Emission Standards Division

U.S. Environmental Protection Agency

Office of Air And Radiation

Office of Air Quality Planning and Standards

Research Triangle Park, North Carolina 27711

September 2000

National Emission Standards for 

Hazardous Air Pollutants (NESHAP) for 

Source Category: Large Appliances 

Surface Coating Operations - Background 

Information for Proposed Standards

EPA-453/R-00-006
3

DISCLAIMER

This report has been reviewed by the Emission Standards Division of the Office of Air Quality Planning

and Standards, EPA, and approved for publication. Mention of trade names or commercial products

is not intended to constitute endorsement or recommendation for use.
4

ENVIRONMENTAL PROTECTION AGENCY

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP)

FOR SOURCE CATEGORY: LARGE APPLIANCES SURFACE COATING OPERATIONS -

BACKGROUND INFORMATION FOR PROPOSED STANDARDS

1. The standards regulate organic hazardous air pollutant (HAP) emissions from the surface

coating of large appliances. Only those large appliances surface coating operations that are

part of major sources under section 112(d) of the Clean Air Act (Act) will be regulated.

2. For additional information contact:

Dr. Mohamed Serageldin, PH.D.

Coatings and Consumer Products Group

U.S. Environmental Protection Agency (MD-13)

Research Triangle Park, NC 27711

Telephone: (919) 541-2379

E-MAIL: SERAGELDIN.MOHAMED@EPAMAIL.EPA.GOV

3. Paper copies of this document may be obtained from:

U.S. Environmental Protection Agency Library (MD-36)

Research Triangle Park, NC 27711

Telephone: (919) 541-2777

National Technical Information Service (NTIS)

5285 Port Royal Road

Springfield, VA 22161
5

Telephone: (703) 487-4650

4. Electronic copies of this document may be obtained from the EPA Technology Transfer

Network (TTN) over the internet by going to the following address:

http://www.epa.gov/ttn/uatw/coat/lgapp/ (Select large_app.html)

5. Electronic copies of this document may be obtained from the EPA TTN electronic bulletin

board system which is free, except for the normal long distance charges. To access the

Background Information Document:

• Set software communication setting to 8 bits, no parity, and 1 stop bit

• Set a terminal emulation of either VT100, VT102, or ANSI

• Baud rates of 1200, 2400, 9600, 14,400 are accepted

• Use access number (919) 541-5742; access problems should be directed to the

system operator at (919) 541-5384

• Register online by providing a personal name and password

• Specify TTN Bulletin Board: Clean Air Act Amendments

• Select menu item: Recently Signed Rules
6

TABLE OF CONTENTS

Page

1.0 INTRODUCTION ..................................................... 1-1

1.1 Purpose of This Document ......................................... 1-1

1.2 Regulatory Authority .............................................. 1-1

1.3 Data Gathering Efforts ............................................ 1-2

1.4 References ................................................... 1-11

2.0 THE LARGE APPLIANCES SURFACE COATING OPERATIONS SOURCE

CATEGORY ......................................................... 2-1

2.1 Source Category Description ........................................ 2-1

2.2 Large Appliances Surface Coating Methods ............................. 2-4

2.3 Facility Operations and Current Industry Practices ....................... 2-12

2.4 Emissions ..................................................... 2-14

2.5 References .................................................... 2-19

3.0 EMISSION REDUCTIONS FROM COATING APPLICATIONS ................. 3-1

3.1 Air Pollution Control Techniques ..................................... 3-1

3.2 Pollution Prevention (Source Reduction) ............................... 3-3

3.3 Equipment Changes ............................................... 3-3

3.4 Design and Operational Changes ..................................... 3-3

3.5 Work Practices .................................................. 3-4

3.6 References ..................................................... 3-6
7
8

TABLE OF CONTENTS (Concluded)

Page

4.0 MODEL PLANTS AND COMPLIANCE OPTIONS ........................... 4-1

5.0 REGULATORY APPROACH ............................................ 5-1

5.1 Background .................................................... 5-1

5.2 MACT Floor Approach ........................................... 5-1

5.3 Existing Sources ................................................. 5-4

5.4 New Sources ................................................... 5-7

5.5 Beyond the Floor ................................................. 5-8

5.6 References .................................................... 5-15

6.0 ENVIRONMENTAL, HEALTH, AND ENERGY IMPACTS ..................... 6-1

6.1 Approach to Estimating Impacts ...................................... 6-1

6.2 Estimated HAP Emission Reductions ................................. 6-1

6.3 Non-Air Quality Health and Environmental Impacts ....................... 6-2

6.4 Energy Requirements ............................................. 6-3

7.0 COST IMPACTS ..................................................... 7-1

7.1 Approach to Estimating Costs ....................................... 7-1

7.2 Estimated Cost Impacts ........................................... 7-6

7.3 References ..................................................... 7-8

8.0 ECONOMIC IMPACTS AND SBREFA .................................... 8-1

APPENDIX A ............................................................. A-1
9

LIST OF TABLES

Table Title Page

1-1 Product Description, SIC Codes, and Corresponding NAICS Codes ............ 1-3

1-2 Number of Large Appliances Surface Coating Operations by SIC Code

Found in TRIS and AIRS ........................................... 1-4

1-3 Facilities For Which Air Permit Data Have Been Collected .................. 1-4

1-4 Site Visit Facilities ............................................... 1-10

2-1 Examples of Large Appliances ....................................... 2-2

2-2 Large Appliances Surface Coating Operations Location Distribution by State ..... 2-3

2-3 Large Appliances Surface Coating Operations Employee Distribution ........... 2-4

2-4 HAP Emissions From Potential Major Source Facilities .................... 2-16

4-1 Coating Application Methods Versus SIC Category . . . . . . . . . . . . . . . . . . . . . 4-2

4-2 Coating Type Versus SIC Category . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-2
10

4-3 Model Plant Number 1 (Up to 10,000 Liters of Coating Solids) . . . . . . . . . . . . 4-6

4-4 Model Plant Number 2 (10,001 to 50,000 Liters of Coating Solids) ............. 4-7

LIST OF TABLES (continued)

Table Title Page

4-5 Model Plant Number 3 (50,001 to 200,000 Liters of Coating Solids) ............ 4-8

4-6 Model Plant Number 4 (Greater Than 200,000 Liters of Coating Solids) ......... 4-9

4-7 Data for Model Plant Number 1 ..................................... 4-10

4-8 Data for Model Plant Number 2 ..................................... 4-11

4-9 Data for Model Plant Number 3 ..................................... 4-12

4-10 Data for Model Plant Number 4 ..................................... 4-13

5-1 Surface Coating Emission Data Used in Developing the MACT Floors ......... 5-11

5-2 Default Densities Used for Unit Conversions ........................... 5-14

6-1 Summary of Estimated Environmental Impacts ........................... 6-3

6-2 Facilities Switching to Powder Coatings ................................ 6-4
11

7-1 Model Plant Number 1 Cost Impacts 

 (Up to 10,000 Liters of Coating Solids) ........................... 7-9

LIST OF TABLES (concluded)

Table Title Page

7-2 Model Plant Number 2 Cost Impacts 

 (10,001 to 50,000 Liters of Coating Solids) ........................ 7-10

7-3 Model Plant Number 3 Cost Impacts 

 (50,001 to 200,000 Liters of Coating Solids) ....................... 7-11

7-4 Model Plant Number 4 Cost Impacts 

 (Greater Than 200,000 Liters of Coating Solids) .................... 7-12

7-5 Summary of Cost Impacts for Existing Sources .......................... 7-13

7-6 Summary of Estimated Monitoring, Recordkeeping, and Reporting Costs –

Years 1 - 5 .................................................... 7-14

7-7 Total Estimated Cost of Proposed Standards – Years 1 - 5 ................. 7-15

A-1 Large Appliance Potential Major and Synthetic Minor Facilities ............... A-2
12

A-2 Summary of Regulations by State ..................................... A-6

LIST OF FIGURES

Figure Title Page

1-1 Liquid Coating UOS .............................................. 1-7

1-2 Unit Operations Included in Affected Source ............................ 1-8

5-1 HAP Emission Rate (Normalized Emissions) Versus SIC Code . . . . . . . . . . . . 5-6
1-1

1.0 INTRODUCTION

1.1 PURPOSE OF THIS DOCUMENT

The Background Information Document (BID) provides background information on, and

rationale for, decisions by the Environmental Protection Agency (EPA) related to the proposed

standards for the reduction of hazardous air pollutants (HAP) emitted from large appliances surface

coating operations. The BID supplements the preamble for the proposed standards.

This document is separated into seven chapters providing a combination of background

information and EPA rationale for decisions made in the standards development process. Chapters 2,

3, and 4 provide background information including: an industry description in Chapter 2, a description

of the control techniques used by the industry in Chapter 3, and the model plants developed for this

industry in Chapter 4. Chapter 5 provides the determination of the Maximum Achievable Control

Technology (MACT) “floors”, and an evaluation of control beyond the MACT Floor. Chapters 6 and

7 present the predicted HAP emission reductions and cost impacts associated with the proposed

standards. Appendix A provides a listing of major and synthetic minor facilities thought to be subject

to the standards. Appendix A also contains factors for converting Metric units to English units. 

Supporting information and more detailed descriptions for technical and rationale chapters are

provided in the items referenced in this document and located in the project docket.

1.2 REGULATORY AUTHORITY

Section 112 of the Clean Air Act (CAA), as amended in 1990 (1990 Amendments) provides

the EPA with the authority to establish national standards to reduce air emissions from sources that

emit one or more of 188 hazardous air pollutants. Section 112(b) of the Clean Air Act contains a list

of HAP to be regulated by National Emission Standards for Hazardous Air Pollutants (NESHAP), and

Section 112 (c) directs the EPA to use this pollutant list to develop and publish a list of source

categories for which NESHAP will be developed. The EPA must list all known source categories and

subcategories of “major sources” that emit one or more of the listed HAP. A major source is defined
1-2

in Section 112 (a) as any stationary source or group of stationary sources located within a contiguous

area and under common control that emits, or has the potential to emit considering controls, in the

aggregate, 10 tons (9.07 Mg) per year of any one HAP or 25 tons (22.7 Mg) per year of any

combination of HAP. The list of source categories was first published in the Federal Register on July

16, 1992 (57 FR 31576). This published list of source categories included the large appliances

surface coating operations source category.

1.3 DATA GATHERING EFFORTS

Data were collected from the following sources in the development of a database of

information for the large appliances surface coating operations source category: (1) the Toxic Release

Inventory System (TRIS), (2) the Aerometric Information Retrieval System (AIRS), (3) State and

local agencies, (4) Federal and State rules and guidance documents, and (5) site visits. Most of the

information gathered from these sources was used to develop an extensive mailing list of large

appliance manufacturers and detailed questionnaires to be submitted to the industry under the authority

of Section 114. 

In order to begin the task of characterizing the industry and to provide a basis from which data

could be requested from States, a list of product descriptions was developed. The Standard Industrial

Classification (SIC) codes and corresponding North American Industry Classification System

(NAICS) codes relevant to the large appliances surfaces coating operations industry were also used to

identify these products. This information is presented in Table 1-1.

1.3.1 Data Obtained from States

State and local air pollution control agencies provided information (i.e., permits or emissions

inventory data) pertinent to the large appliances source category. A query of the States with the most

large appliances surface coating operations was generated through the use of the TRIS and AIRS

databases. Using the SIC/NAICS codes listed in Table 1-1, the number of facilities in each of the

product categories was found. The results from the TRIS and AIRS searches are presented in Table

1-2.
1-3

In addition to the questionnaire and site visit data, the EPA has collected some air quality

permit data. The permits provided information useful to this rule development on coating usage,

coating HAP content, facility configuration, production technologies, implemented emission reduction

techniques, and add-on emission controls. The facilities for which permit data have been collected are

listed in Table 1-3.

TABLE 1-1 PRODUCT DESCRIPTION, SIC CODES AND 

CORRESPONDING NAICS CODES

SIC Product Description SIC

Code

Corresponding NAICS Product

Description

 Corresponding

NAICS Code

Household Cooking Equipment 3631 Household Cooking Appliance

Manufacturing

335221

Household Refrigerators and Home

and Farm Freezers

3632 Household Refrigerator and Home

Freezer Manufacturing

335222

Household Laundry Equipment 3633 Household Laundry Equipment

Manufacturing

335224

Household Appliances; not

elsewhere classified

3639 - Other Household Appliance Other Major Household Appliance

Manufacturing

335228

- Floor Waxing and Floor Polishing 

 Machines

Household Vacuum Cleaners

Manufacturing (pt)

335212

 Air Conditioning and Warm Air 

Heating Equipment and 

Commercial Industrial 

Refrigeration Equipment

3585

- Except Motor Vehicle Air 

Conditioning

Air Conditioning and Warm Air

Heating Equipment and Commercial

and Industrial Refrigeration

Equipment Manufacturing

333415

- Motor Vehicle Air Conditioning Motor Vehicle Air Conditioning

Manufacturer

336391
SIC Product Description SIC

Code

Corresponding NAICS Product

Description

 Corresponding

NAICS Code

1-4

Service Industry Machinery; not

elsewhere classified

3589 Other Commercial and Service

Industry Machinery Manufacturing

(pt)

333319

NOTE: (pt) indicates that the NAICS code includes additional SIC codes or product codes beyond

corresponding SIC codes shown in the table.

TABLE 1-2. NUMBER OF LARGE APPLIANCES SURFACE COATING OPERATIONS 

BY SIC CODE FOUND IN TRIS AND AIRS DATABASES

Product Category SIC Code Number of Facilities

Air-Conditioning and Warm Air Heating Equipment and

Commercial and Industrial Refrigeration Equipment

3585 38

Service Industry Machinery, Not Elsewhere Classified 3589 3

Household Cooking Equipment 3631 5

Household Refrigerators and Home and Farm Freezers 3632 6

Household Laundry Equipment 3633 6

Household Appliances, Not Elsewhere Classified 3639 6

TABLE 1-3. FACILITIES FOR WHICH AIR PERMIT DATA HAVE BEEN COLLECTED

Facility Products Manufactured SIC Code

Maytag, Herrin, Illinois Washers & Dryers 3633

Frigidaire, Kinston, North Carolina Dishwashers 3639

A.O. Smith Water Products, McBee, South

Carolina

Water Heaters 3639

Maytag, Galesburg, Illinois Refrigerators 3632

1.3.2 Federal and State Rules and Guidance Documents
1-5

A Control Techniques Guideline (CTG) for the large appliances surface coating industry,

Control of Volatile Organic Emissions from Existing Stationary Sources Volume V: Surface

Coating of Large Appliances (EPA-450/2-77-034), was published in December 1977. This

guidance document recommended a limitation of 0.34 kilogram of organic solvent emitted per liter of

coating (minus water and exempt solvents) [2.8 pounds of organic solvent emitted per gallon of coating

(minus water and exempt solvents)] for reduction of VOC from existing stationary sources [1].

A New Source Performance Standard (NSPS) with a different VOC emission limit was

published in October 1982. In the NSPS for the large appliances surface coating industry (40 CFR

Part 60 Subpart SS--Standards of Performance for New Stationary Sources; Industrial Surface

Coating: Appliances), VOC emissions are limited to 0.90 kilogram of VOC per liter of coating

solids applied [7.5 pounds of VOC per gallon of coating solids applied] [2]. This limit is based on the

solids (nonvolatiles) that land on the substrate.

The Bureau of National Affairs (BNA) Environmental Library was searched for State

regulations pertaining to surface coating of large appliances. Most States generally follow the

guidelines or requirements established in the CTG and/or NSPS as described above. Some States

have different limits for individual coating type and curing method (e.g., specialty coatings, air-dried

general coatings, baked general coatings, enamels, etc.). Several State/local agencies have established

guidance for determining Best Available Control Technology (BACT) and Reasonable Available

Control Technology (RACT) for surface coating of large appliances [3]. A tabular summary of these

regulations is presented in Table A-2 [3, 4].

1.3.3 Questionnaires

To obtain the most up-to-date data from the industry, EPA mailed preliminary questionnaires

under the authority of Section 114 of the Clean Air Act to selected industry stakeholders in June 1997. 

Nine companies were selected by EPA to receive questionnaires. The purpose was to compile

detailed information on quantities of HAP and VOC emissions and on current emission control

techniques. In addition, data were needed to analyze the environmental, energy, and economic impacts

associated with implementing feasible emission control techniques.
1-6

The selection process for facilities to receive questionnaires issued under the authority of

Section 114 was intended to obtain information from the major manufacturers of each of the product

groups under consideration for the large appliances surface coating operations rulemaking effort. The

companies were selected for identifying the major technologies in use and for quantifying emissions

from these manufacturing systems.

As a means of identifying and quantifying the possible sources of pollution, the questionnaires

used the Unit Operation System (UOS) as the basis for data reporting. A plant (or facility) consists of

several levels of production activity, which are divided into work areas that are composed of one or

more UOS. The term UOS refers to a formalized concept for performing a material balance. A UOS

system is the ensemble on which the material balance is performed and includes all sources that

contribute to emissions [5]. Furthermore, the facilities were asked to provide a flow diagram of the

manufacturing process, which identifies the different unit operations. They were also asked to describe

the coating specifications, type of parts and substrate material coated, waste handling procedures,

control measures, applicable regulations, and collocated sources.

As illustrated in Figures 1-1 and 1-2, the boundary defines the UOS in which the HAP content

of coating equals the HAP content of coating waste plus emissions. Facilities do not need to measure

emissions from each of the individual unit operations (Coating Application, 

Flashoff, and Oven) in order to calculate the total emissions within the boundary. This information can

be determined if the HAP contents in the coating and in the coating waste 

leaving a unit operation are known. The total emissions from each of the unit operations will vary

depending on the type of coating applied, the application method, the length of the flashoff area, and

other factors that are specific to each facility. In powder coatings systems, most waste coating material

may be recirculated into the Coating Application, and there is no flashoff area. For powder coating

operations, no HAP or VOC emissions were reported. Figure 1-2 shows all of the UOS examined in

the large appliances surface coating operations rulemaking effort.

In June 1998, EPA sent out an additional Section 114 questionnaire designed using information

learned from the June 1997 questionnaire. The questionnaire focused on more specific information
1-7

Coating

Application Flashoff Oven

V1 V2

Boundary

F = Coating Input

XF = HAP content of coating

W = Coating Waste

XW = HAP content of waste

Emissions = (F)(XF) - (W)(Xw)

 = V1 + V2 + V3

 

physically connected unit operations

air emissions

direction of process flow (not physically connected)

V3

W= Waste

V= Emissions

F= Coating Input

about the unit operations within a facility, and contained sections concerned with general facility

information, material data, add-on control devices, coating application, surface preparation, storage,

mixing operations, cleaning operations, and waste and wastewater. The questionnaire also included

components that relate data to the UOS. Data collected from 
1-8

Figure 1-1 Liquid Coating UOS
1-9

Wastewater 

Treatment

Adhesives Storage and 

Mixing

Cutting/Lubricating

Oils 

Surface Preparation Spray Coatings Flashoff

Dip Coating Flashoff Other Cleaning

Touch-up/Repair 

Operations To Drying Ovens

Final 

Assembly

To

Packaging

and Shipping

To

Machine Shop

=Air Emissions =Unit Operations 

Covered Under 

Single Emission 

Limit

=Product Flow

HAP Solvent

Depainting

Figure 1-2. Unit Operations Included in 

Affected Source =The Unit Operations System (UOS) 

Includes All Activities Located Within the 

Dashed Lines 
1-10

this questionnaire included the amount of coatings, organic solvents, adhesives, and cleaners used as

well as information on HAP emissions, coating solids, and major source classification. These data

were used to calculate the MACT floor and resulting HAP emissions limit.

1.3.4 Site Visits

The EPA made site visits to four large appliances surface coating operations in June and July of

1997 and to four additional facilities in August 1998. These facilities are listed in Table 1-4. The types

of information requested during site visits included:

C Description of the plant: size, hours of operation, layout of the unit operations, types of

products coated, products manufactured, and production rate.

C Detailed descriptions of the surface coating operations, including the application

equipment and coating technology used (e.g., dip coating, flow coating, electrostatic

spray, powder coating), the spray booth or application area, and oven.

C Information regarding each material containing any HAP or VOC that is used in or

emitted by any operation at the facility (e.g., coatings, parts cleaners, etc.).

C Descriptions of any control measures or add-on devices used to reduce HAP or VOC

emissions from surface coating processes or any emitting source.

C Available cost information concerning the materials and equipment used in the surface

coating operation, and costs of any HAP or VOC control strategies in place or

planned.
1-11

TABLE 1-4. SITE VISIT FACILITIES

Facility Products Manufactured SIC Code

AAA Plating, Inc.

Denver, Colorado

Metal Plating Only Not available

Amana Refrigeration, Inc.

Florence, SC

Residential Ranges, Cook Tops, Wall Ovens 3631

Amana Refrigeration, Inc.

Amana, IA

Residential Freezers, Refrigerators, Microwaves,

Commercial & Industrial Ovens and Microwaves

3632 (3631 &

3585)

Decorative Coating Systems

Denver, Colorado

Contract Paint Shop (no manufacturing) Not available

Lennox Industries

Marshalltown, IA

Residential Heating (Furnaces & Combination

Furnace/Water Heater) and Cooling (Air Conditioners, Heat

Pumps, Coil Boilers) Products

3585

Maytag Appliances

Newton, IA

Residential Washers and Dryers 3633

The Trane Company

Pueblo, Colorado

Chillers 3585

Windsor Industries, Inc.

