**DRAFT**

**DRAFT CONTROL TECHNIQUES GUIDELINE FOR**

**FLAT WOOD PANELING COATING**

**AUGUST 2006**

**US EPA**

**OAQPS**

**RTP NC 27711**

**TABLE OF CONTENTS**

I. Introduction
.............................................................Page 3

II\. Background and Overview
............................................Page 4

> III\. Applicability
> ............................................................Page 5

IV\. Process Description and Sources of VOC Emissions ..............Page
6

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 7
>
> 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 10

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
     11

VIII. References
      ................................................................Page
      12

> Appendix A
>
> 1978 CTG for Flat Wood Paneling
> .............................................Page 14
>
> Appendix B
>
> State and local regulations for flat wood paneling
> .........................\...Page 15

**I. [Introduction]{.underline}**

Clean Air Act (CAA) section 172(c)(1) 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 draft 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. EPA solicits comment on all aspects of this draft document.

Once finalized, 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. 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

The recommendations contained in this draft 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)(1) may take action in response to
this guidance, as necessary to attain.

**II. [Background and Overview]{.underline}**

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 1978 CTG is included as Appendix A
to this draft 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
requirements found in the 1978 CTG and in the Placer County and South
Coast rules is presented in Section V of this document.

The remainder of this document is divided into six sections. The first
section describes the scope of sources to which this CTG applies. The
second section provides a description of the flatwood paneling industry
and its products and processes and identifies the sources of VOC
emissions from those processes. The third section describes the
available control approaches for addressing VOC emissions from this
source category and summarizes state and local regulatory approaches for
addressing such emissions. The fourth section provides our proposed
recommendations for RACT for flat wood paneling coatings. The fifth
section discusses the cost-effectiveness of the recommended control
approaches. The final section contains a list of references.

The September 1979 guidance includes a model RACT rule for flat wood
paneling coatings. This model rule provides a general organizational
framework for States to use in developing their own state rules
implementing RACT for flat wood paneling coating and includes sample
regulatory language. We are considering including a similar example rule
when we finalize this draft CTG, and such rule would incorporate the
recommendations contained in the final CTG. We are still evaluating,
however, the utility of such a rule. We solicit comment on whether an
example rule that incorporates the RACT recommendations contained in the
final CTG would be useful.

**III. [Applicability]{.underline}**

This draft CTG applies to facilities that apply flat wood paneling
coatings that emit at least 6.8 kg/day (15 lb/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 lb/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 lb/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
lb 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 is a table showing 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 2 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.

**IV. [Process description and Sources of VOC Emissions]{.underline}**

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 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 m^2^ coated): 3.0 for filler, 0.5
for sealer, 2.4 for basecoat, 0.3 for inks, and 1.8 for topcoats.^1^

**V. [Available Controls and State and Local Regulatory
Approaches]{.underline}**

A. [Available Controls]{.underline}

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.

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 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]{.underline}

## 1. *Summary of the 1978 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 (lb VOC/1,000 ft^2^) 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 (lb
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 (lb VOC/1,000 ft^2^). The equivalent coating
limit is especially useful in the context of this draft 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                        | Emission rate    | Equivalent       |
|                                | limit,           | coating limit,   |
|                                |                  |                  |
|                                | pound VOC per    | pound VOC per    |
|                                | 1000 square feet | gallon of        |
|                                | coated surface   | coating , less   |
|                                |                  | water            |
|                                | (lb VOC/1,000    |                  |
|                                | ft^2^)           | and less exempt  |
|                                |                  | compounds (lb    |
|                                |                  | VOC/             |
|                                |                  | gal-water-exempt |
|                                |                  | compounds)       |
+--------------------------------+------------------+------------------+
| Printed interior wall panels   | 6.0              | 2.5              |
| made of hardwood plywood and   |                  |                  |
| thin particleboard             |                  |                  |
+--------------------------------+------------------+------------------+
| Natural finish hardwood        | 12.0             | 3.3              |
| plywood panels                 |                  |                  |
+--------------------------------+------------------+------------------+
| Class II hardboard panels      | 10.0             | 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.

