MEMORANDUM TO: Metal Furniture Project Docket No. A-97-40 SUBMITTED BY: Dr. Mohamed Serageldin, ESD/CCPG DATE: August 4, 1997 SUBJECT: Summary of the July 31, 1997, Metal Furniture Integrated Rule Development, Second Roundtable Meeting (P-MACT/P-BAC) Phase The purpose of this memorandum is to summarize the discussion that took place during the second roundtable meeting for the metal furniture integrated rule development, held on July 31, 1997, at the Mutual Building in Durham, North Carolina. The meeting objectives were to present the current database of information about the metal furniture industry, discuss possible methods of data evaluation with industry and raise issues of concern to all parties, and to coordinate regulatory development efforts and scheduling with industry representatives. MEETING PARTICIPANTS Environmental Protection Agency (EPA) Dr. Mohamed Serageldin, Office of Air Quality Planning and Standards Ms. Linda Herring, Office of Air Quality Planning and Standards EC/R Incorporated David Hendricks Karen Holmes Co-regulators and Industry Representatives See Attachment 1. SUMMARY OF DISCUSSION Dr. Serageldin opened the meeting by welcoming all of the participants and allowing each participant to provide a brief introduction. He then gave an overview of the regulatory development process and explained that both a National Emission Standard for Hazardous Air Pollutants (NESHAP) under Section 112 of the Clean Air Act and a Control Techniques Guideline (CTG) document or national standard for the control of volatile organic compounds (VOC) emissions under Section 183(e) of the Act, will be developed for the metal furniture industry. Dr. Serageldin explained that many of the responses from the Section 114 questionnaire were labeled as Confidential Business Information (CBI) and as such, the information that the EPA can release to the Work Team is restricted. Mr. Hendricks presented an overview of the results of the Section 114 questionnaire covering coating operations, cleaning operations, and emission reduction and pollution prevention techniques (see Attachment 2). The coating data were evaluated by coating line type, surface area coated, and variability of VOC and solids content by color. One issue raised during the presentation was the use of solids content on a percent by weight basis in the analyses. The industry felt that the trends established would be more valid if the solids content was evaluated on a solids content by percent volume basis. An overview of the information requested and received from State/local agencies was presented by Ms. Holmes (see Attachment 2). Ms. Holmes explained that States identified as containing the highest number of metal furniture manufacturers were requested to provide the EPA with RACT/BACT/LAER information, state emission inventories, and Title V permit applications. A summary of the information received to date was provided to the Work Team. A handout entitled "Development of Industrial Surface Coating Regulations" was distributed (see Attachment 3) to address industry concerns over the objectives of the P-MACT/BAC phase of the regulatory development. The handout indicated that the P-MACT/BAC document may or may not contain a preliminary emission limitation/control strategy for P-MACT/BAC. Dr. Serageldin explained that information was evaluated on a per surface area basis because this method accounts for transfer efficiency without having to consider variables such as the operator and gun type. Mr. Hendricks explained that the EPA intends to incorporate different methods of evaluating data, as well as multiple compliance options for the the final regulation. Ms. Mika stressed that in order to correctly evaluate data on a surface area basis, coating thickness must be determined. Additionally, a facility