United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park NC 27711
JPA-450/3-8Q-007b
October 1982
Air
Surface Coating of Fina
Metal Furniture - EIS
Background Information
for Promulgated Standards
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EPA-450/3-80-007b
Surface Coating of Metal Furniture
Background Information
for Promulgated Standards
Emission Standards and Engineering Division
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air, Noise, and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
October 1982
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This report has been reviewed by the Emission Standards and Engineering
Division of the Office of Air Quality Planning and Standards, EPA, and
approved for publication. Mention of trade names or commercial products
is not intended to constitute endorsement or recommendation for use.
Copies of this report are available through the Library Services Office
(MD-35), U.S. Environmental Protection Agency, Research Triangle Park,
N.C. 27711, or from National Technical Information Services, 5285 Port
Royal Road, Springfield, Virginia 22161.
Publication No. EPA-450/3-80-007b
n
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ENVIRONMENTAL PROTECTION AGENCY
Background Information
and Final
Environmental Impact Statement
for Surface Coating of Metal Furniture
Prepared by:
Don R. Goodwin (Date)
Director, Emission Standards and Engineering Division
U. S. Environmental Protection Agency
Research Triangle Park, NC 27711
1. The promulgated standards of performance will limit emissions of
volatile organic compounds from new, modified, and reconstructed
facilities for surface coating of metal furniture. Section 111 of
the Clean Air Act (42 U.S.C. 7411), as amended, 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 promulgated
standards of performance are expected to affect all regions of the
nation.
2. Copies of this document have been sent to the following Federal
Departments: Office of Management and Budget; Labor; Health and
Human Services; Defense; Transportation; Agriculture; Commerce;
Interior; and Energy; the National Science Foundation; and Council
on Environmental Quality; to members of the State and Territorial
Air Pollution Program Administrators (STAPPA) and the Association
of Local Air Pollution Control Officials (ALAPCO); to EPA Regional
Administrators; and to other interested parties.
3. For additional information contact:
Gene W. Smith
Standards Development Branch (MD-13)
U. S. Environmental Protection Agency
Research Triangle Park, NC 27711
telephone: (919) 541-5624.
5. Copies of this document may be obtained from:
U. S. EPA Library (MD-35)
Research Triangle Park, NC 27711
National Technical Information Service
5285 Port Royal Road
Springfield, VA 22161
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TABLE OF CONTENTS
Section
1. Summary 1-1
1.1 Summary of Changes Since Proposal 1-1
1.2 Summary of the Impacts of the Promulgated
Action 1-2
2. Summary of Public Comments 2-1
2.1 General 2-1
2.2 Emission Control Technology 2-9
2.3 Modification and Reconstruction 2-30
2.4 Economic Impact 2-31
2.5 Environmental Impact 2-33
2.6 Energy Impact 2-33
2.7 Reporting and Recordkeeping 2-34
2.8 References 2-41
LIST OF TABLES
Number
2-1 List of Commenters on the Proposed Standards of
Performance for Surface Coating of Metal
Furniture 2-39
IV
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1. SUMMARY
On November 28, 1980, the U.S. Environmental Protection Agency
(EPA) proposed new source performance standards (NSPS) for metal furni-
ture surface coating facilities under the authority of Section 111 of
the Clean Air Act. The proposed standards were published in the Federal
Register (45 FR 79390) with a request for public comment. A public
hearing was held on January 9, 1981, and four speakers presented comments
on the proposed standards. A total of ten commenters representing
industry, trade associations, and a State air pollution control agency
submitted written comments during the comment period. Their comments
and EPA's responses are summarized in this document. The summary of
comments and responses serves as the basis for the revisions that have
been made to the proposed standards.
1.1 SUMMARY OF CHANGES SINCE PROPOSAL
In response to the public comments and as a result of EPA reevaluation,
certain changes have been made in the proposed standards. The most
significant change has been a revision in the allowed volatile organic
compound (VOC) emission limit. The proposed standards would have limited
VOC emissions from affected facilities to 0.70 kilogram per liter of
coating solids applied. Several commenters indicated that high solids
coatings were not demonstrated at the 68 percent by volume solids content
level. Data obtained during the comment period revealed that, although
coatings with a solids level capable of complying with the proposed
standards and application equipment capable of applying these coatings
are available, their use in actual production line situations is not
sufficiently demonstrated to be the basis for the standards. Consequently,
the emission limit has been revised to 0.90 kilogram of VOC per liter of
coating solids applied. This emission limit is based on the use of a
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coating with 62 percent by volume solids which is the highest solids
content found to be adequately demonstrated and a 60 percent transfer
efficiency.
It became evident from the comments received that the designation
of affected facility was not clearly understood by all the commenters.
Therefore, this section of the promulgated standards has been clarified
to define the affected facility as each surface coating operation which
includes the coating application station(s), flashoff area, and curing
oven.
In order to maintain consistency with other surface coating standards,
the definition of "transfer efficiency" has also been slightly reworded.
Definitions for the terms "organic coating," "surface coating operation,"
and "powder coating" have been added to the promulgated standards for
clarification. Surface coating operations that apply only powder coatings
are exempt from these standards because there are virtually no VOC
emissions from powder coatings.
As a result of an internal EPA reevaluation, all reporting
requirements have been deleted from this regulation. Monitoring and
recordkeeping sufficient to verify the calculation of monthly emissions
from each affected facility are required. No reports will be made to
EPA, however, except those found in the General Provisions to 40 CFR
Part 60 concerning notification and the results of the initial performance
test.
Section 60.313, "Performance test and compliance provisions," has
been restructured to make it easier to read and understand. The results
of the calculations required are identical to those in the proposed
standard, but the manner and order in which they are performed have been
changed.
In addition, a provision allowing for case-by-case approval of
application methods not listed has been added to the standard.
1.2 SUMMARY OF THE IMPACTS OF THE PROMULGATED ACTION
1.2.1 Alternatives to the Promulgated Action
The alternative control techniques are discussed in Chapter 3 of
"Surface Coating of Metal Furniture - Background Information for Proposed
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Standards," EPA-450/3-80-007a, September 1980. (This document is also
referred to as the Background Information Document [BID].) These alterna-
tive control techniques are based upon the best demonstrated technology,
considering costs and environmental and energy impacts, for metal furniture
surface coating facilities. The alternatives of taking no action and of
delaying the proposed action are analyzed in Chapter 6 of the BID.
These impacts have been reduced by the revision of the emission limits
in the promulgated standards.
1.2.2 Environmental Impact of the Promulgated Action
The environmental impacts of the proposed standards are discussed
in Chapter 6 of the BID. The projected beneficial air pollution impacts
have been reduced somewhat by the revision in the emission limit for the
promulgated standards. Emission reduction for the promulgated standards
will be greater, however, than that projected for the baseline emissions
due to the consideration of transfer efficiency in the NSPS and because
the solids content of a complying coating is two percent higher than in
the baseline case. Other environmental impacts remain unchanged since
proposal.
1.2.3 Economic and Energy Impacts of the Promulgated Action
The economic impact of the promulgated standards depends on the
best demonstrated control technology used as the basis for the standards.
Since the use of either high solids, waterborne, or powder coatings is
still considered to be the best available control technology, the economic
impact, as discussed in Chapter 7 of the BID, remains unchanged. The
energy impact of the proposed standards is discussed in Chapter 6 of the
BID, and remains unchanged for the promulgated standards.
1.2.4 Other Considerations
1.2.4.1 Irreversible and Irretrievable Commitment of Resources.
This impact is discussed in Chapter 6 of the BID, and remains unchanged
since proposal.
1.2.4.2 Environmental Impact of Delayed Standards. This impact is
discussed in Chapter 6 of the BID. The impact will be reduced, however,
due to the revision of the emission limit in the promulgated standards.
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2. SUMMARY OF PUBLIC COMMENTS
A list of commenters and their affiliations is shown in Table 2-1.
Ten comment letters were received containing comments on the proposed
standards and the Background Information Document (BID). These comments
have been divided into the following categories:
2.1 General
2.2 Emission Control Technology
2.3 Modification and Reconstruction
2.4 Economic Impact
2.5 Environmental Impact
2.6 Energy Impact
2.7 Reporting and Recordkeeping
The comments, issues, and the responses to them are discussed in
the following sections. A summary of the changes to the standards is
included in Section 1.1 of Chapter 1 of this document.
2.1 GENERAL
2.1.1 Comment: (IV-D-6) A commenter suggested that EPA should encourage
operator training on the proper use and maintenance of equipment, possibly
by offering additional transfer efficiency credits for firms with operator
training programs.
Response: Proper operation and maintenance of facilities is required
in Section 60.11(d) of the General Provisions of 40 CFR Part 60. Although
EPA does certainly encourage industry to provide adequate training for
their spray equipment operators, a program which would give a "credit"
for operator training is not within the scope of EPA's regulatory
development program. The adequacy of the training program itself would
have to be monitored and the implementation and enforcement requirements
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are considered to be excessive. Decreases in coating use, part rejection,
and maintenance are major economic incentives for a company to implement
an operator training program. The Agency believes these reasons are
sufficient to encourage proper operation and maintenance of application
equipment.
2.1.2 Comment: (IV-F-1; IV-D-5) Two commenters recommended that
uniform reporting and recordkeeping requirements be established between
all States and EPA. They claimed that nonuniformity creates duplication
of records and imposes additional cost upon the manufacturer. The use
of one set of terms, formulas, units, methods, and reporting procedures
would avoid the burden placed on industry to present data in different
formats to the various States and EPA. One commenter suggested that
individual States be encouraged to revise existing rules to contain
similar emission allowances and compliance dates. This would allow a
company operating in more than one State to adopt a uniform compliance
plan for all their facilities.
