EPA 453/R-06-004 Septem ber 2006



# Control Techniques Guidelines for Flat Wood Paneling CoatingsThis page intentionally left blank.

iiEPA 453/R-06-004 Septem ber 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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ivTABLE OF CONTENTS

I. Introduction.................................................................................. Page 1

II. Background and Overview

.......................................................... Page 2

III. Applicability

................................................................................ Page 3

IV. Process Description and Sour ces of VOC Emissions

.................. Page 4 A. Types of Flat W ood Paneling 1. Decorative Interior Panels 2. Exterior Siding 3. Tileboard B. Source of VOC Em i ssions

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. W o rk Practices B. The 1978 CTG and Existing State and Local Regulatory Approaches 1. Summ ary of the 1978 Flat Wood Paneling CTG Doc u m e nt 2. Summ ary of Existi ng State and Local VOC Requirem e nts

VI. Recommended Control Options

.................................................. Page 9 A. Em issions L i m it based on Low-VOC Coatings for Inks, Coatings and Adhesives B. Optional Add-On Controls for Inks, Coatings and Adhesives

C. W o rk Pr actices

VII. Cost Effectiveness of Recommended Control Options

............... Page 10

VIII. References

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Appendix A 1978 CTG for Flat W ood Paneling

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Appendix B State and Local Regulations fo r Flat Wood Paneling

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Appendix C Estim ated Costs Associated with th e Recommendations Contained in the Control Techniques Guideline for Flat W ood Pa neling Coating

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viI. Introduction

Clean Air Act (CAA) section 172(c)(1) pr ovides that state implementation plans (SIPs) for nonattainment areas must include “reasonably available control measures” (RACM), including “reasonably available c ontrol technology” (RAC T), for sources of emissions. Section 182(b)(2)(A) provides that for certain nonattainment areas, States must revise their SIPs to include RACT for s ources of VOC emissions covered by a control techniques guidelines (CTG) document issu ed after November 15, 1990 and prior to the area’s date of attainment.

The United States Environmental Protecti on 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 r easonably available considerin g 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 fo r 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 ar eas 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 s ection 183(e) list.

This CTG is intended to provide state and local air pollution control authorities information that should assist them in dete rmining RACT for volatile organic compounds (VOCs) from flat wood pane ling 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 contro l approaches for addressing these emissions, including the costs of such approaches. Based on avai lable information and data, EPA provides recommendations for RACT for flat wood paneling coating.

States can use the recommendations in th is 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 re quirements on any entity. It provides only recommendations for state and local air pollu tion control agencies to consider in determining RACT. State and local pollution c ontrol agencies are free to implement other technically-sound approaches that are consis tent with the CAA and EPA’s implementing regulationsThe recommendations contained in this CTG are based on data and information

curren tly av ailab l e to EP A. These general recom m e ndations m a y not apply to a particular situation based upon the circum stances of a speci fic source. Regardle ss of whether a State chooses to implem e nt the recomm endations contained herein thr ough State rules, or to issue State rules that adopt differe nt approaches for RACT for VOCs from flat wood paneling coating s , Sta t es m u st subm it their RACT rules to EPA for review and a pproval as part of the SIP process. EPA will evaluate the rule s and determ ine, thro ugh notice and comment rulem a king in the SIP process, whether they m eet the RACT requirem e nts of the Act and EPA’s regulations. To the exten t a State adopts any of the recommendations in this guidance into its State R A CT rules, interest ed parties can rais e que stions and objections about the substance of this guidance and the appropriateness of the application of this guidance to a particular situa tion during the developm ent of t h e State rules and EPA’s SIP approval process.

CAA section 182(b)(2) provides that a CTG issued after Novem b er 15, 1990 and before the date of attainm e nt m u st include the date by which States m u st subm it SIP revisions in response to the CTG. St ates su bject to section 182(b) should subm it their SIP revisions within one year of the date of i ssuance of the final CTG for flat wood paneling coatings. States subject to CAA section 172( c)(1) m a y 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 Em issions from Existing S t atio nary S ources, Volum e VII, Factory Surf ace Coating of Flat W o od Paneling,” EPA-450/2-78-034 (Jun e 1978). 1 The cover page of the 1978 CTG is included as Appendix A to this CTG. In Se ptem ber 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 prom ulgated national em ission standards for hazardous air pollutants (NESHAP) covering su rface coating of wood building products (including flat wood paneling). See 68 FR 31746 (May 28, 2003).