that has a lower thickness specification and lower transfer efficiency may use the same amount of coating as a facility with a higher thickness specification and higher transfer efficiency. Ms. Mika stated that many companies do not know the actual coating thickness and only have minimum coating thickness specifications. Mr. Lesnet stressed that the calculation must use coating properties for the coating as supplied to the applicator. Mr. Naour questioned if it was reasonable to require each individual facility to calculate the surface area of multiple geometric shapes. Mr. Lesnet suggested the use of an assumed transfer efficiency as in 40 CFR Part 60, Subpart EE--Standards of Performance for Surface Coating of Metal Furniture. Dr. Serageldin cautioned against using the transfer efficiencies as stated in 40 CFR Part 60, Subpart EE, because the EPA currently has no evidence industry is actually achieving those efficiencies. Ms. Mika questioned the benefit of going into such detail regarding surface area of each part coated and transfer efficiency when emission reduction may still be achieved through other methods more familiar to the industry. Mr. Lesnet suggested comparing the best technology currently available with the 40 CFR Part 60, Subpart EE, limit of 0.9 kg per liter of coating solids applied using the transfer efficiencies as listed to determine the greatest possible emission reduction. Ms. Mika asked if it would be possible to receive, evaluate, and prepare comments on a draft copy of the next Section 114 questionnaire before it is distributed. There was general concurrence on this suggestion by the Work Team. Ms. Herring stated that the EPA plans to develop the questionnaire in conjunction with the seven other coating categories and will ask industry to be involved with sections relevant to their specific coating category. The Work Team discussed industry's current methods of evaluating coatings for purchase. Mr. Lesnet stated that HON purchases coatings based on price per gallon regardless of coverage. The assumption here is that there is very little difference in coverage from one supplier to another, and it is not worthwhile to evaluate. Ms. Mika explained that generally there is not a large difference in solids content of the coatings supplied by different vendors. She also explained that Steelcase purchases coatings from only top quality vendors and multiple considerations are weighted, not only coverage. Mr. Olsen explained that the type and amount of coating purchased by Lozier is determined by the coating price per area covered. Mr. Lesnet explained that coverage is dependent on the volume of solids. Therefore, coverage should be the same gallon to gallon for different colors, given an equal volume of solids. He stated that "hiding" is a greater concern. The lighter the color the thicker the coating requirement to hide the substrate and ensure that the particular color appears the same from part to part. ACTION ITEMS The EPA will post a copy of the Section 114 questionnaire on the TTN. The third Roundtable meeting is tentatively scheduled for September 16, 1997. ATTACHMENT 1 LIST OF ATTENDEES METAL FURNITURE INTEGRATED RULE DEVELOPMENT SECOND ROUNDTABLE MEETING JULY 31, 1997 LIST OF ATTENDEES Name Company Mailing Address Telephone/Fax Number e-mail Address Mohamed Serageldin U.S. EPA OAQPS/ESD/CCPG (MD-13) Research Triangle Park, NC 27711 (919) 541-2379 fax(919) 541-5689 serageldin.mohamed@epamail.epa.gov David Hendricks EC/R Incorporated 2327 Englert Drive Suite 100 Durham, NC 27713 (919) 484-0222 ext. 335 fax-(919) 484-0122 hendricks-ecr@mindspring.com Karen Holmes EC/R Incorporated 2327 Englert Drive Suite 100 Durham, NC 27713 (919) 484-0222 ext. 310 fax-(919) 484-0122 ecr-rtp@mindspring.com Scott Lesnet HON Industries SMH Technical Center 