EPA 453/R-°6-°04
September 2006
Control Techniques Guidelines for
Flat Wood Paneling Coatings
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EPA 453/R-06-004
September 2006
Control Techniques Guidelines for
Flat Wood Paneling Coatings
Sector Policies and Programs Division
Office of Air Quality Planning and Standards
U.S. Environmental Protection Agency
RTP, NC
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IV
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TABLE OF CONTENTS
I. Introduction Page 1
II. Background and Overview Page 2
III. Applicability Page 3
IV. Process Description and Sources of VOC Emissions Page 4
A. Types of Flat Wood Paneling
1. Decorative Interior Panels
2. Exterior Siding
3. Tileboard
B. Source of VOC Emissions
V. Available Control Options Page 6
A. Available Controls
1. Low-VOC Coatings
2. Ultraviolet Cure and Electron Beam Cure Coatings
3. Add-On Controls
4. Work Practices
B. The 1978 CTG and Existing State and Local Regulatory Approaches
1. Summary of the 1978 Flat Wood Paneling CTG Document
2. Summary of Existing State and Local VOC Requirements
VI. Recommended Control Options Page 9
A. Emissions Limit based on Low-VOC Coatings for Inks, Coatings and
Adhesives
B. Optional Add-On Controls for Inks, Coatings and Adhesives
C. Work Practices
VII. Cost Effectiveness of Recommended Control Options Page 10
VIII. References Page 11
Appendix A
1978 CTG for Flat Wood Paneling Page 13
Appendix B
State and Local Regulations for Flat Wood Paneling Page 15
Appendix C
Estimated Costs Associated with the Recommendations Contained in the
Control Techniques Guideline for Flat Wood Paneling
Coating Page 17
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VI
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I. Introduction
Clean Air Act (CAA) section 172(c)(l) provides that state implementation plans
(SIPs) for nonattainment areas must include "reasonably available control measures"
(RACM), including "reasonably available control technology" (RACT), for sources of
emissions. Section 182(b)(2)(A) provides that for certain nonattainment areas, States must
revise their SIPs to include RACT for sources of VOC emissions covered by a control
techniques guidelines (CTG) document issued after November 15, 1990 and prior to the
area's date of attainment.
The United States Environmental Protection Agency (EPA) defines RACT as "the
lowest emission limitation that a particular source is capable of meeting by the application
of control technology that is reasonably available considering technological and economic
feasibility." 44 FR 53761 (Sept. 17, 1979). In subsequent Federal Register notices, EPA
has addressed how states can meet the RACT requirements of the Act.
CAA section 183(e) directs EPA to list for regulation those categories of products
that account for at least 80 percent of the VOC emissions, on a reactivity-adjusted basis,
from consumer and commercial products in areas that violate the NAAQS for ozone (i.e.,
ozone nonattainment areas). EPA issued the list on March 23, 1995, and has revised the list
periodically. See 60 FR 15264 (March 23, 1995); see also 71 FR 28320 (May 16, 2006), 70
FR 69759 (Nov. 17, 2005); 64 FR 13422 (Mar. 18, 1999). Flat wood paneling coatings are
included on the current section 183(e) list.
This CTG is intended to provide state and local air pollution control authorities
information that should assist them in determining RACT for volatile organic compounds
(VOCs) from flat wood paneling coating. In developing this CTG, EPA, among other
things, evaluated the sources of VOC emissions from the flat wood paneling coating
industry and the available control approaches for addressing these emissions, including the
costs of such approaches. Based on available information and data, EPA provides
recommendations for RACT for flat wood paneling coating.
States can use the recommendations in this CTG to inform their own determination
as to what constitutes RACT for VOCs for flat wood paneling coatings in their particular
nonattainment areas. There are several HAP that are also VOCs. The information contained
in this document is provided only as guidance. This guidance does not change, or substitute
for, applicable sections of the CAA or EPA's regulations; nor is it a regulation itself. This
document does not impose any legally binding requirements on any entity. It provides only
recommendations for state and local air pollution control agencies to consider in
determining RACT. State and local pollution control agencies are free to implement other
technically-sound approaches that are consistent with the CAA and EPA's implementing
regulations
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The recommendations contained in this CTG are based on data and information
currently available to EPA. These general recommendations may not apply to a particular
situation based upon the circumstances of a specific source. Regardless of whether a State
chooses to implement the recommendations contained herein through State rules, or to issue
State rules that adopt different approaches for RACT for VOCs from flat wood paneling
coatings, States must submit their RACT rules to EPA for review and approval as part of the
SIP process. EPA will evaluate the rules and determine, through notice and comment
rulemaking in the SIP process, whether they meet the RACT requirements of the Act and
EPA's regulations. To the extent a State adopts any of the recommendations in this
guidance into its State RACT rules, interested parties can raise questions and objections
about the substance of this guidance and the appropriateness of the application of this
guidance to a particular situation during the development of the State rules and EPA's SIP
approval process.