At leas t 28 State and lo cal jurisdictions have regulations that control VOC e m issions from surface coating op erations that include fl at wood paneling. Most of these regulations are general surface coating rules; a few are specif ic to flat w ood panelin g. Al m o st 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 re qu ire m ents specif i c to flat wood paneling that g o beyond th e 1978 CTG. These jurisdictions are Placer Cou n ty California A i r Pollution Control District (P lacer County) and Sout h Coast Air Quality Managem e nt District (S outh Coas t). A discussion of the app licab ility a nd contro l o p tions found in the 1978 CTG a nd in the Placer Count y and South Coast rules is presented in Section V of this docum ent.

2The rem a inder of this do cum e nt is divided in to six sections. Section III d e scrib e s th e scope of sources to which this CTG could a pply. Section IV de scribes the flat wood paneling industry along with the types of flat wood products, and identifies the sources of VOC e m issions from fla t wood related processes. Section V describes the available control approaches for addressing VOC e m is sions from t h is source categor y and summarizes state and local regulato r y app r oaches for address i ng such em issions. Section VI provides our

recomm endations for R A CT for flat wood pane ling coatings. Section VII discusses the cost-effectiv eness of the recomm ended contro l approaches. Section VI II contains a list of references.

III. Applicabilit y

This CTG applies to f a c ilitie s tha t a pply f l at wo od paneling coating s tha t em it at least 6.8 kg/day (15 lb/day ) of VOC before consideration of controls. F l at wood paneling coatings m e ans wood paneling products that are any interior, exterior or tileboard (class I hardboard) panel to which a protective, decorati ve, or functional m a terial or layer has been applied.

This threshold of 6.8 kg/day (15 lb/day) is co nsistent with the applicability threshold level contained in m a ny previous final CTGs. It is also cons istent with the purpose of the section 183(e). In section 183(e) , Congress directed EPA to a ssist S t ates in achieving VOC

em ission reductions from consum er and commerc ial products. These products individually

m a y result in relatively sm all a m ounts of VOC em issions but, in the aggregate, they contribute significantly to ozone form ation in nonattainm e nt areas. Give n the nature of the products and sources at issue he re, we believe that the 15 lb/d ay applicability threshold is appropriate.

We used the 2002 National Em ission Inventory (NEI) as the source of em issions data and statistical inform ation concerning the flat w ood paneling industry as a whole. Plants are located throughout the United States, with the P acific Coast and the Southern States having the larges t n u m b ers of facilities. There are appro x im ately 80 f acilities in the United States that produce flat wood paneling products. W e found that there are 24 flat wood paneling coating facilities that m e et the 15 lb of VO C per day applicability threshold for this CTG that are located in current oz one nonattainm e nt areas (based on April 2006 designations) in eight States. Appendix B shows the distributi on of these facilities and the current State and/or local requirem e nts that apply to them . Inform ation on flat wood paneling coatings f acilities in the South Coast ar ea of Calif ornia was not contained in the 2002 NEI database. We have other inform ation, however, which indi cates that there are two flat wood paneling f acilities in the South Coast area. Appendix B does not iden tify these facilities becaus e Appendix B focuses solely on the in form ation we obtained from NEI.

3IV. Process Des cription and Sources of VOC Emissions

A. Types of Flat W ood Paneling

Flat wood paneling products are used in c onstruction and can be classified as three

m a in product types: decorative interior panels, exterior siding, and tileboard.

1. Decorative interior panels

Interior wall paneling is usually groove d, frequently em bossed, and som e tim es grain printed to resem b le various wood species. Inte rior panels are typically m a nufactured at the

sam e facilities as tileboard, although in m u ch s m a ller quantities.

Coated board used for interior panels are subject to industry perform a nce specification s (consensu s standa rds) which have more decora tive coating requirem e nts than other produ c t s. These s t andards r e q u ire m u ltiple coating lay e rs and co ating steps. Production speeds of 30 to 35 boards per m i nute re quire the use of solvents that evaporate without leaving cure b listers and without leaving residual solvent in the coating film or substrate. T h e substrate can be hardboard, pl ywood, m e dium density fi berboard (MDF ), or particleboard.

2

. Exterior Siding

Exterior siding m a y be m a de of solid w ood, hardboard, or w a fer board. Siding m a de of solid wood and hardb o ard is typically p r im ed at the m a nufacturing facility and finis h ed in the field, although som e finishing m a y be perform e d during m a nufacturing on a lim ited basis. Field-applied coatings are not subject to this CTG. Exterior trim (m aterial m a de out of siding panels and used for edges and corn ers around the siding) is typically m a nufactured at the sam e facility and coated w ith the sam e coatings as siding.

