VOLATILE ORGANIC COMPOUND EMISSION CONTROLS
FOR THE WOOD FURNITURE INDUSTRY
PEDCo ENVIRONMENTAL
-------
VOLATILE ORGANIC COMPOUND EMISSION CONTROLS
FOR THE WOOD FURNITURE INDUSTRY
by
PEDCo Environmental, Inc.
1006 N. Bowen Road
Arlington, Texas 76012
Contract No. 68-02-3512
Task Order No. 43
Project Officer
Raymond D. Chalmers
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION III
PHILADELPHIA, PENNSYLVANIA 19106
October 1983 U.S. EPA Region III
Regional Center for Environmental
Information
1650 Arch Street (3PM52)
Philadelphia, PA 19103
-------
CONTENTS
Page
Tables iii
Summary iv
1. Introduction 1
1.1 Source Description and Types of VOC Emissions 1
2. Emission Control Techniques 5
2.1 Waterborne coatings 5
2.2 Electrostatic spraying 7
2.3 Heated airless spraying 9
2.4 Incineration 10
2.5 Other VOC control methods 11
3. Cost Analysis 12
3.1 Model plants 12
3.2 Assumptions 12
3.3 Costs 14
3.4 Cost-effectiveness 14
4. Regulatory Analysis 17
4.1 Draft regulation 17
4.2 Other proposed regulations 22
4.3 Compliance and monitoring 24
4.4 Potential problem areas 24
References 26
Appendix
A Proposed Illinois Regulation A~1
B South Coast AQMD Regulation B-l
i i
-------
TABLES
Number Page
1 Typical Wood Furniture Finishing Schedule 3
2 Control System Costs for the Wood Furniture Coating
Industry 15
ii i
-------
SUMMARY
Surface coating processes in the wood furniture industry involve a con-
siderable amount of handwork, and methods of application differ from plant to
plant. A 1975 estimate indicated a total of 5477 plants in the United States,
only 214 (about 4 percent) of which had 250 or more employees. Current wages
are in the $4.50 to $5.00 per hour range, which restricts the degree of tech-
nical sophistication and operating flexibility.
Coatings are typically applied by air spraying with a 40 percent transfer
efficiency (i.e., 40 percent of the consumed coating covers the surface). The
coatings are usually organic-solvent based and a variety of solvents are used.
All of the organic solvents are flammable; some are water soluble.
Proposed control methods include the use of electrostatic spraying,
heated airless spraying, and waterborne coatings. Electrostatic spraying and
airless spraying processes reduce V0C emissions by increasing transfer effi-
ciency. The transfer efficiency for electrostatic spraying is about 65 per-
cent, and for conventional airless spraying it is about 50 percent. Heating
the coating allows the use of a coating with a higher solids content, which
increases the transfer efficiency to 65 percent. Waterborne coatings can
reduce or eliminate V0C emissions. Add-on controls such as incinerators and
carbon adsorbers are generally too expensive to be cost-effective.
Industry objections to waterborne coatings and electrostatic spraying are
based on the quality and appearance of the coating rather than cost. Some of
the objections also may be due to resistance to change. As the-market for
these coatings and application methods grow, however, improvements in products
and techniques can be expected.
This report includes a draft regulation that would achieve a 35 to 40
percent reduction in V0C emissions by more efficient application of coatings
i v
-------
through electrostatic or airless spraying, by conversion to waterborne coat-
ings, or by a combination of these methods. This regulation would apply to
plants that emit at least 10 tons of VOC per year or 55 pounds (25 kilograms)
per day, and would place them on a 24-month compliance schedule.
v
-------
SECTION 1
INTRODUCTION
Over the past several years EPA's Office of Air Quality Planning and
Standards (OAQPS) has developed a series of Control Techniques Guidelines
(CTGs) for volatile organic compounds (VOC) to assist state and local agencies
in developing regulations for VOC control. Although the CTGs cover major VOC
source categories from an overall nationwide perspective, they do not cover a
number of VOC source categories 'that represent a major contribution to the
ozone problem within given areas.
Air pollution control agencies in the Philadelphia Air Quality Control
Region (AQCR) have requested guidance in determining whether VOC controls are
available for non-CTG sources and information useful for developing appropri-
ate regulations. One such non-CTG source category to be investigated is the
wood furniture coating industry.
This industry includes six SIC codes: 2434 - Wood Kitchen Cabinets;
2511 - Wood Household Furniture, except Upholstered; 2512 - Wood Household
Furniture, Upholstered; 2517 - Wood Television, Radio, Phonograph, and Sewing
Machine Cabinets; 2521 - Wood- Office Furniture; and 2531 - Public Building and
Related Furniture.
The 1975 County Business Patterns indicated a total of 5477 wood furni-
ture coating plants nationwide, which included 69 in New Jersey and 107 in
Pennsylvania. Eighteen of the New Jersey plants and 43 of the Pennsylvania
plants had 20 or more employees. By industry standards, a large plant is one
that has 250 or more employees. Nationwide, only 214 (four percent) of the
plants are in this category.1
1.1 SOURCE DESCRIPTION AND TYPES OF VOC EMISSIONS
The following is a list of the basic coating operations and their pur-
pose:
1
-------
Fi ni sh
Purpose
Gives color uniformity. Develops wood grain and
character.
Body stain
Wash coat
Seals wood surface; prevents subsequent unwanted
staining from filler coat. Stiffens the wood
fiber for subsequent sanding.
Filler
Fills large pores in wood.
Sealer
Seals the wood for application of subsequent
coats.
Glaze, shading,
stains, padding,
spatter
Adds small amounts of color coating to highlight
and give character to the wood. These pieces
are often hand-wiped.
Topcoat
Usually nitrocellulose lacquer. Provides clear,
durable, final finish.
In general, higher quality furniture undergoes more coating operations
than inexpensive furniture; however, a soft wood requires more surface sealing
applications than a hard wood even though it is being used to make less expen-
sive furniture. The quality of the finish, in large part, determines the
quality of the furniture.
In larger furniture factories furniture pieces are loaded onto a conveyor
line, and workers stationed along the line perform various finishing opera-
tions. Coatings are usually applied by air spray; however, on higher-grade
furniture dip coating is sometimes used, and some finishes are applied by
hand. Usually, each coating operation takes place in a separate spray booth
with one to three spray gun operators. After a piece is sprayed, it is con-
veyed to an oven or to the next spray booth. Wood cannot be heated above
about 130°F (54°C) because a higher temperature may drive out the natural
moisture in the wood and damage the coating. Because some drying also takes
place between spray booths, VOC can be emitted from the spray booths, the
drying ovens, and the general factory floor area.
Each plant operates differently, and finishing tends to be more an art
than' a science. Techniques, equipment, and procedures vary from plant to
plant. Table 1 shows a wood furniture finishing schedule for a large plant.
The entire operation requires 399 minutes (6 hours, 39 minutes) and 63 employ-
ees. The nine spraying operations and two wiping operations require a total
2
-------
TABLE 1. TYPICAL WOOD FURNITURE FINISHING SCHEDULE
Operation
Operation time
Number of
number
Operation name
allowed in minutes
per oper
1
Load
5.0
1
2
Spray uniform stain
1.5
2
3
Dry
15.0
4
Spray NGR stain
1.5
2
5
Dry
20.0
6
Spray washcoat
1.5
2
7
Dry
20.0
8
Sand lightly
1.5
4
9
Spray filler
1. 5
2
10
Flash off filler
2.0
11
Wipe filler
4.0
8
12
Dry
45.0
13
Spray sealer
1.5
2
14
Dry
30.0
15
Sand
3.0
7
16
Spray sealer
1.5
2
17
Dry
30.0
18
Sand
3.0
7
19
Spray glaze
1.5
2
20
Wipe and brush
5.0
13
21
Dry
60.0
22
Di stress
2.0
4
23
Spray lacquer
1.5
2
24
Dry
45.0
25
Spray lacquer
1.5
2
26
Dry
75.0
27
Unload
5.0
1
28
Return to load
15.0
TOTAL
399.0
63
Source: Technical paper, Society of Manufacturing Engineers, MS 75-251.
3
-------
of 22.5 minutes, and drying requires 330 minutes (5 hours, 30 minutes). The
furniture must be completely dry at the end of the operation because finished
pieces are stacked for storage.
The coatings consist of solids and organic solvents. The solids content
consists of body stain (about 1 percent by volume), wash coat (about 8 per-
cent), filler (about 40 percent), sealer (about 14 percent), glaze (about 24
percent), and topcoat (about 14 percent). The organic solvents used in wood
furniture coatings usually consist of various mixtures that include acetones,
acetates, alcohols, aromatics, esters, glycol ethers, ketones, and mineral
spirits. All of these solvents are flammable, and many of them are water-
soluble. Solvent manufacturers usually consider the compositions of the
solvent mixtures to be proprietary. The principal topcoat lacquers have been
used for more than 30 years and are highly regarded by the industry. They
include nitrocellulose base materials, which are very flammable. A principal
advantage of nitrocellulose lacquers is the excellent appearance they give to
the finish. The VOC contents of typical solvent-borne coatings are as fol-
Concentrations of airborne VOC i n furniture coating factories are highly
diluted to protect employees from chemical fumes and to avoid the buildup of
explosive mixtures. These concentrations usually range from 70 to 200 ppm
inside the factories.
lows:
lb/gal (kg/liter)
Clear top coat and sealer
Wash coat
Repair coat
Pigmented coat
Transparent stain
Opaque stain
5.6 (0.67)
6.1 (0.73)
5.6 (0.67)
5.0 (0.60)
6.6 (0.79)
4.7 (0.56)
4
-------
SECTION 2
EMISSION CONTROL TECHNIQUES
Among the several VOC control methods available to the wood furniture
coating industry are waterborne coatings, equipment with higher transfer
efficiency, and coatings that are high in solids. Add-on controls are not
normally considered because of the very dilute concentrations of VOC in the
air streams.
2.1 WATERBORNE COATINGS
Waterborne coatings, which have been manufactured for several years, are
used on metal products, baked pigmented topcoats, and flat panels. In 1974,
the Reliance Chemical Company displayed waterborne coated furniture at the
Louisville Furniture Supply Fair.2 The stain, sealer, glaze, and clear top-
coat were all waterborne formulations. Other paint companies have also dis-
played waterborne coated furniture.
Most waterborne coatings are based on water-reducible acrylic resins, but
some water-reducible nitrocellulose film formulations have been developed.