CAA section 182(b)(2) provides that a CTG issued after November 15, 1990 and
before the date of attainment must include the date by which States must submit SIP
revisions in response to the CTG. States subject to section 182(b) should submit their SIP
revisions within one year of the date of issuance of the final CTG for flat wood paneling
coatings. States subject to CAA section 172(c)(l) may take action in response to this
guidance, as necessary to attain.
II. Background and Overview
In June 1978, EPA published a final CTG for flat wood paneling coatings, entitled
"Control of Volatile Organic Emissions from Existing Stationary Sources, Volume VII,
Factory Surface Coating of Flat Wood Paneling," EPA-450/2-78-034 (June 1978).1 The
cover page of the 1978 CTG is included as Appendix A to this CTG. In September 1979,
EPA published guidance to provide assistance to State and local air pollution control
agencies in preparing RACT regulations for a variety of categories, including flat wood
paneling.2 In 2003, EPA promulgated national emission standards for hazardous air
pollutants (NESHAP) covering surface coating of wood building products (including flat
wood paneling). See 68 FR 31746 (May 28, 2003).
At least 28 State and local jurisdictions have regulations that control VOC emissions
from surface coating operations that include flat wood paneling. Most of these regulations
are general surface coating rules; a few are specific to flat wood paneling. Almost all of the
jurisdictions that specifically address flat wood paneling have based their rules on the 1978
CTG. However, there are two jurisdictions in California that have requirements specific to
flat wood paneling that go beyond the 1978 CTG. These jurisdictions are Placer County
California Air Pollution Control District (Placer County) and South Coast Air Quality
Management District (South Coast). A discussion of the applicability and control options
found in the 1978 CTG and in the Placer County and South Coast rules is presented in
Section V of this document.
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The remainder of this document is divided into six sections. Section III describes the
scope of sources to which this CTG could apply. Section IV describes the flat wood
paneling industry along with the types of flat wood products, and identifies the sources of
VOC emissions from flat wood related processes. Section V describes the available control
approaches for addressing VOC emissions from this source category and summarizes state
and local regulatory approaches for addressing such emissions. Section VI provides our
recommendations for RACT for flat wood paneling coatings. Section VII discusses the
cost-effectiveness of the recommended control approaches. Section VIII contains a list of
references.
III. Applicability
This CTG applies to facilities that apply flat wood paneling coatings that emit at
least 6.8 kg/day (15 Ib/day) of VOC before consideration of controls. Flat wood paneling
coatings means wood paneling products that are any interior, exterior or tileboard (class I
hardboard) panel to which a protective, decorative, or functional material or layer has been
applied.
This threshold of 6.8 kg/day (15 Ib/day) is consistent with the applicability threshold
level contained in many previous final CTGs. It is also consistent with the purpose of the
section 183(e). In section 183(e), Congress directed EPA to assist States in achieving VOC
emission reductions from consumer and commercial products. These products individually
may result in relatively small amounts of VOC emissions but, in the aggregate, they
contribute significantly to ozone formation in nonattainment areas. Given the nature of the
products and sources at issue here, we believe that the 15 Ib/day applicability threshold is
appropriate.
We used the 2002 National Emission Inventory (NEI) as the source of emissions data
and statistical information concerning the flat wood paneling industry as a whole. Plants are
located throughout the United States, with the Pacific Coast and the Southern States having
the largest numbers of facilities. There are approximately 80 facilities in the United States
that produce flat wood paneling products. We found that there are 24 flat wood paneling
coating facilities that meet the 15 Ib of VOC per day applicability threshold for this CTG
that are located in current ozone nonattainment areas (based on April 2006 designations) in
eight States. Appendix B shows the distribution of these facilities and the current State
and/or local requirements that apply to them. Information on flat wood paneling coatings
facilities in the South Coast area of California was not contained in the 2002 NEI database.