This industry segm ent involves exterior produc ts that m u st have coatings able to withstand extrem e and long-term weather c onditions. These requirem e nts impact the

am ount of VOC e m itted from the coating of exterior sid i ng.

3 . Tileboard

Tileboard is a prem ium interior wall paneling product m a de of hardboard that is used in high m o isture areas of the hom e such as kitc hens and bathroom s. Specifically, tileboard

m eets the specifications for Class I hardboa rd as approved by the Am erican National Standards In stitu te. The standard specifie s requirem e nts and test m e thods for water absorption, thickness sw elling, m odulus of r upture, tensile strength, surface finish, dim e nsions, squareness, edge straightness, and m o isture content for five classes of hardboard.

Product specifications for tileboard are established by consensus standards. Tileboard has m o re stringent product perform a nc e requirem e nts (i.e., adhesion and hardness

4standards, household stain, sc rub an d m o isture r e sistance, w h ile m a intaining a re lative

sm ooth surface) com p ared to standard interior wall paneling.

B. Sources of VOC Emissions

Flat wood paneling, like m o st wood products, are vulnerable to light, m o isture and insects. Coatings are used for three principa l purposes: protection, appearance, and surface modification

. Surface co atings are ap plied to redu ce poten tial dam a ge from environmental elem ents such as m o isture and tem p eratu r e ex trem es and other clim ate-related h azard s and from insect infestation. Coatings are also app lied to enhance surfaces to m a ke other coatings m o re effective. Finally, coatings are applied to im prove the appearance of th e wood product. Releases of VOC occur during th e coating process as the coatings are m i xed or thinned, as they are applied to the substr ate, and as they dry and the VOC within the coating evap orate into th e air.

A typical flat wood coating facility applie s stains and varnishes to natural plywood panels used for wall coverings. Other plants print wood grain pattern s on particle board panels that were first undercoated with an opa qu e coating to m a sk the original su rfac e. Coatings applied to flat wood paneling include fillers, sealers, “groove” coats, prim ers, stains, b a secoats, inks an d topcoats. Most co atin gs are app lied by dire ct roll coating. Filler is usually applied by reverse ro ll coating. The offset rotograv ure process is used where the coating and printing operation requires prec ision printing techniques. Other coating

m e thods include spray techniques, brush coati ng and curtain coating. A typical flat wood paneling coating line includes a succession of coating operatio ns. 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 w ith m echanical alterations o f the substrate (filling of holes, cutti ng of grooves, sanding, etc.), followe d by the coating operations, and packaging / stacking for s h ipm e nt.

Em issions of VOC from a flat wood coating facility occur prim arily at the coating line, although som e e m is sions also occur at paint m i xing and storag e areas. To assist facilities an d regulatory agencies in estim ating em issions, VOC e m ission factors for conventional solvent based coatings applied to interior printed panels are as follows (expressed as kilogram s 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

5V. Available Controls and State and Local Regulatory Approaches

A. Available Controls

1. Low-VOC Coatings

The use of low-VOC, waterborne coa tings has increased since 1978. Paint

m a nufacturers have developed and are con tinuing to develop waterborne coating for m ulations that replace conve ntional organic solvent-borne coatings. These coatings are generally available and often are not produced and m a rketed specifically for the flat wood paneling industry. Conversion to waterborne coatings can lower VOC e m issions greatly, and m o st 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 cu re by ultraviolet (UV) light. This techno logy is gain ing greater acceptan ce and, where applicable, achieves a near 100 percent reduction of VOC e m issions. In the f l at wood paneling industry, UV system s have been found us eful on specialty coatings operations. UV curing is extrem ely fast usually taking appr oxim a tely 10 seconds. UV coatings are f ound only in th e a pplica tion of clea r to sem itr anspar ent f iller and to pcoats f o r p a neling and cabinetry products. Opaque UV coatings are not available for the flat wood paneling industry; however, electron beam (EB) cure system s 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 co sts of both the cure system and coatings them selves lim it the applicability of this te chniqu e at th is time. 1

3. Add-On Controls

For applications where perform a nce require m e nts or other needs dictate the use of high-VOC coatings, flat wood pa neling coaters can em ploy add-on controls to reduce their VOC e m issions. Currently, an overall control an d capture efficien cy of 90 percen t is a widely-accepted and readily available technique.