Every industrial formulation "is customized and therefore different. Such
customization takes into account such factors as method of application, drying
equipment available, surface to which coating will be applied, and end use of
furniture (e.g., kitchen cainets, living room furniture). Most coatings,
however, have a VOC content of up to 7 percent.3 The EPA calculates VOC as
fol1ows:3
volume-water = "ercent V0C
The EPA sponsored a display of waterborne coated wood furniture at the
Southern Furniture Manufacturing Association Show in High Point, North Caro-
lina, in 1979.4 Despite the fact that waterborne body stains and waterborne
topcoats have been used in the industry and all the paint manufacturers have
waterborne systems, waterborne coatings are not in common use. They are used
5
-------
to some extent on large flat area furniture and "knock-down" furniture (i.e.,
furniture that is painted and assembled after shipping). The topcoat is
generally difficult to formulate as a waterborne coating, partially because it
is difficult to achieve a finish with the desired gloss, clarity, and surface
sheen. Waterborne coatings have been discussed in the furniture trade litera-
ture and manufacturers are aware of their availability.
Some general industry comments concerning waterborne coatings are
1i sted:1'2
1. The appearance of waterborne coatings differs from solvent-
borne coatings. Water-base finishes can have less luster and
color depth.
2. The repairability of coatings is reportedly not as good be-
cause repair coats do not blend as well with previous water-
borne coats. About 10 to 20 percent of wood furniture must be
refinished at the plant. An additional 10 percent has to be
repaired by dealers because of damage during shipping. In the
latter case, water-borne coatings can be repaired by use of
conventional solvent-borne touchup coatings.
3. Opinions vary as to whether waterborne coatings are easier or
harder to apply and whether more drying time is needed. The
working and application techniques are new for waterborne
coatings, and some application problems may be eliminated as
the spray gun operators get more experience.
4. Compatibility with previous layers of coating has reportedly
not been as' good for waterborne coatings as for organic-based
coatings.
5. Mar resistance or "print resistance" (resistance to blemishes
caused by pressure on the coated surface) is somewhat of a
problem when fast assembly-line speeds and minimum oven heat
are used. Finished furniture is often stacked in warehouses,
which can cause marring.
6. Waterborne topcoats are more difficult to polish than conven-
tional topcoats. New rubbing techniques may have to be devel-
oped.
7. Flash-off areas may have to be extended to allow proper evapor-
ation of the water, and curing ovens may have to be modified
to drive the water out of the finish. Humidity control may be
necessary.
6
-------
8. The inside of storage vessels may have to be lined to prevent
corrosion; pipes, pump materials, and spray gun fittings may
have to be made of stainless steel. Dual storage and dispens-
ing systems may be required for waterborne and solvent-borne
coatings.
9. Water-borne finishes may require inside storage to prevent
freezing. Fire hazards will be eliminated, however, and this
should lower storage and insurance costs.
10. Resistance to water and alcohol is acceptable. Furniture
finished with waterborne coatings seems to stand up to house-
hold wear as well as furniture finished with solvent-borne
coati ngs.
11. Grain raising presents a minor problem. When wood is exposed
to water for extended periods, it adsorbs the water, swells,
and causes a well-sanded surface to feel rough and uneven.
This problem can be solved by light sanding, and this is often
done with conventional organic solvent-borne coatings.
Coating manufacturers have already demonstrated their ability to produce
acceptable waterborne coatings. As the market for these coatings grows, the
manufacturers can be expected to devote more effort to new product develop-
ment. A reasonable expectation is that the new products will be superior to
existing ones and that most of the objections to waterborne coatings will be
eliminated. Some existing water-borne coatings, however, use formaldehyde
resins in which free formaldehyde is present. Possible future restrictions on
the use of formaldehyde in manufactured products could inhibit the development
of waterborne furniture coatings.5
2.2 ELECTROSTATIC SPRAYING
Electrostatic spraying can be economical because it makes more efficient
use of coating material than concentrated spraying techniques.1'2'4'5'6 This
method has been demonstrated to be effective on tubular or slender parts of
furniture, such as table legs, picture frames, chairs, and baby cribs; how-
ever, a savings has not been demonstrated for its use on larger pieces.2
The main incentive for the development of electrostatic spraying has been
a reduction in material costs as a result of the more efficient utilization of
the coating material. This, in turn, lowers VOC emissions. Electrostatic
spraying usually increases the transfer efficiency (the amount of coating that
7
-------
actually remains on the furniture) from 40 percent to 65 percent.1'2'7 Two
different kinds of equipment are used in electrostatic spraying, automatic and
manual. The automatic spray equipment has a transfer efficiency in the range
of 80 to 93 percent, whereas the manual equipment has a transfer efficiency of
about 65 percent.2 The automatic spray equipment is generally'used for clear
coats such as sealers and laquers. The manual equipment is used for color
coats because the varying colors of the grain require the use of human judg-
ment.
Wood is not an electrical conductor; therefore, it must be treated with
an electrolyte to render it conductive before coating. The electrolyte is ap-
plied as a thin transparent layer by spraying, dipping, or flow-coating. It
is difficult to apply this prep solution efficiently on case goods. Dipping
and flow-coating are difficult because of the size and shape of the pieces,
and hand-spraying is difficult because the clear prep makes it hard to be sure
that all the parts that are to be coated have been sensitized. One solution
would be to mix the prep in with a stain. This would assure that only the
parts of the case goods that are to be coated would be sensitized. All stains
are not compatible with the prep coats, however. Also, emissions reduction
may be lowered when a separate prep application step is added. For example,
for dipping and flow-coating the prep solution must be diluted to 4 percent
with organic solvents such as textile or eactol spirits. The evaporation of
these solvents results in additional VOC emissions in the finishing operation.
When the prep solution is mixed with an existing coating, however, these
additional emissions do not occur.
The furniture must be grounded during the spraying operation. In many
cases, the piece is grounded directly on the metal conveyor or on an indivi-
dual pallet. In either case, some of the sprayed solvent is attracted to the
grounded conveyor or pallet, which lowers the coating transfer efficiency.
The fact that case goods have to be turned loose without losing ground (so
that all the necessary parts can be sprayed) also presents difficulties at
some installations. Small pieces can be hung from an overhead conveyor.
-Because of their large and varying sizes, case goods cause additional
problems with electrostatic spraying. Automatic equipment usually cannot be
used. Therefore, manual equipment must be used, which lowers the transfer
8
-------
efficiency. This in turn lowers the coating savings and decreases VOC emis-
sions reduction. For these reasons, conversion to electrostatic spray equip-
ment may not be justified.
Another problem involved in electrostatic spraying is that the solvent
content of the coating may have to be changed to allow the equipment to work
effectively. If the coating is being made "wetter," a solvent with a higher
boiling point is added or substituted to prevent the coating from drying out
before it reaches the piece. These solvents sometimes dry so slowly that
ovens are needed after the spray booths to dry the finish. These higher-
boiling-point solvents can also raise the price of the coating somewhat. Some
coatings have to be changed to be less conductive because a solvent that is
too conductive will cause the spray head to lose its charge.
2.3 HEATED AIRLESS SPRAYING
California's South Coast Air Quality Management District (AQMD) considers
heated airless spraying to be a very promising control method.8'9 The coating
quality is at least as good as that obtained by conventional spraying, and VOC
emissions are reduced both by improved transfer efficiency and by the in-
creased solids content of the spray. Conversion costs are less than for
either waterborne coatings or electrostatic spraying.
The coating is heated to about 110°F (43°C), and it is atomized by hy-
draulic pressure at about 1200 psi. A small amount of air may be used to help
disperse the spray. Heating decreases the viscosity of the coating and allows
a higher solids content. The use of little or no air reduces cooling of the
spray by solvent evaporation, which reduces the tendency of the coating to
"blush" as a result of moisture condensation. This technique improves trans-
fer efficiency over that achieved with conventional spraying.8'9 Airless
spraying increases the transfer efficiency to about 50 percent,-but heating
allows the use of a coating with a higher solids content, which gives an
emission reduction equivalent to that achieved by electrostatic spraying. The
South Coast AQMD demonstrated this method to the wood furniture coating indus-
try in January 1983.
One coating manufacturer5 indicated that airless spraying (unheated) is
used extensively in the furniture industry and is suitable for applying thick
9
-------
coatings. Unheated airless spraying makes it difficult to control the amount
of material being sprayed, however, and is therefore less suitable for apply-
ing thin coatings.
2.4 INCINERATION
The practice of VOC incineration has been evaluated by EPA, by the Illi-
nois EPA, and by the South Coast AQMD.1,4'8'9'10 All of these agencies have
found conventional or catalytic incineration to be technically feasible,
however, its use has not been demonstrated in the wood furniture industry
because of high costs involved. Because no incinerator systems are currently
being used in the wood furniture industry for controlling VOC emissions, the
technology would have to be borrowed from other coating industries.
The two types of incinerators available are thermal and catalytic. With
a thermal incinerator, organic vapors are oxidized to carbon dioxide and
water, and the sol vent-laden air is exposed to a high temperature in the range
of 540° to 820°C (in some cases, to a direct flame) for a period of 0.3 to 0.6
second. Catalytic incinerators, which use a catalyst bed to oxidize the
organic vapors, operate at lower temperatures (400° to 540°C).
Primary heat recovery is feasible with incineration. Heat exchangers
would recover heat from the incinerator exhaust gases to heat incoming air and
thereby save on fuel costs for operating the incinerator. Secondary heat
recovery, which would, recover, heat from the exhaust gases for use in plant
processes, is not practical. The plants already have a cheap fuel supply in
the wood dust from sawing and sanding operations.
The use of incinerators in the wood furniture industry presents several
problems. The main problem results from high exhaust flow rates from spray
booth and low VOC concentrations. Air flow rates range from 140 to 1400
m3/min, whereas the VOC concentrations are usually less than 20D ppm. This
results in an exhaust stream that has a low heat content, and supplemental
fuel would be required. Another problem stems from the fact that exhaust
streams from the different spray booths cannot be ducted together because they
could be incompatible, and spontaneous combustion might occur. Therefore,
each spray booth would require its own incinerator, which would be more
expensive than having one large incinerator. Another fire hazard results from
10
-------
the nitrocellulose solids present in the coatings settling out in the ducts.
A buildup of nitrocellulose could cause an explosion or a fire.
Incinerators could be selectively used as a part of an overall control
strategy under the following conditions:
1. If the incinerators were applied only to fairly high-concentra-
tion streams such as those from drying ovens, flash-off areas,
or automated booths.
2. If nitrocellulose buildup were avoided by:
a. Restricting application to nonspray booth uses, or
b. Removing particulate nitrocellulose with filters or a
water-wash prior to entry into ductwork.
3. If fire control systems such as water deluge and inert gas
blanketing were used.
Where incinerators have been used, control efficiencies of at least 90 percent
have been attained on VOC emissions reaching the incinerator.
2.5 OTHER CONTROL METHODS
Carbon adsorption has also been evaluated.4'8'9 Because adsorption of a
very dilute VOC stream presents technical problems, however, it is preferred
over incineration only when the solvent can be recovered and reused. Many
wood furniture coating solvents are water-soluble, so steam-stripping of the
carbon bed produces dilute VOC solutions in water. Because the proportions of
solvents that are recovered by steam-stripping would be in different from the
proportions used in the coatings and would have to be processed further for
reuse, carbon adsorption does not seem to be a feasible control method.
