DRAFT
CTG
for
Flat
Wood
Paneling,
Docket
No.
EPA­
HQ­
OAR­
2006­
0583
I.
Introduction
Clean
Air
Act
(
CAA)
section
172(
c)(
1)
provides
that
state
implementation
plans
(
SIPs)
for
nonattainment
areas
must
include
"
reasonably
available
control
measures"
(
RACM),
including
"
reasonably
available
control
technology"
(
RACT),
for
sources
of
emissions.
Section
182(
b)(
2)(
A)
provides
that
for
certain
nonattainment
areas,
States
must
revise
their
SIPs
to
include
RACT
for
sources
of
VOC
emissions
covered
by
a
control
techniques
guidelines
(
CTG)
document
issued
after
November
15,
1990
and
prior
to
the
area's
date
of
attainment.

The
United
States
Environmental
Protection
Agency
(
EPA)
defines
RACT
as
"
the
lowest
emission
limitation
that
a
particular
source
is
capable
of
meeting
by
the
application
of
control
technology
that
is
reasonably
available
considering
technological
and
economic
feasibility."
44
FR
53761
(
Sept.
17,
1979).
In
subsequent
Federal
Register
notices,
EPA
has
addressed
how
states
can
meet
the
RACT
requirements
of
the
Act.

CAA
section
183(
e)
directs
EPA
to
list
for
regulation
those
categories
of
products
that
account
for
at
least
80
percent
of
the
VOC
emissions,
on
a
reactivity­
adjusted
basis,
from
consumer
and
commercial
products
in
areas
that
violate
the
NAAQS
for
ozone
(
i.
e.,
ozone
nonattainment
areas).
EPA
issued
a
list
on
March
23,
1995,
and
has
revised
the
list
periodically.
See
60
FR
15264
(
March
23,
1995);
see
also
71
FR
28320
(
May
16,
2006),
70
FR
69759
(
Nov.
17,
2005);
64
FR
13422
(
Mar.
18,
1999).
Flat
wood
paneling
coatings
are
included
on
the
current
section
183(
e)
list.

This
draft
CTG
is
intended
to
provide
state
and
local
air
pollution
control
authorities
information
that
should
assist
them
in
determining
RACT
for
volatile
organic
compounds
(
VOCs)
for
flat
wood
paneling
coatings.
In
developing
this
CTG,
EPA,
among
other
things,
evaluated
the
sources
of
VOC
emissions
from
the
flat
wood
paneling
coating
industry
and
the
available
control
approaches
for
addressing
these
emissions,
including
the
costs
of
such
approaches.
Based
on
available
information
and
data,
EPA
provides
recommendations
for
RACT
for
the
flat
wood
paneling
coatings
at
issue
in
this
document.
EPA
solicits
comment
on
all
aspects
of
this
draft
document.

Once
finalized,
States
can
use
the
recommendations
in
this
CTG
to
inform
their
own
determination
as
to
what
constitutes
RACT
for
VOCs
for
flat
wood
paneling
coatings
in
their
particular
nonattainment
areas.
The
information
contained
in
this
document
is
provided
only
as
guidance.
This
guidance
does
not
change,
or
substitute
for,
applicable
sections
of
the
CAA
or
EPA's
regulations;
nor
is
it
a
regulation
itself.
This
document
does
not
impose
any
legally
binding
requirements
on
any
entity.
It
provides
only
recommendations
for
state
and
local
air
pollution
control
agencies
to
consider
in
determining
RACT.
State
and
local
pollution
control
agencies
are
free
to
implement
other
technically­
sound
approaches
that
are
consistent
with
the
CAA
and
EPA's
implementing
regulations
DRAFT
CTG
for
Flat
Wood
Paneling,
Docket
No.
EPA­
HQ­
OAR­
2006­
0583
The
recommendations
contained
in
this
draft
CTG
are
based
on
data
and
information
currently
available
to
EPA.
These
general
recommendations
may
not
apply
to
a
particular
situation
based
upon
the
circumstances
of
a
specific
source.
Regardless
of
whether
a
State
chooses
to
implement
the
recommendations
contained
herein
through
State
rules,
or
to
issue
State
rules
that
adopt
different
approaches
for
RACT
for
VOCs
from
flat
wood
paneling
coatings,
States
must
submit
their
RACT
rules
to
EPA
for
review
and
approval
as
part
of
the
SIP
process.
EPA
will
evaluate
the
rules
and
determine,
through
notice
and
comment
rulemaking
in
the
SIP
process,
whether
they
meet
the
RACT
requirements
of
the
Act
and
EPA's
regulations.
To
the
extent
a
State
adopts
any
of
the
recommendations
in
this
guidance
into
its
State
RACT
rules,
interested
parties
can
raise
questions
and
objections
about
the
substance
of
this
guidance
and
the
appropriateness
of
the
application
of
this
guidance
to
a
particular
situation
during
the
development
of
the
State
rules
and
EPA's
SIP
approval
process.