505 Ford Avenue Muscatine, IA 52761 (319) 262-7865 fax-(319) 262-7899 Brad Miller BIFMA International 2680 Horizon Drive, SE Suite A-1 Grand Rapids, MI 49546 (616) 285-3963 fax-(616) 285-3765 bmiller@bifma.com William English PPG Industries One PPG Place Pittsburgh, PA 15272 (412) 434-3198 fax-(412) 434-3705 Stan Schmitt Kimball, Inc. 1155 West 12th Avenue Jasper, IN 47549 (812) 634-3274 fax-(812) 634-3250 staschm@kimball.e-mail.com Larry Runyan AFMA P.O. Box HP-7 High Point, NC 27261 (910) 884-5000 fax-(910) 884-5303 lfrun@aoi.com Mary Ellen Mika Steelcase, Incorporated P.O. Box 1967 Mail Code: PS Grand Rapids, MI 49501 (616) 246-9787 fax-(616) 246-9191 mmika@steelcase.com Venkata Panchakarla Florida Department of Environmental Protection Mail Station #5500 2600 Blair Stone Road Tallahassee, FL 32399 (904) 488-0114 fax-(904) 922-6979 panchakarla_v@dep.state.fl.us Ron Tucker Lilly Industries 2137 Brevard Rd. High Point, NC 27261 (910) 802-4337 fax-(910) 889-6007 Robert Nelson NPCA 1500 Rhode Island Ave. NW Washington, DC 20005 (202) 462-6272 fax-(202) 462-8549 bnelson@paint.org Mick Durham Stanley Environmental, Incorporated 225 Iowa Avenue Muscatine, IA 52761 (319) 264-6342 fax-(319) 264-6658 durhammick@stanleygroup.com Mary Husted Husted & Associates, Inc. P.O. Box 5256 High Point, NC 27262 (910) 869-3097 fax-(910) 869-3031 Jeffery A. Masi Allsteel Inc. 71 Denton Fly Road Milan, TN (901) 686-4116 fax-(901) 686-4120 Greg Olsen Lozier Corporation Box 19999 Omaha, NE 68119-0999 (402) 457-8433 fax-(402) 457-8554 gregolsen@compuserve.com Walt Hammond Thomasville Furniture Ind., Inc. P.O. Box 339 Thomasville, NC 27361-0339 (910) 476-2263 fax-(910) 472-4080 Andy Counts American Furniture Manufacturers Association P.O. Box HP-7 High Point, NC 27261 (910) 884-5000 fax-(910) 884-5303 acounts@ng.infi.net Bernard Zysman Occidental Chemical P.O. Box 344 Niagara Falls, NY 14302 (716) 278-7894 fax-(716) 278-7297 bernie_zysman@oxy.com Thomas Ashley Charleston Forge 251 Industrial Park Dr. Boone, NC 28607 (704) 264-0100 fax-(704) 264-5901 Bob Wood Lexington Furniture Industries P.O. Box 1008 Lexington, NC 27293 (910) 249-5316 fax-(910)-249-5588 BWood@InfoAve.net Dave Mazzocco PPG Industries 4325 Rosanna Dr. Allison Park, PA 15101 (412) 492-5476 fax-(412) 492-5377 massocco@ppg.com Michael S. McMullen American Seating Company 401 American Seating Center Grand Rapids, MI 49504 (616) 732-6650 fax-(616) 732-6401 Diane Luo Pelton & Crane 11727 Fruehauf Dr. Charlotte, NC 28241 (704) 587-7294 fax-(704) 587-7214 dluo@smspelton.sms.siemens.com Hank Naour Illinois EPA Bureau of Air P.O. Box 19506 Springfield, IL 62794-9506 (217) 785-1716 fax-(217) 524-5023 Christy Myers Alabama DEM 1751 Cong. W.L. Dickenson Drive Montgomery, AL 36130 (334) 271-7861 fax-(334) 279-3044 Stan Cowen Ventura County APCD 669 County Square Drive Ventura, CA 93003 (805) 645-1408 fax-(805) 645-1444 Richard Wales Mojave Desert/Antelope Valley APCD 15428 Civic Drive Suite 200 Victorville, CA 92392-2383 (760) 245-1661 fax-(760) 245-2699 John Ramsey Kansas Department of Health and Environment Forbes Field, Building 740 Topeka, KS 66620 (913) 296-1593 fax-(913) 296-1545 ATTACHMENT 2 EC/R PRESENTATION OVERHEADS EPA/INDUSTRY/STATES ROUNDTABLE MEETING NO. 2 Metal Furniture Integrated Rule Development July 31, 1997 Durham, NC METAL FURNITURE SURFACE COATING INDUSTRY QUESTIONNAIRE Sent to 8 companies 4 Office furniture - SIC Code 2522 2 Store fixtures - SIC Code 2542 1 Laboratory furniture - SIC Code 3821 1 Dentist's chairs and equipment - SIC Code 3843 Received responses from 17 facilities representing 46 coating lines CRITICAL DATA REPORTED BY COATING LINE IN SECTION 114 QUESTIONNAIRE RESPONSES Requested Information Complete Response Partial Response No Response Surface Area Coated 21 0 25 UOS Diagrams 17 23 6 Process