11
-------
SECTION 3
COST ANALYSIS
3.1 MODEL PLANTS
Plant size in the wood furniture coating industry is based on the number
of coating spray booths. Data in the County Business Patterns1 suggest that
plants with one to eight booths are small; large plants generally have at
least 24 booths. Thus, we have selected a small plant (8 booths), a medium
plant (16 booths), and a large plant (24 booths) for study. All plants are
assumed to operate 8 hours per day, 5 days per week, and 52 weeks per year.
Each spray booth is assumed to be a source'of 29.5 tons (26.7 megagrams) of
VOC per year.1
3.2 ASSUMPTIONS
Estimate of capital and operating costs for the various VOC control sys-
tems are based on several assumptions. For all control options, annual costs
include a capital recovery charge and an allowance for property taxes, insur-
ance, and administrative costs. An annual capital recovery charge of 14.67
percent of the capital investment is based on a 12-year control system life
and a 10 percent interest rate.1 The allowance for taxes, insurance, and
administrative costs is 4 percent of the capital investment.
3.2.1 'Waterborne Coatings
The costs are based on an EPA study1 and have been updated to September
1982 dollars by use of the Equiment Cost Index from Chemical Engineering maga-
zine. Incremental operating costs were assumed to be unchanged. The costs
were verified with a wood furniture equipment vendor.11 In some cases water-
borne coatings are less expensive than solvent-based coatings and are now
being used for that reason. In other cases, waterborne coatings are more
expensive. Coating industry representatives stated that each plant is a
12
-------
separate case, and sweeping generalizations are not appropriate.5'12 Each
plant will have to be evaluated on a case-by-case basis.
In these estimates, a plant was assumed to convert its entire product
line to waterborne coatings. (This assumption is useful for cost comparisons,
but an actual plant might use a variety of control methods.) The capital
investment required for eight spray booths is:
Three 3000-gallon (11.36-m3) stainless steel storage tanks with
agi tators.
Three stainless steel pumps.
Three spray guns for each booth, 24 total.
Replacement of piping, tubing, hoses, regulators, filters, etc.
Equipment installation.
Contractor's overhead and profit.
Taxes, interest on construction funds, and other indirect costs.
A 20 percent contingency.
3.2.2 Electrostatic Spraying
Capital costs were obtained from an Illinois EPA study6 prepared in July
1982, and updated to September 1982 dollars by use of the Equipment Cost Index
from Chemical Engineering Magazine.
The spray solution is estimated to cost $1 per pound,5 and eight spray
booths are estimated to use 318,000 pounds of coating per year,1 which re-
flects a 40 percent decrease in the amount of coating used. The cost of the
prepping solution for electrostatic spraying is estimated to be 10 percent of
solvent cost2 or $32,000 for eight booths. All other direct operating costs
are assumed to remain unchanged. The entire plant was assumed to be converted
to electrostatic spraying.
3.2.3 Heated Airless Spraying
Capital costs were estimated at $2500 per spray booth on an installed
equipment basis.13 All direct operating costs are assumed to be unchanged.
The spray solution was estimated to cost $1 per pound,5 and the eight spray
13
-------
booths were estimated to use 318,000 pounds of coating per year. This re-
flects a 40 percent decrease in the amount of coating used. The entire plant
was assumed to be converted to heated airless spraying.
3.2.4 Catalytic Incineration With No Heat Recovery
Capital and operating costs were obtained from an EPA report1 and updated
to September 1982 dollars using the Equipment Cost Index from Chemical Engi-
neering magazine. This incineration option was used because it had the lowest
cost. The capture efficiency and the incinerator efficiency were each assumed
to be 90 percent for an overall system efficiency of 81 percent.
3.3 COSTS
Table 2 shows capital and annual costs for the four control systems.
These represent typical costs; actual costs will vary on a plant-to-plant
bas i s.5'7'9'10'12
Conversion costs for water-borne coatings, electrostatic spraying, and
heated airless spraying are low; in certain cases the conversion is profit-
able. Current use of these techniques in the wood furniture coating industry
supports this conclusion. However, very few plants have completely converted
voluntarily from conventional solvent base sprays. The wood- furniture indus-
try's chief concerns have been product quality and appearance rather than
COSt 4 ' 8 ' J) ' 10 ' 12 »13 > 14
Control by incineration has much higher capital and annual costs than
other control methods. No add-on controls are considered viable by the U.S.
EPA, the Illinois EPA, or the South Coast AQMD.4'6'7'9 Consequently, inciner-
ation is not considered an economically feasible control system.
Annual costs for the three feasible control techniques range from $48,000
to a $185,000 credit for a small plant with eight spray booths.
3.4 COST-EFFECTIVENESS
Any of the three control options (water-borne coatings, electrostatic
spraying, and heated airless spraying) is cost-effective in controlling V0C
emissions. The costs range from $230 to a credit of $1950 per ton of V0C
controlled, regardless of plant size. The deciding factor for a plant is
14
-------
TABLE 2. CONTROL SYSTEM COSTS FOR THE WOOD FURNITURE COATING INDUSTRY
(PER THOUSANDS OF DOLLARS, SEPTEMBER 1982)
51 cl cl
VOC control techniques Small plant Medium plant Large plant
A. Waterborne coating
Capital costs including installation 238 445 650
Incremental direct operating costs 0 0 0
Annual capital charges 44 83 121
Total annual cost 44 83 121
Tons of VOC controlled 189 378 567
Cost per ton of VOC controlled,
$/ton 230 220 210
B. Electrostatic spraying
Capital costs including installation
Incremental direct operating costs
Annual capital charges
Total annual cost
Credit for reduced coating usage
Net annual cost (credit)
Tons of VOC controlled
Cost (credit) per ton of VOC
controlled, $/ton
C. Heated airless spraying
Capital costs including installation
Incremental direct operating costs
Annual capital charges
Total annual cost
Credit for reduced coating usage
Net annual cost (credit)
Tons of VOC controlled
Cost (credit) per ton of VOC
controlled, $/ton
D. Catalytic incineration with no
heat recovery
Capital costs including installation
Incremental direct operating costs
Annual capital charges
Total annual cost
Tons of VOC controlled
Cost (credit) per ton of VOC
controlled, $/ton
56 112 168
32 64 96
10 21 31
42 85 127
(189) (378) (567)
(147) (293) (440)
95 189 284
(1550) (1550) (1550)
20 40 60
0 0 0
3.7 7.5 11.2
3.7 7.5 11.2
(189) (378) (567)
(185) (370) (555)
95 189 284
(1950) (1960) (1960)
1988 3976 5964
985 1959 2954
371 742 1113
1356 2701 4067
191 382 573
7100 7100 7100
aSmall plant = 8 spray booths and ovens; medium plant = 16 spray booths and
ovens; large plant = 24 spray booths and ovens.
15
-------
attainment of a coating with sufficient appearance, durability, and quality to
be competitive in the marketplace.
16
-------
4. REGULATORY ANALYSIS
For wood furniture manufacturers in the Philadelphia AQCR, VQC control
should be based on a percentage reduction of VOC emissions compared with
emissions from a base plant that uses only air spraying of solvent-borne coat-
ings. The reduction would be accomplished by the use of any combination of
the three controls -- waterborne coatings, electrostatic spraying, and heated
airless spraying. The amount of VOC emission reduction should be based on the
operating experience of plants in the Region and other states.
4.1 DRAFT REGULATION
A. Definitions--
1. For the purpose of this Regulation, the general definitions
apply.
2. For the purpose of this Regulation, the following definitions
also apply:
a. Clear topcoat: The final coating, which contains binders
but not opaque" pigments and which is specifically formu-
lated to form a transparent or transluent solid protec-
tive film.
b. Semitransparent stains: Stains containing dyes and/or
semi transparent pigments that are formulated to enhance
the wood grain and to change the color of the surface,
but not to conceal the surface, including sap stain,
toner, non-grain-raising stains, pad stain, spatter
stain, and other semitransparent stains.
c. Opaque stains: All stains containing pigments that are
not classified as semitransparent stains, including
stains, glazes, and other opaque material to give charac-
ter to wood.
d.
Pigment coatings: Opaque coatings containing binders and
colored pigments that are formulated to conceal the wood
surface either as an undercoat or topcoat.
-------
e. V/ash coat: Coating containing binders that seal wood
surfaces, prevent undesired staining, and control penetra-
tion.
f. Sealer: Coating containing binders that seal the wood
prior to application of subsequent coatings.
g. Final repair coatings: Coatings to correct imperfections
or damage to furniture surface.
h. Transfer efficiency: The portion of coating solids that
adheres to the wood surface during the application pro-
cess, expressed as a percentage of the total volume of
coating solids delivered by the applicator.
i. Furniture coating application line: The combination of
coating application equipment, flash-off areas, spray
booths, ovens, conveyors, and other equipment operated in
a predetermined sequence for the purpose of applying
coating materials to wood furniture.
B. Applicability--
1. This Regulation is applicable to wood furniture coating. Wood
furniture includes all activities under the Standard Indus-
trial Classification Codes 2434 (Wood kitchen cabinets), 2511
(Wood household furniture, except upholstered), 2512 (Wood
household furniture, upholstered), 2517 (Wood television,
radio, phonograph, and sewing machine cabinets), 2521 (Wood
office furniture), and 2531 (Public building and related
furniture).
2. This Regulation applies to the furniture coating application
line and to the application of clear topcoat, semitransparent
stains, opaque stains, pigment coatings, wash coat, sealer,
and final repair coating.
3. Volatile organic compound sources that emit less than 10 tons
per year or 55 pounds (25 kilograms) per day shall be exempt
from this regulation. The more stringent requirement will
apply.
C. Provisions for Specific Processes--
1. No owner or operator engaged in the surface coating of wood
furniture may operate a coating application system that emits
volatile organic compounds in excess of:
18
-------
Operation
VOC emissions per quantity
of coating delivered by the Minimum transfer
applicator, kg/liter (lb/gal) efficiency, percent
Clear topcoat and sealer 0.67 (5.6) 65
Wash coat 0.73 (6.1) 65
Repair coat 0.67 (5.6) 30
Pigmented coat 0.60 (5.0) 65
Semi transparent stain 0.79 (6.6) 65
Opaque stain 0.56 (4.7) 65
2. VOC emissions per quantity of coating applied to the surface
shall be computed by:
VOC emissions per quantity VOC content of coating
of coating applied Transfer efficiency
3. The emission limits set forth in Paragraph 1 may be achieved
by:
a. Coating application by airless spraying.
b. Coating application by electrostatic spraying.
c. The application of low-solvent coating technology.
d. An equivalent means of VOC removal proposed by the owner
or operator and approved by the Director.