Englewood, Colorado

Service Machinery, NEC (Floor Maintenance Equip.,

Vacuum Equip.)

3589
1-12

1.4 REFERENCES

1. Control of Volatile Organic Emissions from Existing Stationary Sources Volume V: Surface

Coating of Large Appliances, U. S. Environmental Protection Agency, Office of Air and

Waste Management, Office of Air Quality Planning and Standards, Research Triangle Park,

NC, EPA-450/2-77-034. December 1977.

2. Industrial Surface Coating: Large Appliances - Background Information for Promulgated

Standards, U. S. Environmental Protection Agency, Office of Air Quality Planning and

Standards, Research Triangle Park, NC, EPA-450/3-80-037b. October 1982.

3. Beyond VOC RACT CTG Requirements, U. S. Environmental Protection Agency, Office of

Air Quality Planning and Standards, Research Triangle Park, NC, EPA-453/R-95-010. April

1995.

4. BNA's ENVIRONMENTAL LIBRARY on CD, Windows 3.97, Environmental Compliance

Series, The Bureau of National Affairs, Inc., Copyright 1996.

5. “Standardized Accounting for a Formal Environmental Management and Auditing 

System,” Waste Minimization through Process Design, Chapter 20, A. P. Rossiter, ed., 

McGraw-Hill, Inc., 1995. Pages 289-303.
2-1

2.0 THE LARGE APPLIANCES SURFACE COATING OPERATIONS 

SOURCE CATEGORY

This chapter presents a description of the large appliances surface coating operations source

category and identifies types of surface coating operations that would potentially be subject to the

proposed standards. Also included in this chapter is a summary of current facility operations and

industry practices that contribute to the emission of HAP.

2.1 SOURCE CATEGORY DESCRIPTION

The large appliances surface coating operations source category includes any operation

engaged in the surface coating of any large appliance part or product. There are several industries that

coat items considered large appliances. These industries coat products such as heating and air

conditioning units and parts, chillers, refrigerators and home and farm freezers, laundry equipment,

cooking equipment, dishwashers, floor waxers and polishers, garbage disposal units, trash compactors,

and water heaters. See Table 2-1 for a listing of examples of large appliances.

The large appliances surface coating operations source category is primarily represented by the

following six SIC codes:

3631 Household Cooking Equipment

3632 Household Refrigerators and Home and Farm Freezers

3633 Household Laundry Equipment

3639 Household Appliances, Not Elsewhere Classified

3585 Air Conditioning And Warm Air Heating Equipment and Commercial and 

Industrial Refrigeration Equipment

3589 Service Industry Machinery, Not Elsewhere Classified

Products manufactured under these six SIC codes are considered large appliances for purposes of the

rule. However, the large appliances surface coating operations source category also encompasses

facilities coating similar products under other SIC codes. Therefore, a facility may be operating under
2-2

a different SIC code but can still be subject to the rule because they coat a product that is a large

appliance.

TABLE 2-1. EXAMPLES OF LARGE APPLIANCES

heating and air conditioning

units (including home, motor

vehicle, industrial)

household refrigerators,

iceboxes, and home and farm

freezers

household floor waxers and

polishers, janitor’s carts, mop

wringers, floor sanding

machines

chillers, heating and airconditioning parts and

equipment (coils, fin plates,

compressors, etc.)

refrigerated cabinets, cases, and

lockers

household sewing machines and

buttonhole and eyelet machines

condensers, electric nonportable dehumidifiers, electric

and gravity flow furnaces

household laundry/dry-cleaning

equipment, including coinoperated (washers, dryers,

wringers, etc.)

snow making machinery

non coin-operated cold drink

dispensing equipment, beer

dispensers, electric water and

milk coolers, refrigerated

drinking fountains

cooking equipment (ovens,

ranges, stoves, microwaves,

grills, barbecues, etc.)

sewage treatment and sewer

cleaning equipment, sludge

processing equipment

non-household vacuum cleaners

and sweepers

dishwashers industrial water treatment

equipment, water conditioners

for swimming pools

non-household pressure

cookers, steam cookers, corn

poppers, and fryers

garbage disposal units and trash

compactors

household water filters and

softeners, water purification

equipment

ice making machinery water heaters, electric heat

pumps

car washing machinery

(including coin-operated)

1These are only examples of large appliances. This table does not include the entire large appliances industry and is

meant to only provide examples of the types of products considered large appliances.

2.1.1 Number of Sources

The questionnaire sent to industry by EPA in 1998 requested data from the 1997 calendar

year. Results from the questionnaire indicate there are 222 facilities that perform large appliances
2-3

surface coating operations. Large appliance surface coating operations are distributed across 38

States and Puerto Rico. Based on data received from the questionnaires, the states with the largest

numbers of large appliances surface coating operations are Ohio (19), Tennessee (16), Illinois (15),

Texas (14), Wisconsin (13), and Georgia (10). Table 2-2 presents the distribution of large appliances

surface coating operations per state. The size of the facilities and the number of employees

represented in the questionnaire vary, ranging from 11 to 5,500. Based on responses to the EPA’s

Section 114 questionnaire, an average plant employs about 640 people. Table 2-3 presents the total

number of employees and the average number of employees per plant for different types of large

appliances. For each type of large appliance, the total number of employees reported by the

questionnaire respondents was divided by the number of respondents that provided employment data. 

Of the 222 facilities, 95 are considered potential major sources based on potential facility HAP

emissions (see Table 2-4 for those facilities considered major sources).

TABLE 2-2. LARGE APPLIANCES SURFACE COATING OPERATIONS 

LOCATION DISTRIBUTION BY STATE

State Number of

Facilities

State Number of

Facilities

Alabama 5 Mississippi 6

Arkansas 7 Nebraska 1

Arizona 2 New Hampshire 1

California 6 New Jersey 3

Colorado 3 New York 3

Connecticut 1 North Carolina 9

Delaware 1 Ohio 19

Florida 4 Oklahoma 5

Georgia 10 Oregon 1

Idaho 7 Pennsylvania 8

Illinois 15 Puerto Rico 2
State Number of

Facilities

State Number of

Facilities

2-4

Indiana 5 Rhode Island 1

Kansas 1 South Carolina 8

Kentucky 7 Tennessee 16

Louisiana 1 Texas 14

Massachusetts 1 Virginia 6

Maryland 6 Vermont 1

Michigan 4 Washington 3

Minnesota 7 Wisconsin 13

Missouri 8

TABLE 2-3. LARGE APPLIANCES SURFACE COATING OPERATIONS 

EMPLOYEE DISTRIBUTION

Appliance Type Total Employees Average Employees

per Plant

Cooking Equipment 12,766 799

Refrigerators and

Freezers

15,344 1,180

Laundry Equipment 12,734 1,415

Miscellaneous

Household Appliances

17,797 890

Air Conditioning,

HVAC, Industrial

Refrigeration, etc.

58,969 627

Miscellaneous Service

Equipment

6,407 279

Other Miscellaneous 8,098 253
2-5

2.2 LARGE APPLIANCES SURFACE COATING METHODS

 The large appliances surface coating operations industry is diverse and uses a range of coating

application technologies. The methods used most frequently are typical of surface coating operations

in any industry. The following paragraphs provide a brief discussion of the most common application

technologies. Facilities often use several of these methods.

2.2.1 Air and Airless Spray Guns

The processes of air spraying and airless spraying of coatings involve the atomization of a liquid

coating in order to apply it to a substrate. Air spraying achieves atomization by the use of compressed

air. Airless spraying uses an airless pump system to force a coating through a nozzle designed to

atomize the coating [1].

Air spraying offers good coating quality with a wide range of coating systems and a high

application rate. Also, the air spray can coat irregular shapes with recessed areas effectively. This

technology can provide transfer efficiencies of up to 40 percent. Excessive overspray is the major

drawback of an air spray system, which results in high material waste and high cleanup costs [2].

Airless spray systems offer comparable spray characteristics to air spray systems. However,

the airless spray system typically has a higher transfer efficiency (50-60 percent) than air spray system

(30-40 percent) [3]. Airless systems can also atomize coatings at high flow rates. However, with

airless spray the spray nozzles are prone to clogging and wear. Also, stiff high pressure fluid hoses are

required with airless systems. Problems with high pressures have been alleviated through the use of the

air-assisted airless spray gun. This system uses some air to help atomize the coating and therefore

allows for lowering of the pumping pressure [1].

The high-volume low-pressure (HVLP) system is a newer technology which further reduces

overspray because it propels the atomized coating at a lower velocity than the air or airless system [2]. 

However, there are some difficulties with applying coatings with low solvent content and certain waterbased coatings using an HVLP system when the flow viscosity is high.

In this case proper atomization may not be achieved with high flow rates. 
2-6

The EPA recently completed an Environmental Technology Verification for a laser-guided

targeting device designed to improve the transfer efficiencies of spray guns. The device attaches easily

to a regular manual spray gun and enables a precise painting technique. The EPA's Environmental

Technology Verification Statement reports that the system increases relative transfer efficiency at an

average of 11.1 percent. This would result in a corresponding reduction in material usage and volatile

HAP emissions. The EPA's Verification Statement can be found at

http://www.epa.gov/etv/verifrpt.htm#prevention under "P2 Innovative Coatings and Coating Equipment

Systems Pilot."

2.2.2 Dip Coating

The dip coating operation involves the immersion of a part into a tank containing the coating. 

Typical transfer efficiencies are near 85 percent [4]. The high transfer efficiency is due to the fact that

there is no atomization and excess coating can be returned to the dip tank as it drips off [5].

Dip coating is advantageous because it is simple and provides a quick and inexpensive way of

applying a coating to coat large numbers of substrates. Potential problems with dip coating involve the

large amounts of coating required and fire risk in large installations. The fire risk can be eliminated by

using water-based coatings [5].

Dip coating is feasible using solvent-based or water-based coatings. However, with either

coating type extensive attention must be given to maintaining proper mix characteristics (coating

viscosity) in the tank because of evaporative losses [5].

2.2.3 Electrodeposition

Electrodeposition is a dip coating method in which an electric field is used to facilitate the

deposition of the coating on the substrate. The substrate to be coated acts as an electrode that is

oppositely charged from the coating (particles) in the dip tank [1]. Electrodeposition has the same

advantages as dip coating, and , in addition, the transfer efficiency for an electrostatic dip coat

operation is closer to 95 percent [4]. Many types of polymers can be used in the electrodepositon

process if they are used with solubilizers, which charge the polymer electrically. Early

electrodeposition processes were anodic, but due to problems with electrolysis, cathodic systems are

now preferred [6].
2-7

Like the dip-coating operation, the electrodeposition operation requires close monitoring and

recirculation of the coating in the tank [6]. One consideration with electrodeposition is that the use of

water-based coatings requires the equipment to be electrically isolated [7].

2.2.4 Electrostatic Spraying

An electrostatic spray can be generated using an air or an airless gun system. In such systems,

the transfer efficiency is improved because electrostatic principles are used to attract the coating to the

substrate (85 percent transfer efficiency) [1, 4]. Coating droplets are injected into an electrostatic field

set up by several electrodes that impart a charge to the coating. Negatively charged atomized coating

droplets are propelled to the substrate to be coated and deposit themselves through electrostatic

attraction [5].

A unique advantage of applying coatings in the form of an electrostatic spray is the

“wraparound effect.” Due to the wraparound effect, an entire product can be coated from one side. 

This is a result of the electrostatic attraction of the coating to the substrate [5]. The advantages of

using an electrostatic spray include high transfer efficiencies (90 percent for automatic systems and 60

percent for manual systems), as well as applicability to coatings containing a high amount of

nonvolatiles (coating solids). If water-based coatings are to be used, the system must be electrically

isolated to avoid electric shocks [2].

2.2.5 Electrostatic Bell and Disk Gun Systems

The electrostatic bell and disk systems are similar in many respects. They use the rapid

rotation of either a bell or disk shaped applicator to mist the coating. The use of oppositely charged

substrate and coating allows for higher transfer efficiencies and better coating uniformity [1]. The

transfer efficiency of the bell or disk system is close to 90 percent [4].

Electrostatic bell and disk systems can also be used with almost any liquid coating from the

thinnest up to 80 percent nonvolatiles [6]. The electrostatic system helps carry the coating to the

substrate and causes it to adhere to the surface of the substrate. Hence, the result is a coating of good

quality and finish characteristics. Due to the design and purpose of the bell application systems, they

are best used on automated large volume coating lines to coat parts that have similar characteristics

(size, shape, and material) [2].
2-8

2.2.6 Carbon Dioxide Spray System

The carbon dioxide spray application technology was introduced in 1990 as a new pollution

prevention (source reduction) technology to reduce the amount of organic solvent needed before the

coating is sprayed. The technology was used to apply conventional solvent-based formulations and the

higher coating solids formulations [8, 9]. The equipment is a modified airless spray system that makes

it possible to mix carbon dioxide, a solvent under certain conditions, with the coating [8]. To dissolve

the carbon dioxide in the coating, the mixture is pressurized to supercritical pressures ranging from

1,200 to 1,700 psig, which are well within the capacity of current airless spray application systems. In

addition, the solution is heated to a temperature ranging from 40 to 70 degrees Celsius to make the

carbon dioxide supercritical and to offset the cooling that occurs as the carbon dioxide diffuses from

the solution as a free gas in the spray.

Even though the carbon dioxide spray is airless in nature, it has all the desirable traits of air

spray, without high air volumes [8]. The carbon dioxide spray produces a high quality uniform film

which has both good appearance and high transfer efficiency [10]. This technology has been used to

apply urethane clear topcoat to exterior plastic automotive components, acrylic clear topcoat to

automotive bumpers, adhesion promoter to automotive components, acrylic lacquer to automotive

sport wheels, alkyd lacquer to heavy equipment chassis and components, and nonstick silicone coating

to metal bakeware [8].

The carbon dioxide spray system appears to have economic, performance, and environmental

advantages over conventional spray systems. Using a carbon dioxide spray system also has a number

of environmental and safety benefits. The carbon dioxide spray system reduces solid waste, lowers

volatile emissions, and reduces flammable solvent inventory. The carbon dioxide used for this

application is a by product from other sources, hence it helps reduce greenhouse gas inventory [8]. 

A few deterrents exist for switching to a carbon dioxide spray system. The system is new

relative to more established technologies. Some minor equipment modifications and purchases are

required. Coating reformulation in some cases may be required [8].

2.2.7 Powder Coating Technology
2-9

Powder coatings (dry resin) are applied to a substrate in a dry form. The resin is typically a

thermosetting (polyurethane, acrylic, epoxy, etc.) or thermoplastic (nylon, vinyl, etc.) resin which is

electrostatically applied to the surface of a part. Application is done with a spray gun or fluidized bed

(powder which has been fluidized by compressed air adheres to the surface of a heated metal part as it

passes through the fluidized bed of powder). The powder-coated part is then cured in an oven where

the powder fuses to form a continuous, uniform coating [10]. Powder coatings have been used by

numerous industries to coat parts such as lawn and garden equipment, appliances, playground

equipment, patio furniture, and automotive parts [11].
2-10

Powder coating has some distinct advantages over conventional coating operations. First,

no organic solvents are normally added to powder coatings. A negligible HAP (less than

approximately one percent by mass volatiles [10,12] are released during curing stage compared to

e.g., 15 percent for water-based coatings and e.g., 66 percent for conventional solvent-based

coatings) [10]. Because organic solvents are not normally added to powder coatings, worker safety is

improved, ventilation and pollution control requirements in the workplace are reduced, and permitting

and regulatory compliance is more cost effective [11]. Another advantage of using powder coatings is

that the overspray can be collected using a vacuum cleaner or compressed air. If the retrieved powder

is reused, the overall coating costs and hazardous disposal costs will be reduced [10]. Powder coated

surfaces are more resistant to chipping, scratching, fading, and wearing than other finishes [13].

Uncertainty exists as to the validity of testing powder coatings by the same methods as liquid

coatings. The Powder Coating Institute recommends an alternative method which involves weighing

the powder coating before and after placing it in an oven set to similar conditions as production curing. 

The difference in mass is the volatile content. Some other concerns associated with powder coating

involve storage of powder coating and cleaning of the application equipment. Temperature and

humidity must be monitored closely in the areas where the powder coating is stored and applied. 

Moisture in the powder must be kept at a reasonably low level to prevent cohesion problems

(clumping of powder particles) during spraying. Because there are no organic solvents in the dry

powder to absorb or disperse contaminants, the air delivery system to the powder spray guns must not

deliver significant amounts of water or oil [2]. Cleaning the application equipment can be very time

consuming when color changes are required. All of the first color powder must be removed from the

system before the second color powder can be started. Equipment duplication may be a cost-effective

solution to this problem [10]. 

2.2.8 UV/EB Coating Technologies

Radiation-cured coatings are specially formulated adhesives, inks, and coatings materials that

cure with exposure to either UV light (UV-cured) or focused electrons (EB-cured) rather than heat

[14]. All of the material in these coatings enter into the curing reaction and become part of the final

solid coating film rather than being volatilized. This UV/EB coating technology is particularly useful for

products such as paper, foil, wood, and plastic that can not be exposed to the high temperatures of

traditional coating ovens. Some products that are currently being coated using radiation technology
2-11

include fiber optics, toiletry bottles, sporting equipment, medical equipment, headlight assemblies,

wood trim, windshields, magazines, labels, cereal boxes, milk/juice cartons, CDS, DVDs, and circuit

boards [15].

There are several components that are used in the UV/EB cured coatings. These include an

oligomer or prepolymer containing double-bond unsaturation, monomers (with varying degrees of

unsaturation), a photoinitiator to absorb the UV light radiation (this is not needed for EB curing), and

pigments/dyes or other additives. Essentially, the curing process is dependent on the availability of

extra electrons to form the bonds with the unsaturated components. This creates a material that has

saturated bonds (i.e., the final product or film). The extra electrons come from either the photoinitiator

in the UV coating or from the electron beam that is applied in EB coatings.

Unlike conventional coatings, UV/EB coatings emit few or no VOC/HAP. The only HAP

expected to be present in the UV/EB coatings as they are applied would be solvents that may be

added by the user. Approximately 98 percent of UV and EB coatings are applied as supplied by the

coating manufacturer [16]. Other benefits of using radiation-cured UV and EB coatings include: (1)

elimination or reduction of solvent use, (2) very rapid curing, (3) high productivity from rapid curing

and instant startup and shutdown, (4) low-temperature processing, which allows for the use of heat

sensitive substrates such as plastic, (5) good film properties and performance, such as hardness; and

improved solvent, stain and abrasion resistance, (6) higher non-volatile content that results in higher

gloss, better build, and lower shrinkage, (7) lower energy use because of high efficiency UV/EB

systems when compared to thermal ovens, and (8) lower space requirements than conventional coating

systems [17].

Radiation-cured coating systems also have a number of limitations, which include: (1) higher

cost coating formulations because of expensive raw materials and smaller volume, (2) line-of-sight

curing is limited to flat or cylindrical materials that can be directly exposed to the radiation source.

Radiation systems for three dimensional substrates are being developed to overcome this limitation, (3)

the presence of pigments reduces penetration by UV light, limiting use in high-build applications, (4)

many polymers used in radiation-cured coatings are allergens and can cause skin irritation and

sensitization, (5) UV/EB curing is not always suitable for porous materials, and (6) EB systems

generally require an inert environment because atmospheric oxygen can interfere with the curing of

resins [17].
2-12

2.2.9 Flow Coating

Flow coating is a method that involves the application of the coating directly onto the substrate

without atomizing the coating [1]. Small streams of liquid coating are applied to a flat, horizontallyoriented substrate and allowed to spread to form a continuous film. The typical transfer efficiency for

flow coating is 85 percent [4]. Flow coating does not require the large coating volumes that dip

coating does. However, the maintenance of mix characteristics is equally important. Flow coating also

allows for low ventilation rates and a variety of substrate shapes [6].

For many applications, electrostatic de-tearing is required to control droplet formation in flow

coating operations. De-tearing uses electrostatic currents to remove excess paint droplets from the

part. Also, if the coating cures too quickly the coating will skim (the surface of the coating will dry

before the rest of the coating). Therefore, it is sometimes necessary to place the coated substrate in a

solvent-rich environment to slow the curing process and prevent skimming. While flow coating allows

for reduced solvent emissions, if a solvent rich environment is maintained emissions rise considerably

[6].

2.2.10 Final Touch-up/Reinforcement of Coated Pieces

The majority of touch-up operations are performed by using manual air spray guns and a

lacquer based coating. This is because the lacquer coating has good drying characteristics that allow

for shorter drying times. In some cases, touch-up might include recoating a product entirely, but the

majority of touch-up lines consist of manual coating application to a small portion of the product

surface [2].

2.2.11 Coating Type & Composition

Several types of coatings were represented in the questionnaire responses, including powder

coatings, organic solvent-based coatings, and water-based coatings. Organic solvent-based coatings

are considered to be the more traditional coatings. High nonvolatiles, medium nonvolatiles, and low

nonvolatiles coatings fall into this coating category [4]. All three are comprised of some amount of

paint nonvolatiles including the pigments, with the balance of their composition being some type of

organic solvent. High nonvolatiles formulations of coatings appear to be a principal method of choice

for controlling HAP emissions in large appliances surface coating operations. High nonvolatiles

formulations simply have a higher nonvolatiles to volatiles ratio than conventional coatings, typically

greater than 60 percent nonvolatiles by volume. Medium nonvolatiles formulations typically have 50 to
2-13

60 percent nonvolatiles by volume, and low nonvolatiles formulations have less than 50 percent

nonvolatiles by volume [1]. The questionnaire responses report that approximately 15,800,000 liters

of coating solids were used in 1997 to coat large appliances. Powder coatings make up 65%

(10,570,000 liters coating solids) of the total coatings used, waster-based coatings 15% (2,270,000

liters coating solids), and solvent-based coatings 20% (2,970,000 liters coating solids).