We have other information, however, which indicates that there are two flat wood paneling
facilities in the South Coast area. Appendix B does not identify these facilities because
Appendix B focuses solely on the information we obtained from NEI.
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IV. Process Description and Sources of VOC Emissions
A. Types of Flat Wood Paneling
Flat wood paneling products are used in construction and can be classified as three
main product types: decorative interior panels, exterior siding, and tileboard.
1. Decorative interior panels
Interior wall paneling is usually grooved, frequently embossed, and sometimes grain
printed to resemble various wood species. Interior panels are typically manufactured at the
same facilities as tileboard, although in much smaller quantities.
Coated board used for interior panels are subject to industry performance
specifications (consensus standards) which have more decorative coating requirements than
other products. These standards require multiple coating layers and coating steps.
Production speeds of 30 to 35 boards per minute require the use of solvents that evaporate
without leaving cure blisters and without leaving residual solvent in the coating film or
substrate. The substrate can be hardboard, plywood, medium density fiberboard (MDF), or
particleboard.
2. Exterior Siding
Exterior siding may be made of solid wood, hardboard, or waferboard. Siding made
of solid wood and hardboard is typically primed at the manufacturing facility and finished in
the field, although some finishing may be performed during manufacturing on a limited
basis. Field-applied coatings are not subject to this CTG. Exterior trim (material made out
of siding panels and used for edges and corners around the siding) is typically manufactured
at the same facility and coated with the same coatings as siding.
This industry segment involves exterior products that must have coatings able to
withstand extreme and long-term weather conditions. These requirements impact the
amount of VOC emitted from the coating of exterior siding.
3. Tileboard
Tileboard is a premium interior wall paneling product made of hardboard that is used
in high moisture areas of the home such as kitchens and bathrooms. Specifically, tileboard
meets the specifications for Class I hardboard as approved by the American National
Standards Institute. The standard specifies requirements and test methods for water
absorption, thickness swelling, modulus of rupture, tensile strength, surface finish,
dimensions, squareness, edge straightness, and moisture content for five classes of
hardboard.
Product specifications for tileboard are established by consensus standards.
Tileboard has more stringent product performance requirements (i.e., adhesion and hardness
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standards, household stain, scrub and moisture resistance, while maintaining a relative
smooth surface) compared to standard interior wall paneling.
B. Sources of VOC Emissions
Flat wood paneling, like most wood products, are vulnerable to light, moisture and
insects. Coatings are used for three principal purposes: protection, appearance, and surface
modification. Surface coatings are applied to reduce potential damage from environmental
elements such as moisture and temperature extremes and other climate-related hazards and
from insect infestation. Coatings are also applied to enhance surfaces to make other
coatings more effective. Finally, coatings are applied to improve the appearance of the
wood product. Releases of VOC occur during the coating process as the coatings are mixed
or thinned, as they are applied to the substrate, and as they dry and the VOC within the
coating evaporate into the air.
A typical flat wood coating facility applies stains and varnishes to natural plywood
panels used for wall coverings. Other plants print wood grain patterns on particle board
panels that were first undercoated with an opaque coating to mask the original surface.
Coatings applied to flat wood paneling include fillers, sealers, "groove" coats, primers,
stains, basecoats, inks and topcoats. Most coatings are applied by direct roll coating. Filler
is usually applied by reverse roll coating. The offset rotogravure process is used where the
coating and printing operation requires precision printing techniques. Other coating
methods include spray techniques, brush coating and curtain coating. A typical flat wood
paneling coating line includes a succession of coating operations. Each individual operation
consists of the application of one or more coatings followed by a heated oven to cure the
coatings. A typical production line begins with mechanical alterations of the substrate
(filling of holes, cutting of grooves, sanding, etc.), followed by the coating operations, and
packaging/stacking for shipment.