D. Compliance Schedule--
1. The owner or operator of a source of volatile organic compound
emissions s-ubject to this regulation shall meet the following
schedules:
a. Submit final plans within 4 months after this regulation
becomes effective.
b. Complete an evaluation of product quality and commercial
acceptance within 9 months after this regulation becomes
effective.
c. Issue purchase orders or contracts within 12 months after
this regulation becomes effective.
d. Initiate process modifications within 15 months after
this regulation becomes effectives.
e. Complete process modifications and be in compliance
within 24 months after this regulation becomes effective.
19
-------
2. The owner or operator of a volatile organic compounds source
subject to this regulation may submit to the Director, and the
Director may approve a proposed alternative compliance sched-
ule provided:
a. The proposed alternative compliance schedule is submitted
within 3 months after this regulation becomes effective.
b. The owner or operator provides information showing the
need for an alternative schedule;
c. The alternative compliance schedule contains increments
of progress;
d. Sufficient documentation and certification from appropri-
ate suppliers, contractors, manufacturers, or fabricators
are submitted by the owner or operator of the volatile
organic compound source to justify the dates proposed for
the increments of progress; and,
e. Final compliance is achieved as expeditiously as possible
and before the photochemical oxidant attainment date.
f. The owner or operator of a volatile organic compound
source subject to a compliance schedule of this section
shall certify to the Director, within 5 days after the
deadline for each increment of progress, whether the
required increment of progress has been met.
E. Determining Compliance--
1. The owner or operator of a source of volatile organic com-
pounds subject to this regulation shall demonstrate compliance
by:
a. Certifying that the appropriate control equipment and
low-solvent coatings are in place and in use.
b. Providing the Director with certified analyses of all
coatings that are in place and in use. The analyses
shall include determinations of volatile organic com-
pounds content, solid content, water content, and any
other determinations requested by the Director. Analyses
may be provided by the manufacturer of the coatings, the
owner-operator of the source, or an independent labora-
tory acceptable to the Director.
c. Maintaining the appropriate control equipment in a manner
consistent with manufacturer's recommendations.
d. Maintaining operating and maintenance records on the
appropriate control equipment in such a manner that the
Director can determine compliance.
20
-------
2. The Director may require that the owner or operator of a
volatile organic compound source subject to this regulation
demonstrate compliance by conducting emission tests in a
manner consistent with U.S. EPA standards. All tests shall be
made by, or under the direction of a person qualified by
training and/or experience in the field of air pollution
testing. The Director shall receive at least 30 days advance
notice of such testing so that the Director and/or his author-
ized representative(s) may witness the test.
3. If alternative control equipment is used, the Director may
require additional control equipment, testing, and other mea-
sures as may be necessary to determine compliance.
F. Petition for Alternative Controls--
1. The owner or operator of a source of volatile organic com-
pounds subject to this regulation may petition the Director to
allow the use of alternative operational and/or equipment
controls for the reduction of volatile organic compound emis-
sions. The petition must be submitted in writing to the
Director within 2 months after this regulation becomes effec-
tive and must contain:
a. The name and address of the company and the name and
telephone number of a responsible company representative
over whose signature the petition is submitted;
b. A description of all operations conducted at the location
to which the petition applies and the purpose the vola-
tile organic compound emitting equipment serves within
the operations;
c. Reference to the specific emission limitations in C. for
which alternative operational and/or equipment controls
are proposed;
d. A detailed description of the proposed alternative opera-
tional and/or equipment controls, the magnitude of vola-
tile organic compound emission reduction that will be
achieved, and the quantity and composition of volatile
organic compounds that will be emitted if the alternative
operational and/or equipment controls are instituted;
e. A schedule for the installation and/or institution of the
alternative operational and/or equipment controls in
conformance with the appropriate compliance schedule
section;
21
-------
f. Certification that emissions of all other air contami-
nants from the subject facility are in compliance with or
under a schedule for compliance with all applicable
local, State, and Federal laws and regulations; and
g. All additional information requested by the Director or
necessary to determine whether the VOC emission reduction
achieved by the alternative controls is equivalent to the
emission reduction achieved by the applicable regula-
tions.
2. The Director may approve a Petition for Alternative Control
if:
a. The petition is submitted in accordance with Paragraph
(1) of this section;
b. All other air contaminant emissions from the subject
facility are in compliance with or under a schedule for
compliance as expeditiously as practicable with all
applicable local, State, and Federal regulations;
c. The petition demonstrates that the aggregate VOC emis-
sions from the affected operations will in no case be
greater through application of the alternative control
plan than would be permitted through conformance with the
applicable VOC emission reduction regulations;
d. The petition contains a compliance schedule for achieving
and maintaining a reduction of volatile organic compound
emissions as expeditiously as practicable, but no later
than the compliance date that would be required under the
applicable VOC- emission reduction regulation; and
e. A nuisance condition will not result from operation of
the source as proposed in the Petition.
3. No alternative control plan is effective until it is submitted
to and approved by the Administrator of the U.S. Environmental
Protection Agency (U.S. EPA) as a revision of the State Imple-
mentation Plan pursuant to Section 110(a)(3)(A) of the Clean
Air Act.
4.2 OTHER PROPOSED REGULATIONS
In April 1979, the U.S. EPA issued draft Control Techniques Guidelines
(CTG) for the wood furniture coating industry. The EPA proposed limits of 120
pounds of VOC per 1000 square feet of coated surface for furniture and 40
pounds of VOC per 1000 square feet of coated surface for cabinets. The CTG
22
-------
drew over 200 objections from industry representatives. As a result, EPA
withdrew the CTG and is conducting additional research. In November 1982,
Mr. William Johnson of the EPA4 indicated that he believed at least one more
year of effort would be needed before a new proposed standard could be issued.
The State of Illinois and California's South Coast AQMD have each pro-
posed standards based on a minimum transfer efficiency. The standards can be
achieved by the use of water-base sprays, electrostatic spraying, or airless
sprayi ng.
The Illinois regulation was proposed on July 12, 1982 and is currently
still a proposal. The State held hearings in August and September that pro-
duced comments. Dr. John Reed of the Illinois EPA presented the proposed
regulation at the Forest Products Research Society Meeting in St. Charles,
Illinois, on October 7 and 8, 1982. The regulation would affect the six
furniture coating companies in Illinois that emit 100 or more tons of VOC per
year.15
The proposed regulation is based on the VOC content and a minimum trans-
fer efficiency (transfer efficiency representing the fraction of sprayed
coating that actually reaches and adheres to the surface). Appendix A of this
report presents a copy of the proposed Illinois Regulation affecting wood
furniture coatings.
The South Coast AQMD (Los Angeles area) contains 20 major manufacturers
that use 10,000 gallons or more gallons per day and 700 minor firms that use
less than 10,000 gallons per day.16 SCAQMD is proposed a standard similar to
the Illinois regulation. The new version of the proposal was presented
June 3, 1983 at a South Coast District Board meeting and was adopted Septem-
ber 16; 1983. The goal of this program is a 40 percent reduction in VOC
emissions. The requirements of the regulation are:
1. The use of airless spraying for all coating operations using
1000 gallons or more of coating material per year, with a
phase-in compliance schedule depending on the size of the
operati on.
2. To achieve VOC reductions equivalent to those achieved with
airless spraying by use of a "bubble" concept for all coating
steps. A calculation formula for the "bubble" concept is not
included in the proposal, but is available to industry. In
the "bubble" concept, the entire plant is treated as a single
source and the overall VOC emission reduction rate is targeted.
23
-------
Therefore, a larger reduction rate in one process can be used
to offset a lower reduction rate in another. For example,
with two processes of equal uncontrolled VOC emission rates
and a target emission reduction of 50 percent, one process
could be reduced 75 percent, and the other 25 percent to meet
the 50 percent reduction requirement.
3. Operators using 10,000 gallons or more of coating per year
should obtain at least a 14 percent additional reduction,
above the actual reductions achieved in complying with the
airless spray or equivalent reduction requirement provisions
of the rule.
A copy of the SCAQMD regulation is in Apppendix B of this report.
4.3 COMPLIANCE AND MONITORING
A 2-year compliance schedule for the Philadelphia AQCR is consistent with
EPA practice for control by low-solvent technology.15 The schedule, starting
from the effective date of the proposed regulation, is:
Submit compliance plan 4 months
Evaluate product quality and commercial acceptance 9 months
Issue purchase orders or contracts 12 months
Initiate process modifications 15 months
Complete process modifications and be in compliance 24 months
Compliance with the regulation is a certification by the owner or opera-
tor that the required control equipment is in place, in use, and certified by
means of analyses of coating solutions. Company purchasing records, inventor-
ies, and operating schedules should provide most of the required information.
The Region could spot-check through plant inspections and laboratory analyses
of the coatings.
4.4 POTENTIAL PROBLEM AREAS
The greatest potential problem might be the industry's resistance to
change. This would usually be expressed as a conviction that the furniture
finishes produced by waterborne coatings, electrostatic spraying, and airless
spraying are inferior in quality, durability, and/or appearance and could not
compete in the marketplace with domestic and foreign-manufactured furniture
that is not subject to this regulation. This would be very hard either to
24
-------
prove or refute. Specific industry objections to waterborne coatings, elec-
trostatic spraying, and airless spraying are discussed in Section 2. Many of
these problems may have been overcome now that a substantial part of the
industry has already reduced VOC emissions.
25
-------
REFERENCES
1. U.S. Environmental Protection Agency. Draft Document, Control Technique
Guidelines for the Control of Volatile Organic Emissions from Wood Furni-
ture Coating. Office of Air and Waste Management, Office of Air Quality
Planning and Standards, Research Triangle Park, North Carolina. April,
1979.
2. U.S. Environmental Protection Agency. Volatile Organic Compound Control
at Specific Sources in Louisville, Kentucky, and Nashville, Tennessee.
Section B, Furniture Coating. (Draft copy) EPA 904/9-81-087, December,
1981.
3. Personal communication from Gary Currier, Reliance Universal, Inc., High
Point, North Carolina, on Composition and Applications of Waterborne
Coatings, October 3, 1983.
4. Personal communication from William L. Johnson, U.S. Environmental Pro-
tection Agency on the Status of VOC Regulations for the Wood Furniture
Coating Industry, November 22, 1982.
5. Personal communication from Gary Currier, Technical Director, Reliance
Universal, Inc., High Point, North Carolina, on the Technical and Econom-
ic Aspects of Waterborne Coatings, Electrostatic Spraying, and Airless
Spraying, January 4, 1983.
6. Illinois Environmental Protection Agency, Reasonably Available Control
Technology for Surface Coating of Wood Furniture and Cabinets, May, 1982.
7. Personal communication from Andrew B. Rawuka, Air Quality Control Engi-
neer, South Coast Air Quality Management District (Los Angeles area), on
the Transfer Efficiencies Achievable with Electrostatic and Heated Air-
less Spraying, January 28, 1983.