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 draft 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/l (2.1 lb 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.

**VI. [Recommended Control Options]{.underline}**

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 draft CTG.

> A. [Emissions Limit based on Low-VOC Coatings for Inks, Coatings and
> Adhesives]{.underline}

The low-VOC materials recommendation for inks, coatings and adhesives
include an emissions limit of 250 g VOC/l (2.1 lb 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 lb of VOC per gal of solids). The
default VOC density used for making this conversion was 7.36 lb/gal
(0.88 kg/liter).

B. [Optional Add-On Controls for Inks, Coatings and
Adhesives]{.underline}

Should 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]{.underline}

The draft 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 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,     | **Should    |              |              |
| Inks, or Adhesives      | Meet One of |              |              |
| Applied to the          | These       |              |              |
| Following Flat Wood     | Emission    |              |              |
| Paneling Categories**   | Limits:**   |              |              |
+-------------------------+-------------+--------------+--------------+
|                         | **lb VOC    | **lb VOC     | **Overall    |
|                         | per**       | per**        | Control      |
|                         |             |              | Efficiency   |
|                         | **gallon    | **gallon     | Using an     |
|                         | material**  | solids**     | Add-On       |
|                         |             |              | Control      |
|                         | **(grams    | **(grams VOC | Device:**    |
|                         | VOC per**   | per**        |              |
|                         |             |              |              |
|                         | **liter     | **liter      |              |
|                         | material)** | solids)**    |              |
|                         |             |              |              |
|                         | **          |              |              |
|                         | \[excluding |              |              |
|                         | water and   |              |              |
|                         | exempt      |              |              |
|                         | compounds   |              |              |
|                         | \]**        |              |              |
+-------------------------+-------------+--------------+--------------+
| Printed interior panels | 2.1 (250)   | 2.9 (350)    | 90%          |
| made of hardwood,       |             |              |              |
| plywood, or thin        |             |              |              |
| particleboard           |             |              |              |
+-------------------------+-------------+--------------+--------------+
| Natural finish hardwood | 2.1 (250)   | 2.9 (350)    | 90%          |
| plywood panels          |             |              |              |
+-------------------------+-------------+--------------+--------------+
| Class II finishes on    | 2.1 (250)   | 2.9 (350)    | 90%          |
| hardboard panels        |             |              |              |
+-------------------------+-------------+--------------+--------------+
| Tileboard               | 2.1 (250)   | 2.9 (350)    | 90%          |
+-------------------------+-------------+--------------+--------------+
| Exterior siding         | 2.1 (250)   | 2.9 (350)    | 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**]{.underline}

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 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 as a compliance option the use of low-HAP materials. The
majority of organic HAP are VOCs. In developing the NESHAP, EPA
estimated in 1998 dollars, the cost-effectiveness of using low-HAP
materials. The cost of compliance for facilities in the interior wall
paneling and tileboard category was estimated to be \$2.59 million and
result in VOC reductions of 480 tons (\$1,600 per ton of VOC). The cost
of compliance for six facilities in the exterior siding subcategory was
estimated to be \$760,000 and result in VOC reductions of 690 tons
(\$3,700 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 \$4,400 per ton of VOC for exterior siding and \$1,900
per ton of VOC for interior paneling/tileboard.

Due to higher estimated cost for a given amount of emission reductions
from exterior siding, and because exterior siding is not covered by the
1978 CTG, EPA solicits comments on whether it is appropriate to exclude
exterior siding from applicability of the draft CTG.

**VIII. [References]{.underline}**

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/R00-003. U. S.
    Environmental Protection Agency, Research Triangle Park, NC. May
    2001.