CAA
section
182(
b)(
2)
provides
that
a
CTG
issued
after
November
15,
1990
and
before
the
date
of
attainment
must
include
the
date
by
which
States
must
submit
SIP
revisions
in
response
to
the
CTG.
States
subject
to
section
182(
b)
should
submit
their
SIP
revisions
within
one
year
of
the
date
of
issuance
of
the
final
CTG
for
flat
wood
paneling
coatings.
States
subject
to
CAA
section
172(
c)(
1)
may
take
action
in
response
to
this
guidance,
as
necessary
to
attain.

II.
Background
and
Overview
In
June
1978,
EPA
published
a
final
CTG
for
flat
wood
paneling
coatings,
entitled
"
Control
of
Volatile
Organic
Emissions
from
Existing
Stationary
Sources,
Volume
VII,
Factory
Surface
Coating
of
Flat
Wood
Paneling,"
EPA­
450/
2­
78­
034
(
June
1978).
1
The
1978
CTG
is
included
as
Appendix
A
to
this
draft
CTG.
In
September
1979,
EPA
published
guidance
to
provide
assistance
to
State
and
local
air
pollution
control
agencies
in
preparing
RACT
regulations
for
a
variety
of
categories,
including
flat
wood
paneling.
2
In
2003,
EPA
promulgated
national
emission
standards
for
hazardous
air
pollutants
(
NESHAP)
covering
surface
coating
of
wood
building
products
(
including
flat
wood
paneling).
See
68
FR
31746
(
May
28,
2003).

At
least
28
State
and
local
jurisdictions
have
regulations
that
control
VOC
emissions
from
surface
coating
operations
that
include
flat
wood
paneling.
Most
of
these
regulations
are
general
surface
coating
rules;
a
few
are
specific
to
flat
wood
paneling.
Almost
all
of
the
jurisdictions
that
specifically
address
flat
wood
paneling
have
based
their
rules
on
the
1978
CTG.
However,
there
are
two
jurisdictions
in
California
that
have
requirements
specific
to
flat
wood
paneling
that
go
beyond
the
1978
CTG.
These
jurisdictions
are
Placer
County
California
Air
Pollution
Control
District
(
Placer
County)
and
South
Coast
Air
Quality
Management
District
(
South
Coast).
A
discussion
of
applicability
and
control
requirements
found
in
the
1978
CTG
and
in
the
Placer
County
and
South
Coast
rules
is
presented
in
Section
V
of
this
document.
DRAFT
CTG
for
Flat
Wood
Paneling,
Docket
No.
EPA­
HQ­
OAR­
2006­
0583
The
remainder
of
this
document
is
divided
into
six
sections.
The
first
section
describes
the
scope
of
sources
to
which
this
CTG
applies.
The
second
section
provides
a
description
of
the
flatwood
paneling
industry
and
its
products
and
processes
and
identifies
the
sources
of
VOC
emissions
from
those
processes.
The
third
section
describes
the
available
control
approaches
for
addressing
VOC
emissions
and
summarizes
state
and
local
regulatory
approaches
for
addressing
such
emissions.
The
fourth
section
provides
our
proposed
recommendations
for
RACT
for
flat
wood
paneling
coatings.
The
fifth
section
discusses
the
cost­
effectiveness
of
the
recommended
control
approaches.
The
final
section
contains
a
list
of
references.

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

III.
Applicability
This
draft
CTG
applies
to
facilities
that
apply
flat
wood
paneling
coatings
that
emit
at
least
6.8
kg/
day
(
15
lb/
day)
of
VOC
before
consideration
of
controls.
Flat
wood
paneling
coatings
means
wood
paneling
products
that
are
any
interior,
exterior
or
tileboard
(
class
I
hardboard)
panel
to
which
a
protective,
decorative,
or
functional
material
or
layer
has
been
applied.

This
threshold
of
6.8
kg/
day
(
15
lb/
day)
is
consistent
with
the
applicability
threshold
level
contained
in
many
previous
final
CTGs.
It
is
also
consistent
with
the
purpose
of
the
section
183(
e).
In
section
183(
e),
Congress
directed
EPA
to
assist
States
in
achieving
VOC
emission
reductions
from
consumer
and
commercial
products.
These
products
individually
may
result
in
relatively
small
amounts
of
VOC
emissions
but,
in
the
aggregate,
they
contribute
significantly
to
ozone
formation
in
nonattainment
areas.
Given
the
nature
of
the
products
and
sources
at
issue
here,
we
believe
that
the
15
lb/
day
applicability
threshold
is
appropriate.