Powder coatings are comprised primarily of various types of plastic resin. These coatings

produce very low organic emissions relative to solvent-based coatings. Some references state that in

some cases, powder coatings may possibly emit up to 6 percent by mass E-caprolactam; however,

this substance is not a HAP[1, 18].

Water-based coatings contain at least 5 percent water by mass in the volatile (liquid) fraction. 

These coatings offer some advantages over conventional solvent-based coatings because they contain

significantly less organic solvent, and water-based coatings represent less of a fire risk than

solvent-based coatings. However, water-based coatings have longer drying times because water

evaporates more slowly than the organic solvents (which can have production impacts), and the water

content may present a corrosion problem for the application equipment [1, 4].

2.3 FACILITY OPERATIONS AND CURRENT INDUSTRY PRACTICES

There are several activities that take place to support the coating application process that may

contribute to HAP emissions. These activities include cleaning and pretreatment, mixing of paints and

thinners, storage of coatings and other solvents, wastewater, and adhesive usage. The following

section describes these activities in more detail.

2.3.1 Cleaning and Pretreatment

One of the most important activities in the surface coating industry is cleaning and pretreatment. 

Proper cleaning removes all organic and inorganic soils from the substrate prior to coating, which is

critical for achieving maximum performance from the coating, especially with powder coating. 

Cleaning and pretreatment can consist of numerous stages that include several types of chemical

washes, such as solvent cleaning, an acid wash, a phosphate wash, and a deionized water wash. 

Facilities use various combinations of these stages. Except for solvent cleaning and wetting oil

treatment, most stages do not emit any HAP or VOC emissions. Pretreatment and cleaning
2-14

requirements vary depending on the type of coating application and curing, as well as the type of metal

to be coated. 

2.3.2 Mixing

Paint mixing may be performed in an agitated 208 liter (55 gallon) drum, or it may be

performed by merging two different coating lines into one. Coating mixing is typically performed by the

coating manufacturer prior to shipment to a large appliances manufacturer’s facility. Some facilities

add water or solvent to the coating, which may be performed in a small mixing booth or it may be

automated. Some facilities combine reclaimed coatings from various coating applications and mix the

different coatings together in a 208 liter (55 gallon) drum. Mixing also varies depending on the type of

coating and usage requirements.

2.3.3 Coating Storage

Storage demands vary based on the type of coating and usage requirements. Container size

and type vary depending on coating manufacturer and end user needs. Most coatings are stored in

208 liter (55 gallon) drums. Powder coatings can also be stored in 208 liter (55 gallon) drums, as

long as the temperature and the humidity are controlled. To prevent moisture absorption, most

facilities store powder coatings in 23 kilogram (50 pound) cardboard boxes that are lined with plastic,

but the size of the container can vary from 1.4 to 136 kilograms (3 to 300 pounds) [19].

2.3.4 Wastewater Treatment

Since many of the operations employed by the large appliances surface coating operations

produce wastewater, some facilities have wastewater treatment systems on-site. Some of the activities

that produce wastewater include pretreatment, molten salt baths, some electrodeposition systems, and

many primer and topcoat systems. The effluent from their wastewater handling or treatment systems

must be acceptable to discharge either back into a body of water, or to the Publicly Owned Treatment

Works (POTW). Otherwise, they must perform some degree of wastewater treatment in order to

reach the levels specified by regulations. The effluent limitations for existing indirect discharges are

imposed by the EPA through National Pollution Discharge and Elimination Systems (NPDES) permits

[20].

2.3.5 Adhesives

Based on data obtained from the questionnaires, the typical application for large quantity

adhesive usage in the large appliances surface coating operations industry is attaching insulation to
2-15

metal substrates. Adhesives are also used to attach brake hubs in products such as washing machines. 

Small usage of adhesives include thread-lockers, PVC/CPVC adhesives, and other usages. Adhesives

are applied using spray guns, rollers, or by brush. Pressure sensitive adhesives, which are

characterized by a peel-off, self-stick backing, are also used.

2.4 EMISSIONS

Surface coating activities are a source of both VOC and HAP emissions. Because this

regulation only addresses volatile HAP emissions, they will be the only emissions discussed in this

section.

2.4.1 General

The typical unit operations at a large appliance surface coating operations that may result in

HAP emissions include:

•metal cutting and forming steps using cutting oils and lubricants

•metal surface cleaning and pretreating steps

•bonding of some component parts with adhesives

•application of one or more layers of coatings

•cleaning of coating application areas, conveyors, and coated parts

•storage of coatings and thinners in mix areas

•collection and disposal of waste materials

The coating application unit operation is by far the largest source of HAP emissions, accounting for an

estimated 80 percent of emissions from all of the listed activities.

The major HAPs emitted from large appliances surface coating operations are xylene (27% of

total HAPs), glycol ethers (21%), toluene (13%), methyl diphenyl diisocyanate (12%), and methyl

ethyl ketone (9%). While some HAPs, such as xylene or toluene, may be used as a single component

solvent, many are components of solvent blends [21]. 

2.4.2 Baseline Emissions

To determine the magnitude of the potential HAP reductions that may be achieved by the

proposed standards, the current level of emissions must first be determined. The HAP emissions level

that exist currently, in the absence of the proposed standards, is referred to as the baseline emission

level. Because the proposed standards only affect major sources (as defined in Chapter 1), baseline
2-16

emissions were calculated for the subset of the 1997 and 1998 industry questionnaire responses that

were believed to be potential major sources. 

Potential major sources were identified as: (1) those facilities that listed "major source" or

"synthetic minor source" as their Title V status on their questionnaire response, (2) those facilities that

reported their HAP emissions under "maximum design capacity" as greater than 9.1 Mg/yr (10 tpy),

and (3) other facilities that we judged to have the capacity to increase their HAP emissions to above

9.1 Mg/yr, even though they did not identify themselves as major or synthetic minor sources. 

Synthetic minor sources are defined as sources whose emissions are limited to levels below the

definition of a major source by their operating permits or other Federally enforceable commitments. 

Although these sources were included in the determination of the baseline emission level, no emission

reductions from these facilities is projected. 

The final group of facilities (criteria 3, above) were included because they reported actual HAP

emissions of greater than 3 Mg (3.3 tons) during the reporting year and did not report a "maximum

design capacity.” 

The database that resulted from applying these criteria contained 95 facilities and baseline HAP

emissions of approximately 2,400 Mg. Table 2-4 presents each potential major source facility and its

corresponding HAP emissions. Table A-1 provides a list of the 95 potential major source facilities and

the names of the states in which they are located.
2-17

TABLE 2-4 HAP EMISSIONS FROM POTENTIAL MAJOR SOURCE FACILITIES

Facility SIC Codes Activity

Total 1997

Coating solids

Usage (L)

Total 1997 HAP

Emissions (kg)

 1 3631 gas and electric ranges 167,606 4

2 3585 air conditioner units 18,110 114

3 3585 mix dispensing equip./vending machines 18,419 117

4 3585 air conditioners 109,954 316

5 3585 air conditioning, refrigerators, heating equip. 2,085 449

6 3585 hermetric compressors 11,634 458

7 3634 small kitchen appliances 7,485 817

8 3589 water purification systems 677 932

9 3585 commercial HVAC equipment 160,593 983

10 3585 commercial refrigeration display cases 64,850 997

11 3585 air conditioner units 8,247 1,018

12 3585 large commercial HVAC 730 1,087

13 3585 heat exchangers/air handling equipment 6,059 1,416

14 3632 refrigerators and freezers 26,351 1,493

15 3585 remanufactured refrigerant compressors 4,162 1,515

16 3556 soft serve ice cream/slush machines, gas grill 6,326 1,632

17 3632 refrigerators and freezers 57,559 1,793

18 3585 air conditioners 4,443 1,891

19 3585 heating/cooling units 157,622 2,069

20 3585 chiller refrigeration equipment 5,677 2,616

21 3585 refrigeration compressors 8,197 2,617

22 3585 evaporators, coolers, condensers, cooling

towers

1,807 2,821

23 3585 air handling equipment 5,029 3,027

24 3585 refrigerator display cases 136,836 3,036

25 3585 industrial refrigeration pressure vessels 3,682 3,065

26 3585 compressors, motors 1,562 3,401

27 3589 water filters 4,289,470 3,602

28 3589 food machines, mixers, scales 11,281 3,872

29 not provided not provided 12,446 3,890

30 3585 industrial refrigerators and heat exchangers 6,446 4,199

31 3585 hermetric compressors 43,312 4,535

32 3589 floor scrubber/sweeper 12,379 4,609

33 3585 commercial refrigerators 105,150 4,695

34 3589 various tanks 3,728 5,077

35 3639 ranges 722 5,314

36 3632 refrigerator compressors 15,144 5,552

37 3585 absorption units, chillers, compressors 26,411 5,677

38 3585 commercial and industrial air handler units 10,971 5,767

39 3639 air conditioning compressors 9,512 6,036
TABLE 2-4 HAP EMISSIONS FROM POTENTIAL MAJOR SOURCE FACILITIES

(Continued)

Facility SIC Codes Activity

Total 1997

Coating solids

Usage (L)

Total 1997 HAP

Emissions (kg)

2-18

40 3585 air handling equipment 3,984 7,423

4 1 3585 condensers, chillers 3,070 7,788

42 3585 refrigerant compressors 43,160 7,951

43 3585 air handling systems 6,590 8,029

44 3589,3631 grills, broilers, griddles 2,188 8,551

45 3589 food service equip., gas combustion equip. 341 8,774

46 3639 metal tanks 48,670 9,133

47 3585 refrigerated display cases 31,783 9,188

48 3585 refrigeration equipment 11,286 9,670

49 3639 food waste disposers, hot water dispensers 63,105 10,551

50 3585 air conditioners 4,169 11,523

51 3585 refrigeration equipment 20,438 11,688

52 3631 household cooking equipment 51,919 13,081

53 3633 washers and dryers 118,423 13,701

54 3585 commercial refrigeration 21,573 14,721

55 3585 chillers 12,043 14,796

56 3585 refrigerators 30,379 15,340

57 3632 refrigerators 6,615 16,323

58 3585 waste chillers 9,093 16,604

59 3631 gas and electric ranges 138,263 16,622

60 3632 refrigerators, cooking equip., ovens,

microwaves

417,969 17,344

61 3585 compressors, coils, industrial chillers 30,755 17,685

62 Unk unknown 1,633 19,005

63 3631 metal fabrication 32,657 19,971

64 3585 refrigerated display cases 29,310 20,635

65 3585 air conditioners, heating equipment 12,897 22,553

66 3639 range hoods, bath fans, garbage compactors 58,278 22,757

67 3585 water heaters 156,444 24,231

68 3631 microwaves 167,238 24,558

69 3585 evaporators, coolers, condensers, cooling

towers

5,212 25,409

70 3589 floor maintenance equipment 25,509 25,527

71 3632 refrigerator 33,069 26,739

72 3585 motor vehicle air conditioning 7,324 26,780

73 3585 dehumidifiers 68,656 26,994

74 3585 air conditioners, air cleaners 66,278 31,856

75 3632 household refrigerators 80,253 32,401

76 3585 air conditioners, gas heaters 346,102 43,450

77 3585,3632,

3639

air conditioners, refrigerators, dehumidifiers 105,966 64,947
TABLE 2-4 HAP EMISSIONS FROM POTENTIAL MAJOR SOURCE FACILITIES

(Concluded)

Facility SIC Codes Activity

Total 1997

Coating solids

Usage (L)

Total 1997 HAP

Emissions (kg)

2-19

78 3585 furnaces, heat pumps, gas grills 36,226 76,197

79 3639 water heaters 267,894 89,014

80 3633 laundry products 226,438 89,122

81 3633 clothes dryers 1,112,454 102,025

82 3639 dishwashers 515,602 116,031

83 3633 household laundry equipment 1,078,668 136,567

84 3633 washers and dryers 536,632 141,851

85 3585 heat transfer coils, coolers, ice machines 78,179 142,143

86 3633 household and commercial laundry 580,521 190,521

87 3632 refrigerators and trash compactors 133,146 295,256

88 3639 water heaters and water storage tanks 629,607 0

a

89 not provided not provided 77,912 0

a

90 not provided not provided --

b

–

b

91 not provided not provided --

b

--

b

92 3585 air handlers and furnaces --

b

--

b

93 3631 gas and electric ranges --

b

--

b

94 3633,3631,

3632,3639

laundry, ranges, refrigerators, dishwashers --

b

--

b

95 3635 central vacuums --

b

--

b

aThese facilities reported only powder usage and no other operations were reported (i.e., surface preparation,

cleaning, etc.).

bThese facilities did not provide sufficient data to determine the HAP emissions; however, because these facilities

are considered potential major sources on the basis of a facility’s statement or its potential to emit, the facilities

were counted as part of the potential major source population when determining the number that represented the

top 12% performing facilities.

Multiply Liters by 0.264 to obtain gallons

Multiply kilograms by 2.205 to obtain pounds
2-20

2.5 REFERENCES

1. Glossary for Air Pollution Control of Industrial Coating Operations, Second Edition, U. S.

Environmental Protection Agency, Office of Air Quality Planning and Standards, Research

Triangle Park, NC, EPA-450/3-83-013R. December 1983.

2. Finishing Systems Design and Implementation, Society of Manufacturing Engineers, Dearborn,

Michigan, J. L. Stauffer, Copyright 1993.

3. W. J. Fabini, “Back to Basics: A General Overview of Coatings Technology,” Paint &

Application: Industrial and Architectural 1996 FSCI International Coatings Technology

Conference, Federation of Societies for Coatings Technology, Blue Bell, PA. 1996.

4. Compilation of Air Pollutant Emission Factors, Volume I: Stationary, Point, and Area Sources,

Fifth Edition (AP-42), U. S. Environmental Protection Agency, Office of Air Quality Planning

and Standards, Office of Air and Radiation, Research Triangle Park, NC. January 1995.

5. Outlines of Paint Technology, Third Edition, W. M. Morgans, Halsted Press, 1990.

6. Industrial Paint Finishing Techniques and Processes, Gene F. Tank, Ellis Horwood Publishers,

NY, 1991.

7. Industrial Surface Coating: Large Appliances - Background Information for Proposed

Standards, U. S. Environmental Protection Agency, Office of Air Quality Planning and

Standards, Research Triangle Park, NC, EPA-450/3-80-037a. November 1980.

8. J. Lewis, J.N. Argyropoulos, and K.A. Nielson, “Supercritical Carbon Dioxide Systems”,

Metal Finishing. April 1997. pp. 33-41. Docket No. A-97-41, Item No. II-I-1.

9. A. Wojciechowski and J. Lewis, “Development of a Low VOC Chemical Agent Resistant

Coating (CARC) for use with Supercritical CO2,” International Waterborne, High-Solids, and
2-21

Powder Coatings Symposium, New Orleans, LA, February 1999. Docket No. A-97-41,

Item No. II-I-2.

10. “Powder Coating. Article downloaded from Georgia Department of Natural Resources

Pollution Prevention Assistance Division website http://www.ganet.org/dnr/p2ad. 2 pp. 

Docket No. A-97-41, Item No. II-I-5.

11. The Powder Coating Institute. Powder Coating: The Complete Finisher’s Handbook. C. J.

Krehbiel Company, Cincinnati, OH, 1994.

12. Correspondence from F. Lettice, South Coast Air Quality Management District, to K.

Summers, PES, Inc. Facsimile transmitting draft information about SCAQMD Method 316C

- Determination of Volatile Organic Content of Powdered Coatings. June 14, 2000. 16 pp. 

Docket No. A-97-41, Item No. II-D-436.

13. “The Benefits of Powder Coating - What Are Its Advantages?” Powder Coating Institute. 

Article downloaded from Powder Coating Institute website http://www.powdercoating.org. 1

p. Docket No. A-97-41, Item No. II-I-4.

14. “Pressure Sensitive Tapes and Labels: The Clean Air Act Amendments of 1990 and Pollution

Prevention Opportunities.” A study from NEWMOA, NESCAUM and the U.S. EPA. 

Article downloaded from Radtech International North America website

http://www.radtech.org/publications/publications.htm. 3 pp. Docket No. A-97-41, Item No.

II-I-6. 

15. A. Ross. ”Eliminating Air Pollution (VOC & HAP) at the Source Through the Use of 

Ultraviolet or Electron Beam Polymerization.” Radtech International North America. Article

downloaded from Radtech International North America website 

http://www.radtech.org. 5 pp. Docket No. A-97-41, Item No. II-I-3.
2-22

16. Telecon from K. Summers, PES, to A. Ross, RadTech. Discussion of volatile emissions

information on UV/EB coating. May 8, 2000. 2 pp. Docket No. A-97-41, Item No. II-E14.

17. The US EPA Website, es.epa.gov/program/epaorgs/ord/org-coat.html, “Guide To Cleaner

Technologies Organic Coating Replacements."

18. Control of Volatile Organic Emissions from Existing Stationary Sources Volume V: Surface

Coating of Large Appliances, U. S. Environmental Protection Agency, Office of Air and

Waste Management, Office of Air Quality Planning and Standards, Research Triangle Park,

NC, EPA-450/2-77-034. December 1977.

19. The Powder Coating Institute, Powder Coating, The Complete Finisher’s Handbook, First

Edition, C. J. Krehbiel Company, Cincinnati, OH, 1997.

20. B. T. Ray, “Regulations,” Environmental Engineering, PWS Publishing Company, Boston, MA,

1995. pp. 300-307.

21. Memorandum from P. Almodovar, EPA:CCPG, to CCPG Project Teams. "Petroleum

Solvent Blends and Associated HAP Contents", (undated). 4 pp. Docket No. A-97-41,

Item No. II-B-14.
3-1

3.0 EMISSION REDUCTIONS FROM COATING APPLICATIONS

This chapter presents information about the various methods of emission reduction and control

that are currently in use, or are available for use, at large appliances surface coating operations.

3.1 AIR POLLUTION CONTROL TECHNIQUES

There are many types of emission control technologies that could be used to reduce emissions

from large appliances surface coating operations. The most common method of volatile HAP emission

reduction utilized in surface coating operations is the reformulation of coating materials. Reformulation

refers to basic changes in the raw coating materials that allow them to perform their desired function

while containing a lower than typical percentage of HAP ingredients. Reformulation is a desirable

method of HAP emission reduction because it is a pollution prevention option that often achieves many

performance and cost benefits. While volatile HAP emissions are the primary concern in the proposed

standards, this chapter also presents brief descriptions of some of the most common particulate and

VOC control techniques.

3.1.1 Reformulation of Materials

3.1.1.1 Coating Solids (nonvolatiles) 

A coating is composed of a volatile and nonvolatile portion. The nonvolatiles will also be

referred to as coating solids to mean the portion of the coating material remaining after a coating dries

on the substrate. One method of emission control employed by the coating industry is to increase the

ratio of the nonvolatiles to volatiles in a particular coating. The goal is to use less organic solvent per

volume of nonvolatiles used for a job. This reduces the amount of organic solvent that is emitted in the

process. Coating formulations may be classified as high, medium, or low nonvolatiles. High

nonvolatiles coatings would be considered, for our purpose, to be any coating with a nonvolatiles

content above 60 percent nonvolatiles by volume. Medium nonvolatiles coatings are considered to be

between 50 percent and 60 percent nonvolatiles by volume. A low nonvolatiles coating is considered

to contain less than 50 percent nonvolatiles by volume. With all other variables held constant,

increasing the nonvolatiles in a coating formulation should produce lower HAP and lower VOC

emissions per unit volume of coating used [1].
3-2

For the existing industry, the primary short-term, and in some cases the long-term, solution to

reduce emissions is to switch from a lower nonvolatiles coating to a coating with a higher nonvolatiles

content. This solution is probably the most cost effective means of reducing emissions. In calculating

emissions from a coating, any cure volatiles that are HAP or VOC will need to be counted.

3.1.1.2 Water-based Coatings

A water-based coating uses water as the organic solvent rather than a traditional organic

solvent. This does not mean that a water-based coating has no organic solvent, it just means that there

is less organic solvent than if it were a traditional organic solvent-based coating. A water-based

coating is considered to be a coating that contains more than 5 percent by mass water in its volatile

fraction. Water-based coatings can have VOC contents less than 120 grams per liter (1.0 lb/gal) [1,

2].

The most commonly available water-based coatings include water-reducible alkyds and

modified alkyds, acrylic latexes, and acrylic/epoxy hybrids. Water-reducible coatings are available in a

wide range of colors and gloss levels. Typical applications include dipping primers and topcoats,

general purpose primers, and spray enamels [2].

3.1.1.3 Powder Coatings

The use of powder coatings, where applicable, provides an opportunity for significant emission

reduction. There are practically no organic HAP or VOC emissions during the application of powder. 

However, small amounts of cure volatiles are emitted from powder coatings during the oven cure

stage. The information on cure volatiles is sparse in the literature. However, there are data showing

that E-caprolactam (not a HAP or VOC) is emitted from certain powder coatings [3]. Formaldehyde

may also be emitted from certain powder coatings. The nature of the cure volatiles can be determined

through testing. Other emissions from powder coating result during cleaning of part hangers used to

move the parts along the coating line. Even considering these emissions, the powder coating system

offers emission reductions that can only be matched by the best performing add-on control devices [3].