4. Work Practices

Another effective m eans to reduce VOC e m issions associated with flat w ood paneling coatings is the implem e ntation of work practice s t an dards. W o r k practice standards that have proven part icularly effective include: (1) frequent visual inspections for all equ i pm ent used to tr ansf er or apply coatings, adhesives, or organic solven ts ; (2 ) clean ing and wash off solvent accounting system ; (3 ) collecting and co ntain i ng all VOCs when cleaning coating lines and spray guns; and (4 ) using low-VOC or low-vapor pressure clean ing m a terials.

6To provide structure and consistency to th eir work practices, facilities can develop and im ple m ent a work practice plan. Such a plan is a com p liance option under the 2003 NESHAP for Surface Coating of W o od Building Pr oducts an d is equally applicable to VOC

em issions. The work practice plan is a proven a nd trad ition a l approa ch f o r cle a ning that is easily adopted and m a na ged by various industrie s, including flat wood paneling coatings. The work practice plan s e ts forth the steps to be taken to ensure th at work practices are im ple m ented properly and that VOC em issions are m i ni m i zed from m i xing operations, storage tanks and other containe rs, and handling operations fo r coatings, thinners, cleaning

m a terials, an d waste m a terials.

B. The 1978 CTG and Existing State and Local Regulatory Approaches

1. Summary of the 1978 Flat Wood Paneling CTG Document

The 1978 CTG recommends em ission lim its fo r flat wood paneling surface coating operations. Table 1 summ arizes these lim its , which are expressed in pounds of VOC

em itted per 1,000 square feet (lb VOC/1,000 ft 2 ) of coated su rface. Thes e lim its could be achieved by either using coatings with VOC cont ents low enough to achieve these lim its during app l ication, o r by reducing th e am ount of VOCs e m itted through the use of add-on controls. Because the 1978 RACT re comme nded em ission lim it could be m e t by using coating s with suf f i ciently low VOC content to meet th e lim it, Table 1 als o presents th e equivalent VOC coating lim it expressed as pounds of VOC per gallon of coating, less water and exem pt com pounds (lb VOC/gal-water-exe m p t com pounds). The pounds of VOC per gallon of coating is the VOC cont ent of a coating, taking into ac count such factors as coating coverage rate and solids cont ent, that is expec t ed to achieve th e em ission lim itation (lb VOC/1,000 ft 2 ). The equivalent coating lim it is especi ally u s ef ul in the context of th is CTG, because it allows for comparison between the 19 78 RACT recommended lim it and th e current Placer County and South Coast requir ements discussed later in this section.

Table 1. 19 78 RACT Lim its for Factor y Surface Coating of Flat W ood Pa neling

Pr odu ct Emissio n rate li m i t,
p oun d VO C p e r 1 000

square feet c o a t ed s u rface (lb VOC/ 1

, 0 0 0 ft 2 ) Eq ui val e nt c o a t i ng l i m it

, p oun d VO C p e r g a llo n of

co atin g , less water and l e ss e x em pt

com pou nd s (lb VOC/ g al-water-exem p t

com pou nd s)

Pri n t e d i n t e ri or wal l pa nel s m a de of ha rd w o od

p l ywood an d th in p a rticleb o a rd 6. 0 2

. 5

Nat u ral fi ni s h har d wo o d pl y w o o d panel s 12 .0 3. 3

Class I I h a r dboar d p a n e ls 1 0 .0 3

. 6

As indicated in Table 1, the 1978 CTG r ecomm e nds em ission lim its for only three categories of flat wood paneling products. Other significant cat egories of factory finished flat wood paneling products, exterior siding, and tileboar d, were not reviewed during preparation of the 1978 CTG. Cons equentl y, em ission lim i t s for these product categories

were not recomm ended in that docum ent.

72. Summary of Existing State and Local VOC Requirements

At leas t 28 State and lo cal ju risdictions have regulations that control VOC e m issions from surface coating op erations that include fl at wood paneling. Most of these regulations are general surface coating rules; a few are spec ific to flat w ood panelin g. Appendix B lists the ju risd ictions where th e 24 f acilitie s that m eet the applicability criter ion in this CTG are located.

Alm o st all o f the jurisdic tions th at sp ecifically address flat wood paneling have based their rules on the 1978 CTG. However, th ere are two jurisdictions in California that have requ irem ents specific to flat wood pa neling that go beyo nd the 1978 CTG. In Placer County, VOC e m issions from fl at wood paneling operations in a nonattainm ent area are lim ited to 250 g VOC/l (2.1 lb VOC/gal) of coating (excluding water and exem pt

com pounds) or the overall control device effici ency m u st be at least 90 percent (see Appendix B).