We
used
the
2002
National
Emission
Inventory
(
NEI)
as
the
source
of
emissions
data
and
statistical
information
concerning
the
flat
wood
paneling
industry
as
a
whole.
Plants
are
located
throughout
the
United
States,
with
the
Pacific
Coast
and
the
Southern
States
having
the
largest
numbers
of
facilities.
There
are
approximately
80
facilities
in
the
United
States
that
produce
flat
wood
paneling
products.
We
found
that
there
are
24
flat
wood
paneling
coating
facilities
that
meet
the
15
lb
of
VOC
per
day
applicability
threshold
for
this
CTG
that
are
located
in
current
ozone
nonattainment
areas
(
based
on
April
2006
designations)
in
eight
States.
Appendix
B
is
a
table
showing
the
distribution
of
these
facilities
and
the
current
State
and/
or
local
requirements
that
apply
to
them.
DRAFT
CTG
for
Flat
Wood
Paneling,
Docket
No.
EPA­
HQ­
OAR­
2006­
0583
IV.
Process
description
and
Sources
of
VOC
Emissions
A.
Types
of
Flat
Wood
Paneling
Flat
wood
paneling
products
are
used
in
construction
and
can
be
classified
as
three
main
product
types:
decorative
interior
panels,
exterior
siding,
and
tileboard.

1.
Decorative
interior
panels
Interior
wall
paneling
is
usually
grooved,
frequently
embossed,
and
sometimes
grain
printed
to
resemble
various
wood
species.
Interior
panels
are
typically
manufactured
at
the
same
facilities
as
tileboard,
although
in
much
smaller
quantities.

Coated
board
used
for
interior
panels
are
subject
to
industry
performance
specifications
(
consensus
standards)
which
have
more
decorative
coating
requirements
than
other
products.
These
standards
require
multiple
coating
layers
and
coating
steps.
Production
speeds
of
30
to
35
boards
per
minute
require
the
use
of
solvents
that
evaporate
without
leaving
cure
blisters
and
without
leaving
residual
solvent
in
the
coating
film
or
substrate.
The
substrate
can
be
hardboard,
plywood,
medium
density
fiberboard
(
MDF),
or
particleboard.

2.
Exterior
Siding
Exterior
siding
may
be
made
of
solid
wood,
hardboard,
or
waferboard.
Siding
made
of
solid
wood
and
hardboard
is
typically
primed
at
the
manufacturing
facility
and
finished
in
the
field,
although
some
finishing
may
be
performed
during
manufacturing
on
a
limited
basis.
Field­
applied
coatings
are
not
subject
to
this
CTG.
Exterior
trim
(
material
made
out
of
siding
panels
and
used
for
edges
and
corners
around
the
siding)
is
typically
manufactured
at
the
same
facility
and
coated
with
the
same
coatings
as
siding.

This
industry
segment
involves
exterior
products
that
must
have
coatings
able
to
withstand
extreme
and
long­
term
weather
conditions.
These
requirements
impact
the
amount
of
VOC
emitted
from
the
coating
of
exterior
siding.

3.
Tileboard
Tileboard
is
a
premium
interior
wall
paneling
product
made
of
hardboard
that
is
used
in
high
moisture
areas
of
the
home
such
as
kitchens
and
bathrooms.
Specifically,
tileboard
meets
the
specifications
for
Class
I
hardboard
as
approved
by
the
American
National
Standards
Institute.
The
standard
specifies
requirements
and
test
methods
for
water
absorption,
thickness
swelling,
modulus
of
rupture,
tensile
strength,
surface
finish,
dimensions,
squareness,
edge
straightness,
and
moisture
content
for
five
classes
of
hardboard.

Product
specifications
for
tileboard
are
established
by
consensus
standards.
Tileboard
has
more
stringent
product
performance
requirements
(
i.
e.,
adhesion
and
DRAFT
CTG
for
Flat
Wood
Paneling,
Docket
No.
EPA­
HQ­
OAR­
2006­
0583
hardness
standards,
household
stain,
scrub
and
moisture
resistance,
while
maintaining
a
relative
smooth
surface)
compared
to
standard
interior
wall
paneling.

B.
Sources
of
VOC
Emissions
Flat
wood
paneling,
like
most
wood
products,
are
vulnerable
to
light,
moisture
and
insects.
Coatings
are
used
for
three
principal
purposes:
protection,
appearance,
and
surface
modification.
Surface
coatings
are
applied
to
reduce
potential
damage
from
environmental
elements
such
as
moisture
and
temperature
extremes
and
other
climaterelated
hazards
and
from
insect
infestation.
Coatings
are
also
applied
to
enhance
surfaces
to
make
other
coatings
more
effective.
Finally,
coatings
are
applied
to
improve
the
appearance
of
the
wood
product.
Releases
of
VOC
occur
during
the
coating
process
as
the
coatings
are
mixed
or
thinned,
as
they
are
applied
to
the
substrate,
and
as
they
dry
and
the
VOC
within
the
coating
evaporate
into
the
air.