3.1.1.4 Add-on Control Devices

There are many types of emission control technologies that could be used to reduce emissions

from large appliances surface coating operations. While the most common method of volatile HAP

emission reduction utilized in surface coating operations is the reformulation of coating materials, addon control devices are another technique available for use in reducing HAP emissions. The responses
3-3

to the industry questionnaires provided information on seven such devices located at five facilities. 

Add-on control devices are discussed in the memorandum entitled “Available Add-on Control Devices

for Use in the Large Appliances NESHAP” (Docket No. A-97-41, Item No. II-B-11). The

memorandum describes the types of add-on control devices and presents the monitoring requirements

for these devices and the rationale for selecting these monitoring parameters.

3.2 POLLUTION PREVENTION (SOURCE REDUCTION)

Steps that can be taken to eliminate the generation of pollutants at the source are the preferred

approach to reducing HAP emissions. In surface coating operations, there are numerous opportunities

to implement pollution prevention measures. In addition to the use of lower-HAP coatings, the use of

non-HAP or lower-HAP surface preparation materials and cleaning materials results in the generation

of less HAP emissions. Likewise, the conversion of conventional organic solvent-based coating

operations to water-based or powder coatings reduces the generation and release of HAP emissions. 

The increased use of technologies that reduce the overall amount of organic solvents in coating

materials can serve as pollution prevention measures. The EPA welcomes comments and

recommendations from the industry and the public on additional pollution prevention measures that may

be implemented within large appliances surface coating operations.

3.3 EQUIPMENT CHANGES

One of the major factors in making changes to application equipment as a control measure is

transfer efficiency. With higher transfer efficiencies less coating is used to coat the same amount of

product, resulting in less emissions. Transfer efficiency itself is not simple to quantify. However, some

application equipment clearly has a better transfer efficiency than other equipment. For example, a

rotational electrostatic spray system typically has a higher transfer efficiency than a simple manual spray

gun [2, 4]. A description of the major coating application technologies and their associated transfer

efficiencies is presented in Section 2.2.

3.4 DESIGN AND OPERATIONAL CHANGES

Air recirculation can be used to reduce capital and operating costs of the air handling system. 

Recirculation can also reduce air flow streams to oxidizers, allowing a smaller control system to be
3-4

installed. Typical air recirculation systems filter, dehumidify, and return 10 to 80 percent of exhausted

air to the supply air stream of a spray system. The remaining air is sent to the HAP/VOC control

system [2].

This type of system is most viable for automated systems because it can be hazardous to

personnel in manual spray areas. It can only be used for manual spray systems if the personnel are

very well protected from the high organic solvent concentrations [2].

Air cascading systems can alleviate the employee risk problems concerning manual spray

areas. In this type of scenario, exhausted air from a manual spray system can be used as supply air for

an automated system (after particulate and humidity control). Therefore, the organic solvent rich air is

cascaded to an automated coating line where there are no employees to be harmed by the air [2].

3.5 WORK PRACTICES

3.5.1 Material Storage and Handling

Storage demands vary based on the type of coating and usage requirements. Container size

and type vary depending on coating manufacturer and end user needs. Most coatings are stored in

208 liter (55 gallon) drums. Powder coatings can also be stored in drums, as long as the temperature

and the humidity are controlled. Most facilities store powder coatings in 23 kilogram (50 pound)

cardboard boxes that are lined with plastic to prevent moisture absorption, but the size of the container

can vary from 1.4 to 136 kilograms (3 to 300 pounds) [2].

These containers should be well maintained to prevent leakage and excessive spillage or

material loss during transfer to other containers or coating equipment. They should also remain sealed

except when it is necessary to remove material from the containers, after which they should be

promptly closed again.

3.5.2 Fluid Handling Equipment

All fluid handling equipment such as coating lines, holding tanks, coating storage containers, or

any fluid handling equipment that contains a VOC or HAP containing coating should be well

maintained to prevent spills, leaks, or other problems that would release some of the contents of the

fluid handling system.

3.5.3 Mixing Operations
3-5

Coating mixing may be performed in an agitated 208 liter drum, or it may be performed by

merging two different coating lines into one. Coating mixing is typically performed at the coating

manufacturer prior to shipment to a large appliances surface coating operation. Some operations add

water or organic solvent to the coating, which may be performed in a small mixing booth or it may be

automated. Some operations combine reclaimed coatings from various coating applications and mix

the different coatings together in a 208 liter drum. Mixing also varies depending on the type of coating

and usage requirements [2].

3.5.4 Spraying Operations and Cleaning

Nozzle maintenance, although often overlooked, is a critical component of any metal

pretreatment system. In order to keep the system running at maximum efficiency to produce the

highest-quality finished product, nozzle maintenance must become a regular part of system operation

[5].

Improperly maintained nozzles decrease spray impact and distort spray patterns, reducing

cleaning efficiency. As a result, more time will be spent and more chemicals will be used to accomplish

cleaning tasks [2].

Learning to identify, solve, and prevent spray nozzle performance problems in a parts washer

can cut spray liquid and energy waste, assure better washer performance, and reduce chances of

equipment damage. The same holds true for coating spray nozzles [2].

Typical cleaning activities involve organic solvent wipes, dips, and spraying of pure organic

solvent which can contribute to the emissions from a facility. The amount of organic solvent released in

this manner should be minimized to reduce emissions [2].
3-6
3-7

3.6 REFERENCES

1. Glossary for Air Pollution Control of Industrial Coating Operations, Second Edition, U. S.

Environmental Protection Agency, Office of Air Quality Planning and Standards, Research

Triangle Park, NC, EPA-450/3-83-013R. December 1983.

2. ‘97 Organic Finishing Guidebook and Directory Issue, Volume 95, Number 5A, Metal

Finishing, Tarrytown, NY, May 1997.

3. "VOC’s in Powder Coatings." Technical Brief. Morton Powder Coatings. Article

downloaded from Morton Powder Coatings website

http://www.mortonpowder.com/morton_pages/learn_more/techbriefs.vocs.htm. 2 pp. 

Docket No. A-97-41, Item No. II-I-7.

4. Compilation of Air Pollutant Emission Factors, Volume I: Stationary, Point, and Area Sources,

Fifth Edition (AP-42), U. S. Environmental Protection Agency, Office of Air Quality Planning

and Standards, Office of Air and Radiation, Research Triangle Park, NC. January 1995.

5. The Powder Coating Institute, Powder Coating, The Complete Finisher’s Handbook, First

Edition, C. J. Krehbiel Company, Cincinnati, OH, 1997.
4-1

4.0 MODEL PLANTS AND COMPLIANCE OPTIONS

The model plants that have been developed for the large appliances NESHAP project are

presented in Tables 4-3 through 4-6. Four model plants were developed to represent the facilities in

the database that have been projected to be potential major sources, and thus, subject to this

rulemaking. The following paragraphs present the methodology used to develop the model plants and

the rationale for the assumptions that were made. A model plant does not represent any single actual

facility, but rather it represents a range of facilities with similar characteristics that may be impacted by

a standard. Each model plant is characterized in terms of facility size and other parameters that affect

the estimates of emissions, control costs, and secondary environmental impacts. The model plants

developed for this source category incorporate the baseline characteristics presented in this chapter.

The reductions in HAP emissions that will be required by these standards is expected to be

achieved through the use of a combination of low-HAP and zero-HAP liquid coatings, thinning

solvents, cleaning materials, and powder coatings. As described in Chapter 5 and the memorandum

documenting the development of the MACT floor (Docket Item No. II-B-9), these low-HAP

materials are in use at some facilities within the source category now, and are believed to be available

for use by the entire source category. Because complying low-HAP material technology is believed to

be available, none of the model plants are assumed to use add-on control devices. 

The first step in developing the model plants was to decide on an approach to characterize the

facilities in the database. Because this project focuses on the surface coating and related operations, it

was decided that parameters related to the surface coating performed at each facility was the best way

to characterize the model plants. Our analysis of the questionnaire responses, site visit reports, and

other data available to us did not reveal patterns in the types of coatings or cleaning materials used, the

application methods used, or the overall emissions that could be used to group the facilities into subsets

for modeling. Tables 4-1 and 4-2 present information showing the distribution of coating application

methods and coating types across the source category. The quantity of coating solids (nonvolatiles)

annual usage appeared to be the most logical parameter to use to define the models because it relates

directly to the level of production. Therefore, liters of coating solids used was chosen as the parameter

by which the model plants would be defined.
4-2

TABLE 4-1. COATING APPLICATION METHODS VERSUS SIC CATEGORY

Coating

Application

Method

Number of Facilities Using Each Application Methoda

Totals

SIC 3585 SIC 3589 SIC 3631 SIC 3632 SIC 3633 SIC 3639

Dip coating 13 2 4 3 6 6 34

Air spray 24 3 6 1 2 2 38

Airless spray 8 2 NR NR 1 1 12

Air-assisted

airless spray

17 2 1 2 NR 2 24

Electrostatic

spray

30 5 7 3 6 8 59

Rotary bell/

disk

2 NR NR 1 3 2 8

HVLP 17 7 2 1 2 29

Totals 111 21 20 10 19 23 204

a

Facilities reporting more than one method are listed under each of the methods that they use.

Note: NR means this technology was not reported in the SIC category.

TABLE 4-2. COATING TYPE VERSUS SIC CATEGORY

Coating 

Type

SIC CODE

SIC 3585 SIC 3589 SIC 3631 SIC 3632 SIC 3633 SIC 3639

Solvent-based 10.90% 0.00% 27.50% 2.00% 28.90% 48.80%

Water-based 47.90% 1.20% 13.60% 98.00% 25.10% 20.20%

Powder 41.20% 98.80% 58.90% 0.00% 45.90% 31.00%

The MACT floor database contains questionnaire responses from 95 potential major source

facilities. To determine the size characteristics of the model plants, the 95 facilities in the database

were sorted by total volume of coating solids used, with reported values ranging from less than 100
4-3

liters to over 1,000,000 liters. An evaluation of various size ranges that could be created from the

database resulted in a decision to develop four groups of facilities, each to be represented by a model

plant. The groups were characterized by total coating solids used, as follows: (1) up to 10,000 liters

of solids represented by a model plant using 5,000 liters; (2) 10,001 to 50,000 liters of solids

represented by a model plant using 25,000 liters; (3) 50,001 to 200,000 liters of solids represented by

a model plant using 100,000 liters of solids; and (4) greater than 200,000 liters of solids represented

by a model using 625,000 liters. Key parameters used to define each model plant were derived from

an analysis of the actual facilities within the size range represented by the model. Because many of the

questionnaire responses were incomplete, a subset of the database consisting of 66 facilities was used

to calculate the average values used as parameters to define the model plants. These 66 facilities were

believed to provide an adequate representation of the entire database of potential affected facilities. 

The 66 facilities cover the manufacturing of all major product types found within the source category,

they include facilities that use small amounts of surface coating materials and 2 of the 3 largest users of

surface coatings, they include all types of coating materials and application techniques reportedly used

in the source category, and they include facilities covering all NAICS/SIC codes within the source

category. Table 1-1 presents a listing of the products and the corresponding NAICS and SIC codes.

 Tables 4-7 through 4-10 present the data used for the development of the model plants. Each

row of data in these tables lists the HAP content and coating solids derived from the material usage

and formulation information provided by one facility. The HAP emission rate for a facility, kg HAP/L

coating solids (the last column in Tables 4-7 through 4-10), was determined by first adding all the HAP

content shown in a row and dividing that value by the sum of the coating solids values. The rows were

sorted and arranged in order of increasing coating solids usage. Table 4-7 contains information for all

facilities that reported up to 10,000 liters of solids

 usage, which was used as the basis for defining model plant number 1. Tables 4-8 through 4-10

present the information used to define model plants 2 through 4, respectively. The HAP and coating

solids values in each column were summed and divided by the number of facilities to
4-4

generate an average value that is characteristic of the model plant. The average total coating solids

usage value was then rounded for use in defining each model plant. All other HAP and coating solids

usage values were adjusted (scaled up) by the ratio of the average total coating solids to the rounded

total coating solids. [For example, the average total coating solids usage for the facilities in Table 4-7 is

4,254 liters, which was rounded to 5,000 liters. The average HAP content of the water based

coatings used by these facilities is 241 kg, which was scaled up to 283 kg (241 kg * 5,000 L / 4,254

L) for model plant number 1. Each of the other parameters were calculated by the same procedure.] 

The characteristic parameters for model plants 1 through 4 are shown in Tables 4-1 through 4-4,

respectively. 

Each of the four model plants has some level of material usage, and some HAP emissions, for

all of the coating operations included within our affected-source-wide MACT floor approach. 

Therefore, each model plant has values for coatings, thinning, surface preparation, cleaning, and

adhesives. While it is clear that in actual practice not every facility will employ all types of materials,

the use of these materials is widespread within each size grouping of facilities. However, the coating

technologies used within the four size groupings does exhibit a pattern that was included in the model

plants. Water based coatings and solvent based coatings are used extensively in all sizes of facilities,

but the use of powder coatings is much more common in larger facilities. For this reason, the two

smallest model plants use only water based and solvent based coatings, while the two largest model

plants use all three types of coatings.

To summarize, there are currently 95 potential major source facilities in the database that were

used to develop the MACT floor. Data from 66 of these facilities were used to develop the

characteristics of the 4 model plants because these facilities provided the most complete information. 

The characteristics of the 66 facilities that provided the most complete information are representative of

the other 29 facilities in the database. Of the 95 facilities in the database, 21 facilities are classified as

"synthetic minor sources" and, therefore, 74 facilities were assumed to be the population of affected

sources. Model plant number 1, using 5,000 liters of solids, represents 26 facilities. Model plant

number 2, using 25,000 liters of solids, represents 19 facilities. Model plant number 3, using 100,000

liters of solids, represents 17 facilities. Model plant number 4, using 625,000 liters of solids,

represents 12 facilities. 
4-5

 
4-6

TABLE 4-3. MODEL PLANT NUMBER 1 

(UP TO 10,000 LITERS OF COATING SOLIDS)

Plant Definition

HAP

(kg)

Density

(g/l)

Coating

Solids

(liters)

% Coating

Solids

Total

Usage

(liters)

Total Usage

(gallons)

Water-based Coatings 283 1,186 793 31 2,558 676

Solvent-based Coatings 1,872 1,189 3,794 42 9,011 2,381

Powder Coatings 0 0 100 0 0

Thinning Solvents 630 876 0 0 719 190

Surface Preparation 378 991 0 0 381 101

Cleaning Solvents 721 991 0 0 728 192

Adhesives 3 954 413 47 886 234

Total 3,887 5,000 14,284 3,774

 kg HAP/L coating solids =0.777

Notes:

Thinning and cleaning solvents are considered 100% HAP

Total Usage for coatings and adhesives= Coating Solids/(% Coating Solids/100)

Total Usage for solvents = HAP/(density/1000)
4-7

TABLE 4-4. MODEL PLANT NUMBER 2 

(10,001 TO 50,000 LITERS OF COATING SOLIDS)

Plant Definition

HAP

(kg)

Density

(g/l)

Coating

Solids

(liters)

% Coating

Solids

Total Usage

(liters)

Total

Usage

(gallons)

Water-based Coatings 708 1,186 4,741 31 15,294 4,041

Solvent-based Coatings 8,357 1,189 19,612 42 46,584 12,308

Powder Coatings 0 0 100 0 0

Thinning Solvents 1,955 876 0 0 2,232 590

Surface Preparation 324 991 0 0 327 86

Cleaning Solvents 3,242 991 0 0 3,271 864

Adhesives 648 954 647 47 1,388 367

Total 15,234 25,000 69,096 18,255

 kg HAP/L coating solids = 0.609

Notes:

Thinning and cleaning solvents are considered 100% HAP

Total Usage for coatings and adhesives= Coating Solids/(% Coating Solids/100)

Total Usage for solvents = HAP/(density/1000)
4-8

TABLE 4-5. MODEL PLANT NUMBER 3 

(50,001 TO 200,000 LITERS OF COATING SOLIDS)

Plant Definition

HAP

(kg)

Density

(g/l)

Coating

Solids

(liters)

% Coating

Solids

Total

Usage

(liters)

Total Usage

(gallons)

Water-based Coatings 4,102 1,186 30,299 31 97,739 25,823

Solvent-based Coatings 11,212 1,189 42,079 42 99,950 26,407

Powder Coatings 0 26,918 100 26,918 7,112

Thinning Solvents 6,500 876 0 0 7,420 1,960

Surface Preparation 229 991 0 0 231 61

Cleaning Solvents 7,340 991 0 0 7,407 1,957

Adhesives 53 954 704 47 1,511 399

Total 29,436 100,000 241,175 63,719

 kg HAP/L coating solids = 0.294

Notes:

Thinning and cleaning solvents are considered 100% HAP

Total Usage for coatings and adhesives= Coating Solids/(% Coating Solids/100)

Total Usage for solvents = HAP/(density/1000)
4-9

TABLE 4-6. MODEL PLANT NUMBER 4 

(GREATER THAN 200,000 LITERS OF COATING SOLIDS)

Plant Definition

HAP

(kg)

Density

(g/l)

Coating

Solids

(liters)

% Coating

Solids

Total

Usage

(liters)

Total Usage

(gallons)

Water-based Coatings 24,460 1,186 162,884 31 525,432 138,820

Solvent-based Coatings 31,544 1,189 160,112 42 380,314 100,479

Powder Coatings 0 292,908 100 292,908 77,387

Thinning Solvents 42,992 876 0 0 49,078 12,966

Surface Preparation 122 991 0 0 123 33

Cleaning Solvents 15,408 991 0 0 15,548 4,108

Adhesives 10,709 954 9,096 47 19,519 5,157

Total 125,235 625,000 1,282,922 338,949

 kg HAP/L coating solids = 0.200

Notes:

Thinning and cleaning solvents are considered 100% HAP

Total Usage for coatings and adhesives= Coating Solids/(% Coating Solids/100)

Total Usage for solvents = HAP/(density/1000)
4-10

TABLE 4-7 DATA FOR MODEL PLANT NUMBER 1

A B C D E F G H I J K L M N O

SIC Codes Water Based Solvent Based Powder Thinning Surface Prep Cleaning Adhesives Total HAPs Total

Coating

Solids

HAP Emission Rate

HAP (kg) Coating

Solids (L)

HAP (kg) Coating

Solids (L)

HAP (kg) Coating

Solids (L)

HAP (kg) HAP (kg) HAP (kg) HAP (kg) Coating

Solids (L)

(kg) (L) (kg HAP/L coating

solids)

3589 564 677 215 153 932 677 1.376

3585 1087 730 1087 730 1.49

3589 74 40 472 174 749 720 789 0.913

3585 3044 920 491 0 3535 920 3.844

3585 244 1472 15 90 3142 3401 1562 2.177

3585 1066 1807 1720 35 2821 1807 1.562

3585 444 1995 5 90 449 2085 0.215

3589, 3631 894 2188 367 2470 4820 8551 2188 3.908

3585 65 588 1580 2482 1367 1633 3143 7788 3070 2.537

3585 1669 3427 435 2104 3427 0.614

3585 732 3682 310 1042 3682 0.283

3589 2337 3728 1010 1730 5077 3728 1.362

3585 6213 3984 1210 7423 3984 1.863

3585 1515 4162 1515 4162 0.364

3585 61 277 1470 4166 360 1891 4443 0.426

3585 2517 5029 510 3027 5029 0.602

3585 2286 5677 330 2616 5677 0.461

3585 3656 6446 543 4199 6446 0.651

3585 3039 6590 4260 730 8029 6590 1.218

3634 360 4599 457 2886 817 7485 0.109

3585 2607 5289 69 2365 2676 7654 0.35

3585 1667 8197 950 2617 8197 0.319

3585 705 2161 220 766 93 0 5320 1018 8247 0.123

3639 2387 939 1035 8573 2041 573 6036 9512 0.635

AVERAGE 241 675 1593 3228 0 0 536 322 613 3 351 3307 4254 0.777

ROUNDED 283 793 1872 3794 0 0 630 378 721 3 413 3887 5000 0.777

NOTES: Information in this table was obtained from the responses to the 1998 industry questionnaires. Responses are located in Docket A-97-41, Category II-D. 

 Column O (HAP Emission Rate) = Columns (B+D+F+H+I+J+K) ÷ Columns (C+E+G+L) 
4-11

TABLE 4-8 DATA FOR MODEL PLANT NUMBER 2

A B C D E F G H I J K L M N O

SIC Codes Water Based Solvent Based Powder Thinning Surface Prep Cleaning Adhesives Total HAPs Total

Coating

Solids

HAP Emission Rate

HAP (kg) Coating

Solids (L)

HAP (kg) Coating

Solids (L)

HAP (kg) Coating

Solids (L)

HAP (kg) HAP (kg) HAP (kg) HAP (kg) Coating

Solids (L)

(kg) (L) (kg HAP/L coating

solids)

3585 390 3580 2120 6256 624 303 2260 70 1135 5767 10971 0.526

3589 1475 11268 2397 0 13 3872 11281 0.343

3585 885 3208 2085 8078 6700 9670 11286 0.857

3585 458 11634 458 11634 0.039

3585 704 5193 7866 6796 26 6138 62 54 14796 12043 1.229

3585 20012 12897 2541 0 22553 12897 1.749

3632 1057 0 4023 19137 404 67 5551 19137 0.29

3585 473 20438 7985 3230 11688 20438 0.572

3585 4782 21573 8579 1360 14721 21573 0.682

3585 5269 22269 1160 4 6433 22269 0.289

3585 543 25013 440 983 25013 0.039

3589 22370 25509 2887 270 0 25527 25509 1.001

3632 303 26351 360 830 1493 26351 0.057

3585 6579 29310 156 13900 20635 29310 0.704

3585 8742 30379 1213 5385 15340 30379 0.505

3585 1948 15079 3112 9326 5280 1912 5433 6350 17685 30755 0.575

3632 7069 33069 2470 17200 26739 33069 0.809

3585 59771 31297 9497 6929 4929 76197 36226 2.103

3585 4114 4535 39198 4535 43312 0.105

3639 8220 48629 31 41 192 690 9133 48670 0.188

AVERAGE 683 4572 8058 18910 0 0 1885 312 3126 625 624 14689 24106 0.609

ROUNDED 708 4741 8357 19612 - - 1955 324 3242 648 647 15234 25000 0.609

 

 NOTES: Information in this table was obtained from the responses to the 1998 industry questionnaires. Responses are located in Docket A-97-41, Category II-D. 