8. Personal communication from Andrew B. Rawuka, Air Quality Control Engi-
neer, South Coast Air Quality Management District (Los Angeles area),
regarding proposed AQMD Standard for Wood Furniture Coating, November 22,
1982.
9. -Personal communication from George Rhett, Senior Air Quality Engineer,
Coating Operations Unit, Permit Processing Division, South Coast Air
Quality Managment District (Los Angeles area) on the VOC Emissions from
Wood Furniture Coating, November 24, 1982.
26
-------
10. Personal communication from John Reed, Supervisor of Technical Support
for Air Quality Planning Section, Illinois Environmental Protection
Agency, regarding proposed Illinois Standard for Wood Furniture Coating,
November 22, 1982.
11. Personal communication from William Ball, Production Sytems, Inc., High
Point, North Carolina on the Cost of Waterborne Coating System, Janu-
ary 18, 1983.
12. Personal communication from Paul Leary, Reliance Universal Inc., Louis-
ville, Kentucky, on the Technical and Economic Aspects of Waterborne
Coatings, January 3, 1983.
13. Personal communication from Andrew B. Rawuka, Air Quality Control Engi-
neer, South Coast Air Quality Management District (Los Angeles area), on
the Industry Reaction to Proposed Standard, and Costs, Benefits, and
Properties of Hot, Airless Spraying of Coatings, December 8, 1982.
14. Personal communication from John Reed, Supervisor of Technical Support
for Air Quality Planning Section, Illinois EPA, on Clarification of
Proposed Standard and Industry Objections to the Proposed Standard,
December 8, 1982.
15. State of Illinois. Proposal to Amend Air Pollution Control Regulations,
RACT III, Amendments to Air Pollution Control Regulations, Rule 205,
Emissions of Volatile Organic Material. Proposed July 12, 1982.
16. South Coast Air Quality Management District. Wood Furniture and Cabinet
Coatings, Rule 1136. Adopted September 16, 1983.
27
-------
APPENDIX A
PROPOSED ILLINOIS REGULATION
FOR WOOD FURNITURE COATING
-------
STATE OF ILLINOIS )
)
COUII1Y OF SANGAMON )
BEFORE HIE IU HIOI ^ POLUM ION COflTP.OL BOARD
RACT I I I
AMENDMENTS TO
AIR POLLUTION CONTROL
REGULATIONS - RULE 205
EMISSIONS OF VOLATILE
ORGANIC MATERIAL
PROPOSAL TO AMEND AIR
POLLUTION CONTROL REGULATIONS
Pursuant, to Section 23 of the Illinois Env 1 ronmenLa 1 Protection Act
(111. Rev. Stat., Ch 111 1/2, Sec. 1 028, 19 7 7 ) and the Illinois Pollution
Control Board Rules and Regulations, Procedural Rules, Rule 203 and 20'1,
the Environmental Protection Agency (Agency) proposes the following
amendments and revisions to Illinois Pollution Control Board Rules and
Regulations, Ch. 2, Rules 10 , 201 and 205:
) R"2 -
I GENERAL AMENDMEII1 S ANO REFINEMENTS
L. The Agency proposes that Rule 10<1(a)(l) be amended tn read as
follows•
(1) No person shall cause or allow the operation of an emission
source not in compliance y/ith the requirements of Rule
205t'*Mv) unless s ich person is in compliance with a
compliance program as provided for in Rule 104(g)", (h) or
(i) or Rule 205(m).
-------
2. Hi" Agency proposes Mi?,! 1 0<1 () (¦!i lu-> t'"'i<;e
-------
Ru Ie ''JL^-er Pr0,ruiion
C• 5ill'LL-JJ.9 L 3;hl
^njjljlM)_,_
iiililillilA) ;__!ilr
f ac i 1 i 11 es 1 or. a t ed i n
all other counties
('I) Ui]]_oss the submitted coriji 1 i meg program or peoject
completion schedule is d i s app,-o .'ud by t_he_ Auency, the owner or operator
of a facility or emission source subject to Rules 10 ^ ( i) ( 1') pay operate
the emission source in accordance with the program and schedule submitted.
(3) The program and schedule shall meet the requirements of
Rule 104(b) inc1uding spec i f ic interim dates as required in Rule
104(b)(2).
4. The Agency proposes that the definition of Volatile Organic
Material in Rule 201 be amended to read as follows:
Volatile Organic Material: Any oruanic material which has a vapor
pressure of 17.24'.;Pa (2.5 psi) or greater at 294.3k (7Q0F). For
purposes of Rule 205(l)(l-3), volatile organic material means any organic
material which has a vapor pressure of 10.34kPa (1.5 osi) or greater at
294.3k (7QOF). For purposes of Rule 205(k), 205( 1 )( 4 ), ? 0 5 (n), 205(s),
205(t), 205(u), 205(v), 205(w), anr 1 205(f)(2), volatile organic material
means a.ny organic material winch lias a vapor pressure greater than
0.13kPa (.0019 psi) at 294.3k (70op). pnr purposes of this definition,
the following are not volatile organic material: 1. Methane, 2.. Ethane,
3. 1,1,1-Trichloroethane 4 Methylene Ohloride.
5. The Agency proposes that Rule ~'05(j) be revised to read as
foilows:
-------
(J)
Every ov/n°r or opT-ilO'" of .vi inn so'irce shall conp 1 /
with t ho L l)
['is ting [m ; ?
jO'HTP S
¦ ^ ion
December
31,
1973
^ u 1 e
205(a)(3)
A1 1
Eniss ion
Sources
Pec ember
31,
1985
Ru le
205(f)(2)
A11
Enission
Sou r c.es
December
31, .
.1925
Rule
205(k)
A 1 1
Em i ss i on
Sources
July 1,
1980
Rule
205 (1) ( 1 ) -( 3)
A11
Emis slon
Sources
July 1,
1980
Rule
205( 1) ('1) - (10)
A1 1
Enn ssion
Sources
S°e Rule
205 (
m) (4)
Ru 1 e
205(n)
205(n)(l)(J), (K)
3 r1,< ( 1 \
All
A1 1
Em lesion
Emission
Sources
Sources
December
December
31,
31,
1932
1932
an'J ^lj
205(n)(l)(K)(ii)
¦md ( L j ( 11)
A1 1
Emission
Sources
See Pule
205(m)(5)
205( n) \ 1 ) ('¦!)
A1 1
Em i ss i on
Sources
Pe c err.b °r
31,
1935
205(n j(2)(A)
A1 1
Emi ss ion
Sources
Dece "ber
31,
1985
Rule
205(o) (1) and (2)
(o)(3)
A1 1
All
Emlsslon
Emls Sion
Sources
Sources
July 1,
Denember
1931
31,
1983
Rule
205(p)
A1 1
Em i ssion
Sources
See Rule
205 (
m)
Ru le
205(q)
All
Emi ss ion
Sources
December
31,
1983
Rule
205(s) and (t)
A1 1
Emission
Sources
December
31,
1983
Rule
205(u)(1) (A)-(C)
('O(D(D)-(G)
(u)H)
All
A1 1
All
E m i s s ion
Emission
Emi s s ion
Sources
Sources
Sources
December 31,
December 31,
December 31,
1983
1983
1985
Rule
205(v) and (w)
A'l 1
Emi ssion
Sources
December
31,
1985
-------
The Agency proposes tn amend Nule f3 { n) ( ?) ( ^ ) to road as
4
A( i) For facilities subject to Rule 205(n)(l)(B) an afterb>.irner
system, provided that 75 percent of the emissions from the
coating line and 90 percent, of the nonmethane volatile
organic material (measured a^ total combustlble carbon)
v/h ich enters the afterburner are oxidized to carbon dioxide
and water; or
( ii) For all other facilities subject to Ru le 205(n) (1) except
205 ( n) (1) [ 8) a n _ after bur_i i er system, provided that 81
percent of the ein i ss ions from the coatinq_hne and 90
percent of the nonmethan e v o 1 a 1.11 e org anic ma erial
(measured as total combust ib 1 e carbon) v.'tich enters the
afterburner are ox id i zed to car b o n dio/icle and w a t e r .
6. The Agency proposes to amend Rule 205(H)(4)(A) by clarifying the
meaning of the internal offset equa'ions to read as follows.
^i = the allowable emission rate fo> each coating pursuant to
Rule 205(n)(l) in kilograms per liter 'pounds per q?llon) of
sol uis eeat^T excluding water, delivered to the coaling
aop 1 icator.
= the volume of each coating in liters per day (gallons per
day), exe T^g-waterof solids, delivered to the coating
app 1 icator.
= the weight of volatile cruanic material oer volume of
so 1 i d s eeatiR'j in kg/1 (lb/gal) for each coating applied.
5.
foil o.'/s :
-------
ii geiieral F.nis:-.iO!» sources
1. The Agency proposes Ui.it n 1 /1 c -'O'^f) anr-nded by rearrangement
and the addition of new Rule t^ read as follows:
(f)(1) Use of Organic Material, flo person shall cause or allow the
discharge of mere than 0 pounds per hour- of organic material
into the atmosphere rrom any emission source not otherwise
specifically limited by Board reuu 1at ions except as provided in
paragraph (f)(1)(B) and (f)(2) of this Rule 205 and the
foilowi ng:
ExGepoi9Pu--{£-A9-a^9r-Ry}S'>F!Ge-ex49fes-t he-Urn itat-ifls-ef-tiqis
Ryle-205(.f)-ch^ll-apply-9nly-t9-ph9t9sti?.:?:isaHy-reaetiy9.
pa£e>=i-al r
(A)(1) Alternative Standard. Emissions of organic material in
excess of those permitted by Rule 205(f)(1) are
allowable if such emissions are controlled by one of the
folio.ving methods"
(i) flame, thermal or catalytic incineration so as
either to reduce such emissions to 10 oom
equivalent methane (molecular weiaht 15) or less,
or to convert 85 percent of the hydrocarbons to
carbon din/ido and water; or,
(11) a vapor recovery system ^liich adsorbs and/or
absorbs an:l/or condenses at least G5 percent of
the total uncontrolled organic material that would
otherwise be emitted to the atmosphere; or,
-------
(ill) .-iny n 111 p r air pollut. ion co'itrol o n '• J1 pm0 n L approved
by the Aoor.ry c -np.ib I*"> of reducing hv 05 percent or
more the uncontrn I lei 01uanir materia I t i 1 -3 L would
be otherwise emitted to the atmosphere.
(B)(2) Exceptions: Hie provisions of Rule 205(f)(1) shall not
ap ply to:
(i) the spraying or 'JSC of insecticides, herbicides,
or other pes t ;e ides;
(n) fuel combustion emission sources;
(in) the apol ication of paving asphalt and pavement
marking paint from sunrise to sunset;
(iv) any owner, operator, user or manufact.-urer of
paint, varnish, lacqu°r, coatinos or printed ink
whose Compliance Program and Project Completion
Schedule, as required by Part 1 of this Chapter,
provides for the reduction of organic material
used in such process to 20 percent o<~ less of
total volume by Hay 30, 197 7.