A
typical
flat
wood
coating
facility
applies
stains
and
varnishes
to
natural
plywood
panels
used
for
wall
coverings.
Other
plants
print
wood
grain
patterns
on
particle
board
panels
that
were
first
undercoated
with
an
opaque
coating
to
mask
the
original
surface.
Coatings
applies
to
flat
wood
paneling
include
fillers,
sealers,
"
groove"
coats,
primers,
stains,
basecoats,
inks
and
topcoats.
Most
coatings
are
applied
by
direct
roll
coating.
Filler
is
usually
applied
by
reverse
roll
coating.
The
offset
rotogravure
process
is
used
where
the
coating
and
printing
operation
requires
precision
printing
techniques.
Other
coating
methods
include
spray
techniques,
brush
coating
and
curtain
coating.
A
typical
flat
wood
paneling
coating
line
includes
a
succession
of
coating
operations.
Each
individual
operation
consists
of
the
application
of
one
or
more
coatings
followed
by
a
heated
oven
to
cure
the
coatings.
A
typical
production
line
begins
with
mechanical
alterations
of
the
substrate
(
filling
of
holes,
cutting
of
grooves,
sanding,
etc.),
followed
by
the
coating
operations,
and
packaging/
stacking
for
shipment.

Emissions
of
VOC
from
a
flat
wood
coating
occur
primarily
at
the
coating
line,
although
some
emissions
also
occur
at
paint
mixing
and
storage
areas.
To
assist
facilities
and
regulatory
agencies
in
estimating
emissions,
VOC
emission
factors
for
conventional
solvent
based
coatings
applied
to
interior
printed
panels
are
as
follows
(
expressed
as
kilograms
of
VOC
per
100
m2
coated):
3.0
for
filler,
0.5
for
sealer,
2.4
for
basecoat,
0.3
for
inks,
and
1.8
for
topcoats.
1
V.
Available
Controls
and
State
and
Local
Regulatory
Approaches
A.
Available
Controls
1.
Low­
VOC
Coatings
The
use
of
low­
VOC,
waterborne
coatings
has
increased
since
1978.
Paint
manufacturers
have
developed
and
are
continuing
to
develop
waterborne
coating
formulations
that
replace
conventional
organic
solvent­
borne
coatings.
These
coatings
are
generally
available
and
often
are
not
produced
and
marketed
specifically
for
the
flat
DRAFT
CTG
for
Flat
Wood
Paneling,
Docket
No.
EPA­
HQ­
OAR­
2006­
0583
wood
paneling
industry.
Conversion
to
waterborne
coatings
can
lower
VOC
emissions
greatly,
and
most
coatings
operations
are
capable
of
converting
to
waterborne
coatings.

2.
Ultraviolet
Cure
and
Electron
Beam
Cure
Coatings
A
process
change
that
is
an
alternative
to
waterborne
coatings
is
the
use
of
coatings
that
cure
by
ultraviolet
(
UV)
light.
This
technology
is
gaining
greater
acceptance
and,
where
applicable,
achieves
a
near
100
percent
reduction
of
VOC
emissions.
In
the
flat
wood
paneling
industry,
UV
systems
have
been
found
useful
on
specialty
coatings
operations.
UV
curing
is
extremely
fast
usually
taking
approximately
10
seconds.
UV
coatings
are
found
only
in
the
application
of
clear
to
semitransparent
filler
and
topcoats
for
paneling
and
cabinetry
products.
Opaque
UV
coatings
are
not
available
for
the
flat
wood
paneling
industry;
however,
electron
beam
(
EB)
cure
systems
can
use
opaque
coatings
and
are
available
for
use
in
the
flat
wood
paneling
industry.
Over
99
percent
reduction
can
be
achieved
by
using
EB
cure
coatings,
but
the
costs
of
both
the
cure
system
and
coatings
themselves
limit
the
applicability
of
this
technique
at
this
time.
1
3.
Add­
On
Controls
For
applications
where
performance
requirements
or
other
needs
dictate
the
use
of
high­
VOC
coatings,
flat
wood
paneling
coaters
can
employ
add­
on
controls
to
reduce
their
VOC
emissions.
Currently,
an
overall
control
and
capture
efficiency
of
90
percent
is
a
widely­
accepted
and
readily
available
technique.

4.
Work
Practices
Another
effective
means
to
reduce
VOC
emissions
associated
with
flat
wood
paneling
coatings
is
the
implementation
of
work
practice
standards.
Work
practice
standards
that
have
proven
particularly
effective
include:
(
1)
frequent
visual
inspections
for
all
equipment
used
to
transfer
or
apply
coatings,
adhesives,
or
organic
solvents;
(
2)
cleaning
and
wash
off
solvent
accounting
system;
(
3)
collecting
and
containing
all
VOCs
when
cleaning
coating
lines
and
spray
guns;
and
(
4)
using
low­
VOC
or
low­
vapor
pressure
cleaning
materials.