 Column O (HAP Emission Rate) = Columns (B+D+F+H+I+J+K) ÷ Columns (C+E+G+L) 
4-12

TABLE 4-9 DATA FOR MODEL PLANT 3

A B C D E F G H I J K L M N O

SIC Codes Water Based Solvent Based Powder Thinning Surface Prep Cleaning Adhesives Total HAPs Total Coating

Solids

HAP Emission

Rate

HAP (kg) Coating

Solids (L)

HAP (kg) Coating

Solids (L)

HAP (kg) Coating

Solids (L)

HAP (kg) HAP (kg) HAP (kg) HAP (kg) Coating

Solids (L)

(kg) (L) (kg HAP/L

coating solids)

3632 655 57559 69 479 590 1793 57559 0.031

3639 0 42296 9538 15982 809 12410 22757 58278 0.39

3639 10551 63105 0 10551 63105 0.167

3585 17575 64291 13455 35 0 791 1987 31856 66278 0.481

3585 0 2085 14551 58031 4248 8195 0 8540 26994 68656 0.393

3585 8801 43493 32209 34686 51195 49938 142143 78179 1.818

3632 553 80253 11087 20761 32401 80253 0.404

1795 1478 0 103672 2900 4695 105150 0.045

3632, 3639 5250 78520 57947 27446 1470 280 64947 105966 0.613

3585 4057 108241 91 5040 9188 108241 0.085

3633 6266 93399 0 25024 185 7250 13701 118423 0.116

3631 6617 106731 4136 15008 452 2050 13255 121739 0.109

12940 9747 147 0 128369 3682 16622 138263 0.12

17624 11419 0 145025 6437 170 24231 156444 0.155

3631 17116 106615 573 60623 3909 2960 24558 167238 0.147

AVERAGE 4085 30173 11165 41904 0 26806 6473 228 7310 53 702 29313 99585 0.294

ROUNDED 4102 30299 11212 42079 - 26918 6500 229 7340 53 705 29435 100000 0.294

 NOTES: Information in this table was obtained from the responses to the 1998 industry questionnaires. Responses are located in Docket A-97-41, Category II-D. 

 Column O (HAP Emission Rate) = Columns (B+D+F+H+I+J+K) ÷ Columns (C+E+G+L) 
4-13

TABLE 4-10 DATA FOR MODEL PLANT NUMBER 4

A B C D E F G H I J K L M N O

SIC Codes Water Based Solvent Based Powder Thinning Surface Prep Cleaning Adhesives Total HAPs Total Coating

Solids

HAP Emission

Rate

HAP (kg) Coating

Solids (L)

HAP (kg) Coating

Solids (L)

HAP (kg) Coating

Solids (L)

HAP (kg) HAP (kg) HAP (kg) HAP (kg) Coating

Solids (L)

(kg) (L) (kg HAP/L

coating solids)

3633 35707 148526 0 77912 36820 840 15755 89122 226438 0.394

3639 33317 266654 15012 39999 686 1240 89014 267894 0.332

3639 6975 86183 6466 29894 0 397851 92400 0 10248 1287 116089 515215 0.225

3633 58133 178182 0 301163 12108 10770 60840 57287 141851 536632 0.264

3633 0 100992 64414 256996 0 219512 108546 15350 2211 3021 190521 580521 0.328

3633 104052 676678 4399 52164 0 349826 3544 24572 136567 1078668 0.127

3633 57956 261434 15485 173724 0 677296 28584 102025 1112454 0.092

AVERAGE 24140 160755 31132 158020 0 289080 42431 120 15207 10569 8976 123598 616832 0.2

ROUNDED 24460 162884 31544 160112 - 292908 42992 122 15408 10709 9095 125235 625000 0.2

 NOTES: Information in this table was obtained from the responses to the 1998 industry questionnaires. Responses are located in Docket A-97-41, Category II-D. 

 Column O (HAP Emission Rate) = Columns (B+D+F+H+I+J+K) ÷ Columns (C+E+G+L) 
5-1

5.0 REGULATORY APPROACH

This chapter presents the approach used to determine the MACT floor level of control for new

and existing facilities in the large appliances surface coating source category. 

5.1 BACKGROUND

Section 112 of the CAA requires that we establish NESHAP for the control of HAP from

both new and existing major sources. The CAA requires the NESHAP to reflect the maximum degree

of reduction in emissions of HAP that is achievable. This level of control is commonly referred to as

the MACT.

The MACT floor is the minimum control level allowed for NESHAP and is defined under

section 112(d)(3) of the CAA. In essence, the MACT floor ensures that the standard is set at a level

that assures that all major sources achieve the level of control at least as stringent as that already

achieved by the better-controlled and lower-emitting sources in each source category or subcategory. 

For new sources, the MACT floor cannot be less stringent than the emission control that is achieved in

practice by the best-controlled similar source. The MACT standards for existing sources can be less

stringent than standards for new sources, but they cannot be less stringent than the average emission

limitation achieved by the best-performing 12 percent of existing sources in the category or

subcategory (or the best-performing five sources for categories or subcategories with fewer than 30

sources).

In developing MACT, we also consider control options that are more stringent than the floor. 

We may establish standards more stringent than the floor based on the consideration of the cost of

achieving the emission reductions, any non-air quality health and environmental impacts, and energy

requirements.

5.2 MACT FLOOR APPROACH

Within the large appliances industry, organic HAP emission control for cleaning and surface

coating operations is accomplished primarily through the use of lower-HAP coatings, thinners, and

cleaning materials. Add-on capture and control systems for organic HAP are rarely used by the

industry. While lower organic HAP materials have achieved broad use throughout the industry, each
5-2

particular coating technology is not used at every facility. Rather, facilities use various combinations of

low-HAP coatings, thinning solvents (thinners), and cleaning materials. Thus, we judged the most

reasonable approach to establishing a MACT floor to be the evaluation of a facility’s organic HAP

emissions from all coating-related operations. To account for differences in production levels from one

facility to another, we normalized the organic HAP emissions by the volume of coating solids used to

calculate the emision rate. We believe coating solids usage is an appropriate indicator of overall

production level. 

We used information obtained from industry responses to a 1998 questionnaire submitted

under the authority of Section 114 to calculate the source-wide organic HAP emission rate from each

survey respondent. The questionnaire was submitted to all known large appliance manufacturers, and

the responses represent the most complete (and most current) information available to us. Of the 222

facilities that provided responses to the questionnaire, 95 were found to be potential major sources,

with 21 of these identified as synthetic minor sources. Table 5-1 presents a summary of data extracted

from the responses submitted by the 95 potential major sources and used in developing the MACT

floors. We calculated total organic HAP emissions by assuming that 100 percent of the organic HAP

in all coatings (including adhesives), thinners, and cleaning materials (including surface preparation

materials) is emitted. This is a reasonable assumption for coatings and thinners, because coated

substrates are generally cured in an oven, which will accelerate the release of HAP containing volatile

materials. We also expect that a large portion of cleaning solvents will evaporate during the application

operation and from waste solvent. Major sources were identified as: (1) those facilities that listed

"major source" or "synthetic minor source" as their Title V status on their questionnaire response, (2)

those facilities that reported their HAP emissions under "maximum design capacity" as greater than 9.1

Mg/yr (10 tpy), and (3) other facilities that were judged to have the capacity to increase their HAP

emissions to greater than 9.1 Mg/yr, based on their reported emissions. Facilities that were included

as a result of item (3) were those that did not report a "maximum design capacity," but did report

actual emissions of greater than 3 Mg (3.3 tons) during the reporting year. These facilities were

assumed to be operating one shift per day and to have the capacity to operate three shifts per day,

resulting in emissions of greater than 9.1 Mg per year.

The questionnaire response information from the 95 potential major source facilities was used

to determine the total source-wide HAP emissions and the total volume of coating solids used by each
5-3

facility from all types of coatings. Data provided in the responses to the questionnaires were reviewed

for completeness and, where needed, were converted to consistent Metric units. In some cases where

facilities did not provide complete information on the quantity or formulation of materials in the

requested units, a default value for material density was used to enable conversion between units of

mass and volume. The default values were calculated by averaging the values reported by all other

respondents for similar types of materials. Table 5-2 presents the default density values that were used

when necessary for unit conversions. The HAP and solids contents of all materials used at each facility

were summed by material type (water-based, solvent-based, powders, thinners, surface prep,

cleaners, and adhesives) to yield the source-wide data presented in Table 5-1. We included

decorative, protective, and functional coatings as well as thinners and surface preparation materials in

this total.

Using the source-wide organic HAP emissions and the total volume of coating solids used for

each survey respondent, we calculated the normalized organic HAP emission rate in units of kilograms

organic HAP per liter of coating solids used. This value is presented on Table 5-1 in column P, titled

"HAP emission rate." Using the column headings A through R in Table 5-1 for reference, the equation

for this calculation is as follows:

(C+E+G+I+J+K+L) ÷ (D+F+H+M) = HAP emission rate

The facilities were then ranked from the lowest emission rate to the highest (sorted in ascending

order based on the values in column P). We did not include in the MACT floor calculations facilities

which: (1) did not report any cleaning material usage or did not provide sufficient coating material

formulation data; (2) reported more than 90% of their coating solids as being from powder coatings;

and (3) used an unusually large percentage of low HAP and non HAP adhesives. The facilities that

were excluded from the MACT floor calculations are indicated by the footnotes in Table 5-1. Only

those facilities that were evaluated as MACT floor facilities and excluded from the top 12 percent

were assigned a footnote in Table 5-1. We excluded facilities that did not report any cleaning material

usage or did not provide adequate coating material formulation data because we did not have

confidence that the final calculated HAP emission rate value would represent all their emissions. 

Facilities that reported the predominant use of powder coating technology (greater than 90 percent of

all coating solids usage) were excluded from the MACT floor calculations. While powder coating

technology is a proven low-HAP coating technology, its applicability is not considered to be universal
5-4

for all products manufactured within the source category. For those facilities whose products can be

coated with this technology, powder coatings are a very effective and efficient means of reducing HAP

emissions. However, because not all large appliance parts and products can be satisfactorily coated

with powder coating technology, we concluded that it would not be appropriate to define the MACT

floors based primarily on their use. We excluded facilities with very low organic HAP to coating solids

ratios due to use of unusually large quantities of low-HAP and non-HAP adhesives. The low- and

non-HAP adhesive usage for these facilities ranged from 40 to 84 percent of all coating solids. While

many facilities in this source category use adhesives, their use is not as widespread compared to the

decorative and protective coatings usually associated with the appearance of large appliance products. 

On the average, adhesives account for about 4 percent of the total coating solids used by the facilities

in the database. Because of the specific function served by adhesives, the low-HAP adhesives

technology employed in these coatings may not be transferrable to decorative coatings and protective

coatings which account for the remaining 96 percent of the coating solids usage in the surce category. 

Thus, we concluded that the facilities using atypically large quantities of these adhesives relative to

decorative and protective coatings should not be included in the determination of the floors for new

and existing sources.

5.3 EXISTING SOURCES

For the existing source MACT floor, the top 12 percent of the facilities were determined

based on the number of facilities in the MACT floor database (95 database facilities x 12 percent =

11.4). Because the calculated value was greater than 11, we used data from 12 facilities to determine

the MACT floor. The floor was calculated as the arithmetic average of the emission rates of the top

12 best-performing representative facilities. These 12 facilities are identified in Table 5-1 by the

shaded rows.

This process resulted in a MACT floor equal to 0.134 kg HAP/L of coating solids. For the

proposed standards this value was rounded to two significant figures, i.e., 0.13 kg HAP/L of coating

solids (1.1 lb/gal). The MACT floor facilities are typical of the remaining facilities in the database in

terms of the substrates coated, the coating and coating application technologies used, or the

applicability of control measures across the various operations. The 12 facilities included in the MACT

floor calculation include facilities that manufacture a range of products that are typical of the entire
5-5

industry, and include washers and dryers, laundry equipment, refrigerators/freezers, microwave ovens,

dishwashers, water heaters, air conditioners, gas heaters, supermarket refrigerated display cases,

chillers, fans, compressors, and air handling units. Coating application techniques used at the 12

facilities include all those typically found within the source category, and include conventional air and

airless atomized spraying, electrostatic spraying, and dip coating. The amount of coatings applied by

the 12 MACT floor facilities is representative of facilities throughout the source category. The 12

facilities reported coating solids usage ranging from about 6,000 liters to about 1,079,000 liters. For

the entire MACT database of 95 facilities, coating usage ranges from below 1,000 liters to over

4,000,000 liters of coating solids. Only three facilities in the database reported the use of over

1,000,000 liters of coating solids, and one of those facilities is in the MACT floor. The average

coating usage for the 12 MACT floor facilities is about 211,000 liters of coating solids and for all

facilities in the MACT database the average usage is about 147,000 liters of coating solids. Six of the

12 facilities use a combination of liquid coatings and powder coatings. The other six do not use any

powder coatings, and are using only low-HAP liquid coating materials to achieve the low HAP

emission rates indicated in Table 5-1. Four of the 12 MACT floor facilities reported the use of

adhesives, compared to 19 of the 95 MACT database facilities that reported adhesive use. The

amount of adhesives used by the 12 MACT floor facilities and the HAP content of those adhesives is

typical of the other facilities in the source category. 

To evaluate the potential availability of low-HAP liquid coatings, an examination of the

reported HAP contents of water based and solvent based coatings was performed. When the HAP

emission rate for each facility in the spreadsheet was calculated using the HAP and solids data from

only liquid coatings plus thinners, 15 facilities were found to have HAP emission rates below 0.13 kg

HAP/L coating solids. The coating solids content of the liquid coatings applied at these 15 facilities

equals 29 percent of the total coating solids from liquid coatings applied at all facilities in the

spreadsheet. Therefore, 29 percent of the liquid coatings currently in use, in terms of coating solids,

would comply with the proposed existing-source emission limit. 

A similar evaluation was performed to examine the availability of low-HAP adhesives and

cleaning materials. Of the 19 facilities that provided data on adhesives, 6 reported using adhesives

containing no HAP, and 4 additional facilities reported using adhesives with HAP levels that are less
5-6

0

0.5

1

1.5

2

2.5

3

3.5

4

4.5

5

5.5

6

6.5

7

7.5

8

SIC 3585 SIC 3589 SIC 3631 SIC 3632 SIC 3633 SIC 3639

kg HAP/ L Coating Solids

than 0.13 kg HAP/L coating solids. In addition, nine of the facilities in the spreadsheet reported the

use of cleaning materials with zero HAP content. 

Figure 5-1 shows the range of HAP emission rates calculated for facilities within each of the

six activity (SIC) categories, with the arithmetic average HAP emission rate indicated by the diamondshaped symbol. (Table 1-1 shows the six SIC categories, a description of the major products

manufactured under each category, and the corresponding NAICS information.) As shown in Figure

5-1, the average emission rate for each of the SIC categories is in the same general range. The

average for SIC 3639 is somewhat misleading because a single facility reported a HAP level of 7.36

kg per liter of coating solids, and the next highest reported level in the SIC category is only 0.635 kg

per liter of coating solids. The similarity of the average values for all SIC categories indicates that the

HAP content of materials used throughout the source category does not vary significantly from one

product line to another. Also, because low-HAP coatings are already being used within each SIC

category, it appears that the use of low-HAP 

coatings is a viable option for products manufactured under all six of the SIC categories. 

Figure 5-1. HAP emission rate (normalized emissions) versus SIC code.
5-7

 In addition to the availability of low-HAP liquid coatings, the widespread usage of powder

coatings within the appliance industry provides evidence of the availability of applicable low-HAP

coating technology. Powder coating technology is reported to be the fasted growing industrial finishing

method in North America, representing about 15 percent of the total industrial finishing market.[1] The

appliance industry is the largest single market sector for thermosetting powders.[1] Current uses within

the source category include refrigerators, washer tops and lids, dryer drums, range housings,

dishwashers, microwave oven cavities, and freezer cabinets.[1]

With the availability of powder coatings and because the percentages of liquid coatings,

adhesives, and cleaners that currently comply with the HAP emission limit are relatively high, and

because the use of these materials is reported across the SIC categories, we believe that low-HAP

coating technology is available to all facilities within the source category. In addition, for a majority of

the facilities within the source category, the "one number" format of the standard would allow the higher

HAP emissions from certain operations where low-HAP materials may not be readily available to be

offset by increased usage of available low-HAP materials in other operations within the facility. 

5.4 NEW SOURCES

To determine the new source MACT limit, we identified the best performing sources from the

list of database facilities ranked by their emission rate. As discussed above, two of the best performing

of the potential major sources reported a HAP content well below the existing source MACT floor. 

However, these facilities were judged to be unique in their level of adhesives usage relative to their

decorative coating usage and were not considered for the new source MACT.

The next best performing facility reported a HAP content level of 0.022 kg HAP per liter of

coating solids. This facility operates under SIC 3585 and manufactures supermarket display cases and

equipment. This facility uses both solvent-based coatings and powder coatings, and is considered to

be representative of the entire source category. The proposed new source MACT limit was,

therefore, established using the data from this facility. The facility-wide HAP content value of 0.022 kg

HAP per liter of coating solids was determined to be the new source MACT floor. The fact that the

facility upon which the new source MACT level is based uses a combination of solvent-based and

powder coatings indicates that new facilities would not be limited to the use of only powder coatings to

comply with the proposed standards. The 
5-8

availability of low-HAP liquid coatings, in conjunction with the widespread increase in the use of

powder coatings in the large appliance source category (as discussed in the previous section of this

chapter), indicates that the new source MACT level is achievable for new facilities. 

5.5 BEYOND THE FLOOR

An analysis of the impacts of establishing standards more stringent than the MACT floors was

conducted. For the analysis of standards more stringent than the existing source MACT floor, we

considered the impacts of standards based on the average performance of the top 6 percent of the

best performing facilities compared to the MACT floor level based on the top 12 percent. This level

of stringency was evaluated because it represented roughly the midpoint between the existing and new

source MACT floors, and because it was expected to result in significant HAP emission reductions. 

From Table 5-1, the top 6 percent of the best performing facilities would be the first 6 shaded rows. 

The average HAP emission rate for these 6 facilities is 0.08 kg/L coating solids. Applying this level of

control to Model Plant Number 1 would result in an incremental HAP emission reduction of 250 kg. 

[MP #1 uses 5,000 liters of coating solids: at the proposed emission limit of 0.13 kg/L coating solids,

HAP emissions are 5,000 * 0.13 = 650 kg; at an emission limit of 0.08 kg/L coating solids, HAP

emissions are 5,000 * 0.08 = 400 kg] For Model Plants 2 through 4, the incremental emission

reductions are 1,250 kg, 5,000 kg, and 31,250 kg, respectively.

At the beyond the floor level considered here, the availability of complying coating materials

and cleaning materials that could be used without extensive process or equipment modifications is

expected to become a problem for many existing facilities. Because complying materials that can be

used with existing coating equipment may not be available, some facilities may be faced with the

possibility of being required to convert a liquid coating line to powder coatings or to install add-on

control devices to comply with the standards. While a detailed cost analysis for this type of conversion

or installation was not performed for our evaluation of the beyond the floor option, it is expected that

the cost effectiveness of requiring such steps would not be acceptable. As an example of the range of

cost effectiveness values that could be expected, we projected the annual costs for converting Model

Plants 2 and 3 to the use of powder coatings. The costs for such a conversion were estimated from

information gathered during the development of the NESHAP for the metal furniture source

category.[2] The annual costs to convert Model Plants 2 and 3 from liquid coating lines to powder
5-9

coating lines were projected from the costs developed to convert similar sized metal furniture model

plants. For Model Plant 2, which uses 25,000 liters of coating solids per year, the annual cost for the

conversion to powder coatings was estimated to be $150,000. For Model Plant 3, which uses

100,000 liters of coating solids, the annual cost was estimated to be $200,000. In order to project the

highest possible emission reduction values, and, thus, the "best-case" cost effectiveness values, it was

assumed that the two model plants converted all of their coatings to powder coatings and that they also

use zero-HAP cleaning and surface preperation materials. Therefore, for our example, the emission

rate for the models under our beyond the floor option would be zero. For Model Plant 2, which could

emit 3,250 kg of HAP under the floor level of control (25,000 liters of coatings solids * 0.13 kg per

liter of coating solids = 3,250 kg), the projected cost effectiveness is $46,154 per Mg of HAP

emissions reduced ($150,000 ÷ 3,250 kg *1,000 kg per Mg). For Model Plant 3, which could emit

13,000 kg of HAP under the floor level of control (100,000 liters of coating solids * 0.13 kg per liter

of coating solids = 13,000 kg), the projected cost effectiveness is $15,385 per Mg of HAP emissions

reduced ($200,000 ÷ 13,000 kg * 1,000 kg per Mg).