(v) Photochemically non-reacti ve ma Leri a 1 not
con tribu t inq to an odor nuisance.
No person shall cause or allow the emission into the atmosphere
from any e:r.i ss ion so' i rce not ot h erw i se spec i f ic a 1 1 y 1 i in i ted by
Board Regulations and located at a f a c i 1 i ty wli i c h won 1 d em 11
more than 100 tons per year of volatile o_rganic material (taken
as a three year c a 1 e n da_r 3 .¦ e r a r.\ e) ui the absence 0 f control
equipment or enforceable operating permit conditions to exceed
the maximum allowable emission rate calculated as follows:
-------
(A) Slop A: . Determine the vapor piessui e at Lindard
conditions in pounds per square inch absolute of the
vo 1 a t i 1 e n r gam c j natr-r la 1 (VU'l) emit ted from the sou r c e .
(G) Step 13: Determine the percent by volume of the VOH in the
gas emitted from the source. Whene.'er dilution gas is
added to the gas from a source, the gas shall be considered
to have the gas d ischarge rate and compos 11 ion pr ior to
such dilution, in accordance with the follow in
(i) If the source disch a roe s_i i n d o_r_a_ ven t i 1 a t ion hood ,
concentrat ion of V Of 1 and the flow rate of the gas may
be measured or other'; i se determined in the duct
connecting the hood to the inlet of the ventilation •
f an.
(i l) [f the emissions and ventilation alr are conveyed
through ducts from the source to the outdoor
atmosphere with no interruption, the concentration of
VOr'i and the flow rate of the gas are to he determined
ins ide the ducts.
(i i i) For all other sources including, but not limited to,
evaporation from steps in chemical manufacturing
processes, the concentration of VQM and the flow rate
of the gas sha 11 be measured at a point no farther
than 6 inches (15 centimeters) downstream fron the
point at wh ich _the vapors leave Hie process equipment.
( C) Step C: F_r o:ri fable ?.b, find the gas range cla s s i f i c a t i o n
by selecting the appropriate line for the vapor pressure as
determined in Step A and the appropriate column for the
percent VQM as detenuined in Step B.
-------
('!) Source opei'a t ion ; n^irnll/ f/illiiH -.nihin t h" category subject
to the _p_r o v 1ions 'if fi u I o .-'l)b(l ){'.) hut. uvd for research or
(I e i° I ojjmn n1 purposes arc ni,em[H frm rump I 1 ance piovided '.hey do
not exceed (he hour' 1 y p/c 1jjs_i_om_ rales [2.'_L.ill
forth in_ Table 2 . '3 , Column oy i ded :
Ho mure s.hciii ? 1 nn?s the t p [11 i'. O-hlj^ hourly e '.c 1 us i on rate
set fo-'LI> ri I -Mi 1 e . 5, <1 imn ? i' emitted in any one
hour; and
(B) Ho mure than 3 times the applicable hourly exclusion rate
se_t_ foi'Jdi__i_n_ J_ab_ l_e_ 2_5Co_n.]im 3^ r, c-ini t_ted in any 2'1-hour
per i od.
K\fLE ?.[¦
I I'.u: 1 ALLOWABLE VOLA'l 1 LE "ORG^'I IC ' iA ' ERIA I. b'HSSlUMS
ColUinn I
Range
He term ined
fi"on Tab le «. .6
Rang'0 A
Range 3
Range C
Co 11nwi ?
' h v in:ii.-n
A 1 lrr..'ali 1 r>
Em i_5 s_i_ons
P_oj"Cen_t_ of 1'roccss
bi i_s_s_ion_s I'y ','eicitit
T5
I'i
Co himu 3
Exclusion Rates,
'Continuous or Batcli
C yc1e Emiss i on
Tv-Tin¦ f? '¦* i 1 ogr am
per hour rer hour
3. 2
c . /
Range D
Range E
Range r
Range G
Rang; H
Range 1
lu
t
0.3
IS'
1 .8
EI
0.9
0J3
0
1.2
in
-------
S top D: T rom f ib 1 e 2.';, Cn 1 utim 2, d'-M ermine the maximum
¦31 lowab l_e__pei_ceni_ of_pro^ ;s o_:m_i_s_s ions_for Lho gas range as
determined in r-tep C.
Step E: The maximum allowable emission rate shal 1 be
pounds_Jj:_i_loqrams) per hour_ (or per batch cycle hour)
equ 17 a lei I to the percent of the process emissions shown in
Cojumn ? or the Exclusion Rate siio.-.'n in Column 3, whichever
is greater.
(F) Step F: Gases from a single source operation which are
emitted from different vents _in different range
classifications as deternined from Table 2.5 s hall be
considered as being discharged frcm separate source
operations for each of v.hirh the maximum allowable emission
rate must be d e_t e r m i n e d s e p a r a i, e 1 y .
(3) The provisions of Rule 2( )_5 (f)(2) shall not apply to a gas in
Range A or B discharged into t'n° outdoor atmosp1 |_Q_'^e__t_hro_uah a
local exhaust ventilation system whose inta'-'.e is located within
5 mches (15 . cent imeters) of p_ojnt at ¦.¦1 i i ch the source gas
is discharged to an internal wo rk_ pace, pro.' l d e d such e x h a u s t
ventilation system:
(A) Collects at least 6CK by volume of a Range A source gas or
85^ by volume of a Range B source gas emitted from the
source operat l on ; _on_d
(B) Is equipped with a vapo>~ rnntrol system which prevents from
be i ng 11 sen n ged _i nto the _ou t door atmosphere at least 85%
by volume of the VOf'i collected.
1111
(I)
-------
TABLE 2.6 - Determ i nan! "> nf rnntr"nK Regm rod for
Volatile Organic l-hternl Sourres
Vapor Concentrat)on of Vo1 a t i I f Organic Material by Volume, Percent
Pressure
psia P 7pop Ranug A Range B Range C Range D Range E Range P G H
0.0
0.1
1 .0
18.0
18.0
0. 1
0.2
1.0
7.0
7.0
29.0
29.0
0.2
0.3
6.0
6.0
n.o
1 3.0
40.0
40.0
0.3
0.4
9.0
9.0
13.0
18.0
4 5.0
45.0
0.4
0.5
)?.0
12.0
22.0
22.0
50.0
50.0
0.5
0.6
l-i.O
1 4 .0
25.0
25.0
56.0
56.0
0.6
0.7
16.0
16.0
28.0
28.0
60.0
60.0
0.7
0.8
n.o
18.0
31.0
31.0
64.0
64.0
0.8
0.9
20.0
20.0
34.0
34.0
6 7.0
67.0
0.9
1.0
22.°
22 .0
37.0
3 7.0
70.0
70.0
1 .0
1.2
26.0
26.0
41.0
4 1.0
7 4.5
74.5
1.2
1.4
29 .0
29.0
4 5.0
4 o. 0
77.5
77.5
1 .a
1 .6
32.0
3?.0
49 .0
'•9 .0
80.5
80.5
1. &
1.8
.5
34 .5
52.0
52.0
83 .0
83.0
] .3
2.1
73.0
38.0
55.0
5 5 .0
86.0
86.0
2 A
2. '1
i 1 .5
4 1.5
58.0
6 8.0
83.0
88.0
2 .4
2.7
=15.0
4 5. n
61.0
61 .0
90.0
90.0
2.7
3.0
48.0
'18.0
64 .0
64.0
Q1 .5
91 .5
3.0
3.5
52.0
52.0
68.0
68.0
9 3.5
93.5
3.5
4.0
I" j . 0
55.0
71.0
71.0
95.5
95.5
4.0
4.5
53.0
53.0
74 .0
7 4 . n
9 7.0
4.5
5.0
61 .0
61.0
76.0
76.0
97.0
5.0
5.5
64.0
64.0
78.0
78.0
97.0
5.5
6.0
66.5
66.5
79.5
79.5
97.0
6.0
6.5
68.5
68 .5
81.Q
81.0
97 .0
6.5
T. 0
70.5
70.5
82.5
82.5
97.0
7.0
7.5
72.0
72.0
84 .0
84.0
9 7.0
1.5
8.0
73.5
7 3.5
85.0
85.0
9 7.0-
S .0
3.5
7 3.0
7 5.0
86.0
86.0
97.0
a. 5
9.5
7 7. 5
7 7.5
87.5
87.5
9 7.0
9.5
10.5
80.0
OiJ.O
89 .0
89 .0
97.0
19.5
11.5
H, .0
82 .0
90.5
90. 5
9 7.0
11.5
'13.0
84 . 5
8 4.5
Q 2 .0
92.0
97.0
13.0
14.7
H 7,0
87.0
93.0
93.0
97.0
R a n g e I
Hi'^ater Tlwi Bui 'lot Greater Than
1 97 %
1 I
-------
51jrfact, ro^n.'in of woon
f!iF:inurf Ann : adi riFis
K. 1. The Agency proposes th.it ^ule ?ni be amended by adding the
following clef i n i 11 ons:
Wood Furniture: Room furnishings' inc hiding cabinets (kitchen, ba th
and vanity), tables, cl rnirs, bedssof as, shutters, ir t objects, wood
paneling, wood flooring, and any other co a t e d_fuj__n i sh i ivis made o f wood ,
wood compos i t i on or simulated won^ ma te r i a 1 .
Fur n 1 ture Coa ting App 1 i cation Line: ["he combi nation of coating
app 1 l c at ion equipment, fl a s h_-o f f a r e i. soray booths, ovens, conveyors,
and other equipment operated in a_ predetermined se'juence for purpose of
applying coating materials to wood f urn i[ure.
Cl ear Topcoat: The final coating which contains binders, but, not
opaque pigments and is specifics My formulated to form a transparent or
t r a n s luent solid protective film.
Semi-transparent Stain;: Stains con ta ining dyes a' id/or
semi-transparent pigments which are formulated to enhanr.e wo'-d nrain and
change the color of the surface but not to concea_ 1 the surface including
sap stain, toner, non-gra in ra i s ing st a ins, pad stain, spatter stain, and
other semi-transpaicnt stains.
Opaque' Stains: All stains containing pigments not classified as
semi - transparent stains mc 1 ud i no stains, glazes an d__o t_l i_e r opaque
material to give character to wood
Pigments Coatings: Opaque coatings containing binders and colored
pigments h i c h are form1.! 1 1 ted lo conceal the wood surf ice either as an
¦ undercoat or topcoat.
l'P
-------
Wash Coat: Coat wig <; o_n_t a 1 m i ug h wider s_ .vhich S'Mls wood surfaces,
prevent; uncles wed sta in inc] and roj111'o 1 s [i_e 1 hHt a_t_ j
Sealer : Coating containing b i nder s__wh i_2_b_ Hie .-.ond prior to
application to subsequent coatings-
Final Repair Coatings: Coatings to corrc-ct imperfections or damage
to furniture surface.