Response: The Agency recognizes the importance of uniformity of
terms, formulas, units, methods, and formats among the States and EPA.
Through its technical support and guidelines, EPA encourages States to
adopt, to the extent possible, consistent units, formulas, methods,
terms, and formats. States are also encouraged to obtain delegation
authority to enforce EPA standards. This would provide the States the
opportunity to eliminate conflicts and duplications. Also, it is easier
for States to revise their requirements to conform with a single set of
EPA requirements than for EPA to somehow facilitate uniformity at the
time it promulgates its own requirements. However, one must recognize
that the States and EPA are separate entities which operate under different
statutory mandates and internal requirements, and each has the option of
selecting the most appropriate means of accomplishing its goals. In the
past, EPA has attempted to establish, to the extent practical, uniform
terms, formulas, units, formats, and will continue to do so.
2.1.3 Comment: (IV-F-1; IV-F-2; IV-D-2; IV-D-3; IV-D-5) Several
commenters requested a change in the definition of the affected facility
to include all finishing systems within a manufacturing plant or the
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finishing system necessary to provide a finished product. This would
allow a plant to average its topcoat emissions with the much lower
emissions from an electrocoat system. One commenter requested that the
NSPS allow the option of a plantwide emission reduction plan, particularly
as it relates to application of the bubble concept for new and/or modified
sources at a given plant.
Response: The choice of the affected facility for this standard
(each surface coating operation which includes the application station(s),
flash-off area, and bake oven) is based on EPA's interpretation of
Section 111 of the Clean Air Act and judicial construction of its meaning.
In choosing the affected facility, EPA must decide which pieces or
groups of equipment are the appropriate units for separate emission
standards in the particular industrial context involved. EPA must do
this by examining the situation in light of the terms and purpose of
Section 111. One major consideration in this examination is that the
use of a narrower definition results in bringing replacement equipment
under NSPS sooner; if, for example, an entire plant were designated as
the affected facility, no part of the plant would be covered by the
standard unless the plant as a whole is "modified." If, on the other
hand, each piece of equipment is designated as the affected facility,
then as each piece is replaced, the replacement piece will be a new
source subject to the standard. Since the purpose of Section 111 is to
minimize emissions by the application of the best demonstrated control
technology (considering cost, other health and environmental effects,
and energy requirements) at all new and modified sources, there is a
presumption that a narrower designation of the affected facility is
proper. This ensures that new emission sources within plants will be
brought under the coverage of the standards as they are installed. This
presumption can be overcome, however, if the Agency concludes that the
relevant statutory factors (technical feasibility, cost, energy, and
other environmental impacts) point to a broader definition. Since it is
technologically feasible to control each surface coating operation and
such control would not be exorbitantly costly (as shown in the economic
analysis section of the BID accompanying the proposed standards), selecting
this narrowest definition of affected facility is most consistent with
the purposes of Section 111.
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Two other possible definitions of the affected facility for this
standard are: all prime coat (or topcoat) operations in a product line
and all prime coat (or topcoat) operations within an assembly plant.
The product line definition would have reduced the number of affected
facilities and would have permitted tradeoffs between different coatings
and application technologies. Likewise, defining all prime coating (or
topcoating) operations within a plant as the affected facility would
have reduced the number of affected facilities and consequently the
associated recordkeeping and compliance calculations. However, such a
definition would not necessarily result in either the use of the best
technology or the minimizing of emissions from new sources.
For these reasons, the Agency has chosen each surface coating
operation as the affected facility.
2.1.4 Comment: (IV-F-1) One commenter stated that the metal furniture
industry should not be considered as a "significant source of VOC
emissions." He pointed out that EPA listed the industry as a minor
source of VOC's according to the impact it would have on public health
and also that EPA estimates VOC emissions from the industry at
five percent of the nation's VOC emissions.
Response: Standards of performance are promulgated under Section 111
of the Clean Air Act. Section lll(b)(l)(A) requires that the Administrator
establish standards of performance for categories of new, modified, or
reconstructed stationary sources which in his judgment cause or contribute
significantly to air pollution which may reasonably be anticipated to
endanger public health or welfare. One important purpose of standards
of performance is to prevent new air pollution problems from developing
by requiring the application of the best technological system of con-
tinuous emission reduction which the Administrator determines to be
adequately demonstrated. The 1977 Amendments to the Clean Air Act added
the words, "in the Administrator's judgment," and the words, "may reason-
ably be anticipated," to the statutory test. The legislative history
for these changes stresses two points: (1) the Act is preventive, and
regulatory action should be taken to prevent harm before it occurs; and
(2) the Administrator should consider the role of each single class of
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sources in contributing to the cumulative impact of VOC emissions from
all sources.
The 1977 Amendments to the Clean Air Act also required that the
Administrator promulgate a priority list of source categories for which
standards of performance are to be promulgated. A list for new source
performance standards was promulgated at 44 FR 49222 (August 21, 1979).
Priority ranking was based on consideration of the source's quantity of
emissions, the extent to which each pollutant endangers public health
and welfare, and the mobility and competitive nature of the source
category. The statutory test for listing a category of sources was that
it "causes or contributes significantly to air pollution which may
reasonably be anticipated to endanger public health or welfare."
As stated in the preamble for the proposed standards, the surface
coating of metal furniture is listed as a minor source category on this
listing. This classification as a minor source is due primarily to the
fact that individual metal furniture surface coating facilities typically
emit less than 100 tons of VOC per year. However, the priority list
states that "the metal furniture coating industry is also a significant
source of VOC emissions, and there are over 300 existing facilities with
the potential to emit more than 100 tons per year."
There are approximately 1,400 metal furniture manufacturing
establishments in the United States which paint their products. These
metal furniture manufacturers are located throughout the country and are
generally situated in highly populated urban areas. In fact, 70 percent
of the industry is concentrated in nine highly populated States.
The metal furniture industry emits about 95.5 gigagrams (1975 data)
of VOC per year. The emissions of VOC result from usage of solvent-based
coatings by the industry. These coatings contain organic solvent mixtures
of aromatics, saturated and unsaturated aliphatics, alcohols, ketones,
esters, and ethers. The emissions of these organic solvents contribute
to ozone formation in urban atmospheres. EPA has established a National
Ambient Air Quality Standard (NAAQS) for ozone of 0.12 microgram per
cubic meter which is currently exceeded in those States where metal
furniture manufacturing establishments are concentrated. Information
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concerning health and welfare effects associated with ozone can be found
in "Air Quality Criteria for Ozone and Other Photochemical Oxidants,"
EPA-600/8-78-004, April 1978.
The Administrator is called upon in the Clean Air Act to evaluate
an industry's contribution to air pollution and make a determination as
to the significance of the subject industry's emission contribution. In
the case of the metal furniture surface coating industry, the Administrator
has determined that VOC emissions from new or modified facilities contri-
bute significantly to air pollution, even though the total amount of
emissions like that from many sources which contribute to the inventory
of VOC emissions is by itself a small portion of the nation's total VOC
emissions, and that this industry would contribute significantly to the
nation's total VOC emissions.
In addition, the metal furniture industry is projected to have an
annual growth rate of 4 percent through 1985 and will include about
2,000 new, modified, or reconstructed affected facilities by 1985.
Based on this growth, the industry will contribute increasing amounts of
VOC to urban atmospheres.
Therefore, industrial surface coating of metal furniture was listed
as a "significant contributor". This selection was based upon the the
number of affected facilities, coating method, the yearly VOC emission
rate, the growth rate of the industry, and the location of this industry
in or near highly populated urban areas.
2.1.5 Comment: (IV-F-2) One commenter requested that the effective
date of the standard be the promulgation date rather than the proposal
date.
Response: Section lll(a)(2) of the Clean Air Act states, "The term
'new source' means any stationary source, the construction or modifica-
tion of which is commenced after the publication of regulations (or, if
earlier, proposed regulations) prescribing a standard of performance
under this section which will be applicable to such source." Therefore,
the statute requires that the applicability date for a new or revised
standard be the date of proposal.
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2.1.6 Comment: (IV-D-4) One commenter stated that coatings
manufacturers and users have a right to demand the same treatment as
other citizens who continue to use pounds and gallons instead of metric
equivalents.
Response: It is EPA's policy to use metric units, not English
units, in regulations and technical documents. This policy is in con-
formance with Section 3 of Public Law 94-168, the Metric Conversion Act
of 1975, which states that the policy of the United States shall be to
coordinate and plan the increasing use of the metric system. Therefore,
EPA is now in the process of incorporating the International System of
Units (SI) into all of its regulations. EPA is currently using as the
basic reference a publication entitled "Standard for Metric Practice"
(E 380-76) published by the American Society for Testing and Materials
(ASTM). This publication explains the SI units and symbols, their
application, and rules for conversion and rounding. It may be obtained
from the American Society for Testing and Materials, 1916 Race Street,
Philadelphia, Pennsylvania 19103. This document is useful in explaining
the abbreviations of units of measurement cited in EPA regulations.
2.1.7 Comment: (IV-D-4) One commenter suggested that the specification
of weight VOC per dry coating volume could force the exploration of
counterproductive technologies and has undermined the initiative to
develop powder, aqueous, radiation curable, and high solids coatings.
Response: The commenter provided no data to substantiate his claim
that the standard has undermined the initiative to develop low-solvent
coatings. The units of the standard are presented in weight VOC per
liter of coating solids rather than weight VOC per dry coating volume.
The volume of coating solids is obtained from manufacturers formulation
and would not necessarily be the volume of the dried coating. Further-
more, these units were selected to encourage the development of
low-solvent coatings.