The South Coast rule def i nes flat wood paneling as “interior wood panels and exterior wood siding, which include, by way of illustration and not lim itation, redwood, cedar o r ply w ood stocks , plywood panels, partic le boards, co mposition h a rd boards, and any other panels or siding cons tructed of solid wood or a wood-containing product.” The

em issions lim it establish e d by the So uth Coast ru le is identica l to th e em ission lim it estab lished by Placer C ounty, and also covers ex terior sidin g, which the Placer Cou n ty rule does not.

8VI. Recommen d ed Control Options

Based on a review of the recomm endations in the 1978 CTG, the current S t ate and local requirem e nts discussed above, and th e 2003 NESHAP, we recommend em ission lim its for the inks, coatings and adhesives used by the flat wood paneling coating fac ilities and work practices for cleaning m a terials used.

The recommended em ission lim its for inks, co atings, and adhesives can be achieved either by using m a terials with VOC c onten ts low enough to achieve the lim its during application, or by reducing the am ount of VOC e m itted throu gh the use o f add-on controls. There are tw o alternative lim its reco mmended fo r the use of low VOC inks, coatings and adhesives. These lim its are exp r ess e d in di fferent units, but are equivalent. Table 2 summarizes the VOC emission lim its recomm ended in th is CTG.

A. Em issions L i m it based on Low-VOC Coatings for Inks, Coatings and Adhesives

The low-VOC m a terials recomm endation for inks, coatings and adhesives include an

em issions lim it of 250 g VOC/l (2.1 lb VOC/gal ) of m a terial (m inus water and exem pt

com pounds)

. An equivalent lim it, expressed as units of weight of VOC per volum e of solids in all coatings would is 350 gram s of VOC per liter solids (2.9 lb of VOC per gal of solids). The default VOC density used for making th is conversion was 0.88 kg/liter (7.36 lb/gal).

B. Optional Add-On Controls for Inks, Coatings and Adhesives

Should product perform a nce requirem e nts or other needs dictate the use of higherVOC coatings than specified a bove, a facility could choose to use add-on control equipm ent
to m eet an overall control efficiency of 90 percent. Add-on devices include oxidizers and solvent reco very systems, which cou p led with th eir a ttend ant system s to captur e the VOC being releas ed at th e affected facilities, can ach ieve an overa ll control efficiency of 90 percent. This control option, like the lo w-VOC m a terial option noted above, applies to surface coatings, inks, an d adhesives app lied to all types of flat wood paneling.

C. W o rk Practices

This CTG also recomm e nds work practices for use in all flat wood paneling coating facilities m eeting the applicab ility threshold noted above. We recomm end that the work practice p l an include steps to ensure th at VOC em issions are m i nim i zed from m i xing operations, storage tanks and other containers, and handli ng operations for coatings, thinners, cleaning m a terials, and waste m a teri als. Exam ples of wo rk practice standards include: storing all VOC coatings, thinners, and clean ing m a terials in clo s ed containers,

m i ni m i zing spills of VOC containing coatings , thinners, cleaning up spills imm e diately, conveying any coatings, thinners , and cleaning m a terials in cl osed containers or pipes, closing m i xing vessels w h ich contain VOC co atings and other m a terials except when

9specifically in use, and m i ni m i zing em issions of VOC during cleaning of storage, m i xing, and conveying equipm e n t.

Table 2. Recommended Em ission Lim its for Flat W ood Pane ling Coating Operations

Should Meet One of These Emission Lim i ts: Surface Coatings, In ks, or Adhesi ves Applied to the Fo llo wing Flat Woo d Panel i n g Ca te gori e s lb VO C per gal l o n m a teri al (gr a ms VOC per

liter material) [exclu ding water and exe m pt compounds ] lb VO C per g a llon so lids (gr a ms VOC per liter so lids) Ov era ll Co ntro l Efficiency Usi n g an

A d d- O n Co ntro l Device :

Prin ted in terio r p a n e ls m a d e of h a rdw ood , p l yw ood , o r th i n p a rticlebo ard 2. 1 (2 5 0 ) 2. 9 (3 5 0 ) 90 %

N a tur a l f i n i sh h a rdw ood p l yw ood panel s 2. 1 (2 5 0 ) 2. 9 (3 5 0 ) 90 %

C l ass II fi ni s h e s o n har d boa r d pa nel s 2. 1 (2 5 0 ) 2. 9 (3 5 0 ) 90 % Ti l e boar d 2. 1 (2 5 0 ) 2. 9 (3 5 0 ) 90 %
Ex ter i or si d i ng 2

. 1 ( 250 ) 2

. 9 ( 350 ) 90 %

* W e also reco mmen d that th o s e facilities th at m eet th e app licab ility th resh o l d no ted abo v e fo llow work practice sta nda rds

.