Binders: Organic materials and resins wind i do not inc Uide vol at i le
organic materials.
2^ The Agency proposes that Rule ?05(n)(l) be amended by adding a
0.6 7 (5.6)7_
0.73 (6.1)7
0.67 (5.6)8
0.60 (5.0)7
0.79 (6.6)7
0.56 (4 .7) 1_
new subsection as follo.-.'s:
(n) (1)(M) Wood Furniture and cabinet coating
(i) Clear topcoat and sealer
(ii) Was hepa t
( i i i) Repair Coat
(i v) Pio'nemed Coat
(v) Semi - transparent stain
(vi) Opaque Stain
Z At overall transfer efficiency of 65 percent
3 At overall transfer efficiency of 30 percent
-------
APPENDIX B
SOUTH COAST AQMD REGULATION
-------
Agenda #20
South Coast
AIR QUALITY MANAGEMENT DISTRICT
9150 FUViR DRIVE. EL MONTE. CA 91731 (213) 572-6200
August 16, 1983
South Coast Air Quality
Management District Board
Proposed Rule 1136 -
Wood Furniture and Cabinet Coatings
As directed by your Board the staff has modified the draft Proposed Rule 1136
wich was presented at tho June 3, 1983 District Board meeting. This latest
araft is a result of cooperative efforts of the District staff and the wood
furniture industry to achieve trie objectives of the previous draft rule.while
mitigating some provisions which were objectionable to industry.
The significant changes to tho earlier draft are:
" Case goods and noncase goods are no longer distinguished in the rule.
The transfer efficiencies have been adjusted to reflect a weighted
average efficiency for coating all furniture items.
VOC limits for topcoat were adjusted to 700 grams per liter and sealer
to 690 grams per liter to reflect actual average values for such material
sold in the District. Based on industry data, "toner" (previously
included with semi transparent stains) has been included in the same
category as washcoat.
The demonstration portion of the rule has been strengthened to require
all wood furniture operations using 10,000 or more gallons per year of
coating material to participate in the demonstration program.
Requirements of the proposed rule now are.
" Use of airless spray for all coating operations by owners/operators
wno use 1000 gallons or more of coating material per year, with a
phase-in compliance schedule depending on the size of operation.
* Alternatively, to achieve VOC reductions equivalent to those achieved
with airless spray application, by use of a "bubble" concept for all
coating steps.
* A demonstration program by operators using 10,000 gallons or more of
coating material per year to obtain at least a 14 percent additional
reduction, above the actual reductions achieved in complying with the
airless spray or equivalent reduction requirement provisions of the
rule.
SCAQMD Board
-2-
August 16, 1983
At the June 3, 1983 meeting, your Board instructed staff to maintain the
emission reductions anticipated in the previously proposed rule and projected
in AQMP Tactic B5. This has been done, after adjusting to a more realistic
projection of actual VOC emissions. The emission inventory for 1979, as
reported in the AQMP, was 16.8 tons per day of which 9.4 tons per day were for
small miscellaneous operations and ,7.4 tons for major operations. The total
was projected to increase to 20.2 tons per day by 1987 but actual coatings
material sales for 1982 were 20 percent below those for 1979. This reduction
in activity has been verified by both paint vendors and wood furniture
manufacturers, as well as by the District inventory for 1982. Although the
uncontrolled emissions are lower than forecast in Tactic B5, the proposed rule
should achieve the 54 percent reduction projected in that Tactic.
Issues brought up at or after the June 3, 1983 Board meeting and
discussed at a public workshop and/or meetings with owner/operators are
Summari2ed below:
Separate requirements for case goods and noncase goods, as defined in
the previously proposed rule, were unacceptable to industry because most
operators coat both case goods and noncase goods components on a single
furniture coating line. The rule now proposed does not distinguish
between case goods and noncase goods.
" Baseline VOC limits for clear topcoats and sealer were thought by
industry to be too stringent. Staff requested backup information on VOC
content in materials sold in the District. As a result of data reported
by the large coating material suppliers, the VOC baseline value for clear
topcoat is adjusted from 680 grams per liter to 700 grams per liter and
the sealer baseline value is adjusted from 680 grams per liter to 690
grams per liter.
* To meet the goal of the AQMP Tactic B5, it is necessary to achieve a
54 percent reduction in total emissions. The airless spray requirement
should achieve a 40 percent reduction and there was considerable
discussion as to methods for achieving an additional reduction of at
least 14 percent. Some operators wished to have a program to demonstrate
a total 54 percent reduction at a given plant, rather than a program to
demonstrate additional reductions. Staff felt, however, that some larger
owner/operators, simply by using airless spray, may attain a 54 percent
emissions reductions but should not, thereby, be free from the
demonstration provisions of the rule. The efforts of all the larger
manufacturers are required to achieve the maximum VOC reductions for the
entire industry, through technology developed In the demonstration
program. The rule now proposed includes a demonstration program for
additional reductions.
-------
SCAQMD Board
-3-
August 16, 1983
* Many questions were raised regarding equivalency calculations under the
"bubble" concept and requests were made that a calculation forrrula be
Included in the rule. At the final workshop, staff presented a
Calculation sheet which gave an equivalency calculation fornula, with
definition of terms, .and sample calculations. This calculation procedure
1s not Included in the rule but will be available to industry and will be
used for engineering evaluation by the District staff.
* The issue was raised of substituting nonreactive solvents, particularly
1,1, l-tnchloroethane, as a means of attaining VOC emission reductions.
It was specifically suggested that such substitution be listed as an
acceptable technology for the demonstration program. Although the use of
such solvents to meet VOC limits in District rules is allowed, the
question of potential toxicity is an issue which must be clarified before
unlimited use of these solvents can be encouraged by the District. Use
of such solvents is, therefore, not included as an acceptable innovative
tecnnology in the proposed rule.
* A question was raised as to rule applicability where both metal and
wooden articles are coated. It was clarified that the rule pertains only
to wood furnishings and that the coatings actually used on wood items
only would determine owner/operator compliance with the rule.
Many discussions were held with representatives of the larger operators. In
addition, copies of the latest proposed rule draft were mailed to several
hundred small operators. The responses received in return included suggestions
for further clarification of some points which were not addressed at the last
public workshop and not received prior to notification of the rule. The staff
has prepared draft language for three of the suggested rule changes which are
included in the attachment to this Board letter and has recommended that your
Board include these with the adoption of the rule.
The staff, after cooperative meetings and other commjnications with a wide
cross section of industry and their legal staff, concludes that the previous
objections have been resolved. Staff recommends the new proposed rule as the
most effective measure which can be implemented, considering current
t echno logy.
THEREFORE, IT IS RECOMMENDED THAT YOUR BOARD
-- Adopt Proposed Rule 1136, Wood Furniture and Cabinet Coatings, at
your September meeting. ,
Respectful ly,
J/. A. Stuart
,£xecut i ve Off icer
JAS-hs
Attachments
-------
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT
August 2 4, 1983
ATTACHMENT
PROPOSED RULE 1136 AMENDMENTS
Common ts were received after the Jast public workshop and rule
notification, requesting further clarification of some provisions
in the proposed rule. Staff recommends that the wording of these
subsections in the rule, as noticed for hearing, be amended as
shown below and that the revised wording be incorporated in the
final rule. The double underlined words, e.g., total , and
cross-hatch strikeouts, e.g., t>^T . reflect the recommended
changes made after the notice for hearing. The single underlined
words, e.g., using, and dash strikeouts, e.g., reflect
changes made to the rule after the Board meeting on June 3, 19S3
but before public notice for hearing.
Page 4, subsection (b)(1)
"(1) A person applying coatings to wood furniture and
cabinets shall net apply any coating material
eaee-ge*rte-«B}-e6fi us i ng airless spray or a J r ass i s ted
airless spray application 46-used for all
coating steps-r or_, a I ternati vel y , ach i eve wn4-eRK
equivalent to ta1 emissions reductions in affected
coating application steps + e-a-fcta-j-ned by other me/insT_.
5yeh-H8-pefcJHe£4-eH-<=> Wen teR £ -e-f-eeafci-Rtfe-Hsed
a nd /¦*» p- use-e
tPftRefep-ef^HteRevr"
Page 5, subsection (b)(2)
"(2 ) In add 111on to complvlng with the provis1ons of
subsoction (b)(1), owners and/or operators of wood
-2-
furnlture and cabinet coating operations which used
more than 1 0,000 gal Ions j>41 Vtii of coatinq s during
the 12-mo n t h' period prior t o Sept emb er 1, 1983 shall
submit to the Executive Officer a Coating Application
Step(s) Test Plan te-be - a 5ed - + n establishing a
twelve-month d ewe n s fe p a fc * e n program to_ demonstrate the
f e a slbl 1 it y o f a c hieving f u r t h er emlssion reduct ions:
Page 10, subsection (e)(1):
"(1) Washcoat, toner , or semi transparent stain a*d-epaq«e
sfca*R application steps until {2* 2_l months after
date of adoption). "
-------
July 13. 1983
Proposed Rule 1136 - Wood Furniture and 'Cabinet Coatings
(a) Definitions
For the purposes of-this rule, the following definitions
shall apply:
(1) Wood furniture are those Surface coated room
furnishings which include cabinets (kitchen, bath
and vanity), tables, chairs, beds, sofas,
shutters, art objects, and any other coated
furnishings made of solid wood and/or wood
composition and/or simulated wood material.
(2) Furniture and c a binet coating application operations
are a contD i nation of coating application
steps wnich includes spray guns, flash-off areas,
spray booths, ovens, conveyors and/or other equipment
operated for the purpose of applying coating
materials.
(3) Clear topcoat is a final coating which contains
binders, but not opaque pigments, and Is
specifically formulated to form a transparent
or translucent solid protective film.
(4) Semi transparent stains are stains containing dyes
and/or semit ranspa rent pigments which are formulated
to change surface color, but not to conceal surface
grain, and include sap stain, l9R«pr and non-grain
raising stains.
7-/C-S 3
2
Proposed Rule 1136
(5) Toner 1s £ coat 1ng which contains blnders and dyes £
p1gmen ts to add tint to £ coated surface.
(fc}(6) Opaque stains are stains containing pigments not
classified as semi transparent stains and Include
wiping stains, glazes and other opaque material to
give character or texture to wood.
(6 H7) Pigmented coatings are opaque coatings which contain
binders and colored pigments which are formulated
to hide the wood surface, either as an undercoat
or topcoat.
( 7 H 8) Wash coat Is a coating, containing binders, which
seals wood surfaces, prevents undesired staining
and controls penetration.
(8 H 9) Sealer is a coating, containing binders, which seals
the wood prior to application of the subsequent
coatings.