Emissions of VOC from a flat wood coating facility occur primarily at the coating
line, although some emissions also occur at paint mixing and storage areas. To assist
facilities and regulatory agencies in estimating emissions, VOC emission factors for
conventional solvent based coatings applied to interior printed panels are as follows
(expressed as kilograms of VOC per 100 m2 coated): 3.0 for filler, 0.5 for sealer, 2.4 for
basecoat, 0.3 for inks, and 1.8 for topcoats.1
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V. Available Controls and State and Local Regulatory Approaches
A. Available Controls
1. Low- VOC Coatings
The use of low-VOC, waterborne coatings has increased since 1978. Paint
manufacturers have developed and are continuing to develop waterborne coating
formulations that replace conventional organic solvent-borne coatings. These coatings are
generally available and often are not produced and marketed specifically for the flat wood
paneling industry. Conversion to waterborne coatings can lower VOC emissions greatly,
and most coatings operations are capable of converting to waterborne coatings.
2. Ultraviolet Cure and Electron Beam Cure Coatings
A process change that is an alternative to waterborne coatings is the use of coatings
that cure by ultraviolet (UV) light. This technology is gaining greater acceptance and,
where applicable, achieves a near 100 percent reduction of VOC emissions. In the flat wood
paneling industry, UV systems have been found useful on specialty coatings operations. UV
curing is extremely fast usually taking approximately 10 seconds. UV coatings are found
only in the application of clear to semitransparent filler and topcoats for paneling and
cabinetry products. Opaque UV coatings are not available for the flat wood paneling
industry; however, electron beam (EB) cure systems can use opaque coatings and are
available for use in the flat wood paneling industry. Over 99 percent reduction can be
achieved by using EB cure coatings, but the costs of both the cure system and coatings
themselves limit the applicability of this technique at this time.1
3. Add-On Controls
For applications where performance requirements or other needs dictate the use of
high-VOC coatings, flat wood paneling coaters can employ add-on controls to reduce their
VOC emissions. Currently, an overall control and capture efficiency of 90 percent is a
widely-accepted and readily available technique.
4. Work Practices
Another effective means to reduce VOC emissions associated with flat wood
paneling coatings is the implementation of work practice standards. Work practice
standards that have proven particularly effective include: (1) frequent visual inspections for
all equipment used to transfer or apply coatings, adhesives, or organic solvents; (2) cleaning
and wash off solvent accounting system; (3) collecting and containing all VOCs when
cleaning coating lines and spray guns; and (4) using low-VOC or low-vapor pressure
cleaning materials.
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To provide structure and consistency to their work practices, facilities can develop
and implement a work practice plan. Such a plan is a compliance option under the 2003
NESHAP for Surface Coating of Wood Building Products and is equally applicable to VOC
emissions. The work practice plan is a proven and traditional approach for cleaning that is
easily adopted and managed by various industries, including flat wood paneling coatings.
The work practice plan sets forth the steps to be taken to ensure that work practices are
implemented properly and that VOC emissions are minimized from mixing operations,
storage tanks and other containers, and handling operations for coatings, thinners, cleaning
materials, and waste materials.
B. The 1978 CTG and Existing State and Local Regulatory Approaches
1. Summary of the 19 78 Flat Wood Paneling CTG Document
The 1978 CTG recommends emission limits for flat wood paneling surface coating
operations. Table 1 summarizes these limits, which are expressed in pounds of VOC
emitted per 1,000 square feet (Ib VOC/1,000 ft2) of coated surface. These limits could be
achieved by either using coatings with VOC contents low enough to achieve these limits
during application, or by reducing the amount of VOCs emitted through the use of add-on
controls. Because the 1978 RACT recommended emission limit could be met by using
coatings with sufficiently low VOC content to meet the limit, Table 1 also presents the
equivalent VOC coating limit expressed as pounds of VOC per gallon of coating, less water
and exempt compounds (Ib VOC/gal-water-exempt compounds). The pounds of VOC per
gallon of coating is the VOC content of a coating, taking into account such factors as coating
coverage rate and solids content, that is expected to achieve the emission limitation (Ib
VOC/1,000 ft2). The equivalent coating limit is especially useful in the context of this CTG,
because it allows for comparison between the 1978 RACT recommended limit and the
current Placer County and South Coast requirements discussed later in this section.