The rationale for the selection of the format of the standard is
presented in the preamble to the proposed standard. This format has the
advantage of not requiring stack emission tests unless add-on emission
control devices are used, dilution air would not present a problem, and
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flexibility is allowed in the selection of control systems because it is
usable with any of the control methods. The single most important
advantage of the format chosen is that transfer efficiency is considered
in the emissions determination. Since both solvent content of coatings
and efficiency of application are considered, EPA believes the standard
will encourage the development of improved coating and application
equipment technologies.
2.1.8 Comment: (IV-F-2) One commenter pointed out that the word
"volume" appears to have been omitted from one statement in the proposed
regulation. On page 79393, Column 1, the phrase "68 percent solids"
does not indicate whether the solids content is calculated on a volume
or a weight basis.
Response: The commenter is correct in the assumption that the word
"volume" was inadvertently omitted. For the purpose of this standard,
the solids content of coatings is always considered to be expressed in
percent by volume. The word "volume" is used in the appropriate sections
of the promulgated regulation.
2.1.9 Comment: (IV-F-2) One commenter stated that comments presented
at the National Air Pollution Control Techniques Advisory Committee
(NAPCTAC) meeting were not given sufficient consideration.
Response: While all comments presented during the NAPCTAC meeting
did not result in changes to the proposed standards, all comments were
considered and, where the data supported changes to the BID, changes
were incorporated. In addition to numerous minor changes which were
made in order to clarify the document, several comments made at the
meeting resulted in major revisions. For example, an Appendix E was
added to the BID revising the economic impact analysis of powder coatings.
Discussion of solid waste generation and spray booth ventilation rates
was also added in Appendix E. In addition, the regulation was changed
to incorporate additional transfer efficiencies for different coating
techniques to offer greater flexibility in achieving the proposed
standards.
2.1.10 Comment: (IV-F-2) A commenter expressed concern that customer
demands for product performance and color selection may lead to increases
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in foreign imports of metal furniture items at the expense of American
businesses.
Response: Data presented in the Background Information Document
indicate that the impact of foreign imports on the metal furniture
industry are almost negligible. The economic analysis for the proposed
standard, even at a control level of 0.70 kilogram VOC per liter of
applied solids, does not project a trend toward increased imports.
Coating manufacturers surveyed claim that the performance and color
selection of high solids coatings is comparable to that of conventional
solvent coatings and that operating costs may actually be reduced with
high solids coatings. Therefore, EPA does not feel that this regulation
will have an adverse impact on American businesses.
2.1.11 Comment: (IV-D-1) One commenter, a trade association, stated
that due to the questionable nature of the proposed regulation, its
failure to recognize the obvious cost impact, and its limited measureable
benefits, a significant extension of the comment period should be granted.
He requested an extension until May 8, 1981.
Response: In order to allow additional time for industry review of
the proposed standards, an extension of the public comment period was
granted. The comment period was extended from February 8, 1981 until
March 10, 1981. When the commenter was contacted and informed of the
extension, he stated that after reviewing the proposal there were no
additional comments.
2.1.12 Comment: (IV-D-6) One commenter stated that EPA should have
solicited input on the standard from trade associations such as the
National Spray Equipment Manufacturers Association (NSEMA).
Response: Several companies which are members of NSEMA have been
involved in the development of the standard. Copies of telephone conver-
sation records and of letters to and from equipment manufacturers may be
found in Subcategory II of the docket, which contains material used in
the development of the proposed standard.
2.2 EMISSION CONTROL TECHNOLOGY
2.2.1 Comment: (IV-F-1; IV-F-2; IV-D-2; IV-D-4; IV-D-5) Two commenters
objected to statements in the preamble that 68 percent by volume solids
coatings are demonstrated in this industry and are readily available for
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use. They contend that such coatings are not currently being applied by
hand-held electrostatic spray equipment and are not available for use by
the industry. According to one commenter, stricter regulations on the
industry are not justified by the state of the art of the control tech-
nology, the situation with the economy, and the high cost of borrowing
money. Another commenter stated that EPA is forcing technological
changes too rapidly upon an industry at a time when efforts should be
going into making coatings more cost effective and energy efficient.
Another commenter stated that the high viscosity of coatings with greater
than 60 percent by volume solids creates problems in accomplishing rapid
color changes and that atomization problems limit the types of spray
equipment which can be used. According to one commenter, there 1s not
enough technical basis given for setting the standards at the 68 percent
volume solids level. He stated that the proposed control level was
apparently derived by merely reducing the Control Techniques Guideline
(CTG) emission limit by 30 percent. Another commenter stated that he
viewed the proposed emission limit as "an arbitrary level of suspect
origin."
Response: The proposed standard was based on an analysis of four
alternative levels of controls as described in the preamble. Information
obtained during the analysis led to the determination that 68 percent by
volume solids coatings were being produced by some coating manufacturers
and had been successfully applied in production tests. Therefore, the
use of a 68 percent by volume solids coating was selected as the basis
for the proposed standards. As a result of the comments concerning the
availability and applicability of coatings with a 68 percent volume
solids content, EPA conducted a survey of several coatings manufacturers
and users. The results of this survey (see Docket subcategory IV-E)
indicate that although much laboratory work and some production testing
has been done with 68 percent volume solids coatings, there are some
problems which must be overcome before these coatings can be considered
as the best demonstrated technology. The single most difficult problem
appears to be the increase in viscosity of the coating as the solids
content approaches 68 percent by volume. Increased viscosity requires
more energy for manufacturing, and increases agitation requirements
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during storing, pumping, and atomlzation of the coatings. Improper
atomizatlon of the coatings by the spray equipment also causes problems
with the finish obtained on the metal surface.
Survey results showed that advances are currently being made In the
field of higher solids coatings. Several coating manufacturers claim to
have coatings, available 1n a wide range of colors, which can be applied
by existing spray equipment and have percent sol Ids contents in the
low 60*s. Some manufacturers explained that since the States are
generally adopting the Control Technique Guidelines (CTG) Document
(EPA-450/2-77-032) recommended emission level based on 60 percent by
volume solids, all their efforts have gone toward achieving this level.
At this volume solids level, the problems with viscosity can be overcome
by increased use of in-line heating and slightly larger recirculation
pumps.
Most spray equipment manufacturers contacted during the survey
Indicated that atomizatlon and application of coatings with a percent
solids content above 60 has been demonstrated in production tests.
Some of the manufacturers recommended the use of in-line heaters in
order to maintain a constant material temperature and indicated that
these heaters would not be difficult to install. Several of the equip-
ment manufacturers have stated that much of the problem encountered when
applying higher sol Ids coatings is directly related to the operator
rather than the equipment. According to these contacts, the difficulties
in obtaining proper film thickness 1s a result of solids being delivered
to the nozzle at a greater rate than operators are accustomed to. This
creates a situation 1n which the operator, using his normal application
pattern, is applying more solids to the target than 1s necessary, resulting
in excessive film thickness. The equipment suppliers indicated that
this problem can be overcome by proper operator training and more careful
control of material flow rates.
Several representatives of the metal furniture Industry were contacted
during the survey, Most of those contacted have experimented with
higher solids coatings 1n order to achieve the emission limits required
by the State Implementation Plans (SIP's). Results of these trials have
been mixed, with some plants experiencing viscosity, atomizatlon, and
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excessive film thickness problems when attempting to apply higher solids
coatings with existing coating lines. However, through the use of
techniques such as in-line heating, larger diameter piping, reduced
material flow rates, and improved operator training, many companies have
successfully applied coatings which will comply with the SIP's. Due to
the rapid increase in the viscosity of coatings as the solids content
increases, these corrective techniques are much less efficient and less
cost effective at 68 percent by volume solids level than at 62 percent
by volume solids. Three plants are currently using coatings with at
least 62 percent by volume solids contents. These three plants are
considered typical of the industry; two are manufacturers of office
furniture and the other manufactures shelving and store fixtures. This
represents a wide range of coating uses and specifications since the
appearance of office furniture is very critical and the durability of
shelving is important. In-line heating is used to aid in viscosity
control at one of the plants, and a wide variety of hand-held and automatic
spray equipment is used at these plants. A wide range of colors is
applied at these plants and the surface on the product is considered
acceptable.
The results of the survey clearly showed that 62 percent by volume
solids coatings are available and are being applied successfully with
hand-held as well as automatic electrostatic application equipment.
Some coatings with 68 percent by volume solids are available, but their
use is limited to certain products and application with specific equipment
which may not be feasible in certain situations. Therefore, EPA is
revising the emission limit from 0.7 to 0.9 kilogram of VOC per liter of
applied solids. This level is based on the use of a coating with 62 percent
by volume solids, a solvent density of 0.88 kilogram per liter, and a
transfer efficiency of 60 percent.
2.2.2 Comment: (IV-F-1; IV-D-2) According to one commenter, the basic
problem with alternative coating systems such as waterbased, powder,
electrodeposition, dip and flow coatings (which EPA interprets to mean
those systems which would meet the standard) is the difficulty in obtaining
color/texture matching with products painted by conventional sprays.
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Another commenter stated that the alternative coating systems are not
applicable for a wide range of uses within the industry, thus limiting
the choices of control options available to some segments of the
industry.
Response: The Agency has identified as the best demonstrated
technology the use of either high solids coatings, waterborne coatings,
or powder coatings (with appropriate application equipment). The stan-
dard is achievable through the use of one of these methods, and as a
result, the industry has a choice among several methods capable of
meeting the standard. For example, a coater desiring a thick film with
high durability might choose powder coating for a product. Two coats of
a high solids coating, however, might also accomplish the desired results.
Powder or EDP might be chosen if only one or two colors are required.