To
provide
structure
and
consistency
to
their
work
practices,
facilities
can
develop
and
implement
a
work
practice
plan.
Such
a
plan
is
a
compliance
option
under
the
2003
NESHAP
and
is
equally
applicable
to
VOC
emissions.
The
work
practice
plan
is
a
proven
and
traditional
approach
for
cleaning
that
is
easily
adopted
and
managed
by
various
industries,
including
flat
wood
paneling
coatings.
The
work
practice
plan
sets
forth
the
steps
to
be
taken
to
ensure
that
work
practices
are
implemented
properly
and
that
VOC
emissions
are
minimized
from
mixing
operations,
storage
tanks
and
other
containers,
and
handling
operations
for
coatings,
thinners,
cleaning
materials,
and
waste
materials.

B.
The
1978
CTG
and
Existing
State
and
Local
Regulatory
Approaches
DRAFT
CTG
for
Flat
Wood
Paneling,
Docket
No.
EPA­
HQ­
OAR­
2006­
0583
1.
Summary
of
the
1978
Flat
Wood
Paneling
CTG
Document
The
1978
CTG
recommends
emission
limits
for
flat
wood
paneling
surface
coating
operations.
Table
1
summarizes
these
limits,
which
are
expressed
in
pounds
of
VOC
emitted
per
1,000
square
feet
(
lb
VOC/
1,000
ft2)
of
coated
surface.
These
limits
could
be
achieved
by
either
using
coatings
with
VOC
contents
low
enough
to
achieve
these
limits
during
application,
or
by
reducing
the
amount
of
VOCs
emitted
through
the
use
of
add­
on
controls.
Because
the
1978
RACT
recommended
emission
limit
could
be
met
by
using
coatings
with
sufficiently
low
VOC
content
to
meet
the
limit,
Table
1
also
presents
the
equivalent
VOC
coating
limit
expressed
as
pounds
of
VOC
per
gallon
of
coating,
less
water
and
exempt
compounds
(
lb
VOC/
gal­
water­
exempt
compounds).
The
pounds
of
VOC
per
gallon
of
coating
is
the
VOC
content
of
a
coating,
taking
into
account
such
factors
as
coating
coverage
rate
and
solids
content,
that
is
expected
to
achieve
the
emission
limitation
(
lb
VOC/
1,000
ft2).
The
equivalent
coating
limit
is
especially
useful
in
the
context
of
this
draft
CTG,
because
it
allows
for
comparison
between
the
1978
RACT
recommended
limit
and
the
current
Placer
County
and
South
Coast
requirements
discussed
later
in
this
section.

Table
1.
1978
RACT
Limits
for
Factory
Surface
Coating
of
Flat
Wood
Paneling
Product
Emission
rate
limit,
pound
VOC
per
1000
square
feet
coated
surface
(
lb
VOC/
1,000
ft2)
Equivalent
coating
limit,
pound
VOC
per
gallon
of
coating
,
less
water
and
less
exempt
compounds
(
lb
VOC/
gal­
water­
exempt
compounds)

Printed
interior
wall
panels
made
of
hardwood
plywood
and
thin
particleboard
6.0
2.5
Natural
finish
hardwood
plywood
panels
12.0
3.3
Class
II
hardboard
panels
10.0
3.6
As
indicated
in
Table
1,
the
1978
CTG
recommends
emission
limits
for
only
three
categories
of
flat
wood
paneling
products.
Other
significant
categories
of
factory
finished
flat
wood
paneling
products,
exterior
siding,
and
tileboard,
were
not
reviewed
during
preparation
of
the
1978
CTG.
Consequently,
emission
limits
for
these
product
categories
were
not
recommended
in
that
document.

2.
Summary
of
Existing
State
and
Local
VOC
Requirements
At
least
28
State
and
local
jurisdictions
have
regulations
that
control
VOC
emissions
from
surface
coating
operations
that
include
flat
wood
paneling.
Most
of
these
regulations
are
general
surface
coating
rules;
a
few
are
specific
to
flat
wood
paneling.
Appendix
A
lists
the
jurisdictions
where
the
24
facilities
that
meet
the
applicability
criterion
in
this
draft
CTG
are
located.
In
addition
to
the
State
and
local
requirements,
there
are
two
previous
EPA
actions
that
affect
surface
coating
operations
for
flat
wood
paneling.
DRAFT
CTG
for
Flat
Wood
Paneling,
Docket
No.
EPA­
HQ­
OAR­
2006­
0583
Almost
all
of
the
jurisdictions
that
specifically
address
flat
wood
paneling
have
based
their
rules
on
the
1978
CTG.
However,
there
are
two
jurisdictions
in
California
that
have
requirements
specific
to
flat
wood
paneling
that
go
beyond
the
1978
CTG.
In
Placer
County,
VOC
emissions
from
flat
wood
paneling
operations
in
a
nonattainment
area
are
limited
to
250
g
VOC/
l
(
2.1
lb
VOC/
gal)
of
coating
(
excluding
water
and
exempt
compounds)
or
the
overall
control
device
efficiency
must
be
at
least
90
percent.
(
See
Appendix
B).