VII. Cost Effectiveness of R ecommended Control Options

Cost-effectiveness es tim ates were determ in ed based on South Coast district studies and on studies perform e d by EPA duri ng developm ent of the 2003 NESHAP.

Effective January 1, 2000, a new VOC lim it was proposed for flat wood paneling f acilities in the South Coast Air Quality Man a gem e nt District of California. The new regulation reduced the allowable VOC cont ent for inks from 2.5 pounds per gallon (300

gram s per liter) to 2.1 po unds per gallon (250 gram s per liter) and reduced the allowab l e VOC content for exterior siding coatings from 2.9 pounds per gallon (350 gram s per liter) to 2.1 pounds per gallon (250 gram s pe r liter). At th e tim e of proposal of the South Coast rule, there we re two f acilities in the d i strict tha t would be af f ected by the reg u lation chan ges. One f acility m a nuf acture d inte rior p a neling a nd the other m a nuf actured e x ter i or s i din g. Only the exterior sid i ng f acility was not in com p liance with the new lim its. As part of the South Coast proposal, a cost eff ectiveness analysis was perform e d for the facility. It was determ ined that the facility could switch to two lower-VOC stains for an annual cost of $3,200 and reduce VOC em issions by 2,900 pounds per year (1.45 tons per year), which has a cost-effectiveness of approxim a tely $2,200/to n in 2000 dollars. The facility applying coatings to exterior siding is believed to be re presentative of most exte rior siding facilities.

The surface coating of wood building pr oducts N E SHAP applies to vario u s operations, including flat wood paneling coati ngs. The NESHAP sets requirem ents for

em issions of hazardous air pollutan t s (HAP) and includes the use of low-HAP m a terial as a

com p liance option. The m a jority of HAP ar e VOCs. In developing the NESHAP, EPA estim ated in 1998 dollars, the cost -effectiveness of using low-HAP m a terials. The facilities

10used in developing the NESHAP were also an aly zed for VOC em issions so the cos t effectivenes s is described in term s of HAP and VOC. The cost of com p liance for six facilities in the interior wall paneling and tileboard category was estim ated to be $760,000

and result in VOC reductions of 480 t ons ($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 estim a te 2005 dollars. The re sulting cost effectiveness estim ate, in 2005 dollars, for the California flat wood paneling fac ility that m a nufactures exterior siding is $2,600 per ton of VOC. Escalating the NESH AP figures to 2005 dollars, the cost effectiveness is $1,900 per ton of VOC for interior paneling/tileboard. The cost effectivenes s of controls for ex terior siding operations could va ry substan tia lly f o r f a c ilitie s already complying with the 2003 NESHAP. Wh en developing their requirem ents for the exterior siding operations, States sho u ld consid er the im pacts of such m easures on facilities already subject to the N E SHAP.

VIII. References

1. Control of Volatile Organic Em issions from Existing Sources - Volum e VII: Factory Surface Coating of Flat Wood Paneling. Publication No. EPA-450/2-78-032. U. S. Environm ental Protection Agency, Res earch Triangle Park, N C . June 1978.

2. Guidance to State and Lo cal Agencies in Preparin g Regulatio ns to Contro l Volatile Organic Compounds from Ten Stationary Source Categories. EPA-450-2-79-004. U. S. Environm ental Protection Agency, Research Triangle Park, NC. Septem ber 1979.

3. Placer Coun ty (California) Air Quality Management District Rule 238, Factory Coating of Flat W ood Pa neling. 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 W ood Paneling Su rface Coating Plants. In : Directo r y of Volatile Organic Com pound Sources Covered by Reasonably Av ailable Control Technology (RACT) Requirem e nts, Volum e II: Group II RACT Categories, EPA 450/4-81-0075, U. S. Environm ental Protection Agency, Resear ch Triangle Park, N C . February 1981.

6. Control Techniques for Volatile Organi c Com p ound Em issions from Stationary Sources. Publication No. EPA-453/R-92-018. U. S. Environm ental Protection Agency, Research Triang le Park, NC. Decem ber 1992.