Furthermore, even though EPA's economic analysis has shown that waterbased
coatings are likely to be the most expensive option for controlling VOC
emissions, some metal furniture manufacturers have chosen to use them.
Clearly, in an industry which produces such a wide variety of products
as the metal furniture industry, there are always a few situations
where, due to product specifications, the number of alternative control
methods will be limited. Electrodeposition cannot be used on non-
conductive materials, for example, and waterbased coatings require extra
precaution against corrosion. Products requiring a metallic finish
could not be coated with powder coatings. Nevertheless, there is always
at least one coating method that can meet the standards and the color/
texture requirements of the industry. The Agency has determined, based
on the analysis of the most costly method of control, that when only one
method applies, the cost of using that method is reasonable.
2.2.3 Comment: (IV-D-4) One commenter stated certain coatings have
been formulated with solvents which are exempt under Rule 66 type regu-
lations and that if all solvents are included in these regulations there
would be no substitute coatings of comparable viscosity available.
Response: The Rule 66 regulations exempted solvents based on their
rate of reactivity, with the slowest reacting solvents being exempted.
More recent tests revealed that the rate of reactivity is unrelated to
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the total amount of ozone formed from the reaction of organics in the
atmosphere. It merely requires more time for some solvents to react
completely. In the December 24, 1980 Federal Register (45 FR 85415), a
volatile organic compound is defined as "... any organic compound which
participates in atmospheric photochemical reactions; or which is measured
by a reference method, an equivalent method, and alternative method, or
which is determined by procedures specified under any subpart." EPA has
published a list of chemical compounds which are considered to be
nonreactive and are, therefore, not covered by the definition of VOC
applicable to this standard. This list can be found in the July 8, 1977
Federal Register. An update was published on July 22, 1980. EPA's
objective is to reduce the total amount of VOC's emitted; therefore, no
solvents that were exempted by Rule 66 will be exempted by this standard
except those listed for exemption. Solvents which are normally used in
metal furniture coatings are reactive and are subject to control by the
standard. However, as discussed previously, EPA has determined that
there are coatings available that meet the viscosity requirements of the
industry. It should also be noted that the standard does not preclude
the use of higher solvent content coatings with add-on control equipment
which can be installed at reasonable costs to reduce the VOC emission
levels.
2.2.4 Comment: (IV-F-1, IV-F-2, IV-D-2, IV-D-4) One commenter pointed
out that most coatings suppliers are currently offering higher volume
solids systems that are basically versions of the old lower volume
solids systems. The main limitation of this approach is viscosity,
i.e., as the volume solids increases, the viscosity increases. The
short-term solutions which coating manufacturers are using to solve
viscosity problems can cause problems with the quality of the finish on
the product. Molecular weight reduction of solvents and coatings also
decreases covering.
One of the commenters stated that hand-held electrostatic spray
guns are widely used in the metal furniture industry due to the complexity
of the metal furniture configuration and the parts mix. There is some
touch-up required for hard to reach areas where this type of equipment
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is necessary. Because of increases in viscosity over conventional
coatings, however, hand-held electrostatic spray guns are limited in
their ability to atomize 68 percent by volume solids coatings. Therefore,
there would be a problem achieving the desired quality of finish.
Another commenter claimed that due to finish specifications for
certain types of metal furniture, (for example, matching the color and
texture of products that were produced during different time periods)
automatic electrostatic spray equipment must be used. However, he
stated that he has not been able to spray coatings with higher than
60 percent volume solids with this equipment due to the viscosity of
these coatings.
One commenter stated that equipment is not available which will
spray high solids coatings with their increased viscosity and still
maintain the proper film thickness and texture without excessive overspray.
Another stated that high solids coatings require automatic electrostatic
equipment is required to produce a consistent film thickness and that a
great deal of manual touch-up is required when the solids content of the
coatings is increased.
Response: When the volume solids content of a coating increases
the viscosity also increases. It has been confirmed by several coating
manufacturers and users that the higher solids coatings which comply
with the proposed standard cause significant problems due to their
higher viscosity. However, the standard is being revised to a level
which can be met by available coatings which are acceptable in terms of
viscosity and coverage capacity. The emission limit is now based on the
use of a coating with 62 percent volume solids content. Hand-held
electrostatic spray guns capable of atomizing and applying 62 percent by
volume solids coatings are currently being marketed by several well-known
manufacturers of spray equipment. Five of the six spray equipment
manufacturers recently contacted stated they have equipment available
which can satisfactorily apply 62 percent volume solids coatings. Most
manufacturers have indicated that automatic electrostatic spray equipment
is the most proven method of applying high solids coatings. Three
plants contacted recently indicated that they are successfully applying
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coatings with greater than 60 percent by volume solids contents. The
film thickness and touch-up requirement problems are solved, according
to the equipment manufacturers, by proper training of operators and more
exact process controls. Based on this information, it is EPA's judgment
that hand-held and automatic electrostatic spray equipment can
satisfactorily apply 62 percent volume solids coatings.
2.2.5 Comment: (IV-F-1; IV-F-2) A commenter explained that most of
his facilities are now using between 50 and 60 percent volume solids
coatings and that he does not expect to reach production use of 60 per-
cent volume solids coatings until the end of 1982. Another commenter
concurred stating that the solids levels of coatings for the metal
furniture industry are presently at the 53 to 54 percent by volume
level. He further stated that quite a bit remains to be done in order
to reach the CTG level of 60 percent by volume solids.
Response: The process of converting existing surface coating
facilities to use a new type of coating, for the purpose of meeting
State emission limits based on RACT, could be a time-consuming change.
Each aspect of the line, from initial metal precleaning to final touch-up,
must be made compatible with the physical and chemical characteristics
of the new coating. Although all the components of a coating line
capable of applying 50 to 62 or higher percent by volume solids coatings
are available, the process of integrating this equipment into existing
lines could require some disruption of the facility. In order to
minimize the disruption, most facilities under SIP compliance schedules
are phasing into the use of high solids coatings by adapting much of
their existing equipment to the new coatings. A facility that is being
modified to meet the SIP level can also meet the NSPS level with minor
changes and at minimal or no additional costs. Thus, for facilities
that for some reason come under the NSPS during conversion to meet SIP
requirements, the NSPS will not impose any significant costs beyond
those associated with the existing RACT requirements. For example, if
the spray booth is enlarged or extra spray guns are added to the booth,
then the existing facility might become an affected facility under the
modification provisions and integration of control techniques into the
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line would be required. Facilities already complying with CTG-based
emission limits may become subject to the NSPS through either reconstruc-
tion or modification. NSPS compliance for these facilities would not
require phase-in construction as required in a facility not yet using
CTG coatings. The cost analysis performed during development of the
standards indicates that the costs for such a modified or reconstructed
facility are reasonable.
2.2.6 Comment: (IV-F-2) One commenter stated that if high solids
coatings are used to comply with the standards, increased amounts of
cleanup solvents and time would be required for each color change because
a complete clean out of the entire paint recirculation line would be
necessary. Therefore, the benefit of the standard would be reduced and
production time would be lost.
Response: The most common method of overcoming the problem of
recirculation line cleanout is the use of separate lines for each major
color applied. With this type of system only the spray gun itself must
be purged prior to changing to the next color line. This is a very
common procedure in most surface coating facilities. An additional step
which can be used is portable batch tanks for small jobs or seldom used
colors. These batch tanks can be located near the spray booths and
eliminate the use of regular recirculation lines for seldom used colors.
2.2.7 Comment: (IV-F-1, IV-F-2) One commenter stated that much of the
metal furniture industry is composed of large plants which have long
recirculation systems. The increased viscosity of coatings with greater
than 60 percent volume solids could create the need for much larger
recirculation pumps and larger diameter piping. He also stated that
there will be great difficulty in reformulating a number of colors to
higher solids because certain pigments have a pronounced effect on
viscosity of the coating. Another commenter stated that in-line heaters
are needed to reduce the viscosity of the coatings, however, he has
found no satisfactory method to install in-line heaters. Problems
encountered have been separation of the resins and pigments and the
extent of heating involved over the distance in most large recirculation
systems.
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Response: Data collected during preparation of the Background
Information Document indicate that the metal furniture industry is
actually composed of mostly small facilities. Fifty percent of the
establishments in the industry have less than twenty employees and
eighty percent have less than one hundred employees.
There is an increase in viscosity as the solids content of coatings
increases. However, equipment is available which can adequately handle
62 percent by volume solids coatings. An increase in the capacity of
recirculation pumps and the addition of in-line heating will, with
reasonable costs, allow proper recirculation even in very large plants.
Although high solids coatings (62 percent volume solids) are a
fairly new technology, several suppliers have a wide variety of colors
available. With the vast amount of research going into high solids
coatings, most other suppliers of coatings will also be increasing the
number of colors available.
Several of the equipment manufacturers contacted during the recent
survey provided information on the use of line heating. Most stated
that, regardless of the solids content of the coating, line heating was
useful in maintaining a consistent coating temperature, thus eliminating
frequent spray gun adjustments. With 62 percent volume solids coatings
the amount of line heating required for viscosity control is not con-
sidered by the equipment manufacturers to be a problem. An article in
the July 1981 issue of Products Finishing describes the success which
one metal furniture manufacturer has had with coatings in the 53 to
62 percent by volume solids range. The article points out that no paint
heaters are employed for these coatings and that the pumps used prior to
the conversion to high solids needed no changes. For those instances
in which in-line heating is necessary, however, the Agency believes
that such heating is a demonstrated method of controlling viscosity at
reasonable cost.
2.2.8 Comment: (IV-F-2) A commenter stated that production of high
solids coatings with greater than 60 percent solids will be difficult
due to the increased demand on agitation equipment, difficulties in
filtering, maintaining cleanliness of coatings, increased power input,
and transporting problems.