Table 1. 1978 RACT Limits for Factory Surface Coating of Flat Wood Paneling
Product
Printed interior wall panels made of hardwood
plywood and thin particleboard
Natural finish hardwood plywood panels
Class II hardboard panels
Emission rate limit,
pound VOC per 1000
square feet coated surface
(Ib VOC/1,000 ft2)
6.0
12.0
10.0
Equivalent coating limit,
pound VOC per gallon of
coating , less water
and less exempt compounds
(Ib VOC/gal-water-exempt
compounds)
2.5
3.3
3.6
As indicated in Table 1, the 1978 CTG recommends emission limits for only three
categories of flat wood paneling products. Other significant categories of factory finished
flat wood paneling products, exterior siding, and tileboard, were not reviewed during
preparation of the 1978 CTG. Consequently, emission limits for these product categories
were not recommended in that document.
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2. Summary of Existing State and Local VOC Requirements
At least 28 State and local jurisdictions have regulations that control VOC emissions
from surface coating operations that include flat wood paneling. Most of these regulations
are general surface coating rules; a few are specific to flat wood paneling. Appendix B lists
the jurisdictions where the 24 facilities that meet the applicability criterion in this CTG are
located.
Almost all of the jurisdictions that specifically address flat wood paneling have
based their rules on the 1978 CTG. However, there are two jurisdictions in California that
have requirements specific to flat wood paneling that go beyond the 1978 CTG. In Placer
County, VOC emissions from flat wood paneling operations in a nonattainment area are
limited to 250 g VOC/1 (2.1 Ib VOC/gal) of coating (excluding water and exempt
compounds) or the overall control device efficiency must be at least 90 percent (see
Appendix B).
The South Coast rule defines flat wood paneling as "interior wood panels and
exterior wood siding, which include, by way of illustration and not limitation, redwood,
cedar or plywood stocks, plywood panels, particle boards, composition hard boards, and any
other panels or siding constructed of solid wood or a wood-containing product." The
emissions limit established by the South Coast rule is identical to the emission limit
established by Placer County, and also covers exterior siding, which the Placer County rule
does not.
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VI. Recommended Control Options
Based on a review of the recommendations in the 1978 CTG, the current State and
local requirements discussed above, and the 2003 NESHAP, we recommend emission limits
for the inks, coatings and adhesives used by the flat wood paneling coating facilities and
work practices for cleaning materials used.
The recommended emission limits for inks, coatings, and adhesives can be achieved
either by using materials with VOC contents low enough to achieve the limits during
application, or by reducing the amount of VOC emitted through the use of add-on controls.
There are two alternative limits recommended for the use of low VOC inks, coatings and
adhesives. These limits are expressed in different units, but are equivalent. Table 2
summarizes the VOC emission limits recommended in this CTG.
A. Emissions Limit based on Low-VOC Coatings for Inks, Coatings and
Adhesives
The low-VOC materials recommendation for inks, coatings and adhesives include an
emissions limit of 250 g VOC/1 (2.1 Ib VOC/gal) of material (minus water and exempt
compounds). An equivalent limit, expressed as units of weight of VOC per volume of solids
in all coatings would is 350 grams of VOC per liter solids (2.9 Ib of VOC per gal of solids).
The default VOC density used for making this conversion was 0.88 kg/liter (7.36 Ib/gal).
B. Optional Add-On Controls for Inks, Coatings and Adhesives
Should product performance requirements or other needs dictate the use of higher-
VOC coatings than specified above, a facility could choose to use add-on control equipment
to meet an overall control efficiency of 90 percent. Add-on devices include oxidizers and
solvent recovery systems, which coupled with their attendant systems to capture the VOC
being released at the affected facilities, can achieve an overall control efficiency of 90
percent. This control option, like the low-VOC material option noted above, applies to
surface coatings, inks, and adhesives applied to all types of flat wood paneling.
C. Work Practices
This CTG also recommends work practices for use in all flat wood paneling coating
facilities meeting the applicability threshold noted above. We recommend that the work
practice plan include steps to ensure that VOC emissions are minimized from mixing
operations, storage tanks and other containers, and handling operations for coatings,
thinners, cleaning materials, and waste materials. Examples of work practice standards
include: storing all VOC coatings, thinners, and cleaning materials in closed containers,
minimizing spills of VOC containing coatings, thinners, cleaning up spills immediately,
conveying any coatings, thinners, and cleaning materials in closed containers or pipes,
closing mixing vessels which contain VOC coatings and other materials except when
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specifically in use, and minimizing emissions of VOC during cleaning of storage, mixing,
and conveying equipment.