The
South
Coast
rule
defines
flat
wood
paneling
as
"
interior
wood
panels
and
exterior
wood
siding,
which
include,
by
way
of
illustration
and
not
limitation,
redwood,
cedar
or
plywood
stocks,
plywood
panels,
particle
boards,
composition
hard
boards,
and
any
other
panels
or
siding
constructed
of
solid
wood
or
a
wood­
containing
product."
The
emissions
limit
established
by
the
South
Coast
rule
is
identical
to
the
emission
limit
established
by
Placer
County,
and
also
covers
exterior
siding,
which
the
Placer
County
rule
does
not.

VI.
Recommended
Control
Options
Based
on
a
review
of
the
recommendations
in
the
1978
CTG,
the
current
State
and
local
requirements
discussed
above,
and
the
2003
NESHAP,
we
recommend
emission
limits
for
the
inks,
coatings
and
adhesives
used
by
the
flat
wood
paneling
coating
facilities
and
work
practices
for
cleaning
materials
used.

The
recommended
emission
limits
for
inks,
coatings,
and
adhesives
can
be
achieved
either
by
using
materials
with
VOC
contents
low
enough
to
achieve
the
limits
during
application,
or
by
reducing
the
amount
of
VOC
emitted
through
the
use
of
add­
on
controls.
There
are
two
alternative
limits
recommended
for
the
use
of
low
VOC
inks,
coatings
and
adhesives.
These
limits
are
expressed
in
different
units,
but
are
equivalent.
Table
2
summarizes
the
VOC
emission
limits
recommended
in
this
draft
CTG.

A.
Emissions
Limit
based
on
Low­
VOC
Coatings
for
Inks,
Coatings
and
Adhesives
The
low­
VOC
materials
recommendation
for
inks,
coatings
and
adhesives
include
an
emissions
limit
of
250
g
VOC/
l
(
2.1
lb
VOC/
gal)
of
material
(
minus
water
and
exempt
compounds).
An
equivalent
limit,
expressed
as
units
of
weight
of
VOC
per
volume
of
solids
in
all
coatings
would
is
350
grams
of
VOC
per
liter
solids
(
2.9
lb
of
VOC
per
gal
of
solids).
The
default
VOC
density
used
for
making
this
conversion
was
7.36
lb/
gal
(
0.88
kg/
liter).

B.
Optional
Add­
On
Controls
for
Inks,
Coatings
and
Adhesives
Should
performance
requirements
or
other
needs
dictate
the
use
of
higher­
VOC
coatings
than
specified
above,
a
facility
could
choose
to
use
add­
on
control
equipment
to
meet
an
overall
control
efficiency
of
90
percent.
Add­
on
devices
include
oxidizers
and
solvent
recovery
systems,
coupled
with
their
attendant
systems
to
capture
the
VOC
being
DRAFT
CTG
for
Flat
Wood
Paneling,
Docket
No.
EPA­
HQ­
OAR­
2006­
0583
released
at
the
affected
facilities.
This
control
option,
like
the
lox­
VOC
material
option
noted
above,
applies
to
surface
coatings,
inks,
and
adhesives
applied
to
all
types
of
flat
wood
paneling.

C.
Work
Practices
The
draft
CTG
also
recommends
work
practices
for
use
in
all
flat
wood
paneling
coating
facilities
meeting
the
applicability
threshold.
We
recommend
that
the
work
practice
plan
include
steps
to
ensure
that
VOC
emissions
are
minimized
from
mixing
operations,
storage
tanks
and
other
containers,
and
handling
operations
for
coatings,
thinners,
cleaning
materials,
and
waste
materials.
Examples
of
work
practice
standards
include:
storing
all
VOC
coatings,
thinners,
and
cleaning
materials
in
closed
containers,
minimizing
spills
of
VOC
containing
coatings,
thinners,
cleaning
up
spills
immediately,
conveying
any
coatings,
thinners,
and
cleaning
materials
in
closed
containers
or
pipes,
closing
mixing
vessels
which
contain
VOC
coatings
and
other
materials
except
when
specifically
in
use,
and
minimizing
emissions
of
VOC
during
cleaning
of
storage,
mixing,
and
conveying
equipment.