Descriptions 36 0 10 Process Flow Diagrams 46 0 0 Coating Usage 28 0 17 Coating Properties 40 4 2 Emissions By Emission Point 26 16 4 ANALYSIS OF COATING DATA "As applied" data only 144 Individual coatings In general, trend appears to be that yellows and whites have lower VOC and higher solids content, with "darker" colors having higher VOC and lower solids content. Average VOC and Solids* Content By Color Brown Gray Red Black Blue Green White Yellow VOC Content (g/l) 289 281 279 276 276 274 270 229 Solids Content (% by wt) 78.82 79.31 77.92 76.85 77.73 77.41 82.15 82.52 * Solids = nonvolatiles SUMMARY OF COATING EMISSION DATA Adhesive Application/Curing Systems Liquid Spray Coating Application/Curing Systems Liquid Dip Coating Application/Curing Systems Powder Coating Application/Curing Systems Electrocoat Application/Curing Systems Electrolytic Plating Systems SUMMARY OF COATING EMISSION DATA (continued) ADHESIVE APPLICATION/CURING SYSTEMS 1 Roll coat line Emissions of 0.28 kg VOC/m2 4 Spray applied lines Emission rates of 0.080 and 0.084 kg VOC/m2 (based on 2 lines that reported surface area) 1 "Manually applied" No surface area provided SUMMARY OF COATING EMISSION DATA (continued) LIQUID SPRAY COATING APPLICATION/CURING SYSTEMS Data for 24 coating lines, but only 10 reported surface area Emission rates range from 0.0076 to 0.28 kg VOC/m2 The 0.0076 kg VOC/m2 was based on coating usage of 159,083 kg and surface area of 3.071,224 m2 LIQUID DIP COATING APPLICATION/CURING SYSTEMS Data for 1 coating line, but no surface area reported SUMMARY OF COATING EMISSION DATA (continued) POWDER COATING APPLICATION/CURING SYSTEMS Data for 12 lines, but only 6 reported surface area None of the 12 lines reported any HAP or VOC emissions from the curing step 2 powder coating application booths were reported vented to atmosphere, but no particulate emissions were reported SUMMARY OF COATING EMISSION DATA (continued) ELECTROCOAT APPLICATION/CURING SYSTEMS 1 line reported Emission rate of 0.014 kg VOC/m2 based on coating usage of 10,164 kg and surface area of 202,010 m2 ELECTROLYTIC PLATING SYSTEMS 1 nickel/chromium line reported Emission rate of 0.061 kg HAP/m2 based on surface area of 101,263 m2 SUMMARY OF CLEANING OPERATIONS Basic cleaning process consists of 2 to 6 stages and is generally configured as follows: Alkaline Clean Rinse Phosphate Rinse Pretreatment or Rinse Emissions considered to be very low, and do not consist of any HAP Solvent used for cleaning equipment, flushing paint lines, removal of excess adhesive, and minor surface cleaning No emissions reported from solvent cleaning EMISSION REDUCTION AND POLLUTION PREVENTION TECHNIQUES Conversion to powder coatings Reformulated coatings On-site and off-site recycling of paints and solvents On-site recycling of metal working coolants Number of Facilities in Primary SIC Codes Top 12 States Pennsylvania 16 Michigan 14 Tennessee 10 California 9 Wisconsin 9 Indiana 8 Alabama 7 Kansas 7 New York 7 Mississippi 6 North Carolina 6 Ohio 6 * Information derived from 1995 Toxic Release Inventory System (TRIS) data. Number of Facilities in Primary SIC Codes Top 10 States California 420 Michigan 294 New York 269 Florida 256 Illinois 235 Indiana 191 Texas 189 Missouri 161 Ohio 154 Pennsylvania 147 * Information derived from American Business Disk Database; American Business Information Incorporated; Omaha, Nebraska. SUMMARY OF RACT/BACT/LAER AND SIMILAR INFORMATION SOURCES CALIFORNIA - SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT þ BACT FOR SPRAY BOOTH - (EMISSIONS 63.5 KG VOC/DAY ((140 LB VOC/DAY)) LOWER SOLVENT COATING AND HIGHER TRANSFER EFFICIENCY AND ADD-ON CONTROL DEVICE ACHIEVING 90% OVERALL EFFICIENCY ADD-ON CONTROL DEVICE ACHIEVING 90% OVERALL EFFICIENCY LOWER SOLVENT COATING AND HIGHER TRANSFER EFFICIENCY