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Response: The commenter is correct in stating that viscosity
related problems increase as the solids content of coatings increases.
However, as noted above and from the recently conducted survey other
coating manufacturers indicate that the problems associated with the
production of high solids coatings (62 percent volume solids and greater)
have been overcome. The incremental costs to the affected facility for
the additional equipment are considered by EPA to be reasonable.
2.2.9 Comment: (IV-F-1; IV-D-2) Two comments were received which
detailed some of the problems encountered with powder coating systems
which are an alternative method of complying with the standards. They
claimed that color-critical items cannot be finished with powder coatings
because of color matching problems, color repeatability, and poor quality
of the finish. Other problems which were mentioned include: lack of an
automated color change system, necessity to store powders in an environ-
mentally controlled storage room (which increase energy usage), shorter
storage life than solvent-based materials, and the excessive film thick-
ness which must be applied to produce a good surface finish. One of the
commenters stated that powder coatings do not lend themselves to wide
use in facilities where numerous colors are necessary and frequent color
changes occur.
Response: Although powder coating technology differs substantially
from conventional solvent based coatings, it is EPA's position that
powder coatings are a viable alternative control system for certain
segments of the metal furniture industry. Many facilities which produce
items such as utility shelving, bed frames, or patio furniture can use
powder coatings with excellent results. Information submitted after
NAPCTAC by manufacturers of powder coatings indicated that most of the
problems identified by the two commenters have been overcome by recent
3
technological advances. Separation by color of collected overspray for
recycling purposes is one problem which still exists. For this reason,
powder coatings are best suited for processes where few color changes
are required. There are, however, numerous facilities where only a few
colors are used, and powder coatings would be a reasonable alternative
control measure. In any event, as shown in the proposal preamble and
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earlier responses, in those cases in which powder coating is not adequately
demonstrated, at least one of the other application methods described by
EPA would achieve the revised limit at reasonable costs.
2.2.10 Comment: (IV-F-1; IV-D-2; IV-D-4) Several commenters discussed
concerns with the use of waterbased coatings as an alternative to solvent-
based coatings. One stated that waterbased coatings are only available
in a limited number of colors and that there are problems with quality,
texture, and sheen of the product. He also claimed that equipment and
operating costs and energy usage are all increased with waterbased
coatings. Another commenter stated that these coatings require long
flash-off areas and humidity controls due to the slower evaporation rate
of the water. He also mentioned intercoat adhesion problems when applying
a waterbased topcoat over an electrocoat prime. One commenter suggested
that corrosion problems, leading to rather short equipment life, are
common due to the water content of these coatings.
Response: EPA's analysis of the various control technologies which
could be used to control VOC emissions revealed several characteristics
of waterbased coatings which might limit their use in this industry.
Waterbased coatings are reported by some facilities, however, to be
available in a wide variety of colors and to produce an acceptable
finish. Intercoat adhesion problems can be overcome by the addition of
an intermediate, or "guidecoat," layer of coating applied after the
electrocoat primer. There are more costs associated with waterbased
coatings, however, because of the requirements for humidity controls,
increased coating line length, more careful surface pretreatment, and
stainless steel piping. In situations where waterbased coatings are not
acceptable, however, at least one of the other application methods would
achieve the revised emission limit at reasonable costs.
2.2.11 Comment: (IV-D-4) One commenter stated that although waterbased
coatings appear to be viable candidates for metal furniture, they have
too high a resin/solvent mixture conductivity to be used with electro-
static spray. He also stated that the high-energy aqueous systems which
could meet the regulation will emit formaldehyde under complete cure
conditions. Low-energy systems which do not emit formaldehyde also do
not meet the proposed emission limit.
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Response: Waterbased coatings can be applied by electrostatic
spray if the proper safety precautions are taken. However, most water-
based coatings are capable of meeting the revised emission limit even
when applied by non-electrostatic spray methods. The formation of
formaldehyde from waterbased coatings is due to the amine concentrations
found in certain formulations. Formaldehyde emissions can be minimized
by avoiding unnecessarily high amine concentrations. Waterbased coatings
were selected as the best demonstrated technology for the Automobile and
Light-Duty Truck Surface Coating NSPS, and formaldehyde formation was
not found to be a significant problem. The paint specifications for
metal furniture coatings are not expected to be more stringent than for
automobile coatings.
2.2.12 Comment: (IV-D-4) One commenter stated that the coverage
capacity of high solids coatings can be improved by increasing the
hydroxyl content of certain resins, for example, but the resulting paint
is extremely sensitive to curing conditions. Some of this sensitivity
can be relieved through other chemical modifications to the resins, but
the product is never as convenient to use.
Response: Increasing the hydroxyl content of coatings causes the
coatings to be more dense and, therefore, represents one method of
improving their coverage capacity. EPA recognizes, however, that if too
many hydroxyl groups are added on the resin chain, the coating can
become more brittle and more sensitive to cure conditions.
As a general matter, improper formulation of the resins would have
serious effects on the quality of the finish regardless of the solids
content of the coating. Also, since hydroxyl groups are normally used
only in polyester- and alkyd-type coatings, the curing sensitivity
factor the commenter mentions would not be common to all higher solids
coatings. The EPA does not expect curing sensitivity to be an insur-
mountable problem where hydroxyl content can be increased to improve
coverage. The coverage obtained in a coating operation is not just a
function of coating chemistry. It is also dependent on the application
equipment and the operator of the equipment (in a non-automatic booth).
No metal furniture manufacturer has indicated that proper coverage
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cannot be achieved because increased hydroxyl content results in
unacceptable curing sensitivity. This indicates that several coating
manufactuers have developed coating chemistries that, in combination
with their application methods, provide the necessary coverage without
increasing hydroxyl content so much that extreme curing sensitivity
cannot reasonably be avoided. In those few instances in which satis-
factory low-solvent coatings cannot be developed, a coater could install
add-on control equipment at reasonable costs to meet the standard.
2.2.13 Comment: (IV-D-4) One commenter stated that electrostatic
application techniques and paint preheating can be used to enable a
coater to spray a complying coating. However, there is a danger of
explosion if the equipment handling the paint is operating at up to
0.1 megavolts and the application temperature is far in excess of the
flash point of the coating.
Response: The possibility of an explosion in a spray booth exists
only when the lower explosive limit (LEL) of the solvents in the booth
is exceeded. Current Occupational Safety and Health Administration
(OSHA) regulations specify that sufficient dilution air be provided in
the booths to maintain a maximum solvent concentration well below the
LEL. The same or even more potential for explosions exists when conven-
tional coatings are used since they contain more solvent and are often
heated to insure constant viscosity. Furthermore, electrostatic spray
is a well proven technology in common use and the potential for explosion
is significantly reduced by properly insulating the equipment and pro-
viding adequate ventilation. Therefore, EPA believes coatings and
application equipment which will enable compliance with the standard do
not pose any additional hazards compared to conventional coatings and
equipment.
2.2.14 Comment: (IV-D-4) According to one commenter several coatings
which might meet the emission limit are not suitable for use on metal
furniture because the conductivity of the solvent/resin blends makes
them incompatible with electrostatic spraying. Some of these coatings
are also subject to ''yellowing."
Response: The commenter only mentioned conductivity as a reason
why some coatings cannot be applied with electrostatic equipment at high
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efficiency but provided no specific support for this claim. There are
two primary reasons why this concern appears unfounded. First, waterbased
coatings have a very high conductivity, yet they can be applied electro-
statically in a properly designed system. Second, even if in some cases
conductivity reduces transfer efficiencies substantially, the coater's
ability to comply with these standards would not be affected. This is
because the method of compliance determination allows the operator to
use a value from the transfer efficiency table based on the type of
equipment used even through his actual efficiency may vary somewhat with
different coating formulations.
The problem which the commenter pointed out concerning the "yellowing"
of some coatings may be true in certain cases. Other manufacturers,
however, report that the durability of high solids coatings meets or
exceeds that of conventional solvent coatings. With the endless number
of possible coating formulations there are certain to be many which do
not perform as well as desired. In EPA's judgment, complying coatings
with acceptable properties are available.
2.2.15 Comment: (IV-D-4) One commenter warned that the formation of
reaction byproducts during cure operations can actually increase VOC
emissions by as much as 60 percent over current approaches to lowering
emissions.
Response: The VOC emissions released during the cure operations,
also referred to as "cure volatiles", are dependent on the resin formu-
lation of the coatings and can vary over a wide range. Although there
is no standard test method to quantify actual cure volatile emission
rates under all oven conditions, they are generally considered to be in
the range of 5 to 10 percent of total VOC emissions. Therefore, it is
EPA's policy to concentrate its emission reduction efforts on those VOC
which are contained in the coating prior to the reactions caused by the
elevated temperatures in the bake ovens.
2.2.16 Comment: (IV-D-4) One commenter stated that if current high
solids coatings are able to achieve the emission limit when the paint is
warmed, but are unable to achieve it under wintertime conditions, then
other technologies must be considered.
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Response: The problems of wintertime storage of coating is not
unique to high solids coatings. Conventional solvent coatings require
agitation in bulk storage tanks and warming prior to application just as
high solids coatings would. With an increase in solids content, slightly
more agitation may be required, but the technology is the same. In
addition, conventional solvent coatings are normally purchased and
stored at a solids content level similar to that of a complying coating.
The dilution solvents are then added in the paint mix room. Therefore,
the problems of wintertime storage and use are not expected to be
significantly greater for high solids coatings than for conventional
coatings.
2.2.17 Comment: (IV-D-4) One commenter stated that other types of
coating systems (such as urethane, powder, and radiation cure coatings)
have some limited potential for use but are not sufficiently developed
to be used as an alternative for compliance with the standard.