7. Background Inform ation Docum e nt for NESHAP for the W o od Building P r oducts (Surface Coating Industry). EPA-453/R00- 003. U. S. Environm ental Pro t ection Agency, Research Triangle Park, NC. May 2001.

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12

## Appendix A

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14

## Appendix B

Flat Wood Paneling Coati ng Facilities in Current Nonattainment Areas and Associated State or Local Re quirements (Based on 2002 NEI)

Oz one No na tt ainmen t Area Number of Fa cilities Pro d uct Applica b ility Applicable Sta t e Emissio n Limit Alternati v e Co ntr o l Device Limits

Placer County (C al i f or

ni a) 1 1 9 7 8 C T G

No t app licab le to ex terio r sid i n g

. <2.1 lb VOC per g a llo n of co atin g (excl udi ng

water) Ov erall con t ro l efficiency of 90 %

M i chi g a n 1 Int e ri or pa nel i n g

.
No t app licab le to ex terio r sid i n g , cab in etry, fu rnitu re o r tilebo ard. 1 978 CTG Li m its 1 978 CTG Li m its

N o r t h Caro lin a 1 1 978 CTG

No t app licab le to ex terio r sid i n g and tileb o a rd

. 1 978 CTG Li m its 1 978 CTG Li m its

Ohi o 1 No r u le s p ecifi c to f l at wo od

, w ood b u ild i n g pro ducts o r tileb o a rd. 1 978 CTG Li m its 1 978 CTG Li m its

So ut h C a r o l i n a 1 Wo o d c o n s t r uc t i on pr o duct s f o r i n t e ri or pa nel i n g

No t app licab le to ex terio r sid i n g and tileb o a rd

. 1 978 CTG Li m its 1 978 CTG Li m its

Texas 2 In teri o r p a n e lin g and tilebo ard

No t app licab le to ex terio r sid i n g

. 1 978 CTG Li m its 1 978 CTG Li m its

Vi r g i n i a 1 Int e ri or pa nel s

No t app licab le to ex terio r sid i n g and tileb o a rd

. 1 978 CTG Li m its 1 978 CTG Li m its

Indiana 3 I n t e ri or pa nel s

No t app licab le to ex terio r sid i n g and tileb o a rd

. 1 978 CTG Li m its 1 978 CTG Li m its

Tennessee 1 I n t e ri or pa nel i n g

No t app licab le to ex terio r sid i n g and tileb o a rd

. 1 978 CTG Li m its 1 978 CTG Li m its

Illin o i s 1 N o n e No n e No n e Penn sylv an ia 8 N o n e No n e No n e New Ham p shir e 2 N o n e No n e No n e

W i sconsin 1 19 7 8 C T G Li m i t s

No t app licab le to ex terio r sid i n g and tileb o a rd

. 1 978 CTG Li m its 1 978 CTG Li m its

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16

## Appendix C

Estimated Costs Associated with the Recom m e ndations Contained in the C ont rol Techniques Guideline for Flat Wood Paneling C o ating

I. Introductio n

This appendix presents the estim a ted costs as sociated with implem enting the

recomm endations in the Control Techniques Guidelines (CTG) for controlling volatile organic compounds (VOC) em issions from flat wood paneling surface coating facilities in ozone nonattainm ent areas. The CTG contains guidance for State and lo cal pollution control agencies to use in determ ining reasonably available control technology (RACT) for VOC

em issions from flat wood paneling coatings. S t ate and local agencies are free to adopt the

recomm endations contained in the C T G or to implem ent other technically-sound approaches for RACT, provided these appro ach es are cons istent with th e Clean Air Act (CAA) and EPA im ple m entation regulations. Accordingly, ther e is necessa rily som e uncertainty in any prediction of costs and em ission im pacts associ ated with the recomm endat i ons contained in the CTG. For purposes of this analy s is, we assu m e that all s t ate s will ad opt the

recomm endations of the CTG.

According to the 2002 National Em issions I nventory (NEI), ther e are 24 flat wood paneling facilities in th e United States that are located in ozone nonattainm ent areas (based on April 2006 designations). These faciliti es em it greater than 15 pounds VOC per day from flat wood paneling surface coa t ing opera tion s and will p o ssibly be affected by th e CTG.