The analysis presented above indicates that the cost effectiveness values are better for the

larger facilities. While this may be true in some cases, it should be noted that in actual practice many

facilities, regardless of their size, are expected to be unable to use zero-HAP technology for all their

coating, cleaning, and surface preperation needs. Thus, the example presented above overstates the

potential emission reductions that would be expected if a level of control beyond the MACT floor level

were required. The cost effectiveness values projected here were not considered to be reasonable,

and a beyond the floor option was not selected. 

A beyond the floor option for the new source standards was rejected because no options were

identified that were believed to be applicable to all segments of the source category. While the floor

level of control is believed to be achievable through the use of a combination of available low-HAP

liquid coatings and powder coatings, more stringent control levels would rely on the use of increasing

percentages of powder coatings. As discussed in previous sections, powder coatings are not believed

to be a technology that can be utilized for all coating needs in all segments of the source category. For

example, powder coatings may not be suitable for products with narrow gaps between surfaces or

deep recesses where powder may not penetrate or cover adequately. Thus, establishing beyond the
5-10

floor standards that could be achieved only by the near exclusive use of powder coatings could not be

justified. 
TABLE 5-1. SURFACE COATING EMISSION DATA USED IN DEVELOPING THE MACT FLOORS

5-11

A B C D E F G H I J K L M N O P Q R

Facility SIC Codes Water-Based Solvent-Based Powder Thinning Surface Prep Cleaning Adhesives Total HAPs

Total Coating 

Solids HAP emission rate Title V Status Notes

HAP (kg)

Coating

Solids (L) HAP (kg)

Coating

Solids (L) HAP (kg)

Coating

Solids (L) HAP (kg) HAP (kg) HAP (kg) HAP (kg)

Coating

Solids (L) (kg) (L)

(kg HAP/L coating

solids)

LA-003 3639 0 534,465 0 95,142 0 629,607 0.000 Synthetic Minor Source X

LA-401 NA* 0 77,912 0 77,912 0.000 Major Source X

LA-057 3631 6 13 0 167,593 9 27 42 167,606 0.000 Synthetic Minor Source Y

LA-123 3589 0 4,288,773 966 2,636 697 3,602 4,289,470 0.001 Major Source (>= 3 Mg) Y

LA-351-E 3585 316 974 0 42,698 0 0 0 0 66,282 316 109,954 0.003 Major Source Y

LA-351-D 3585 543 25,013 440 0 135,580 983 160,593 0.006 Major Source Z

LA-351-JA 3585 114 351 0 15,986 0 1,773 114 18,110 0.006 Synthetic Minor Source Y

LA-230-B 3585 16 0 18,403 117 117 18,419 0.006 Synthetic Minor Source Y

LA-205-D 3585 33 34,197 60 61 0 59,537 1,675 301 63,827 2,069 157,622 0.013 Major Source Z

LA-157 3585 651 6,559 0 58,291 346 0 997 64,850 0.015 Synthetic Minor Source Y

LA-170-A 3585 1,606 75,285 0 61,551 250 1,180 3,036 136,836 0.022 Synthetic Minor Source

LA-321-B 3632 655 57,559 69 479 590 1,793 57,559 0.031 Synthetic Minor Source

LA-399-E 3585 458 11,634 458 11,634 0.039

Major Source (Max Design

>= 9.07 Mg) X

LA-271-C 3632 17,344 417,969 17,344 417,969 0.041 Major Source X

LA-045-A 3585 1,795 1,478 0 103,672 2,900 4,695 105,150 0.045 Major Source (>= 3 Mg) Y

LA-321-A 3632 303 26,351 360 830 1,493 26,351 0.057 Synthetic Minor Source

LA-387-G 3633 57,956 261,434 15,485 173,724 0 677,296 28,584 102,025 1,112,454 0.092 Major Source X

LA-399-D 3585 4,114 4,535 39,198 4,535 43,312 0.105 Major Source (>= 3 Mg) X

LA-360-B 3634 360 4,599 457 2,886 817 7,485 0.109 Major Source X

LA-271-B 3633 6,266 93,399 0 25,024 185 7,250 13,701 118,423 0.116 Major Source

LA-222-C 3631 12,940 9,747 147 0 128,369 3,682 16,622 138,263 0.120 Synthetic Minor Source Y

LA-351-JB 3585 705 2,161 220 766 93 0 5,320 1,018 8,247 0.123 Synthetic Minor Source

LA-142-C 3585 43,321 172,236 0 103,306 0 129 70,560 43,450 346,102 0.126 Major Source (>= 3 Mg)

LA-387-B 3633 104,052 676,678 4,399 52,164 0 349,826 3,544 24,572 136,567 1,078,668 0.127 Major Source

LA-302 3631 17,116 106,615 573 60,623 3,909 2,960 24,558 167,238 0.147 Major Source

LA-278-A 3585 17,624 11,419 0 145,025 6,437 170 24,231 156,444 0.155 Major Source Y

LA-175 3639 10,551 63,105 0 10,551 63,105 0.167 Major Source X

LA-089-A 3585 7,951 9,915 0 33,245 7,951 43,160 0.184 Major Source (>= 3 Mg) X

LA-018 3639 8,220 48,629 31 41 192 690 9,133 48,670 0.188 Major Source

LA-351-F 3585 1,096 19,199 1,334 2,622 0 4,590 2,713 0 534 5,677 26,411 0.215 Major Source

LA-104 3585 444 1,995 5 90 449 2,085 0.215 Synthetic Minor Source X

LA-387-D 3639 6,975 86,183 6,408 29,894 0 397,851 92,400 0 10,248 1,674 116,031 515,602 0.225 Major Source

LA-205-B 3585 1,245 2,379 171 799 0 0 2,881 1,416 6,059 0.234 Synthetic Minor Source

LA-386 3631 6,617 36,911 3,962 15,008 452 2,050 13,081 51,919 0.252 Major Source

LA-330 3556 1,358 6,232 124 94 150 1,632 6,326 0.258

Major Source (Max Design

>= 9.07 Mg)

LA-222-B 3633 58,133 178,182 0 301,163 12,108 10,770 60,840 57,287 141,851 536,632 0.264 Major Source

LA-365-A 3585 4,057 31,783 91 5,040 9,188 31,783 0.289 Major Source (>= 3 Mg)

LA-295 NA* 0 12,446 3,890 3,890 12,446 0.313 Major Source (>= 3 Mg)

LA-332-A 3585 1,667 8,197 950 2,617 8,197 0.319 Synthetic Minor Source

LA-222-A 3633 0 100,992 64,414 256,996 0 219,512 108,546 15,350 2,211 3,021 190,521 580,521 0.328 Major Source

LA-318 3639 33,317 266,654 15,012 39,999 686 1,240 89,014 267,894 0.332 Major Source
TABLE 5-1. SURFACE COATING EMISSION DATA USED IN DEVELOPING THE MACT FLOORS

A B C D E F G H I J K L M N O P Q R

Facility SIC Codes Water-Based Solvent-Based Powder Thinning Surface Prep Cleaning Adhesives Total HAPs

Total Coating 

Solids HAP emission rate Title V Status Notes

HAP (kg)

Coating

Solids (L) HAP (kg)

Coating

Solids (L) HAP (kg)

Coating

Solids (L) HAP (kg) HAP (kg) HAP (kg) HAP (kg)

Coating

Solids (L) (kg) (L)

(kg HAP/L coating

solids)

5-12

LA-158-E 3589 1,475 11,268 2,397 0 13 3,872 11,281 0.343 Synthetic Minor Source

LA-089-D 3585 1,515 4,162 1,515 4,162 0.364 Synthetic Minor Source

LA-402 3632 3,972 15,144 404 1,176 5,552 15,144 0.367 Major Source

LA-074-B 3589 4,609 12,379 0 4,609 12,379 0.372 Synthetic Minor Source

LA-055 3639 0 42,296 9,538 15,982 809 12,410 22,757 58,278 0.390 Major Source

LA-126 3585 0 2,085 14,551 58,031 4,248 8,195 0 8,540 26,994 68,656 0.393 Major Source

LA-388-O 3633 35,707 148,526 0 77,912 36,820 840 15,755 89,122 226,438 0.394 Major Source

LA-387-C 3632 553 80,253 11,087 20,761 32,401 80,253 0.404 Major Source

LA-027 3585 61 277 1,470 4,166 360 1,891 4,443 0.426 Synthetic Minor Source

LA-399-H 3585 2,286 5,677 330 2,616 5,677 0.461 Major Source (>= 3 Mg)

LA-132 3585 17,575 64,291 13,455 35 0 791 1,987 31,856 66,278 0.481 Major Source (>= 3 Mg)

LA-199 3585 8,742 30,379 1,213 5,385 15,340 30,379 0.505 Major Source

LA-351-G 3585 390 3,580 2,120 6,256 624 303 2,260 70 1,135 5,767 10,971 0.526 Synthetic Minor Source

LA-399-B 3585 473 20,438 7,985 3,230 11,688 20,438 0.572 Major Source

LA-069-A 3585 1,948 15,079 3,112 9,326 5,280 1,912 5,433 6,350 17,685 30,755 0.575 Synthetic Minor Source

LA-399-G 3585 2,517 5,029 510 3,027 5,029 0.602 Major Source (>= 3 Mg)

LA-266 3631 0 32,657 1 19,970 19,971 32,657 0.612 Major Source (>= 3 Mg)

LA-387-A 3585,3632,9 5,250 78,520 57,947 27,446 1,470 280 64,947 105,966 0.613 Major Source

LA-403 3639 2,387 939 1,035 8,573 2,041 573 6,036 9,512 0.635 Major Source

LA-373 3585 3,656 6,446 543 4,199 6,446 0.651

Major Source (Max Design

>= 9.07 Mg)

LA-388-C 3585 4,782 21,573 8,579 1,360 14,721 21,573 0.682 Major Source

LA-365-B 3585 6,579 29,310 156 13,900 20,635 29,310 0.704 Major Source

LA-222-D 3632 7,069 33,069 2,470 17,200 26,739 33,069 0.809 Major Source

LA-399-F 3585 732 3,682 2,023 310 3,065 3,682 0.833 Major Source (>= 3 Mg)

LA-399-A 3585 885 3,208 2,085 8,078 6,700 9,670 11,286 0.857 Major Source

LA-335 3589 22,370 25,509 2,887 270 0 25,527 25,509 1.001 Major Source

LA-059 3585 3,039 6,590 4,260 730 8,029 6,590 1.218 Major Source (>= 3 Mg)

LA-351-K 3585 704 5,193 7,866 6,796 26 6,138 62 54 14,796 12,043 1.229 Synthetic Minor Source

LA-174 3589 2,337 3,728 1,010 1,730 5,077 3,728 1.362 Major Source (>= 3 Mg)

LA-251-A 3589 564 677 215 153 932 677 1.376

Major Source (Max Design

>= 9.07 Mg)

LA-069-D 3585 1,087 730 1,087 730 1.490 Synthetic Minor Source

LA-121-C 3585 1,066 1,807 1,720 35 2,821 1,807 1.562 Major Source (>= 3 Mg)

LA-038 3585 20,012 12,897 2,541 0 22,553 12,897 1.749 Synthetic Minor Source

LA-205-A 3585 8,801 43,493 32,209 34,686 51,195 49,938 142,143 78,179 1.818 Major Source

LA-223 3585 1,560 4,511 14,584 4,582 460 16,604 9,093 1.826 Major Source

LA-399-K 3585 6,213 3,984 1,210 7,423 3,984 1.863 Synthetic Minor Source

LA-340 3585 59,771 31,297 9,497 6,929 4,929 76,197 36,226 2.103 Major Source

LA-351-C 3585 244 1,472 15 90 3,142 3,401 1,562 2.177

Major Source (Max Design

>= 9.07 Mg)

LA-387-J 3632 147,456 133,146 147,800 295,256 133,146 2.218 Major Source

LA-218 3632 6,474 6,615 3,889 5,960 16,323 6,615 2.468 Major Source

LA-269 3585 65 588 1,580 2,482 1,367 1,633 3,143 7,788 3,070 2.537 Synthetic Minor Source

LA-069-C 3585 11,523 4,169 11,523 4,169 2.764 Major Source

LA-040 3585 0 7,324 26,780 26,780 7,324 3.656 Major Source
A B C D E F G H I J K L M N O P Q R

Facility SIC Codes Water-Based Solvent-Based Powder Thinning Surface Prep Cleaning Adhesives Total HAPs

Total Coating 

Solids HAP emission rate Title V Status Notes

HAP (kg)

Coating

Solids (L) HAP (kg)

Coating

Solids (L) HAP (kg)

Coating

Solids (L) HAP (kg) HAP (kg) HAP (kg) HAP (kg)

Coating

Solids (L) (kg) (L)

(kg HAP/L coating

solids)

5-13

LA-356 3589, 3631 894 2,188 367 2,470 4,820 8,551 2,188 3.908

Major Source (Max Design

>= 9.07 Mg)

LA-121-A 3585 2,281 5,212 8,128 15,000 25,409 5,212 4.875 Major Source (>= 3 Mg)

LA-388-I 3639 5,314 722 5,314 722 7.362 Synthetic Minor Source

LA-360-A NA* 105 1,633 0 18,900 19,005 1,633 11.641 Major Source

LA-288 3589 507 341 0 8,234 33 8,774 341 25.731 Major Source (>= 3 Mg)

LA-351-P 3585 0 0 0 ?? Major Source

LA-388-L 3631 0 0 0 ??

Major Source (Max Design

>= 9.07 Mg)

LA-388-N 3635 0 0 0 ??

Major Source (Max Design

>= 9.07 Mg)

LA-137-L 3631,2,3,9 0 ?? Major Source

LA-170-C NA* 0 ?? Major Source (>= 3 Mg)

LA-264 NA* 0 ??

Major Source (Max Design

>= 9.07 Mg)

* NA = Not Available (Facility did not provide information)

NOTES:

X The facility did not provide sufficient information to calculate their HAP emission rate from all coating operations

Y This data indicates that greater than 90 % of coating solids are from powder.

 Z This data indicates a high adhesive usage.

.

NOTES:

C Information presented in this table was obtained from responses to the 1998 industry questionnaire. Responses are located in 

Docket A-97-41, Category II-D

C Cells with "0" represent reported values of zero; blank cells represent no data reported

C Column P (HAP emission rate) = Columns (C+E+G+I+J+K+L) ÷ Columns (D+F+H+M) 

TABLE 5-2. DEFAULT DENSITIES USED FOR UNIT CONVERSIONS
5-14

TYPE OF MATERIAL DEFAULT DENSITY (GRAMS PER

LITER)

Conventional Solvent Based Coatings 1,063

High Solids Solvent Based Coatings 1,315

Water Based Coatings 1,265

Powder Coatings 1,584

Cleaning Materials 991

Thinning Materials 876

NOTES:

C Information presented in this table was obtained from responses to the 1998 industry

questionnaire. Responses are located in Docket A-97-41, Category II-D.

C Multiply grams per liter by 0.00835 to obtain pounds per gallon
5-15

5.6 REFERENCES

1. G. Bocchi, The Powder Coating Institute. Products Finishing, "Powder Coating in the Year

2000." July, 2000. 4 pp.

2. Memorandum from D. Hendricks, E/CR, Inc. to M. Serageldin, EPA:CCPG. "New Source

MACT Cost Impacts for Metal Furniture Surface Coating Source Category," July 10, 2000

(Revised November 16, 2000). Appendix A. Docket No. A-97-40, Item No. II- A-5.
6-1

6.0 ENVIRONMENTAL, HEALTH, AND ENERGY IMPACTS

This chapter presents the estimated HAP emission reductions and discusses the non-air quality

health and environmental impacts and energy requirements associated with implementing the MACT

level of control at existing and new facilities within the large appliances source category. The projected

HAP emission reductions were developed using a model plant approach and were then scaled up to

the expected number of affected facilities nationwide. The model plants are defined in Chapter 4.0.

6.1 APPROACH TO ESTIMATING IMPACTS

The HAP emission reductions associated with implementing the MACT standard for the large

appliance industry were analyzed for each of the four model plants that were identified in Chapter 4.0

and the memorandum entitled “Development of Model Plants for the Large Appliances NESHAP

Project (Docket No. A-97-41, Item No. II-B-6). The estimated HAP emission reductions for each

model plant were then multiplied by the number of existing facilities represented by each model to

project the impacts to a nationwide value. An example of this calculation is included at the end of this

Chapter.

 Non-air quality health and environmental impacts and energy requirements resulting from the

implementation of the proposed standards were also considered. Sufficient information was not

available to allow these impacts to be quantified, but the potential impacts of proposed standards are

discussed below.

6.2 ESTIMATED HAP EMISSION REDUCTIONS

The estimated reduction in HAP emissions resulting from implementing the proposed standards

at existing facilities is presented in Table 6-1. Emission reductions for each of the model plants were

based on the existing source MACT floor of 0.134 kg HAP emitted per liter of coating solids. Since

the proposed standard is rounded to two significant figures, i.e., 0.13 kg HAP emitted per liter of

coating solids (1.1 lbs per gal), the values presented in Table 6-1 slightly underestimate the predicted

nationwide emission reduction. According to Table 6-1, total nationwide HAP emission reductions

from implementing the MACT level of control at existing facilities are estimated to be around

1,079,871 kg (2,381,113 lbs) per year. This represents a 45 percent reduction in HAP emissions
6-2

industrywide. In Table 6-1, each model plant was assumed to comply with the standard by converting

to non-HAP surface preparation materials, cleaning materials, and adhesives as well as reduced-HAP

coatings and thinners. 

 It is projected that, even in the absence of the proposed NESHAP, most new sources will use

coating technologies that are considered to be "state-of-the-art" coatings (e.g., powder coatings and

low HAP liquid coatings). Powder coating technology has advanced rapidly in recent years, and is

gaining widespread acceptance in the large appliances industry. Powder coatings are not only very

cost effective, their use eliminates the problems associated with worker exposure to organic solvents. 

Many of the facilities in the database indicated that they were in the process of converting part or all of

their coating operations to use powder coatings. Table 6-2 contains a list of these facilities. For these

reasons the baseline emission levels for new sources are expected to be at, or below, the requirements

in the proposed standards. Therefore, no emission reductions beyond the baseline levels from new

sources have been attributed to the proposed standards.

6.3 NON-AIR QUALITY HEALTH AND ENVIRONMENTAL IMPACTS 

The compliance options expected to be used by the large appliance industry for this standard

are not expected to create significant adverse environmental impacts. Coating material reformulation is

expected to be used by most facilities to reduce their emissions of hazardous air pollutants (HAP) from

their coating operations. The use of reformulated coating materials is expected to result in the

generation of equal, or smaller, amounts of solid waste, waste solvents, and wastewater. In addition,

the reformulated coating materials have the benefit of reduced percentages of HAP in the wastes that

are generated. The expected increase in the use of powder coatings will result in a decrease in the

generation of waste because most powder coating booths utilize dry filters to collect overspray. The

dry powder that is collected as overspray can often be recycled, thus reducing the overall amount of

waste material. Because of the many variables involved, and the lack of specific information on the

control approach that will be selected by the affected sources, these impacts could not be quantified. 

6.4 ENERGY REQUIREMENTS
6-3

The impact of the standard on the amount of energy consumed by surface coating operations

within the affected industry could not be determined with the information available. Energy consumed

is extremely variable and depends on the type and formulation of coating materials used, the film

thickness needed for each product, the size and shape of the products being coated, curing oven

capacity and desired line speed, and the method of heating the curing oven. Increases in energy

consumption by the existing capture systems and add-on control devices is also variable and depends

on whether increased utilization of these devices will be a part of the control strategy used by the

facilities that have these devices. Because there is such a range of factors, and because some

compliance options may result in a decrease in energy consumption (for example, high solids coatings

may require less energy to cure than conventional coatings), it was assumed that on a nationwide basis

there would be no quantifiable change in energy consumption as a result of the standard. 

TABLE 6-1. SUMMARY OF ESTIMATED ENVIRONMENTAL IMPACTS

Baseline

Emission

Levels (kg)

Compliant

Emission

Levels (kg)

Emission

Reduction

(kg)

Number of

facilities

Nationwide

Nationwide

Emission

Reduction (kg)

Model Plant 1 3,887 670 3,217 26 83,642

Model Plant 2 15,234 3,350 11,884 19 225,796

Model Plant 3 29,436 13,400 16,036 17 272,612

Model Plant 4 125,235 83,750 41,485 12 497,820

Nationwide 1,079,871
6-4

Table 6-2. Facilities Switching to Powder Coatingsa

FACID Description of Change in Coating Operation Docket Item No.