49H10) Volatile Organic Compound (VOC) 1s any volatile
compound of carbon, excluding methane, carbon oonoxi
carbon dioxide, carbonic acid, metallic carbides or
carbonates, ammonium carbonate, methylene chloride.
1,1,1-trlchloroethane, tr1f1uorooe tha ne and chlorlna
fluorlnated hydrocarbons as determined pursuant to
subparagraph (f).
( 1Q) (11) Binders are non-volatile polymeric organic materials
(resins) which form the surface f1 I¦ In coating
appl1cat1ons.
-------
Proposed Rule 1136
(11^ Ca&a-geeds-ape-a&senbled-weed-Eupnttwpe-wl'th-a
aaN-lllie<'«9nflgitr»t43n-and-lft«lt»de-&u6b-ltens-at
dpesiepii-(il)»i)(tSi-i<^lit-tibte(-i>il-itere9-tRe&^uP0-(paneSr-6lx»p&r-^?^UT-&UVhefc-Pifilt&-ind
una£(em^ed-fuPHvUpe-Genp8neRtSr
(I2}( 12) Transfer efficiency is the ratio of the weight of
coating solids deposited on an object to the total
weight of coating solids used in a coating application
step, expressed as a percentage. Unless the owner/operator
demonstrates an actual measured transfer efficiency, the
transfer efficiencies shall be deemed to be-
Application Methods
Air spray
Electrostatic disk or
bell atomizer
Electrostatic air spray
Airless spray
Heated airless s p r a y
Air assisted airless spray
Dip and drain
Rollercoat, wipe or brush
Transfer Efficiency, pefeent
Percent
24
39
N/A
76
SQ
SO
98
96
85
70
40
40
40
90
95
It
85
it
26
25
96
N/A
Proposed Ru1e 1136
(b) Requ1rese nts
(1) A person applying coatings to wood furniture and cabinets
shall net apply any coating natertal ta-cata-gaadt-anlatt
using airless spray or a i r ass i sted airless spray
application 4t-ut*d for all tata-gaadt coating stepsi orx
alternatively, achieve wnlatt equivalent emissions
reductions^ 1n affected coating application steps it
attained by other neansr. mah-as - pad* t1 ion-a t -1 a V ven t
tentent-e(-caattngfr-wted-and/ap-wta-e(-appl
-------
Proposed Rule 1136
5
methods to effect emission reductions equivalent to
the requirement for airless or a 1r assisted airless
spray application tn all affected coating steps.
Solvent content of actual material used 1n each
coating step shall be compared with the baseline
solvent content for such step, shown in subparagraph
(b)(1)(A), for purposes of calculating equivalent VOC
reduct ions.
(2) |_n addition t o complying with the provi sions o f subsection
(b)(1). owners and/or operators of wood furniture and
cabinet coating operations which use more than 10,000
gal Ions per year of coatings shall submit to the Executive
Officer a Coating Application Step(s) Test Plan ta-be-w&ed
establ ishinq a twelve-month d e»e» s t p a & *• program t o
demonstrate the f e a s 1 bi1 i t y o f achieving f u r t h e r em 1s sion
reduct ions •
(A) Such plan shall include strategies
to demonstrate at least a 54 percent reduction in
total emis sion s from a 1 1 coating applicatlon steps by
additional increases 1 n transfer e ff1c1 en cy and/or
7b-pePcenl-tFaAfr&eP-efti6teA6y-9P-eHuvv*l-eftt-e*ivfr&tan
ped»Gtve*s-*ttalned-by-etbep-meansr-*M6b-*s reductions
In of- solvent contents of coatings *6 applied. That
6
Proposed Rul e 1136
1s , each owner/operator shall dewonstrate £ furt:
overa 1 1 reduction of ajL least 14 percent 1 n add 1
to t h,e actual reduct 1 ons ach 1 eved 1 n comp lying w_
the regu1rements of subsection (b)(1).
(B ) I nc 1 uded 1n such plan shall be £ demons t rat 1 on Oj
least one coating appl1 cat 1 on step of waterborne
coat 1ngs , electrostatlc spray 1ng , h1gher solids
coat 1ng materla 1 o r other Innovative techno!ogy .
(ft} (C) The baseline VOC content of coatings used 1n coa
application steps, for purposes of calculating
ssion redu c 11 on s_
pwppefrebr shall be deemed to be the values liste
subparagraph (b)(1)(A).
V
--G+l-)-0*t*Pep-¥e»p --AppVl»fc»Vi-0»-Steps-Eleq»i-pg<-
}OrOOO-t«-2SrOOO One
Cpeatep -1h*a-2fcrQQQ
t0p-the-d«a«ftttp*tl«fl-pp03P*B-frh*l-l-bet
-------
7
P roposed Rule 1136
(v) Ir no v* 11 v e - f » p -1 he - ped*6 fc * or-e f - V06-em »¦ s s * or t T
ft-*-} U&ed-j.R-*-ppedw6ti.o»-*ppVv6*fci-OR-fop-«o»-G«&e
9#ed4-wbeFe-ef»vst^9R-pedwGUeflS-6iB-be-#eii«pe^r
(i-tt) U(Ude-at4easl-ene-6^eiP-bep6 0dfc-9P-6eaUp
ceatiA9-stept-*Ad-e*e-sfc»iR-dppl-t6dt»en-sfcep
wbeR-bws-goattRg-sbeps-ape-pequiped-by
&y^pdP*SPAph-(.b^(2)(&^r
( S ) ( D ) Performance measurements to determine the
reduction of VOC emissions shall be made by the
owner{i}-4«d/9P /operatorfs} during each month of
operation, and the results o f such tests shall be
reported to the Executive Officer a t the end of each
three-month period o f operation.
{£) Uft9ati&fd6fcApy-9pePafcten-0t-aR-dppW6dtt9R-&tep
sball-be-pepepbed-i-R-d-fflontfel-y-pepopb-te-tbe
E»e6tfVtve-6ftt£ep-ttRles&-pe)-afce4-&e-eGGa9tOR4J-
eqwtpAeRl-ffl4l-ti4R6tieRr
(C )(E ) If an owner and/or operator par11 cipa11ng 1n the
test program meets other requirements of this rule,
failure to wee t - Whe - & p* r & f e p-e i- £ *6 » e f»€y achieve the
full emissions reduct1 on requirements will not
constitute a violation of subparagraph (b)(2).
8
Proposed Rule 1136
( M ) ( F ) Submittal of a compliance test plan shall serve as
a temporary peml t to operate.
(c) Compliance Schedule
(1) Owners/operators who have not by (2 2 "onths after date
of adoption) fulfilled requirements of provisions of
subparagraph (b)(1) of this rule shall comply with the
f o 1 1 ow 1 n g :
(A) No later than (2 3^ months after date of adoption)
submit an Implementation plan to the Executive
Officer for attaining compliance with provisions of
said subparagraph , and
(B) No later than (12 ^9 months after date of adoption)
for a facility using more than 10,000 gallons of
coating material in a year, demonstrate to the
Executive Officer final compliance with the
requirements of subparagraph (b)(1), or
{C) No later than (IB J_5 months after date of
adoption) for a facility using between 5,000 and
10,000 gallons of coating material in a year,
demonstrate to the Executive Officer final
compliance with requirements of subparagraph (b)(1),
' o r
-------
Proposed Rule 1136
D) No later than (36 3_3 months after date of adoption)
for a facility using between 1000 and 5000 gallons
of coating material In a year, demonstrate to the
Executive Officer final compliance with requirements
of subparagraph (b)(1).
(2) An owner and/or operator wh9 - has-«et - by - f4-wo *th- aCVef
d a t e - © f - a d e p w v o r } -1 w l-f v l-i-e d - p e ^ m v p e we r t s - a f who ^s
subject to the provisions of subparagraph (b)(2) of this
rule shall comply with the following.
(A) No later than (4 months after date of adoption)
submit a Coating Application Step(s) Test Plan to
the Executive Officer for fulfillment of require-
ments of provisions of subparagraph (b)(2), and
(B) No later than (12 months after date of adoption)
have the affeeted-Goatvag-stepfs} approved Test Plan
in operation, and
(C) No later than (26 2_2 months after date of adoption)
report all test results of the demonstration program
to the Executive Officer. This report Is to include
the gallons of coating material used, the calculated
percent emissions redue11on(s ) for each affected
coating step and the method by which the reduction
Is calculated.
Proposed Rule 1136
10
(d) Fees
For the purpose of deteruining the appropriate processing
fees only, the filing of a Coating Application Step(s) Test
Plan as provided In subparagraph (b)(2) shall be considered
the equivalent of filing an application for a permit to
construct and operate. The person submitting the Plan shall
be assessed a filing fee as described in Rule 301(a), an
engineering analysis fee and annual operating fee as
described in Rule 301(e) - Schedule 7(A)(v1i1). The fees
shall be due and payable as described 1n those rules.
(e ) Ex emp 11 on
The provisions of subparagraph (b)(1) of this rule shall not
apply to:
(1) Washcoatv o_r semi transparent stain a *4-• - fc t* tn
application steps until (24 2_1^ months after date of
adoption).
(2) Touch-up and repair.
( 3 ) Wood f u rn11 u re and cab 1 net coating operat1ons using less
than 1000 gal Ions per year of coatings.
(f) Method of Analysis
The V0C content of coatings subject to the provisions of
this rule shall be determined by the procedure outlined
In Rule 107.
-------
ESOLUTION NO. 83 -
A Resolution of the South Coast Air Quality Management District adopting
Rule 1136, Wood Furniture and Cabinet Coatings.
WHEREAS, the Board of the South Coast Air Quality Management District
desires to adopt Rule 1136, Wood Furniture and Cabinet Coatings; and
WHEREAS, a public hearing has been properly noticed in accordance with the
provisions of Health and Safety Code Section 40703; and
WHEREAS, the Board of the South Coast Air Quality Management District has
held such hearing this date.
THEREFORE, BE IT RESOLVED that the Board of the South Coast Air Quality
Management District does hereby adopt, pursuant to the authority granted in Health
and Safety Code Section 40703, Rule 1136, Wood Furniture and Cabinet Coatings, of
the District Rules and Regulations as set forth in the attached and incorporated
herein by reference.
BE IT FURTHER RESOLVED that the Board directs the staff to report at a Board
meeting before January 1, 1986, the results of the demonstration program and
general developments in furniture coating technology, with recommendatIons for rule
revisions to accomplish additional emission reductions, and
BE IT FURTHER RESOLVED that the Board hereby finds and determines that
Rule 1136, as adopted, will achieve the lowest emission limitation that sources
subject to its application are capable of achieving by the application of
control technology that is reasonably available, considering the technological
and economic circumstances of the sources, and therefore, is a reasonably
available control measure.
Attachment(s)
DATE:
CLERK OF THE DISTRICT BOARD
------- |