II. Cost Analysis

The 24 flat wood paneling facili ties are found in thirteen stat es. Nine of the states have state regulations that cu rrently affect VOC em issions fr om interio r panels, bu t n o t tileboard or exterior siding. These nine st ate regulations recomm end the sam e com p l i ance options as are recomm ended in the C T G. By contrast, the CT G provides recomm endat i ons for interior paneling, tileboard, a nd exterior siding. In the re m a ining four states, there are currently no state regulations that affect flat wood paneling product facilities.

17To determ ine the overall expected co sts, th e f a c i lities wer e re s earched to d e term ine the product types at each of the 24 facilities. Fifteen faciliti es were roughly identified as interior product producers (int erior panels, tileboard) and nine facilities were roughly identified as exterior product producers (e xterior siding). Thes e product types were

com p ared to the current flat wood paneling state regulations (if any) to determ ine whether or not the facility could be f i nancially affected by th e CTG. If t h e product t ype at the facility is covered by a state regulation, the facility is a ssum e d to be in com p liance with the lim its in the CTG and have no costs.

Costs could be associated w ith 12 facilities from Illinoi s, New Ha m p shire, Michigan, and Pennsylvania. If these states adopt the recomm endations from the CTG, costs could be incurred to m a ke changes to th eir coatings in order to m eet the recomm e ndations of the CTG. The facilities in these four states in cl ude two interior panel f acilities, one tileboard facility, and nine exte rior siding facilities.

The costs of com p liance for the 12 id entif ied facilities were based on the cost effectiveness calculations in the CT G, wh ich 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 f a c ilitie s. To e s tim ate the c o st f o r im plem enting the recomm endations of the CTG for exterior siding, we used the cost effectiveness estim ate from South Coast AQMD ($2,600 per ton of VOC)

, as opposed to the hi gher num ber associated with the NESHAP (i.e., $4,400 per ton). W e believe the South Co ast AQMD estim ate is m o re realistic because it is based on actual VOC reduction and convers ion costs from a specific facility, whereas the NESHAP estim ates were based on average co ating us ages and averag e coating co sts.

The am ount of VOC reduced was based on the V O C e m issions in the 2002 NEI database attributed to flat wood product su rface co ating (acco rding to th e SCC). To calcu late the em ission reductions, an overall percent redu ctio n was used for each of th e twelve facilities. For interior paneling products and tileboard in the NESHAP, VOC

em issions were reduced by an average of 60 perc ent for all facilities. For exterior siding products in the NESHAP, VOC e m is sions were reduced by an average of 91 percent for all facilities. E m ission reduction estim ates for exte rior siding products were also perform e d as part of the cost effectiveness analysis c onducted in South Coast AQMD. The analysis showed a reduction of VOC e m issions by an aver age of 87 percent. To m a intain the m o st realistic es tim a te of exterior s i ding costs, we used the real fa cility reduction associated with South Coast AQMD (87 percent), as opposed to the higher percent re duction estim ate from the NESHAP (91 percen t). The cos t effectiven ess of controls for ex terior siding operations could vary s ubstantially for facilities alre ady complying with the 2003 NESHAP. When developing their requirem e nts for the exterior siding operations, States should consider the im pacts of such m easures on f acilitie s alre ady su bject to th e NESHAP. The respective percent reductions for the two product types were assum e d to be true for the 12 identified facilities in nonattainm e nt areas possibly affected by the CTG.

The overall cost anticipated for the twelve facilities is $1.2 m illion, with an average cost per facility of $101, 000 and an average VOC reduction of 77 percen t. The data are shown in Table C-1.

18Table C-1. Cost Summary for Flat Wood Product Surface Coating Facilities

I n t e r i o r pa nel s /tilebo a r d fa cilities Exterior siding fa cilities
Nu m b er o f faci lities in o z on e n o n a ttain m e n t areas 1 5 9
Nu m b er o f faci lities th at co u l d in cur co sts to

co m p ly with CTG 3 9

VOC em i ssi on s fr om 20 0 2 N E I (t o n s) 29 7 t o n s 36 8 t o n s Perce n t re ducti on expected 60% 91%
Am ount of V O C em i ssi ons re duce d (t o n s ) 17 8 t o n s 33 5 t o n s C o st o f C T G i m pl em ent a t i on ( $ / t o n V O C re duce d ) $1 ,9 0 0 $2 ,6 0 0
To tal co sts ≈ $ 339 ,0 00 ≈ $ 871 ,0 00

1920 This page intentionally left blank.United StatesEnvironmental ProtectionAgencyOffice of Air Quality Planning and StandardsSector Policies and ProgramsDivisionResearch Triangle Park, NCPublication No. EPA 453/R-06-004September 2006