LA-271-C Installation of a powder coating line will reduce actual VOC emissions from this plant. II-D-107

LA-351-E Changed from liquid to powder coating, also changed from solvent based cleaning fluid to an aqueous water wash system II-D-82

LA-388-C Jan. 1998, switched from a solvent based paint to a powder paint II-D-409

LA-222-D Replaced liquid coating with powder coating application process II-D-415

LA-218 Currently installing a powder coating line which will replace the solvent coating line. II-D-295

LA-045-A Replaced two liquid coating booths (using solvent based coatings) with powder paint booths. II-D-253

LA-388-N Added powder coating operation which reduced liquid coating usage and decreased xylene consumption/emissions. II-D-409

LA-388-A The original painting operation using a high solids, solvent based coating was replaced by a powder coating operation. II-D-409

LA-158-M Eliminated use of solvents in surface preperation operations. Changed from water based to powder coatings. II-D-262

LA-170-F Changed from liquid solvent spray coating operation to powder coating operation II-D-360

LA-322 Changed from wet paint system to powder coating II-D-364

LA-089-E Changed from water based enamel dip coating to powder coating II-D-314

LA-388-M Replaced solvent based liquid coatings with dry powder coatings II-D-409

LA-076 Change from VOC - based liquid coatings to powder coatings II-D-309

LA-247 Replaced liquid coating system with powder coating system II-D-218

LA-230-C Eliminated lacquer and replaced with powder coatings about 2.5 years ago II-D-383

LA-045-C Changed from baking enamels (liquid coatings) to powder coatings II-D-255

LA-399-C Installation of electrostatic powder coating line and recycling system to reuse overspray material II-D-290

LA-388-G Voluntarily switched to powder coating in Nov. 1995. This reduced VOC's by over 90%. II-D-409

LA-170-A Converted 2 highest volume liquid coating colors to powder coating. II-D-356

LA-104 Removed and replaced liquid coating system with Eisenmenn dry painting (powder coating) system II-D-175

LA-157 Instituted program to replace liquid coatings with powder coatings; usage of liquid coatings has decreased about 80-90% II-D-426

LA-069-A Eliminated solvent based liquid coating operations & replaced w/ low VOC E-coat and powder coating systems II-D-347

LA-273 Changed process from liquid (HVLP) to powder coating II-D-277

a Information presented in this table was obtained from responses to the 1998 industry questionnaire. Responses are located in Docket Number

A-97-41. Some facilities' responses were edited so that uniform terminology could be presented, and to fit in this table format.
6-5

EXAMPLE OF HAP EMISSION REDUCTION CALCULATION

This example demonstrates the calculations performed to determine the HAP emission reductions from

Model Plant number 3.

C As shown in Table 4-5, Model Plant number 3 is representative of facilities that use from

50,001 and 200,000 liters of coating solids; the model plant uses 100,000 liters of coating

solids.

C At the baseline conditions Model Plant number 3 emits 29,436 kilograms of HAP (the total

from the column labeled "HAP" in Table 4-5.

C The baseline emission rate for Model Plant number 3 is: 29,436 kg HAP ÷ 100,000 liters of

coating solids = 0.29436 kg HAP/liter of coating solids.

C Model Plant number 3 will need in this example to reduce its emission rate to a maximum of

0.134 kg HAP/ liter of coating solids.

C At an emission rate of 0.134 kg HAP/liter of coating solids, and assuming the same amount of

coating solids will be used as under the baseline condition, Model Plant number 3 will emit: 

0.134 kg of HAP/liter of coating solids * 100,000 liters of coating solids = 13,400 kilograms

of HAP.

C The proposed standards result in a reduction of: 29,436 kg - 13,400 kg = 16,036 kg of

HAP.

C Because this model plant is estimated to represent 17 existing facilities, the nationwide HAP

reduction for this segment of the source category is estimated to be: 16, 036 kg of HAP * 17

facilities = 272,612 kilograms of HAP.

C This procedure was applied to each of the four model plants and the results are shown in Table

6-1. 
7-1

7.0 COST IMPACTS

This chapter presents the approach developed to estimate the cost impacts of implementing the

MACT level of control at existing and new large appliances surface coating operations. The cost

impacts were developed using a model plant approach and were then projected to a nationwide

number of facilities. The first section of this chapter describes the approach that was used to estimate

the compliance alternatives and the costing assumptions. The second section presents the results of the

cost analysis on a model plant and nationwide basis.

7.1 APPROACH TO ESTIMATING COSTS

The basic approach used to estimate the cost impacts of the standards was to predict the

method of compliance to be used by each model plant and the costs associated with that method. The

four model plants were developed to represent the range of facility sizes and coating, thinning, and

cleaning materials used throughout the industry. Tables 7-1 through 7-4 present the model plant

parameters as well as cost impact information.

Because an affected source-wide average HAP limit approach was selected for the standard,

there is a wide variety of actions that a facility could take to lower its HAP emissions from coatingrelated operations to a compliant level. Reductions in the HAP contents of adhesives, surface

preparation materials, thinning solvents, and cleaning materials as well as the coatings themselves, all

contribute toward compliance. Converting from HAP-containing liquid coatings to powder coatings

can essentially eliminate HAP emissions from the coating operation. Add-on control devices could be

installed to reduce HAP emissions from selected exhaust gas streams, such as a curing oven exhaust. 

(Thermal incinerators can achieve HAP reductions in excess of ninety percent.) Various combinations

of the actions outlined above can also be implemented to achieve the necessary HAP emission

reductions.
7-2

An analysis of the model plant parameters and information provided in the industry responses

to the 1997 and 1998 questionnaires (114 authority) led to the following selection of compliance

alternatives for performing the cost analysis.

It was estimated that no facility within the industry would install add-on control devices as a

result of the proposed standards. The capital costs and annual operating costs of add-on control

devices usually make them less desirable than other compliance options for reducing volatile organic

emissions from coating operations. The responses to the industry questionnaires included information

on seven such devices located at only five out of the total of 222 facilities. Two of these devices are

used to reduce VOC emissions from the ovens on spray application operations, and five of the devices

are used on dip coating operations. Dip coating operations lend themselves to add-on control because

they generally have configurations that facilitate the use of capture systems. Even though these facilities

may consider the devices' HAP emission reductions when determining compliance with the proposed

standards, no additional cost was attributed to them in our analysis because they would be operated

even in the absence of the proposed standards. 

 Conversion of a liquid coating line to powder coating was also not expected to be a desirable

option for the two smallest model plants. While case studies indicate that powder coatings are very

cost effective for facilities that apply large volumes of coatings, the initial investment required to convert

to powder could discourage smaller coating operations from selecting this option. The two larger

model plants currently use both liquid and powder coatings and, therefore, a possible option would be

to reduce the use of liquid coatings and apply powder to a larger percentage of their products using

existing powder coating capacity. For example, model plant number 4 could achieve compliance with

the standard by switching about 60 percent of the current coating solids usage from solvent based

coatings (and associated thinners) to powder coatings. For this analysis, it was assumed that the

MACT level of control for the final standard will be 0.13 kilograms of HAP emitted per liter of coating

solids used.

For the reasons presented above, the option that would most likely be selected by most

facilities within the industry is the use of a combination of lower HAP liquid coatings and non-HAP
7-3

adhesives, surface preparation materials, and cleaning materials. It was also assumed that the use of

lower HAP coatings would be accompanied by the use of lower HAP coating thinners.

Because the compliance option expected to be used by most facilities to comply with the

standard utilizes reformulated raw materials rather than a different coating technology or add-on

controls, no capital costs were estimated. Some facilities will, no doubt, encounter up-front costs

during a materials conversion. Some facilities may need to upgrade application equipment to be able

to apply reformulated lower HAP coatings that may have a higher viscosity. These costs will be site

specific, however, and will most likely be offset by increased efficiencies of the new equipment and by

reductions in the cost of handling and disposal of HAP-containing wastes. The impacts of variables

such as shelf life of coatings, curing requirements, or spray booth ventilation rates could also be

positive or negative depending on the specific facility being evaluated. No cost information was

available for these variables. It should also be noted that there will be some cost incurred for testing or

qualifying new coating materials. These costs are also very site specific depending on the products

manufactured, the relative usage of each type of material, and the availability of demonstrated

reformulated materials.

For liquid coatings there exists a wide range of HAP contents, coating solids contents, and

prices. Because of the variability from one facility to another regarding coating needs, it was not

possible to estimate each of the variables that must be considered to determine the increase or

decrease in costs that would be encountered in converting to a lower HAP coating. Several contacts

were made with industry representatives in an attempt to obtain data on the relative costs of lower

HAP coatings versus higher HAP coatings (Docket Item No.II-E-12). Most of these contacts did not

result in useful cost data. Because the cost of coatings is usually compared in terms of coating solids

content ($/L coating solids) or actual coverage capability ($/sq m), we found that cost data was not

readily available in terms of HAP content. An assumption was made, therefore, that it was reasonable

to expect that the higher percentage of solvent in a low solids coating would result in a corresponding

higher percentage of HAP. Likewise, the lower percentage of solvent in a high solids coating would

result in a lower percentage of HAP. This assumption correlating high solids to lower-HAP and low
7-4

solids to higher-HAP allowed us to use available data comparing the costs of low solids and high solids

coatings. In an article appearing in Products Finishing Magazine, the costs of high solids coatings were

reported to be about 30 percent less than the costs of low solids coatings [1]. One industry

representative supplied information indicating that the costs of their new high solids coatings are about

10 percent higher than the costs of low solids coatings [2]. Information from a third source indicated

practically no difference in the costs between low solids and high solids coatings [3]. Because of the

many site specific variables, and the lack of a trend in the cost information available, it was assumed

that overall there would be no change in annual costs for coatings and, therefore, no cost was

estimated for this analysis. It is likely, however, that the annual costs of coatings will increase for some

facilities, will remain about the same for many facilities, and may decrease for some when the

reformulation to lower HAP coatings is accompanied by an increase in coating solids content (and

thus, greater coverage and less waste per a given volume). 

For adhesives, as for other coatings, no change in costs was predicted for converting to nonHAP materials. Individual facilities may experience cost increases or decreases depending on the

types and quantities of adhesives used. A telephone survey of several adhesives manufacturers

conducted during the development of the NESHAP for the Plastic Parts and Products Surface Coating

Source Category resulted in the collection of cost and HAP data for seventeen different adhesives. 

The data showed no clear relationship between the costs of the adhesives and the HAP content, and it

was assumed that reformulating to non-HAP adhesives in large appliances would result in no additional

costs [4]. 

The surface preparation materials, thinning solvents, and cleaning materials used by the large

appliances surface coating industry in 1997 were evaluated to determine the constituent compositions

and the amount of product used. Xylene is a commonly used, inexpensive HAP surface

preparation/thinning/cleaning product and isopropyl alcohol is a commonly used, and much more

expensive, non-HAP solvent. The cost of non-HAP alternative solvents such as isopropyl alcohol and

acetone was estimated to be one hundred percent higher than the cost of higher-HAP solvents. A

summary of cost information for xylene and isopropyl alcohol is presented in Docket Item II-B-12. 
7-5

The selection of acceptable non-HAP alternative solvents will be a case-by-case decision to be made

by each facility, and the comparison of xylene to isopropyl alcohol is used here only for the purpose of

establishing a cost differential. Many types of solvent blends, which have much reduced levels of

HAP, may also be acceptable substitutes and may cost less than the non-HAP materials. The one

hundred percent increase in cost for these materials is believed to be a conservative (worst-case)

assumption, however, and also does not consider the savings that could result from current waste

solvent disposal costs [5].

For new sources it is projected that most, if not all, will use coating technologies that are

considered to be "state-of-the-art" coatings (e.g., powder coatings and low HAP liquid coatings) even

in the absence of the proposed standards. Powder coating technology has advanced rapidly in recent

years, and is gaining widespread acceptance in the large appliances industry. Powder coatings are not

only very cost effective, their use eliminates the problems associated with worker exposure to organic

solvents. Many of the facilities in the database indicated that they were in the process of converting

part or all of their coating operations to use powder coatings. Also, four of the most recently

constructed facilities in the database are using powder coatings extensively. Therefore, the baseline

condition for new facilities is expected be the use of powder and low HAP liquid coatings and no

compliance costs beyond the baseline levels from new sources have been attributed to the proposed

standards [6]. New facilities are, however, expected to incur monitoring, recordkeeping, and

reporting costs and these have been included in the analysis.

7.2 ESTIMATED COST IMPACTS

Tables 7-1 through 7-4 present the model plants and the estimated cost that each would incur

as a result of complying with the standard. Each model plant would comply with the standards by

switching to non-HAP adhesives, surface preparation materials, and cleaning materials and reducing

the HAP content of the coating materials and thinners to meet the emission limit of 0.13 kg HAP per

liter of coating solids. The percentage HAP reduction varies from about 35 percent for model plant 4,

which already uses a great deal of powder coatings, to about 83 percent for model plant 1, which uses
7-6

mostly solvent based coatings. [For model plant 1, current emissions of 3,887 kg of HAP are reduced

to a complying level of 650 kg of HAP: ((3,887- 650) ÷ 3,887) * 100 = 83 percent.] As shown in

Table 7-5, the total nationwide annual cost of complying with the standard is estimated to be

approximately $476,000, the sum of the costs for each of the four industry segments.

In addition to the costs associated with complying with the proposed HAP emissions limitation,

affected facilities will incur costs associated with the monitoring, recordkeeping, and reporting

(MR&R) requirements of the proposed standards. The MR&R costs were developed for the first five

years after proposal, and are summarized in Table 7-6 [7]. Costs were developed for existing affected

facilities and for an estimated four new sources each year after the proposed standards become final. 

All existing sources were assumed to come into compliance at the end of the three-year compliance

period in the proposed standards. New sources are assumed to comply when initial operation begins.

Table 7-7 presents a summary of the estimated nationwide costs for the proposed standards,

including the costs to comply with the HAP emissions limit and the monitoring, recordkeeping, and

reporting requirements. The fifth-year nationwide total cost is projected to be approximately $2

million. 
7-7

7.3 REFERENCES

1. G. Bocchi, The Powder Coating Institute. Products Finishing, "Powder Coating 

Advantages." June 1997. 5 pp.

2. Telecon from K. Maw, PES, Inc., to B. Vogt, Whirlpool. Discussion of costs of lower 

HAP coatings and thinners. July 29, 1999. 1 p. Docket No. A-97-41, Item No. II-E-10.

3. Facsimile from C. Profilet, Thermal Engineering Corporation, to J. Paumier, PES, Inc. 

Information on costs and emissions for coatings and two spreadsheets dated January 18 

and 27, 1997. 4 pp. Docket No. A-97-41, Item No. II-D-433.

4. Letter from K. Teal, EPA:CCPG, to M. Serageldin, EPA:CCPG. Adhesive Cost 

Information Prepared for the Plastic Parts and Products Surface Coating NESHAP. 

December 5, 2000. Docket No. A-97-41, Item No. II-B-13.

5. Alternative Control Techniques Document - Industrial Cleaning Solvents. EPA-453/R94-015. U.S. Environmental Protection Agency, Office of Air Quality Planning and 

Standards, Research Triangle Park, North Carolina, February 1994, pp. 5-8 and 5-9.

6. Memorandum from C. Hester and K. Maw, PES, Inc., to M. Serageldin, EPA:CCPG. 

"Projected Number of New Sources and Impacts of the Proposed Standards," October 2, 

2000. Docket No. A-97-41, Item No. II-B-10.

7. OMB 83-I and Supporting Statement for the Large Appliances Surface Coating 

Operations NESHAP. EPA Tracking Number 1954.01. Docket No. A-97-41, Item No. 

II-F-1.
7-8

TABLE 7-1. MODEL PLANT NUMBER 1 COST IMPACTS

(UP TO 10,000 LITERS OF COATING SOLIDS)

Plant Definition Tabular Costs

HAP

(kg)

Density

(g/l)

Coating

Solids

(liters)

% Coating

Solids

Total

Usage

(liters)

Total Usage

(gallons)

$ Cost/Liter

Non-Compliant

Total $ Cost

NonCompliant

$ Cost/Liter

Compliant

Total $ Cost

Compliant

Change in

$ Cost

Water-based Coatings 283 1,186 793 31 2,558 676 NA NA NA NA $0

Solvent-based 1,872 1,189 3,794 42 9,011 2,381 NA NA NA NA $0

Powder Coatings 0 0 100 0 0 NA NA NA NA $0

Thinning Solvents 630 876 0 0 719 190 $0.40 $288 $0.80 $575 $288

Surface Preparation 378 991 0 0 381 101 $0.40 $153 $0.80 $305 $153

Cleaning Solvents 721 991 0 0 728 192 $0.40 $291 $0.80 $582 $291

Adhesives 3 954 413 47 886 234 NA NA NA NA $0

Total 3,887 5,000 14,284 3,774 $731 $1,463 $731

 kg HAP/L coating solids =0.777

Notes:

NA = Specific costs not available

Thinning and cleaning solvents are considered 100% HAP

Total Usage for coatings and adhesives=Coating Solids/(% Coating Solids/100)

Total Usage for solvents = HAP/(density/1000)

Total $ Cost = $Cost/Liter * Total Usage

Change in $ Cost = Total $ Cost Compliant - Total $ Cost Non-Compliant
7-9

TABLE 7-2. MODEL PLANT NUMBER 2 COST IMPACTS

(UP TO 10,001 TO 50,000 LITERS OF COATING SOLIDS)

Plant Definition Tabular Costs

HAP

(kg)

Density

(g/l)

Coating

Solids

(liters)

%Coating

Solids

Total

Usage

(liters)

Total

Usage

(gallons)

$ Cost/Liter

NonCompliant

Total $ Cost

NonCompliant

$ Cost/Liter

Compliant

Total $ Cost

Compliant

Change in

$ Cost

Water-based Coatings 708 1,186 4,741 31 15,294 4,041 NA NA NA NA $0

Solvent-based 8,357 1,189 19,612 42 46,584 12,308 NA NA NA NA $0

Powder Coatings 0 0 100 0 0 NA NA NA NA $0

Thinning Solvents 1,955 876 0 0 2,232 590 $0.40 $893 $0.80 $1,785 $893

Surface Preparation 324 991 0 0 327 86 $0.40 $131 $0.80 $262 $131

Cleaning Solvents 3,242 991 0 0 3,271 864 $0.40 $1,309 $0.80 $2,617 $1,309

Adhesives 648 954 647 47 1,388 367 NA NA NA NA $0

Total 15,234 25,000 69,096 18,255 $2,332 $4,664 $2,332

 kg HAP/L coating solids = 0.609

Notes:

NA = Specific costs not available

Thinning and cleaning solvents are considered 100% HAP

Total Usage for coatings and adhesives=Coating Solids/(% Coating Solids/100)

Total Usage for solvents = HAP/(density/1000)

Total $ Cost = $Cost/Liter * Total Usage

Change in $ Cost = Total $ Cost Compliant - Total $ Cost Non-Compliant
7-10

TABLE 7-3. MODEL PLANT NUMBER 3 COST IMPACTS

(50,001 TO 200,000 LITERS OF COATING SOLIDS)

Plant Definition Tabular Costs

HAP

(kg)

Density

(g/l)

Coating

Solids

(liters)

% Coating

Solids

Total

Usage

(liters)

Total Usage

(gallons)

$ Cost/Liter

NonCompliant

Total $ Cost

NonCompliant

$ Cost/Liter

Compliant

Total $ Cost

Compliant

Change in

$ Cost

Water-based Coatings 4,102 1,186 30,299 31 97,739 25,823 NA NA NA NA $0

Solvent-based 11,212 1,189 42,079 42 99,950 26,407 NA NA NA NA $0

Powder Coatings 0 26,918 100 26,918 7,112 NA NA NA NA $0

Thinning Solvents 6,500 876 0 0 7,420 1,960 $0.40 $2,968 $0.80 $5,936 $2,968

Surface Preparation 229 991 0 0 231 61 $0.40 $92 $0.80 $185 $92

Cleaning Solvents 7,340 991 0 0 7,407 1,957 $0.40 $2,963 $0.80 $5,925 $2,963

Adhesives 53 954 704 47 1,511 399 NA NA NA NA $0

Total 29,436 100,000 241,175 63,719 $6,023 $12,046 $6,023

 kg HAP/L coating solids = 0.294

Notes:

NA = Specific costs not available

Thinning and cleaning solvents are considered 100% HAP

Total Usage for coatings and adhesives=Coating Solids/(% Coating Solids/100)

Total Usage for solvents = HAP/(density/1000)

Total $ Cost = $Cost/Liter * Total Usage

Change in $ Cost = Total $ Cost Compliant - Total $ Cost Non-Compliant
7-11

TABLE 7-4. MODEL PLANT NUMBER 4 COST IMPACTS

(GREATER THAN 200,000 LITERS OF COATING SOLIDS)

Plant Definition Tabular Costs

HAP

(kg)

Density

(g/l)

Coating

Solids

(liters)

%Coating

Solids

Total

Usage

(liters)

Total Usage

(gallons)

$ Cost/Liter

NonCompliant

Total $ Cost

NonCompliant

$ Cost/Liter

Compliant

Total $ Cost

Compliant

Change in

$ Cost

Water-based Coatings 24,460 1,186 162,884 31 525,432 138,820 NA NA NA NA $0

Solvent-based 31,544 1,189 160,112 42 380,314 100,479 NA NA NA NA $0

Powder Coatings 0 292,908 100 292,908 77,387 NA NA NA NA $0

Thinning Solvents 42,992 876 0 0 49,078 12,966 $0.40 $19,631 $0.80 $39,262 $19,631

Surface Preparation 122 991 0 0 123 33 $0.40 $49 $0.80 $98 $49

Cleaning Solvents 15,408 991 0 0 15,548 4,108 $0.40 $6,219 $0.80 $12,438 $6,219

Adhesives 10,709 954 9,096 47 19,519 5,157 NA NA NA NA $0

Total 125,235 625,000 1,282,922 338,949 $25,899 $51,799 $25,899

 kg HAP/L coating solids = 0.200

Notes:

NA = Specific costs not available

Thinning and cleaning solvents are considered 100% HAP

Total Usage for coatings and adhesives= Coating Solids/(% Coating Solids/100)