Table 2. Recommended Emission Limits for Flat Wood Paneling Coating Operations
Surface Coatings, Inks, or Adhesives
Applied to the Following Flat Wood
Paneling Categories
Printed interior panels made of
hardwood, plywood, or thin
particleboard
Natural finish hardwood plywood
panels
Class II finishes on hardboard panels
Tileboard
Exterior siding
Should Meet One of These Emission Limits:
Ib VOC per
gallon material
(grams VOC per
liter material)
[excluding water
and exempt
compounds ]
2.1 (250)
2.1 (250)
2.1 (250)
2.1(250)
2.1 (250)
Ib VOC per
gallon solids
(grams VOC per
liter solids)
2.9 (350)
2.9 (350)
2.9 (350)
2.9 (350)
2.9 (350)
Overall Control
Efficiency Using an
Add-On Control
Device:
90%
90%
90%
90%
90%
We also recommend that those facilities that meet the applicability threshold noted above follow work
practice standards.
VII. Cost Effectiveness of Recommended Control Options
Cost-effectiveness estimates were determined based on South Coast district studies
and on studies performed by EPA during development of the 2003 NESHAP.
Effective January 1, 2000, a new VOC limit was proposed for flat wood paneling
facilities in the South Coast Air Quality Management District of California. The new
regulation reduced the allowable VOC content for inks from 2.5 pounds per gallon (300
grams per liter) to 2.1 pounds per gallon (250 grams per liter) and reduced the allowable
VOC content for exterior siding coatings from 2.9 pounds per gallon (350 grams per liter) to
2.1 pounds per gallon (250 grams per liter). At the time of proposal of the South Coast rule,
there were two facilities in the district that would be affected by the regulation changes.
One facility manufactured interior paneling and the other manufactured exterior siding.
Only the exterior siding facility was not in compliance with the new limits. As part of the
South Coast proposal, a cost effectiveness analysis was performed for the facility. It was
determined that the facility could switch to two lower-VOC stains for an annual cost of
$3,200 and reduce VOC emissions by 2,900 pounds per year (1.45 tons per year), which has
a cost-effectiveness of approximately $2,200/ton in 2000 dollars. The facility applying
coatings to exterior siding is believed to be representative of most exterior siding facilities.
The surface coating of wood building products NESHAP applies to various
operations, including flat wood paneling coatings. The NESHAP sets requirements for
emissions of hazardous air pollutants (HAP) and includes the use of low-HAP material as a
compliance option. The majority of HAP are VOCs. In developing the NESHAP, EPA
estimated in 1998 dollars, the cost-effectiveness of using low-HAP materials. The facilities
10
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used in developing the NESHAP were also analyzed for VOC emissions so the cost
effectiveness is described in terms of HAP and VOC. The cost of compliance for six
facilities in the interior wall paneling and tileboard category was estimated to be $760,000
and result in VOC reductions of 480 tons ($1,600 per ton of VOC) in 1998 dollars.7
Using the Marshall and Swift Index, the costs in 1999 and 1998 dollars, respectively,
were scaled to estimate 2005 dollars. The resulting cost effectiveness estimate, in 2005
dollars, for the California flat wood paneling facility that manufactures exterior siding is
$2,600 per ton of VOC. Escalating the NESHAP figures to 2005 dollars, the cost
effectiveness is $1,900 per ton of VOC for interior paneling/tileboard. The cost
effectiveness of controls for exterior siding operations could vary substantially for facilities
already complying with the 2003 NESHAP. When developing their requirements for the
exterior siding operations, States should consider the impacts of such measures on facilities
already subject to the NESHAP.
VIII. References
1. Control of Volatile Organic Emissions from Existing Sources - Volume VII: Factory
Surface Coating of Flat Wood Paneling. Publication No. EPA-450/2-78-032. U. S.
Environmental Protection Agency, Research Triangle Park, NC. June 1978.
2. Guidance to State and Local Agencies in Preparing Regulations to Control Volatile
Organic Compounds from Ten Stationary Source Categories. EPA-450-2-79-004.
U. S. Environmental Protection Agency, Research Triangle Park, NC. September
1979.
3. Placer County (California) Air Quality Management District Rule 238, Factory
Coating of Flat Wood Paneling. Amended August 14, 1997.