Response: During development of the Background Information Document,
all of the major coating technologies except radiation cured coatings
were found to be in use to some degree in the metal furniture industry.
Urethane coatings were not considered as an alternative method of com-
pliance simply because the VOC emissions from these coatings are too
high. Two component type urethane coatings which can meet the standards
have serious OSHA problems, but nonetheless, could be used to comply if
the problems are overcome. Powder coatings, waterbased coatings, and
high solids coatings were considered as control alternatives because VOC
emissions can be significantly reduced by changing from conventional
solvent based coatings to any of these systems. Designating these
coating systems as control alternatives does not mean that they are
applicable in all situations, but rather that they can comply with the
emission limits in situations where their properties allow their use.
2.2.18 Comment: (IV-F-1; IV-D-5; IV-D-6) Several commenters made
statements concerning the use of the table of assigned transfer effi-
ciencies in the regulation. One commenter suggested that a production
line testing program be used to determine the proper efficiencies and
that EPA clarify whether the table values were intended for equipment
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manufacturers or users. Another commenter stated that the assigned
values seemed unrealistic to be used as universal standards. He also
stated that if transfer efficiencies are to be assigned, however, then
all known application methods should be included in order to avoid the
time consuming process of obtaining approval to use alternative equipment.
In his comment he noted that the continuous coater method and the liquid
seal process were not mentioned. One commenter presented a very detailed
alternative to the use of the existing table of transfer efficiencies.
He stated that the generic classifications of equipment now in the
regulation is very poorly defined and explained that actual transfer
efficiency is dependent on many factors such as equipment configuration,
operating conditions, the part being coated, the coating being applied,
and the operator. He recommended that the variables in design and
operation of equipment be considered by defining such parameters as
voltage, atomizing pressure, flow rates, etc., of each type of spray
equipment. He also suggested that a standardized test method be adopted
to determine transfer efficiency of equipment. Equipment could then be
"certified" by the manufacturers and a list of equipment ratings and
operating conditions could be supplied to EPA for publication.
Response: EPA believes that to reflect the best demonstrated
technology for the metal furniture coating industry, emission limits for
new sources must incorporate the use of both high solids coatings and
relatively efficient application equipment, but must not at the same
time deny industry flexibility to use different types of application
equipment and different coatings. For this reason, the Agency has
included the key transfer efficiency concept in these standards.
The commenters1 claim that all the listed parameters affect transfer
efficiency is correct. However, a universally acceptable test method
for determining precise transfer efficiency under each conceivable set
of variables has not yet been developed. This means that the Agency
must either delete this crucial component of BDT or instead include in
the standards assigned transfer efficiency values that correlate at
least generally to the efficiencies of the application equipment used in
the industry. EPA has chosen the latter course. The Agency has included
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values that are correlated to each piece of equipment and are sufficiently
high to ensure that, regardless of coating properties and other relevant
variables, each facility will be credited with at least the efficiency
its equipment attains with the particular coatings it applies. These
transfer efficiencies listed are based on data provided by spray equipment
manufacturers and results of tests conducted during standard development.
EPA contacted and visited several equipment and coatings manufacturers
during the standard development process.
Moreover, the standards provide that if the operator can demonstrate
to the satisfaction of the Administrator that other transfer efficiencies
are appropriate (e.g., due to variables such as those cited in the
comment), the Administrator will approve their use on a case-by-case
basis. This provision ensures that a facility using equipment that
achieves an efficiency greater than that assigned by the standard is
fully credited for the efficiency achieved.
The preponderance of metal furniture coating application techniques
are addressed in the table. In addition, the regulation contains provi-
sions whereby alternative coating equipment may be approved. Transfer
efficiency values for'coating methods which are not specifically addressed
in the table can be determined in a manner similar to the way the table
was developed. Data can be obtained from the manufacturer of the equip-
ment, testing procedures can be submitted, and based on an analysis of
the data, EPA will determine the efficiency to be used in the emission
calculations. The Agency does not believe this process of obtaining the
Administrator's approval to use alternative equipment would be unreasonably
time consuming. Also, this approval need only be obtained once for any
one application technique. The application methods and values in the
transfer efficiency table will be reviewed in the future and if appropriate,
the table will be revised.
2.2.19 Comment: (IV-D-6) One commenter suggested that key operating
parameters of spray equipment be monitored on a regular basis (monthly)
to be sure they are within design specifications. He recommended this
be done at the same time that monthly determinations of VOC emission
compliance occurs.
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Response: While EPA considers that the proper operation and
maintenance of a coating process should be routine procedure, the signi-
ficance of variations in operating parameters are understood to be
great. Subpart A of the General Provisions of 40 CFR Part 60,
Section 60.11(d) states that: "At all times, including periods of
startup, shutdown, and malfunction, owners and operators shall, to the
extent practicable, maintain and operate any affected facility including
associated air pollution control equipment in a manner consistent with
good air pollution control practice for minimizing emissions. Determina-
tion of whether acceptable operating and maintenance procedures are
being used will be based on information available to the Administrator
which may include, but is not limited to, monitoring results, opacity
observations, review of operating and maintenance procedures, and inspec-
tion of the source." EPA believes that this general requirement, coupled
with economic incentives such as reduced coating use, are sufficient to
ensure that coatings users check key operating parameters and maintain
application equipment in good condition.
2.2.20 Comment: (IV-D-6) One commenter stated that the generic listing
of application equipment in the transfer efficiency table will tend to
encourage the use of lower priced, inferior equipment that does not
perform as well as indicated in the table, while discouraging the use of
equipment that is capable of exceeding the table values.
Response: The EPA recognizes that in some cases a coater may
receive credit under the transfer efficiency table for efficiencies his
equipment does not fully achieve. The Agency does not believe, however,
that this small discrepancy will provide incentive for coaters to choose
such less efficient application equipment when highly efficient equipment
benefitting both the facility and the environment is available. For
example, electrostatic equipment was developed for its improved efficiency,
and that will still be its major selling point.
The Agency has confidence in the ability of manufacturers to assess
the various types of application equipment and to decide which types of
equipment will best meet their particular needs. The transfer efficiency
table will generally assure that relatively poor application equipment
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cannot be used without a corresponding increase in the solids content of
the coatings applied. In this respect, it offers some incentive for
coaters to choose efficient application equipment where they seek to use
lower solids content coatings.
2.2.21 Comment: (IV-D-6) One commenter stated that the necessity of a
case-by-case request for alternate transfer efficiencies poses an
additional burden for suppliers of high performance equipment.
Response: A request to the Administrator for alternate transfer
efficiencies is submitted by the metal furniture manufacturer not the
equipment manufacturer. EPA recognizes that this process is somewhat of
a burden and, therefore, the standard is written in a manner which is
intended to minimize the need for case-by-case transfer efficiency
determinations. Only in the situation where a facility believes their
efficiency is greater than the applicable transfer efficiency table
value would this determination be required. Even in the absence of this
standard a manufacturer who claims to have superior equipment must
demonstrate his claims to prospective customers.
2.2.22 Comment: (IV-D-7) The table of transfer efficiencies listed in
the proposed standards lists 25 percent transfer efficiency for both
airless spray and air atomized spray. One commenter stated that the
transfer efficiency for airless spray systems is superior to that of air
spray systems. Also, he claimed that manual airless electrostatic spray
would have a superior transfer efficiency to manual air electrostatic
spray.
Response: The transfer efficiency of air atomized and airless
spray equipment is very dependent on the product being coated. Airless
spray equipment performs better when the product being coated has large
flat surfaces or enclosed areas such as the interior of desk drawers.
When the target is complex, such as the spokes on a wheel, there is
virtually no difference in efficiency between the two methods. The
difference in efficiency is due primarily to the fact that coating
solids become entrained in the air stream from an air atomized sprayer.
When being directed against a flat plate or into a confined area, the
air movement becomes very turbulent and sometimes carries coating solids
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away from the target. With airless spray, however, only solids are
being sprayed and the turbulence is reduced and entrainment of solids is
eliminated.
The transfer efficiency table is intended to represent an overall
average value and, as such, is believed to be as accurate as possible.
If a situation exists where a facility uses airless spray and feels the
table value is too low, then the owner or operator can provide appropriate
data to support a request for approval from the Administrator to use an
alternate value for transfer efficiency.
2.2.23 Comment: (IV-D-4) The proposed standards seem practicable
according to one commenter, when considering a light color applied by
dipcoat to utility shelving at a high film build. However, this coating
would emit a high quantity of VOC yet be within the VOC emission limit.
A higher quality coating at a lower volume solids applied by spraying
could actually emit less VOC to the atmosphere.
Response: Through variations in the combination of coating formulation
and transfer efficiency, situations such as the commenter described
could be possible. However, the standard is based on what are considered
to be more typical situations. It is not EPA's intention to dictate the
film thicknesses to be used within the industry. The units of the
standard are designed to control the rate of emissions per volume of
coating solids applied regardless of the film thickness desired. Industry-
wide VOC emissions will be reduced by the standard when compared to the
emissions from the use of conventional solvent-based coatings.
2.2.24 Comment: (IV-D-9) One commenter submitted information concerning
the potential for cost effectiveness and performance of regenerative
thermal oxidation systems. A system designed by the commenter is claimed
to be capable of providing primary heat exchange efficiencies of 85 percent,
90 percent, and 95 percent in the thermal oxidation process. The high
thermal energy recovery of this system allows operation in a self-sustaining
mode on hydrocarbon contents of from 3 percent to 5 percent of the Lower
Explosive Limit (LEL). Little or no additional fuel is required. This
system virtually eliminates the following problem areas generally associated
with incineration systems: (1) fouling of heat transfer surfaces, (2)
corrosion, (3) catalyst poisoning, (4) secondary emissions, and (5) high
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operating costs with low LEL gas streams. The commenter requested
clarification of the potential of regenerative thermal oxidation systems
in the documentation for the promulgated standard.
