. IDENTIFIERS/OPEN ENDED TERMS
                                                                       c.  COSATI Field/Group
     Air Pollution Control Equipment
     Hydrocarbons
     Organic Solvents
     New Source Performance Standard
     Metal Furniture, Surface Coating
     Paint
                                             Air Pollution Control
                                             Stationary Sources
                                             Hydrocarbons
                                             Organic Solvent Emission
                                               Control
t
DISTRIBUTION STATEMENT
      Unlimited
                                            19. SECURITY CLASS (ThisReport)
                                              Unclassified
21. NO. OF PAGES

     212
                                            20. SECURITY CLASS (Thispage)
                                              Unclassified
                                                                       22. PRICE
   EPA Form 2220-1 (9-73)

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