Total Usage for solvents = HAP/(density/1000)

Total $ Cost = $Cost/Liter * Total Usage

Change in $ Cost = Total $ Cost Compliant - Total $ Cost Non-Compliant
7-12

TABLE 7-5. SUMMARY OF COST IMPACTS FOR EXISTING SOURCES

Annual Cost ($) Number of Facilities Nationwide Costs ($)

Model Plant 1 731 26 19,006

Model Plant 2 2,332 19 44,308

Model Plant 3 6,023 17 102,391

Model Plant 4 25,899 12 310,788

TOTAL 74 476,493
7-13

TABLE 7-6. SUMMARY OF ESTIMATED MONITORING, RECORDKEEPING, AND REPORTING COSTS -- YEARS 1 - 5

YEAR EXISTING

SOURCE

COSTS ($)

EXISTING

SOURCE

BURDEN

(HOURS)

NEW

SOURCE

COSTS

($)

NEW

SOURCE

BURDEN

(HOURS)

TOTAL

NATIONWIDE

ANNUAL COST ($)

TOTAL

NATIONWIDE

BURDEN (HOURS)

1 158,135 3,404 91,462 1,969 249,597 5,373

2 0 0 153,861 3,312 153,861 3,312

3 458,592 9,872 216,260 4,655 674,852 14,527

4 1,154,386 24,849 278,660 5,998 1,433,046 30,847

5 1,154,386 24,849 341,059 7,342 1,495,445 32,191

AVERAGE 585,100 12,595 216,260 4,655 801,360 17,250

TABLE 7-7. TOTAL ESTIMATED COST OF PROPOSED STANDARDS -- YEARS 1 - 5
7-14

YEAR COST TO COMPLY

($)

MONITORING,

RECORDKEEPING,

REPORTING COSTS ($)

TOTAL ANNUAL

COSTS ($)

1 0 249,597 249,597

2 0 153,861 153,861

3 0 674,852 674,852

4 476,493 1,433,045 1,909,538

5 476,493 1,495,445 1,971,938

AVERAGE 190,597 801,360 991,957
8-1

ECONOMIC IMPACT ANALYSIS: LARGE APPLIANCE COATING

THE FULL TEXT OF THE ECONOMIC IMPACT ANALYSIS IS LOCATED IN THE DOCKET FOR THE

PROPOSED STANDARDS (DOCKET NUMBER A-97-41, ITEM NUMBER II-A-4) .
A-1

APPENDIX A
A-2

TABLE A-1. LARGE APPLIANCE POTENTIAL MAJOR AND 

SYNTHETIC MINOR FACILITIES

Facility City State

Major Sources

Amana Appliances Searcy AR

Amtrol, Inc. West Warwick RI

Beam Industries Webster City IA

Behr Climate Systems, Inc. Ft. Worth TX

Beverage-Air Spartanburg SC

Bristol Compressors Bristol VA

Bristol Compressors - Sparta Sparta NC

Broan Mfg. Hartford WI

Buffalo Air Handling Company Amherst VA

Carrier Corporation Collierville TN

Copeland Sidney OH

Evapco, Inc. - Midwest Greenup IL

Fedders Corp. Effingham IL

Friedrich Air Conditioning Company San Antonio TX

Frigidaire Commercial Products Conway AR

Frigidaire Home Products Edison NJ

Frigidaire Home Products Springfield TN

Frigidaire Home Products, Laundry Division Webster City IA

GE Appliances Louisville KY

Goodman Manufacturing Co. LP Houston TX

Heatcraft Inc. OEM Plant Grenada MS

Hussmann Atlanta Custom Systems Norcross GA

In-Sink-Erator Racine WI

International Comfort Products Corporation Lewisburg TN

International Comfort Products Corporation Lewisburg TN

Kysor Warrren Conyers GA

Lennox Industries Inc. Marshalltown IA

Marvel Industries Richmond IN

Matsushita Compressor Corporation of

America

Mooresville NC
TABLE A-1. LARGE APPLIANCE POTENTIAL MAJOR AND 

SYNTHETIC MINOR FACILITIES (Continued)

Facility City State

A-3

Matsushita Home Appliance Corporation of

America

Danville KY

Matsushita Refrigeration Company of

America

Vonore TN

Maytag Appliances - Newton Laundry

Products-Plant 2

Newton IA

Maytag- GRP Galesburg IL

Maytag Herrin Laundry Products Herrin IL

McQuay International, Inc. Verona VA

MIDCO International Incorporated Chicago IL

Osmonics, Incorporated Minnetonka MN

Pitco Frialator, Inc. Bow NH

Porcelain Metals Corporation Louisville KY

Rheem Manufacturing Company Montgomery AL

Scotsman Ice Systems-Fairfax Operations Fairfax SC

Sharp Manufacturing Company Memphis AL

State Industries, Inc. Ashland City TN

Taylor Company Rockton IL

Tennant Company Minneapolis MN

The Amana Company, L. P. Amana IA

The Ducane Co. Blackville SC

The Trane Company Clarksville TN

The Trane Company Fort Smith AR

The Trane Company La Crosse WI

The Trane Company Trenton NJ

The Trane Company Charlotte NC

Thermal Engineering Corporation Columbia SC

Toastmaster Inc. Macon MO

Toastmaster Inc. Boonville MO

Tyler Refrigeration Corp., Niles Case Plant Niles MI
TABLE A-1. LARGE APPLIANCE POTENTIAL MAJOR AND 

SYNTHETIC MINOR FACILITIES (Continued)

Facility City State

A-4

Tyler Refrigeration Corp., Waxahachie Case

Plant

Waxahachie TX

U.S. Filter / IWT Rockford IL

Vilter Manufacturing Corporation Cudhay WI

West Bend Company West Bend WI

Whirlpool Corporation LaVergne TN

Whirlpool Corporation Evansville IN

Whirlpool Corporation - Findlay Division Findlay OH

Whirlpool Corporation - Marion Division Marion OH

Whirlpool Corporation-Clyde Division Clyde OH

Whirlpool Corporation-Fort Smith Arkansas

Division

Fort Smith AR

York International - Frick Waynesboro PA

York International - Grantley York PA

York International - Reco San Antonio TX

York International - Tempmaster Albany MO

Synthetic Minor Sources

A.O. Smith Water Products Company McBee SC

Addison Products Company Orlando FL

ALTO U.S. Inc. American-Lincoln

Technology

Bowling Green OH

Bard Manufacturing Company Bryan OH

Brown Stove Works, Inc. Cleveland TN

Carrier Corporation Syracuse NY

Carrier Corporation, McMinnville Morrison TN

Copeland Rushville Rushville IN

Dunham Bush Inc Harrisonburg VA

Frigidaire Home Products-Dishwasher

Prod.

Kinston NC

Heatcraft Inc. Danvilee IL

Hill Phoenix, Inc. Colonial Heights VA
TABLE A-1. LARGE APPLIANCE POTENTIAL MAJOR AND 

SYNTHETIC MINOR FACILITIES (Continued)

Facility City State

A-5

Hussmann Corporation Bridgeton MO

IMI Cornelius, Inc. Anoka MN

Maytag Cleveland Cooking Products Cleveland TN

PMI Food Equipment Group/Hobart Hillsboro OH

RAE Corporation Pryor OK

Sub Zero Freezer Co., Inc. Phoenix AZ

Sub Zero Freezer Co.,Inc. Madison WI

Tecumseh Products Division Tecumseh MI

The Trane Company Lexington KY

The Trane Company Macon GA

The Trane Company Macon GA

The Trane Company Pueblo CO

York International - Pace Portland OR
A-6

TABLE A-2. SUMMARY OF REGULATIONS BY STATE

State Regulation Applicability Requirements Recordkeeping

California - Bay

Area

Regulation 8

Rule 14

Surface coating of large

appliances and metal furniture.

Not applicable to any facility which

applies coatings in volumes of less than 20

gallons (75.7 liters) per year.

Not applicable to coating operations

employing hand-held aerosol cans.

Not applicable to the use of powder

coatings provided the emission of VOC

does not exceed that which is equivalent

to the use of complying coatings.

The method of coating application

must have a transfer efficiency of 65%

or greater.

Emission limits for:

•baked coatings

2.3 lbs./gal (275 g/L) of coating,

excluding water

•air-dried coatings 2.8 lbs./gal (340

g/L) of coating, excluding water

Specialty coating VOC limits in lbs/gal

(g/L) of coating, excluding water:

 Baked Air

•high-gloss 3.0 (360) 3.5

(420)

•heat-resistant 3.0 (360) 3.5

(420)

•metallic topcoat 3.0 (360) 3.5

(420)

•pretreatment 3.5 (420) 3.5

(420)

•solar absorbent 3.0 (360) 3.5

(420)

Facilities shall maintain a current list of

coatings in use which includes the

following information:

•coating, catalyst and reducer used.

•quantity of each coating.

•VOC of coatings used.

•mix ratios of coatings.

•type and amount of solvent.

Records shall be kept on a daily basis

and retained for a period of two years.

California - 

Sacramento

District incorporates 40 CFR 60 Subpart SS - Industrial Surface Coating: Large Appliances. The 30-day emissions averaging periods specified in the federal standard are

deleted and replaced with 24-hour maximum emission averaging periods for affected sources. 
TABLE A-2. SUMMARY OF REGULATIONS BY STATE (Continued)

State Regulation Applicability Requirements Recordkeeping

A-7

Connecticut 22a-174-32

RACT for VOCs.

Any facility located in a serious

nonattainment area for ozone that emits

50 tons of VOCs or more is applicable.

Any facility located in a severe

nonattainment area for ozone that emits

25 tons of VOCs or more per year is

applicable.

Any facility which installs and operates

a system of capture and control shall:

•reduce VOC emissions by at least 

 85% of uncontrolled emissions.

•oxidize in carbon dioxide and 

 water at least 95% of the non-

 methane VOCs.

•operate so that the VOC emission 

 rate leaving the outlet does not 

 exceed 10% of the VOC mass 

 emission rate entering the system.

Facilities shall retain records for a

period of at least three years.

Records should include, but are not

limited to:

•purchase records for all material 

 which contain VOCs.

•the name of each coating, the 

 coating density in pounds per 

 unit, the VOC content of each 

 coating by weight, the amount of 

 each coating used, and the total 

 amount of diluent (thinner) used for

each 

 coating.

•the results of any VOC testing.

Florida 62-296.506

Surface coating of large

appliances.

Does not apply to quick-drying lacquers

for repair during assembly provided the

volume of coating does not exceed one

quart (0.95 liters) in any 8-hour period.

Emission limits shall be achieved by:

•the application of low solvent 

 content coating technology; or

•incineration, provided that 90% of 

 the VOCs which enter the 

 incinerator are oxidized.

Daily records of operations shall

include, but are not limited to:

•the application method and 

 substrate type.

•the amount and type of coating 

 and solvent used.

•the VOC content as applied in 

 each coating and solvent.

•oven temperature where 

 applicable.

Louisiana Part III

Chapter 1

Subchapter SS: Standards of

performance for industrial

surface coating: large appliances.

State follows Federal CTG applicability 

standards.

Transfer efficiency requirements:

•air-atomized spray 0.40

•airless spray 0.45

•manual electrostatic 0.60

•flow coat 0.85

•dip coat 0.85

•nonrotational auto. 0.85

•rotating head auto. 0.90

•electrodeposition 0.95 

Records must be retained for a period of

at least two years.

State follows Federal CTG

recordkeeping requirements.
TABLE A-2. SUMMARY OF REGULATIONS BY STATE (Continued)

State Regulation Applicability Requirements Recordkeeping

A-8

Maine Chapter 134

RACT for facilities that emit

VOCs.

Any facility which has the potential to

emit 40 tons of VOC per year or more is

applicable.

A facility must comply with one of the

following emission standards options:

•A VOC capture and control 

 system in which emissions do not 

 exceed 15% of the daily 

 uncontrolled emissions.

•A VOC emission reduction 

 program.

•An approved VOC alternative 

 reduction program.

A facility must comply with one of the

VOC emission reduction plans of

Section 3(B).

State follows the Federal CTG

recordkeeping requirements.

New Hampshire Chapter 1200

Part 1204 - Stationary sources of

VOCs

Section 1204.27 - Applicability

criteria and compliance options

for miscellaneous and multi

category stationary sources of

VOC sources.

Facilities that emit 50 tons or more of

VOCs per year are applicable.

Sources that meet or exceed RACT

criteria are exempt.

Control options:

•Installation and operation of 

 capture and control systems that 

 result in reduction of at least 81% 

 of VOC emissions.

•Limiting the daily weighted 

 average nonexempt VOC 

 emission rate to 0.40 kg VOC per 

 liter (3.5 lb VOC/gallon) of coating as 

 applied, excluding water and exempt 

compounds

•Implementation of a division and 

 EPA-approvable plan.

Copies of all records shall be retained

for a minimum of four years.

Records shall include:

•VOC emissions in tons per year.

•VOC emissions during high ozone 

 seasons in pounds per day.

•coating and diluent (thinner)

formulation 

 and analytical data.

•method of application.

•drying method.

•substrate type and form.

New Jersey 7:27-16.7

Surface coating and graphic arts

operations.

Facilities in which the total surface

coatings containing VOCs are applied at

rates less than one half gallon per hour

AND two and one half gallons per day are

exempt.

Facilities may apply for an alternative

maximum allowable VOC content

provided a transfer efficiency of 60%

or greater is demonstrated.

Maintenance records shall be kept of:

•the VOC content of coatings 

 applied.

•the percent weight of any exempt 

 organics in coatings.

•the daily volume of surface 

 coatings applied.
TABLE A-2. SUMMARY OF REGULATIONS BY STATE (Continued)

State Regulation Applicability Requirements Recordkeeping

A-9

New York Subchapter A

Part 288

Surface coating processes.

Does not apply to coatings that are

applied manually by brush, roller, or

aerosol spray can.

Facilities which emit less than 5 tons of

VOCs annually are exempt.

If a coating system is utilized as a

control strategy it must comply with

the provisions of 228.3(d).

A facility may be allowed to operate

with a lesser degree of control than

required if it is in compliance with the

following provisions:

•utilizing compliant coatings.

•utilizing proven emission control 

 technologies which achieve 

 overall removal efficiency less 

 than or equal to those required.

•utilizing proven production 

 modification methods which 

 result in documented reductions 

 in VOC emissions.

Records must be maintained at the

facility for a period of five years.

State follows Federal CTG

recordkeeping requirements.

North Carolina Chapter 2D

 Section .0900

Volatile organic compounds.

 Section. 0923

Surface coating of large

appliances.

Does not apply to the use of quick-drying

lacquers provided the volume of coating

does not exceed one quart in any eighthour period.

Modeling shall be used to determine

process operational and air pollution

control parameters and emission rates

for toxic air pollutants. 

Copies of all records shall be retained

for a period of two years.

Records shall include, but are not

limited to:

•details of all malfunctions.

•details of all testing that is 

 conducted.

•details of all monitoring 

 conducted.

•any information necessary to 

 determine compliance. 
TABLE A-2. SUMMARY OF REGULATIONS BY STATE (Continued)

State Regulation Applicability Requirements Recordkeeping

A-10

Ohio 3745-21-09 (K)

Surface coating of large

appliances.

Not applicable to: 

•coating line (surface coating operation)

at the "Whirlpool 

 Corporation" facility in Findlay, 

 OH.

•coating line (surface coating operation)

at the "Whirlpool Corporation" facility 

in Marion, 

 OH.

•quick-drying lacquers used for 

 repair during assembly provided the 

 volume of coating does not exceed 

 one quart in any eight-hour period.

•large appliance coatings which are 

 subject to in-use temperatures in 

 excess of 250EF

Emission limits:

•2.8 lbs. of VOC per gallon of 

 coating (excluding water and exempt

 solvents); or

•4.5 lbs. of VOC per gallon of 

 nonvolatiles (Coating Solids) if a

control system is 

 employed.

A facility which complies with the

applicable emission limits by use of

complying coatings shall collect and

record data on a monthly basis and

retain such records for a period of

three years.

Rhode Island Air Pollution Control Regulation 

# 19

Control of VOCs from surface

coating operations.

Applicable to facilities listed under SIC

Code 363.

Does not include quick drying lacquers used

for repair, provided the volume of coating

used does not exceed 0.25 gallons in any

8-hour period.

A facility that emits less than 1,666 lbs.

of VOCs per month is exempt.

Any facility for which emissions are

greater than 15 lbs. of VOCs per day is

applicable.

Compliance shall be achieved as per

subsection 19.3.2.

Alternative VOC emission standards

(bubble concept) may be approved by

the director if requested by the facility.

Compliance by use of Daily-Weighted

Average according to subsection 19.5.2.

Compliance by use of Complying

Coatings according to subsection

19.5.3.

Compliance by use of Control Devices

according to subsection 19.5.4.

Monthly records of the following shall

be kept for a period of five years:

•the name and identification 

 number of each coating.

•the mass of VOCs per volume

(excluding water) of 

 coating.

•the type and amounts of solvents 

 used.
TABLE A-2. SUMMARY OF REGULATIONS BY STATE (Continued)

State Regulation Applicability Requirements Recordkeeping

A-11

South Carolina Appendix C

Standard No. 5

Part D - Surface coating of metal

furniture and large appliances.

State follows Federal CTG standards. The emission limit does not apply to

the use of quick-drying lacquers used for

repairs during assembly provided the

volume of coating does not exceed 1

quart (0.95 liters) in any one 8-hour

period.

Emission limitations can be achieved

by:

•the application of low solvent 

 coating technology

•incineration, provided that 90% of 

 the nonmethane VOCs which 

 enter the incinerator are oxidized

•carbon bed solvent recovery 

 system

•alternative controls allowed under 

 Section 1

•a capture system used in 

 conjunction with emission control 

 equipment systems.

State follows Federal CTG standards.

Tennessee 1200-3-16-.36

Industrial Surface Coating: Large

appliances.

State follows Federal CTG standards. No facility shall discharge VOC

emissions that exceed 0.90 kg of VOCs

per liter.

Daily records shall be maintained for a

period of at least two years.

Facility must maintain records of each

instance in which the volume-weighted

average of the total mass of VOCs

emitted per volume of coating

nonvolatiles is greater than 0.90 kg per

liter.
TABLE A-2. SUMMARY OF REGULATIONS BY STATE (Concluded)

State Regulation Applicability Requirements Recordkeeping

A-12

Vermont 5-253.20

Other sources that emit VOCs.

Any facility which has annual VOC

emissions of 50 tons or more is applicable.

The facility will install and operate

emissions capture and control

techniques or use complying coatings

that have overall VOC reductions of at

least 81 weight percent.

The daily weighted average VOC for all

applicable facilities is 3.5 lbs. of VOC

per gallon or less.

Facilities must comply with an

alternative control plan approved by

the Air Pollution Control Officer.

A facility may be required to use and

maintain air monitoring equipment and

records.

A facility may be required to conduct

diffusion or other air quality modeling. 

Facility will maintain records to

demonstrate continuing compliance as

required by the Air Pollution Control

Officer.

Washington -

Spokane

Section 6.13

General surface coating.

Not applicable to:

•facilities using less than 10 gallons 

 per year of surface coatings.

•infrequent outdoor surface coating 

 of large objects where the control 

 officer determines that it is 

 impractical to totally enclose the 

 object.

•any coating or other agent from pre-

 packaged aerosol cans.

•application of coatings with VOC 

 content less than 2.1 lbs./gal.

A spraying technique must exhibit a

transfer efficiency of at least 65%.

Facilities shall maintain the following

records for a period of two years:

•the most current MSDS or other 

 data sheets which clearly indicate 

 the VOC content of the product.

•records of purchases and usage.

•annual usage of coatings, coating 

 additives, wipe-down agents, 

 reducers and other materials 

 containing VOCs or volatile toxic 

 air pollutants.

Multiply tons by 0.907 to obtain megagrams (Mg).

Multiply pounds by 0.4536 to obtain kilograms (kg).

Multiply gallons by 3.785 to obtain liters (L).
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CONVERSION FACTORS FOR METRIC UNITS

 Metric units may be converted to common English units by using the following conversion factors:

Metric Unit Metric Name Equivalent English Unit

1 m meter 3.2808 ft (feet)

2.54 cm centimeter 1 in. (inch)

0.0283 m3cubic meter 1 ft3 (cubic foot)

liter liter 0.0353 ft3

dscm dry standard cubic meter 35.31 dry standard ft3

scmm standard cubic meters per minute 35.31 ft3/min

kg kilogram (103 grams) 2.2046 lb (pound)

Mg megagram (106 grams) 2,204.6 lb

Mg megagram (106 grams) 1.102 English tons

metric ton metric ton (106 grams) 2,204.6 lb

1 m3cubic meter 264.17 gallons

3.785 liters liters 1 gallon

1.054 kJ kilojoule 1 Btu (British Thermal Unit)

1.054 X 106 kJ kilojoule MMBtu

3514 J/s Joules per second 1 ton (or 12,000 Btu/hr)

16.02 kg/m3kilograms per cubic meter 1 lb/ft3 (pounds/cubic foot)

T (EF) = temperature in degrees Fahrenheit

< Temperature in degrees Celsius (EC) can be converted to temperature in degrees Fahrenheit (EF) by the

following formula:

T (EF) = 1.8 T (EC) + 32

T (EC) = temperature in degrees Celsius or degrees Centigrade

< Temperature in degrees Fahrenheit (EF) can be converted to temperature in degrees Celsius (EC) by the

following formula:

T (EC) = [T (EF) - 32]/1.8