Response: The analysis of incineration found in Chapter 3 of the
BID reveals that this option has a significantly greater capital invest-
ment and an increase in energy consumption, over other control options.
Although the annual operating costs and energy use of a regenerative
thermal oxidation system may be lower, the initial capital investment is
large compared to that for low solvent coatings technology. The reduction
in total organic solvent emissions realized by controlling the topcoat
oven is small because only 20 to 30 percent of these emissions are
concentrated in the oven. The remaining 70 to 80 percent of the emissions
are from fugitives from the application and flashoff areas. The small
percentage of emissions available for reduction by incineration makes
any incinerator difficult to cost justify when compared to low solvent
coatings. Therefore, the Administrator does not believe that further
clarification of the potential of regenerative thermal oxidation systems
is necessary.
2.3 MODIFICATION AND RECONSTRUCTION
2.3.1 Comment: (IV-F-1; IV-F-2; IV-D-5) Several commenters expressed
concern that expenditures made to comply with a State Implementation
Plan (SIP) could bring the facility under the NSPS as a reconstruction.
They requested that this situation be avoided by exempting SIP-related
expenditures from the reconstruction provisions included under the
General Provisions of 40 CFR Part 60.
Response: This was a valid issue at the time the standard was
proposed with an emission limit that was considerably more restrictive
than most State regulations. Since proposal, however, the recommended
standard has been revised so that it is now based on the use of a coating
only two percent higher in volume solids content than the coating recom-
mended in the CTG document. Because the technologies required to comply
with the two emission limits are similar and no additional equipment
would be required to apply an NSPS complying coating versus a CTG complying
coating, the commenters1 situation is no longer considered to be an
issue.
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2.4 ECONOMIC IMPACT
2.4.1 Comment: (IV-F-1) One commenter stated that continued development
of inflexible standards will impact the growth of the industry and
result in loss of job opportunities. The commenter continued by saying
that the cost to comply with the proposed standards will be much higher
than projected. These increased costs are due to higher construction,
operating, and energy costs. A comparison of cost and energy require-
ments for a plant built in 1977 versus a plant built in 1980 was submitted
by the commenter.
Response: It is definitely true that costs of construction, raw
materials, labor, and energy have increased significantly since the
economic analysis portion of the BID was completed. Many of these
costs, however, will not be any greater for a complying high solids
coating system than for a conventional solvent coating system. If line
heating, larger diameter recirculation lines, or more powerful agitation
equipment is specified, there would be an increase in costs. However,
these costs are considered to be reasonable. A recent SME technical
paper (FC81-237) reported that both operating and energy costs can
actually be reduced by using high solids coatings rather than conventional
2
solvent based coatings. The BID also indicates that a potential for
savings in annualized costs exists with the use of higher solids coatings.
This savings results from a decrease in the energy required to dry the
coatings and lower labor and maintenance costs. Materials costs are
also reduced because with higher solids coatings, even though the price
per gallon may be higher, fewer gallons of coating are needed.
2.4.2 Comment: (IV-F-2; IV-D-2) One commenter stated that the types
of application equipment necessary to apply high solids coatings in
order to meet the standards is exceedingly costly to the industry.
Another commenter claimed that the electrostatic equipment is much more
expensive than conventional spray equipment now being used.
Response: The economic impacts discussed in the BID are based on
the use of electrostatic equipment to apply higher solids coatings.
Although electrostatic spray equipment is more expensive than conventional
equipment, EPA believes its advantages outweigh the costs. The projected
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payback time for an average size plant purchasing electrostatic equipment
in lieu of conventional equipment is less than one year. Most of the
newer plants contacted during development of the standard were using
electrostatic equipment (automatic and hand-held) because of the improved
efficiency. Since the standard applies only to new sources and sources
undergoing modification or reconstruction, it is anticipated that many
affected facilities would use electrostatic equipment even in the absence
of the standard.
2.4.3 Comment: (IV-D-5) A commenter stated that the additional
requirements of the NSPS (over the SIP requirements) will cause an
unreasonable financial burden on the industry.
Response: At the revised emission level of 0.90 kilogram VOC per
liter of applied coatings solids, the NSPS will have minimal additional
requirements over what most SIP's require. The SIP's are generally
based on the recommended guidelines in the EPA Control Techniques Guide-
line (CTG) document. Although the CTG document uses different units,
the control level is essentially the same as the revised NSPS level.
Therefore, EPA does not believe the promulgated standards will have an
unreasonable financial impact on the industry.
2.4.4 Comment: (IV-D-8) One commenter expressed concern over the
validity of the cost analyses in the Background Information Document and
requested that EPA solicit information from the industry through the
National Spray Equipment Manufacturers Association (NSEMA).
Response: EPA did solicit information from both industry and the
various associations related to the industry. Most of the data used in
preparing the supporting document for the standard were obtained from
industry related sources. Several members of the NSEMA were contacted
for information during development of the standard. The Agency is
unaware of specific types of information known only to the industry that
should be reflected in the cost analysis.
2.4.5 Comment: (IV-F-2) One commenter stated that the use of coatings
with greater than 60 percent volume solids required larger recirculation
pumps and larger diameter piping which increases the costs of new systems.
This increase in costs was considered by the commenter to be unreasonable.
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Response: A coating system designed to apply a coating with
62 percent by volume solids is not expected to be significantly more
costly than a system designed to apply conventional solvent-based coatings.
The incremental costs of additional equipment required to overcome
viscosity increases is judged to be reasonable. In addition, an overall
savings is expected in operating costs due to a reduction in coating
usage and energy required for drying the coating.
2.4.6 Comment: (IV-F-1) One commenter stated that equipment and
operating costs would increase with the use of waterbased coatings.
Response: The economic analysis performed on the use of waterbased
coatings as a control technology indicated that costs were greater for
waterbased coatings than for the high solids system. As discussed in
other responses, alternatives other than waterbased coatings are available
for use in meeting the standard.
2.5 ENVIRONMENTAL IMPACT
2.5.1 Comment: (IV-D-4) One commenter warned that the requirements of
the standard will create a "numbers game" which will be played by the
coatings manufacturers and users and may cause an increase in VOC emissions
while satisfying the letter of the law.
Response: Situations such as described in this comment are, no
doubt, possible in cases where the environmental concern of the companies
involved is limited to merely not violating EPA regulations. In contrast,
a tremendous amount of effort has already been expended by many companies
in the industry who are concerned with complying with the intent as well
as the letter of the law. Although there have been technical problems
encountered, coating technology is available to meet the standard which
will result in a reduction of VOC emissions to the atmosphere.
2.6 ENERGY IMPACT
2.6.1 Comment: (IV-F-1) One commenter stated that energy usage is
significantly increased with waterbased coatings due to the fact that
water is more difficult to evaporate out of the coating than a
conventional solvent.
Response: The use of waterbased coatings is one of several
alternatives that may be used to meet the standards. Even though the
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cost analysis in the BID shows the method to be expensive, and the
energy impact analysis shows the bake oven energy requirements to be
greater than for conventional solvent-based coatings, some companies
have chosen to use waterbased coatings to meet certain performance
specifications. There are other areas of the coating line, however,
that may actually use less energy with waterbased coatings. An example
of this is the application area where, because of the decrease in solvent
content, less dilution air movement is required to maintain safe
conditions.
2.6.2 Comment: (IV-D-2) A comment was received which stated that
installation of incinerators on all spray booth stacks and oven vents to
obtain compliance with the standards would be an expensive waste of
energy due to the fuel which would be required to sustain combustion of
the exhausted solvents.
Response: Even though incineration is expected to have limited use
in this industry as a means of controlling emissions, EPA did perform an
analysis of the impacts of this alternative. The analysis of incineration
as a means of emissions control indicated a substantial impact on energy
consumption relative to other control technologies. This was the primary
reason that incineration was not considered to be the best demonstrated
control technology even though it is a control technology available at
reasonable cost. EPA recognizes, however, that incineration of oven
vents used in conjunction with coatings having a volume solids content
less than 62 percent could be an alternative to using a 62 percent by
volume solids coating system. Manufacturers using such systems with
incineration would have more flexibility in their selection of coatings
and coating manufacturers and, by returning the available heat from the
incinerator back to the process, would not experience a drastic increase
in energy costs.
2.7 REPORTING AND RECORDKEEPING
2.7.1 Comment: (IV-F-1; IV-D-4; IV-D-5) Several commenters stated
that they viewed the reporting and recordkeeping requirements as an
unnecessary and expensive burden on both the coating manufacturers and
coating users. One commenter stated that monthly recordkeeping to
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determine compliance would be difficult due to the fact that paint is
usually purchased in large volumes and delivered over a long period of
time. Another commenter, a coatings supplier, presented a detailed plan
for recordkeeping and reporting which is based on data contained in
OSHA's Material Safety Data Sheet (MSDS). The major points of his
proposal are as follows:
a. All coatings suppliers submit to users information on their
coatings. Every coating, catalyst, reducer, and modifier
shipped to the user is described in detail with an MSDS for
each coating formulation.
b. Coatings suppliers keep records of all shipments made to each
customer, usually by quarterly and annual basis, and many
suppliers computerize this information.
c. The recordkeeping counterproposal is to switch from a monthly
compliance determination to an annual event, or an "inventory
day," somewhere near the end of the year.
d. By using the shipment records and subtracting inventory on
hand, a total picture of VOC emissions is determined.
e. High technology industrial coatings are expensive and users
will know to the nearest drum or gallon how much was purchased
and how much is on hand, perhaps not on a monthly basis but on
a quarterly or annual basis.
f. The reporting requirements can be implemented by the following
steps:
(1) The coatings and solvent suppliers shall submit a form
20 OSHA approved MSDS with each composition sold to the
user.