4. 1972 Census of Manufacturers, United States Bureau of Census, Vol. II, Industry
Statistics, Part I. SIC 20-26, 2431, 2435, 2436, 2493, 2496
5. Flat Wood Paneling Surface Coating Plants. In: Directory of Volatile Organic
Compound Sources Covered by Reasonably Available Control Technology (RACT)
Requirements, Volume II: Group II RACT Categories, EPA 450/4-81-0075, U. S.
Environmental Protection Agency, Research Triangle Park, NC. February 1981.
6. Control Techniques for Volatile Organic Compound Emissions from Stationary
Sources. Publication No. EPA-453/R-92-018. U. S. Environmental Protection
Agency, Research Triangle Park, NC. December 1992.
7. Background Information Document for NESHAP for the Wood Building Products
(Surface Coating Industry). EPA-453/ROO-003. U. S. Environmental Protection
Agency, Research Triangle Park, NC. May 2001.
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12
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Appendix A
United Slilsi Mice of fit anility EPA-4aO/l-7B-03I
Environmental Praiacften Plannini »ncl SturnUnd* QAQPS No. 1.Z-11Z
Ag, nty tosearcn Tns njl* -Rs.k .1C 27711 June 1978
Air
Guideline Series
Control of Volatile
Organic Emission^
from Existing
Stationary Sources
Volume VII: Factory
Surface Coating of
Flat Wood Paneling
Prc-r
IMA UBRMW SERVICES BfTP NC
TECHNICAL CXKUWENT CCK— ECTION
13
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14
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Appendix B
Flat Wood Paneling Coating Facilities in Current Nonattainment Areas and
Associated State or Local Requirements (Based on 2002 NEI)
Ozone
Nonattainment
Area
Placer County
(California)
Michigan
North Carolina
Ohio
South Carolina
Texas
Virginia
Indiana
Tennessee
Illinois
Pennsylvania
New Hampshire
Wisconsin
Number
of
Facilities
1
1
1
1
1
2
1
3
1
1
8
2
1
Product Applicability
1978 CTG
Not applicable to exterior siding.
Interior paneling.
Not applicable to exterior siding,
cabinetry, furniture or tileboard.
1978 CTG
Not applicable to exterior siding and
tileboard.
No rule specific to flat wood, wood
building products or tileboard.
Wood construction products for
interior paneling
Not applicable to exterior siding and
tileboard.
Interior paneling and tileboard
Not applicable to exterior siding.
Interior panels
Not applicable to exterior siding and
tileboard.
Interior panels
Not applicable to exterior siding and
tileboard.
Interior paneling
Not applicable to exterior siding and
tileboard.
None
None
None
1978 CTG Limits
Not applicable to exterior siding and
tileboard.
Applicable State
Emission Limit
<2.11bVOCper
gallon of coating
(excluding
water)
1978 CTG
Limits
1978 CTG
Limits
1978 CTG
Limits
1978 CTG
Limits
1978 CTG
Limits
1978 CTG
Limits
1978 CTG
Limits
1978 CTG
Limits
None
None
None
1978 CTG
Limits
Alternative
Control
Device Limits
Overall control
efficiency of
90%
1978 CTG
Limits
1978 CTG
Limits
1978 CTG
Limits
1978 CTG
Limits
1978 CTG
Limits
1978 CTG
Limits
1978 CTG
Limits
1978 CTG
Limits
None
None
None
1978 CTG
Limits
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Appendix C
Estimated Costs Associated with the Recommendations Contained in the Control
Techniques Guideline for Flat Wood Paneling Coating
I. Introduction
This appendix presents the estimated costs associated with implementing the
recommendations in the Control Techniques Guidelines (CTG) for controlling volatile
organic compounds (VOC) emissions from flat wood paneling surface coating facilities in
ozone nonattainment areas. The CTG contains guidance for State and local pollution control
agencies to use in determining reasonably available control technology (RACT) for VOC
emissions from flat wood paneling coatings. State and local agencies are free to adopt the
recommendations contained in the CTG or to implement other technically-sound approaches
for RACT, provided these approaches are consistent with the Clean Air Act (CAA) and EPA
implementation regulations. Accordingly, there is necessarily some uncertainty in any
prediction of costs and emission impacts associated with the recommendations contained in
the CTG. For purposes of this analysis, we assume that all states will adopt the
recommendations of the CTG.