LOWER SOLVENT COATING OR HIGHER TRANSFER EFFICIENCY þ BACT FOR SPRAY BOOTH - (EMISSIONS 63.5 KG VOC/DAY ((140 LB VOC/DAY)) LOWER SOLVENT COATING AND HIGHER TRANSFER EFFICIENCY AND ADD-ON CONTROL DEVICE ACHIEVING 90% OVERALL EFFICIENCY SUMMARY OF RACT/BACT/LAER AND SIMILAR INFORMATION SOURCES CALIFORNIA - SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT þ BACT FOR FLOW COATER, DIP TANK, AND ROLLER COATER - (EMISSIONS 16.3 KG VOC/DAY (36 LB VOC/DAY) UNCONTROLLED) LOWER SOLVENT COATING AND ADD-ON CONTROL DEVICE ACHIEVING 90% OVERALL EFFICIENCY COATING WITH SOLVENT CONTENT COMPLYING WITH APPLICABLE RULES AND ADD-ON CONTROL DEVICE ACHIEVING 90% OVERALL EFFICIENCY LOWER SOLVENT COATING þ BACT FOR FLOW COATER, DIP TANK, AND ROLLER COATER - (EMISSIONS 16.3 KG VOC/DAY (36 LB VOC/DAY) UNCONTROLLED) LOWER SOLVENT COATING AND ADD-ON CONTROL DEVICE ACHIEVING 90% OVERALL EFFICIENCY SUMMARY OF RACT/BACT/LAER AND SIMILAR INFORMATION SOURCES TEXAS NATURAL RESOURCE CONSERVATION COMMISSION þ RACT FOR METAL FURNITURE COATING - DAILY WEIGHTED AVERAGE OF 3.0 LB VOC/GAL ( 0.36 KG/LITER) OF COATING (MINUS WATER AND EXEMPT SOLVENT) SUMMARY OF EMISSIONS INVENTORIES AND ASSOCIATED DATA TENNESSEE - METROPOLITAN GOVERNMENT OF NASHVILLE AND DAVIDSON COUNTY þ 0.32 KG VOC/LITER (2.7 LB VOC/GAL), PAINT LINE LIMIT TENNESSEE - CHATTANOOGA/HAMILTON COUNTY AIR POLLUTION CONTROL BUREAU þ 0.012 KG VOC/LITER (0.027 LB VOC/HR), POWDER FINISHING LINE EMISSION LIMIT SUMMARY OF EMISSIONS INVENTORIES AND ASSOCIATED DATA CALIFORNIA - VENTURA COUNTY AIR POLLUTION CONTROL DISTRICT þ COATING LIMITS 130 GRAMS VOC/LITER (1.08 LB VOC/GAL) AS APPLIED, WATERBASED ENAMEL COATING, WATERBASED CLEAR COATING, AND GENERAL COATING (USAGE LIMITS ALSO) 0.245 KG VOC/LITER (2.04 LB VOC/GAL) AS APPLIED, PIGMENT CONCENTRATE 0.25 KG VOC/LITER (2.1 LB VOC/GAL) AS APPLIED, COATING 1 0.25 KG VOC/LITER (2.09 LB VOC/GAL) AS APPLIED, COATING 2 0.27 KG VOC/LITER (2.3 LB VOC/GAL) AS APPLIED, ENAMEL 0.34 KG VOC/LITER (2.8 LB VOC/GAL) AS APPLIED, POLYURETHANE 0.60 KG VOC/LITER (5.0 LB VOC/GAL) AS APPLIED, SURFACE COATING SUMMARY OF EMISSIONS INVENTORIES AND ASSOCIATED DATA CALIFORNIA - VENTURA COUNTY AIR POLLUTION CONTROL DISTRICT þ COATING LIMITS (CONTINUED) 420 GRAMS VOC/LITER (3.51 LB VOC/GAL) AS APPLIED, SPECIALTY COATING 70 GRAMS VOC/LITER (0.58 LB VOC/GAL) AS APPLIED, SURFACE COATING 340 GRAMS VOC/LITER (2.84 LB VOC/GAL) AS APPLIED, AIR-DRIED GENERAL COATING, AIR-DRIED PRIMER, AND AIR-DRIED AND BAKED LABORATORY FURNITURE COATING 275 GRAMS VOC/LITER (2.3 LB VOC/GAL) AS APPLIED, BAKED GENERAL COATING AND PRIMER 340 GRAMS VOC/LITER (2.83 LB VOC/GAL), BAKING ENAMEL 340 GRAMS VOC/LITER (2.83 LB VOC/GAL), POLYURETHANE, REDUCER, AND CATALYST 340 GRAMS VOC/LITER (2.83 LB VOC/GAL), METAL COATING SUMMARY OF EMISSIONS INVENTORIES AND ASSOCIATED DATA CALIFORNIA - VENTURA COUNTY AIR POLLUTION CONTROL DISTRICT þ SURFACE PREPARATION LIMITS 0.70 KG VOC/LITER (0.58 LB VOC/GAL) AS APPLIED, SURFACE PREPARATION 0.19 KG VOC/LITER (1.6 LB VOC/GAL) AS APPLIED, SURFACE PREPARATION þ CLEANING SOLVENT LIMITS 0.801 KG VOC/LITER (6.68 LB VOC/GAL) AS APPLIED, SPRAY EQUIPMENT CLEANING 0.81 KG VOC/LITER (6.72 LB VOC/GAL) AS APPLIED, SOLVENT 0.82 KG VOC/LITER (6.8 LB VOC/GAL) AS APPLIED, CLEANING SOLVENT 0.869 KG VOC/LITER (7.25 LB VOC/GAL) AS APPLIED, CLEANING SOLVENT SUMMARY OF AEROMETRIC RETRIEVAL SYSTEM (AIRS) DATA INDIANA - DEPARTMENT OF ENVIRONMENTAL MANAGEMENT þ VOC CONTROLS LISTED* ACTIVATED CARBON ADSORPTION SIC 3495 SOURCE - THINNER-MEK, CONTROL EFFICIENCY 99.96% SIC 3495 SOURCE - ADHESIVE-PRIMER, CONTROL EFFICIENCY 99.96% DIRECT FLAME AFTERBURN SIC 3499 SOURCE - PLANTWIDE PAINT VOC, CONTROL EFFICIENCY 85% * FURTHER INVESTIGATION IS NECESSARY TO DETERMINE IF SOURCES ARE APPLICABLE TO METAL FURNITURE. ATTACHMENT 3 MEETING HANDOUTS (TO BE POSTED)