**Appendix A**

> ![](media/image1.wmf)

**Appendix B**

Flat wood Paneling Coating Facilities in Current Nonattainment Areas and
Associated State or Local Requirements (Based on 2002 NEI)

+------------+--------+-------------------+------------+-------------+
| **Ozone    | **     | **Product         | **         | **          |
| Non        | Number | Applicability**   | Applicable | Alternative |
| attainment | of     |                   | State      | Control     |
| Area**     | Facili |                   | Emission   | Device      |
|            | ties** |                   | Limit**    | Limits**    |
+------------+--------+-------------------+------------+-------------+
| Placer     | 1      | 1978 CTG          | \<2.1 lb   | Overall     |
| County     |        |                   | VOC per    | control     |
| (C         |        | Does not include  | gallon of  | efficiency  |
| alifornia) |        | Exterior Siding   | coating    | of 90%      |
|            |        |                   | (excluding |             |
|            |        |                   | water)     |             |
+------------+--------+-------------------+------------+-------------+
| Michigan   | 1      | Interior          | 1978 CTG   | 1978 CTG    |
|            |        | paneling.         | Limits     | Limits      |
|            |        |                   |            |             |
|            |        | Does not include  |            |             |
|            |        | exterior siding,  |            |             |
|            |        | cabinetry,        |            |             |
|            |        | furniture or      |            |             |
|            |        | tileboard.        |            |             |
+------------+--------+-------------------+------------+-------------+
| North      | 1      | 1978 CTG          | 1978 CTG   | 1978 CTG    |
| Carolina   |        |                   | Limits     | Limits      |
|            |        | Does not include  |            |             |
|            |        | Exterior Siding   |            |             |
|            |        | and tileboard.    |            |             |
+------------+--------+-------------------+------------+-------------+
| Ohio       | 1      | No rule specific  | 1978 CTG   | 1978 CTG    |
|            |        | to flat wood,     | Limits     | Limits      |
|            |        | wood building     |            |             |
|            |        | products or       |            |             |
|            |        | tileboard.        |            |             |
+------------+--------+-------------------+------------+-------------+
| South      | 1      | Wood construction | 1978 CTG   | 1978 CTG    |
| Carolina   |        | products for      | Limits     | Limits      |
|            |        | interior paneling |            |             |
|            |        |                   |            |             |
|            |        | Does not exclude  |            |             |
|            |        | exterior siding   |            |             |
|            |        | and tileboard     |            |             |
+------------+--------+-------------------+------------+-------------+
| Texas      | 2      | Interior paneling | 1978 CTG   | 1978 CTG    |
|            |        | and tileboard     | Limits     | Limits      |
|            |        |                   |            |             |
|            |        | Not applicable to |            |             |
|            |        | exterior siding   |            |             |
+------------+--------+-------------------+------------+-------------+
| Virginia   | 1      | Interior panels   | 1978 CTG   | 1978 CTG    |
|            |        |                   | Limits     | Limits      |
|            |        | Does not exclude  |            |             |
|            |        | exterior siding   |            |             |
|            |        | and tileboard     |            |             |
+------------+--------+-------------------+------------+-------------+
| Indiana    | 3      | Interior panels   | 1978 CTG   | 1978 CTG    |
|            |        |                   | Limits     | Limits      |
|            |        | Not applicable to |            |             |
|            |        | exterior siding   |            |             |
|            |        | and tileboard.    |            |             |
+------------+--------+-------------------+------------+-------------+
| Tennessee  | 1      | Interior paneling | 1978 CTG   | 1978 CTG    |
|            |        |                   | Limits     | Limits      |
|            |        | Not applicable to |            |             |
|            |        | exterior siding   |            |             |
|            |        | and tileboard.    |            |             |
+------------+--------+-------------------+------------+-------------+
| Illinois   | 1      | None              | None       | None        |
+------------+--------+-------------------+------------+-------------+
| Pe         | 8      | None              | None       | None        |
| nnsylvania |        |                   |            |             |
+------------+--------+-------------------+------------+-------------+
| New        | 2      | None              | None       | None        |
| Ha         |        |                   |            |             |
| mpshire\-- |        |                   |            |             |
+------------+--------+-------------------+------------+-------------+
| Wisconsin  | 1      | 1978 CTG Limits   | 1978 CTG   | 1978 CTG    |
|            |        |                   | Limits     | Limits      |
|            |        | Not applicable to |            |             |
|            |        | exterior siding   |            |             |
|            |        | and tileboard.    |            |             |
+------------+--------+-------------------+------------+-------------+