According to the 2002 National Emissions Inventory (NEI), there are 24 flat wood
paneling facilities in the United States that are located in ozone nonattainment areas (based
on April 2006 designations). These facilities emit greater than 15 pounds VOC per day
from flat wood paneling surface coating operations and will possibly be affected by the
CTG.
II. Cost Analysis
The 24 flat wood paneling facilities are found in thirteen states. Nine of the states
have state regulations that currently affect VOC emissions from interior panels, but not
tileboard or exterior siding. These nine state regulations recommend the same compliance
options as are recommended in the CTG. By contrast, the CTG provides recommendations
for interior paneling, tileboard, and exterior siding. In the remaining four states, there are
currently no state regulations that affect flat wood paneling product facilities.
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To determine the overall expected costs, the facilities were researched to determine
the product types at each of the 24 facilities. Fifteen facilities were roughly identified as
interior product producers (interior panels, tileboard) and nine facilities were roughly
identified as exterior product producers (exterior siding). These product types were
compared to the current flat wood paneling state regulations (if any) to determine whether or
not the facility could be financially affected by the CTG. If the product type at the facility is
covered by a state regulation, the facility is assumed to be in compliance with the limits in
the CTG and have no costs.
Costs could be associated with 12 facilities from Illinois, New Hampshire, Michigan,
and Pennsylvania. If these states adopt the recommendations from the CTG, costs could be
incurred to make changes to their coatings in order to meet the recommendations of the
CTG. The facilities in these four states include two interior panel facilities, one tileboard
facility, and nine exterior siding facilities.
The costs of compliance for the 12 identified facilities were based on the cost
effectiveness calculations in the CTG, which are $2,600 per ton of VOC reduced from
exterior siding facilities and $1,900 per ton of VOC reduced from interior paneling and
tileboard facilities. To estimate the cost for implementing the recommendations of the CTG
for exterior siding, we used the cost effectiveness estimate from South Coast AQMD
($2,600 per ton of VOC), as opposed to the higher number associated with the NESHAP
(i.e., $4,400 per ton). We believe the South Coast AQMD estimate is more realistic because
it is based on actual VOC reduction and conversion costs from a specific facility, whereas
the NESHAP estimates were based on average coating usages and average coating costs.
The amount of VOC reduced was based on the VOC emissions in the 2002 NEI
database attributed to flat wood product surface coating (according to the SCC). To
calculate the emission reductions, an overall percent reduction was used for each of the
twelve facilities. For interior paneling products and tileboard in the NESHAP, VOC
emissions were reduced by an average of 60 percent for all facilities. For exterior siding
products in the NESHAP, VOC emissions were reduced by an average of 91 percent for all
facilities. Emission reduction estimates for exterior siding products were also performed as
part of the cost effectiveness analysis conducted in South Coast AQMD. The analysis
showed a reduction of VOC emissions by an average of 87 percent. To maintain the most
realistic estimate of exterior siding costs, we used the real facility reduction associated with
South Coast AQMD (87 percent), as opposed to the higher percent reduction estimate from
the NESHAP (91 percent). The cost effectiveness of controls for exterior siding operations
could vary substantially for facilities already complying with the 2003 NESHAP. When
developing their requirements for the exterior siding operations, States should consider the
impacts of such measures on facilities already subject to the NESHAP. The respective
percent reductions for the two product types were assumed to be true for the 12 identified
facilities in nonattainment areas possibly affected by the CTG.
The overall cost anticipated for the twelve facilities is $1.2 million, with an average
cost per facility of $101,000 and an average VOC reduction of 77 percent. The data are
shown in Table C-l.
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Table C-l. Cost Summary for Flat Wood Product Surface Coating Facilities
Number of facilities in ozone nonattainment areas
Number of facilities that could incur costs to
comply with CTG
VOC emissions from 2002 NEI (tons)
Percent reduction expected
Amount of VOC emissions reduced (tons)
Cost of CTG implementation ($/ton VOC reduced)
Total costs
Interior panels/tileboard
facilities
15
3
297 tons
60%
178 tons
$1,900
~ $339,000
Exterior siding
facilities
9
9
368 tons
91%
335 tons
$2,600
~ $871,000
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United States Office of Air Quality Planning and Standards Publication No. EPA 453/R-06-004
Environmental Protection Sector Policies and Programs Division
Agency Research Triangle Park, NC September 2006
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