Table
2.
Recommended
Emission
Limits
for
Flat
Wood
Paneling
Coating
Operations
Should
Meet
One
of
These
Emission
Limits:
Surface
Coatings,
Inks,
or
Adhesives
Applied
to
the
Following
Flat
Wood
Paneling
Categories
lb
VOC
per
gallon
material
(
grams
VOC
per
liter
material)
[
excluding
water
and
exempt
compounds
]
lb
VOC
per
gallon
solids
(
grams
VOC
per
liter
solids)
Overall
Control
Efficiency
Using
an
Add­
On
Control
Device:

Printed
interior
panels
made
of
hardwood,
plywood,
or
thin
particleboard
2.1
(
250)
2.9
(
350)
90%

Natural
finish
hardwood
plywood
panels
2.1
(
250)
2.9
(
350)
90%

Class
II
finishes
on
hardboard
panels
2.1
(
250)
2.9
(
350)
90%
Tileboard
2.1
(
250)
2.9
(
350)
90%
Exterior
siding
2.1
(
250)
2.9
(
350)
90%
*
All
facilities
are
also
required
to
follow
work
practice
standards.

VII.
Cost
Effectiveness
of
Recommended
Control
Options
Cost­
effectiveness
estimates
were
determined
based
on
South
Coast
district
studies
and
on
studies
performed
by
EPA
during
development
of
the
2003
NESHAP.

Effective
January
1,
2000,
a
new
VOC
limit
was
proposed
for
flat
wood
paneling
facilities
in
the
South
Coast
Air
Quality
Management
District
of
California.
The
new
regulation
reduced
the
allowable
VOC
content
for
inks
from
2.5
pounds
per
gallon
(
300
grams
per
liter)
to
2.1
pounds
per
gallon
(
250
grams
per
liter)
and
reduced
the
allowable
DRAFT
CTG
for
Flat
Wood
Paneling,
Docket
No.
EPA­
HQ­
OAR­
2006­
0583
VOC
content
for
exterior
siding
coatings
from
2.9
pounds
per
gallon
(
350
grams
per
liter)
to
2.1
pounds
per
gallon
(
250
grams
per
liter).
At
the
time
of
proposal
of
the
South
Coast
rule,
there
were
two
facilities
in
the
district
that
would
be
affected
by
the
regulation
changes,
one
facility
manufactured
interior
paneling
and
the
other
manufactured
exterior
siding.
Only
the
exterior
siding
facility
was
not
in
compliance
with
the
new
limits.
As
part
of
the
South
Coast
proposal,
a
cost
effectiveness
analysis
was
performed
for
the
facility.
It
was
determined
that
the
facility
could
switch
to
two
lower­
VOC
stains
for
an
annual
cost
of
$
3,200
and
reduce
VOC
emissions
by
2,900
pounds
per
year
(
1.45
tons
per
year),
which
has
a
cost­
effectiveness
of
approximately
$
2,200/
ton
in
2000
dollars.

The
surface
coating
of
wood
building
products
NESHAP
applies
to
various
operations,
including
flat
wood
paneling
coatings.
The
NESHAP
sets
requirements
for
emissions
of
hazardous
air
pollutants
(
HAP)
and
includes
as
a
compliance
option
the
use
of
low­
HAP
materials.
The
majority
of
organic
HAP
are
VOCs.
In
developing
the
NESHAP,
EPA
estimated
in
1998
dollars,
the
cost­
effectiveness
of
using
low­
HAP
materials.
The
cost
of
compliance
for
facilities
in
the
interior
wall
paneling
and
tileboard
category
was
estimated
to
be
$
2.59
million
and
result
in
VOC
reductions
of
480
tons
($
1,600
per
ton
of
VOC).
The
cost
of
compliance
for
six
facilities
in
the
exterior
siding
subcategory
was
estimated
to
be
$
760,000
and
result
in
VOC
reductions
of
690
tons
($
3,700
per
ton
of
VOC)
in
1998
dollars.
7
Using
the
Marshall
and
Swift
Index,
the
costs
in
1999
and
1998
dollars,
respectively,
were
scaled
to
estimate
2005
dollars.
The
resulting
cost
effectiveness
estimate,
in
2005
dollars,
for
the
California
flat
wood
paneling
facility
that
manufactures
exterior
siding
is
$
2,600
per
ton
of
VOC.
Escalating
the
NESHAP
figures
to
2005
dollars,
the
cost
effectiveness
is
$
4,400
per
ton
of
VOC
for
exterior
siding
and
$
1,900
per
ton
of
VOC
for
interior
paneling/
tileboard.