(2) The individual signing the MSDS for the coating or solvent
supplier shall be responsible to the user for the accuracy
of the information.
(3) The coatings and solvent suppliers can be asked to supply
shipment information upon request of the user on an
annual basis for purposes of determining compliance with
the regulations.
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(4) The user is responsible for the accuracy of the annual
usage report of VOC-containing materials.
(5) The EPA may audit the data, but may request no records
other than those already required by the IRS, DOT, OSHA,
DOE, and the EPA itself under the Major Generator
Provisions of the Resource Conservation and Recovery Act
(RCRA).
Response: As a result of this comment and others, EPA has been
investigating alternative ways of reducing monitoring, recordkeeping,
and reporting burdens on owners and operators. The goal is to reduce
all recordkeeping and reporting that is not essential to determining
compliance or to ensuring proper operation and maintenance. After
reviewing the requirements in the proposed standards, EPA determined
that monthly compliance tests, monitoring and the compilation of moni-
toring data are essential for both the owner or operator and EPA to
determine compliance and to ensure proper operation and maintenance. A
responsible owner or operator would need monitoring information compiled
in a usable form to determine when adjustments in the control system are
needed to ensure that it is performing at its intended effectiveness
level.
The proposed standard was written with the understanding that much
of the data required to complete a compliance determination would be
provided to the facility by their coating manufacturers. Some additional
information, such as transfer efficiency and dilution solvent added at
the plant, would be provided by the facility itself. It would appear
that a facility manager would keep records of this type, even in the
absence of any requirement to do so, to assure efficient materials
utilization. EPA is therefore requiring only the additional step of
filing the information in an accessible location. Because EPA judges
that monthly compliance tests, monitoring and recordkeeping are essential
for determining compliance and proper operation and maintenance, these
requirements have not been changed since proposal. It was judged,
however, that reporting is not essential to EPA. In addition, when
States are delegated the authority to enforce these standards, they may
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prefer either not to have reporting or to have reporting on a different
schedule than EPA proposed. Therefore, the requirement to report viola-
tions of the standard and quarterly incineration reports have been
removed since proposal. A State, however, at any time is free to impose
its own reporting requirements in conjunction with this regulation.
The data supplied by the coating manufacturers may be in any format
which is agreeable to the plant owner or operator. Likewise, the owner
or operator may use any format in maintaining records as long as all the
pertinent data is clearly identified, complete, and in the appropriate
terms and units. As required in the regulation, a facility must maintain
the records for a period of two years. Reports prepared for other
agencies may be used for EPA requirements if the preceding conditions
are met. Since this standard applies to the metal furniture industry,
the coatings users and not suppliers are responsible to EPA for the
completeness and accuracy of all reports and records.
2.7.2 Comment: (IV-D-4) One commenter recommended an alternative
equation for calculating emissions. He stated that the alternative
equation simplified the reporting tasks for the coating supplier as he
need only report the pounds per gallon of coating, the percent total
nonvolatile of the coating, the percent VOC (if not totally solvent
based), and the percent volume nonvolatile. All of these are normally
covered on the form 20 OSHA approved MSDS used by coating suppliers.
Response: The commenter is correct in that the four coating
parameters he would prefer using can be easily converted to the values
required in the standard to determine emissions. Thus, it is acceptable
for a coating supplier to report these four alternative parameters.
However, the commenter's proposed alternative equation for calculating
emissions is not equivalent to the procedures in the standard, and could
only be used in specialized cases. The commenter1s simplified operation
merely calculates the VOC content (in kilogram VOC per liter of solids)
for each individual coating. This approach is acceptable only if every
coating used at an affected facility had a VOC content (adjusted by the
applicable transfer efficiency) below the standard of 0.90 kilogram VOC
per liter solids applied.
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The EPA procedure for determining emissions allows for the use of
coatings with higher VOC content if they are balanced with low VOC
content coatings. This is possible because the basis of the standard is
a monthly volume-weighted average VOC content for all coatings, not the
VOC content of each individual coating. To calculate this volume-weighted
average, one must know the amount of each coating used that month.
The EPA's approach makes the equations more complicated, and requires
more recordkeeping, but, on the other hand, allows the industry to use a
wider variety of coatings. If only complying, low-solvent content
coatings are used at a particular facility, the commenter's simplified
equation is accepted.
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Table 2-1. LIST OF COMMENTERS ON THE PROPOSED STANDARDS
OF PERFORMANCE FOR SURFACE COATING OF METAL FURNITURE
Docket entry number Commenter/affiliation
IV-D-1 H. 0. Buzzell
Health Industry Mfgrs. Association
1030 15th St. N.W.
Washington, D.C. 20005
IV-D-2 R. Laird
Shaw/Waiker
Muskegon, Michigan 49443
IV-D-3 H. H. Hovey
N.Y. Dept. of Envr. Conservation
50 Wolf Road
Albany, New York 12233
IV-D-4 G. S. Jones
Inmont Corporation
P. 0. Drawer 1297
Morganton, N.C. 28655
IV-D-5 M. I. Harden
Lyon Metal Products Inc.
Aurora, Illinois 60507
IV-D-6, IV-D-14 S. J. Gunsel
Nordson Corporation
Amherst, Ohio 44001
IV-D-7 M. T. Melester
Foy Johnston, Inc.
1776 Mentor Avenue
Cincinnati, Ohio 45212
IV-D-8 K. N. Larson
Graco, Inc.
P. 0. Box 1441
Minneapolis, Minn. 55440
IV-D-9 R. L. Pennington
Reeco, Inc.
Box 600
520 Speedwell Avenue
Morris Plains, N. J. 07950
(continued)"
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Table 2-1. Continued
Docket entry number9 Commenter/affillation
IV-F-1 Transcript of Public Hearing,
Speakers were:
Steven J. Gunsel
Nordson Corporation
David 0. Lawson
PPG Industries
David L. Dornbos, Sr.
Steelcase, Inc.
Lou LeBras
PPG Industries
IV-F-2 D. 0. Lawson
PPG Industries, Inc.
P. 0. Box 127
Springdale, PA 15144
IV-F-3 D. L. Dornbos, Sr.
Steelcase, Inc.
Grand Rapids, Michigan 49501
aThese designations represent docket entry numbers for Docket No. A-79-47.
These documents are available for public inspection at: U.S. Environmental
Protection Agency, Central Docket Section, West Tower Lobby, Gallery 1,
Waterside Mall, 401 M Street, S.W., Washington, D.C. 20460.
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2.8 REFERENCES
1. Letter from Charles Hester, TRW, to Shirley Tabler, U.S. Environmental
Protection Agency, dated January 28, 1981. Summary of results of
telephone survey, (docket entry IV-B-8)
2. Fishkin, H.W. Finishing Systems Economic Overview - A Report of an
Industry Study. SME Technical Paper No. FC81-237. March 1981.
(docket entry IV-J-1)
3. Letter from T.J. Scattoloni, Armstrong Products Co., Warsaw, Indiana,
to Don R. Goodwin, U.S. Environmental Protection Agency, dated
August 19, 1980. Comments on draft documents, (docket entry II-D-31)
4. Telecon. Hester, C.I., TRW, Research Triangle Park, N.C., with
Don Brenner, Sherwin-Williams, Chicago, Illinois. April 21, 1981.
Viscosities of higher solids coatings, (docket entry IV-E-16)
5. Telecon. Hester, C.I., TRW, Research Triangle Park, N.C., with
Steve Gunsel, Nordson Corp., Amherst, Ohio. April 23, 1981.
Transfer efficiencies of spray application equipment, (docket
entry IV-E-17)
6. Products Finishing. July 1981. (docket entry IV-J-2)
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TECHNICAL REPORT DATA
(Please read instructions on the reverse before completing}
1. REPORT NO.
EPA-450/3-80-007b
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
Surface Coating of Metal Furniture - Background
Information for Promulgated Standards
5. REPORT DATE
October 1982
6. PERFORMING ORGANIZATION CODE
AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Office of Air Quality Planning and Standards
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-02-3063
12. SPONSORING AGENCY NAME AND ADDRESS
DAA for Air Quality Planning and Standards
Office of Air, Noise, and Radiation
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
13. TYPE OF REPORT AND PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
EPA 200/04
15. SUPPLEMENTARY NOTES
This document is the second volume of EPA-450/3-80-007 series. The first volume
discussed the proposed standards and the resulting environmental' and economic impacts
16. ABSTRACT
Standards of performance are being promulgated under Section 111 of the Clean Air
Act to control volatile organic compound (VOC) emissions for new, modified, and
reconstructed metal furniture manufacturing plants. This document contains a
detailed summary of the public comments on the proposed standards (45 FR 79390),
responses to these comments, and a summary of the changes to the proposed standards.
17.
KEY WORDS AND DOCUMENT ANALYSIS
a.
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS
COSATI Field/Group
Air Pollution
Metal Furniture
Pollution Control
Standards of Performance
Surface Coating Operations
Volatile Organic Compounds (VOC)
Air Pollution Control
13B
18. DISTRIBUTION STATEMENT
19. SECURITY CLASS (Tliis Report)
Unclassified
21. NO. OF PAGES
Unlimited
54
20. SECURITY CLASS (This page I
Unclassified
22. PRICE
EPA Form 2220-1 (FUv. 4-77) PREVIOUS EDITION is OBSOLETE
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