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

VIII.
References
1.
Control
of
Volatile
Organic
Emissions
from
Existing
Sources
­
Volume
VII:
Factory
Surface
Coating
of
Flat
Wood
Paneling.
Publication
No.
EPA­
450/
2­
78­
032.
U.
S.
Environmental
Protection
Agency,
Research
Triangle
Park,
NC.
June
1978.

2.
Guidance
to
State
and
Local
Agencies
in
Preparing
Regulations
to
Control
Volatile
Organic
Compounds
from
Ten
Stationary
Source
Categories.
EPA­
450­
2­
79­
004.
U.
S.
Environmental
Protection
Agency,
Research
Triangle
Park,
NC.
September
1979.
DRAFT
CTG
for
Flat
Wood
Paneling,
Docket
No.
EPA­
HQ­
OAR­
2006­
0583
3.
Placer
County
(
California)
Air
Quality
Management
District
Rule
238,
Factory
Coating
of
Flat
Wood
Paneling.
Amended
August
14,
1997.

4.
1972
Census
of
Manufacturers,
United
States
Bureau
of
Census,
Vol.
II,
Industry
Statistics,
Part
I.
SIC
20­
26,
2431,
2435,
2436,
2493,
2496
5.
Flat
wood
Paneling
Surface
Coating
Plants.
In:
Directory
of
Volatile
Organic
Compound
Sources
Covered
by
Reasonably
Available
Control
Technology
(
RACT)
Requirements,
Volume
II:
Group
II
RACT
Categories,
EPA
450/
4­
81­
0075,
U.
S.
Environmental
Protection
Agency,
Research
Triangle
Park,
NC.
February
1981.

6.
Control
Techniques
for
Volatile
Organic
Compound
Emissions
from
Stationary
Sources.
Publication
No.
EPA­
453/
R­
92­
018.
U.
S.
Environmental
Protection
Agency,
Research
Triangle
Park,
NC.
December
1992.

7.
Background
Information
Document
for
NESHAP
for
the
Wood
Building
Products
(
Surface
Coating
Industry).
EPA­
453/
R00­
003.
U.
S.
Environmental
Protection
Agency,
Research
Triangle
Park,
NC.
May
2001.
DRAFT
CTG
for
Flat
Wood
Paneling,
Docket
No.
EPA­
HQ­
OAR­
2006­
0583
Appendix
A
Control
of
Volatile
Organic
Emissions
from
Existing
Sources
­
Volume
VII:
Factory
Surface
Coating
of
Flat
Wood
Paneling.

Publication
No.
EPA­
450/
2­
78­
032.

U.
S.
Environmental
Protection
Agency,

Research
Triangle
Park,
NC.

June
1978.
DRAFT
CTG
for
Flat
Wood
Paneling,
Docket
No.
EPA­
HQ­
OAR­
2006­
0583
Appendix
B
Flat
wood
Paneling
Coating
Facilities
in
Current
Nonattainment
Areas
and
Associated
State
or
Local
Requirements
(
Based
on
2002
NEI)

Ozone
Nonattainment
Area
Number
of
Facilities
Product
Applicability
Applicable
State
Emission
Limit
Alternative
Control
Device
Limits
Placer
County
(
California)
1
1978
CTG
Does
not
include
Exterior
Siding
<
2.1
lb
VOC
per
gallon
of
coating
(
excluding
water)
Overall
control
efficiency
of
90%

Michigan
1
Interior
paneling.

Does
not
include
exterior
siding,
cabinetry,
furniture
or
tileboard.
1978
CTG
Limits
1978
CTG
Limits
North
Carolina
1
1978
CTG
Does
not
include
Exterior
Siding
and
tileboard.
1978
CTG
Limits
1978
CTG
Limits
Ohio
1
No
rule
specific
to
flat
wood,
wood
building
products
or
tileboard.
1978
CTG
Limits
1978
CTG
Limits
South
Carolina
1
Wood
construction
products
for
interior
paneling
Does
not
exclude
exterior
siding
and
tileboard
1978
CTG
Limits
1978
CTG
Limits
Texas
2
Interior
paneling
and
tileboard
Not
applicable
to
exterior
siding
1978
CTG
Limits
1978
CTG
Limits
Virginia
1
Interior
panels
Does
not
exclude
exterior
siding
and
tileboard
1978
CTG
Limits
1978
CTG
Limits
Indiana
3
Interior
panels
Not
applicable
to
exterior
siding
and
tileboard.
1978
CTG
Limits
1978
CTG
Limits
Tennessee
1
Interior
paneling
Not
applicable
to
exterior
siding
and
tileboard.
1978
CTG
Limits
1978
CTG
Limits
Illinois
1
None
None
None
Pennsylvania
8
None
None
None
New
Hampshire­­
2
None
None
None
Wisconsin
1
1978
CTG
Limits
Not
applicable
to
exterior
siding
and
tileboard.
1978
CTG
Limits
1978
CTG
Limits
