MEMORANDUM

TO:	Metal Furniture Project Docket No. A-97-40

SUBMITTED BY:	Dr. Mohamed Serageldin, ESD/CCPG

DATE:	June 19, 1997

SUBJECT:	Summary of the May 28, 1997, Metal Furniture Integrated Rule Development, First Roundtable Meeting (P-MACT/P-BAC) Phase

The purpose of this memorandum is to summarize the discussion that took place during the first roundtable meeting for the metal furniture integrated rule development, held on May 28, 1997, at the Mutual Building in Durham, North Carolina. The meeting objectives were to identify data sources for the collection of information about the metal furniture industry, review the regulatory development process with industry and raise issues of concern to all parties, coordinate regulatory development efforts and scheduling with industry representatives, and to discuss potential data sources and action items for participants.

MEETING PARTICIPANTS

Environmental Protection Agency (EPA)

Mohamed Serageldin, Office of Air Quality Planning and Standards

EC/R Incorporated

Graham Fitzsimons

David Hendricks

Karen Holmes

Co-regulators and Industry Representatives

See Attachment 1.

SUMMARY OF DISCUSSION

Dr. Serageldin opened the meeting by welcoming all the participants and allowing each participant to provide a brief introduction. He then briefly explained that the EPA will be working simultaneously on the P-MACT and P-BAC processes. He stressed that the EPA has no predetermined ideas for the outcome of P-MACT/BAC process and is looking to industry for help in establishing P-MACT/BAC.

Ms. Mika presented an overview of Steelcase's pretreatment and cleaning operations, paint mixing and transferring, paint application operations, and use of adhesives, as well as the state and federal regulations applicable to their facilities. One issue raised during the presentation was the use of single coat operations versus dual coat operations. It appeared that the larger metal office furniture participants such as Steelcase, HON Industries, Kimball, and Allsteel use single coat operations. Ms. Stookey pointed out that some of their customers use multiple coating steps. Ms. Mika emphasized the difficultly in tracking coating usage on a single line basis due to the fact that multiple mix rooms may service a single line and a single mix room may also service multiple lines. Ms. Mika also presented her concern over the amount of annual VOC reported in the March 23, 1995, Federal Register notice regarding the consumer and commercial product schedule for regulation under Section 183(e). Based on a coating usage of 21,000 gallons of coating per year for metal furniture and other 2500 SIC major source group codes, as listed in a U.S. Census report for 1995, she felt that the magnitude of annual VOC emissions reported in the Federal Register notice is too large and that inclusion of the metal furniture industry may not be justified based on emissions.

Dr. Serageldin responded that the ranking was not based solely on emissions but agreed that an accurate number must be established for the purpose of cost effectiveness calculations.

Mr. Lesnet stated that the industry representatives present at the meeting did not adequately represent all segments of the metal furniture industry, particularly household products. Dr. Serageldin stressed the need for the industry's help in identifying which industry segments are not represented. He stated that the MACT floor is based only on the information collected by the EPA.

Mr. Miller briefly discussed the role of the Business and Industrial Furniture Manufacturer's Association (BIFMA). He stated that BIFMA represents approximately 120 manufacturers and 80 suppliers to the industry, which accounts for about 80 percent of SIC code 2522. The other 20 percent is not represented at this point. Mr. Miller stated that his role is to keep member companies informed of the rule development process and to facilitate data transfer between member companies and the EPA.

Mr. Runyan questioned how the EPA is going to deal with metal components on wood furniture, wood components on metal furniture, and metal mechanisms. He also questioned why the EPA was looking at operations other than coating and cleaning. Dr. Serageldin stated that the EPA is not eliminating or excluding anything this early in the process. The magnitude of emissions related to each of these areas will have to be quantified before a decision could be made. He explained that sources of all HAP emissions need to be reviewed for making major source determinations, but the regulation will only deal with coating and cleaning operations.

Dr. Serageldin presented an overview of the rule development process (see Attachment 2), then stated that the EPA intends to send out a voluntary survey that will concentrate on emissions from major sources at each facility. The first survey will be strictly voluntary and will not be issued under the authority of Section 114. Dr. Serageldin explained that the EPA needs to gain a good understanding of the industry as quickly as possible, but this survey is not intended to be comprehensive. A two-week schedule of completion upon receiving the survey was discussed to allow for the processing of the data for use in the second roundtable meeting scheduled for late July.

Ms. Mika questioned the purpose of P-MACT and the need to complete a survey for both the P-MACT process and then again for the actual MACT determination. She explained that it is a major expenditure of both time and money to complete these surveys. Several other industry representatives expressed concern regarding the need to go through the P-MACT process. They explained that it would be more beneficial to concentrate on defining the industry rather than developing a P-MACT which may not be representative of the entire industry. Another concern was raised that P-MACT, developed with limited and incomplete data, may be misused by states making Section 112(g) case-by-case MACT determinations.

Dr. Serageldin explained that the EPA needs to gain an understanding of the industry in order to develop a foundation for MACT and to determine what information is missing. He stressed the need for P-MACT as an essential step in the learning process, and explained that P-MACT will allow the EPA to learn about the metal furniture industry at an accelerated pace. Dr. Serageldin stressed that P-MACT is not binding on the EPA during the remainder of the MACT development process, or on the states when making Section 112(g) determinations.

Mr. Hendricks presented an overview of the metal furniture industry based on data that has been gathered to date (see Attachment 2). The presentation covered the following topics:

SIC codes relevant to the metal furniture industry and primary products under each SIC code

Total number of facilities and employees for the primary SIC codes

States with the largest concentration of metal furniture manufacturing facilities

Metal furniture manufacturing operations that may be sources of HAP emissions

Summary of Toxic Release Inventory System emissions data for the primary SIC codes

Mr. Naour asked if, given the maturity of existing state rules, is it possible for the EPA to provide a consolidation rule based on state regulations, new sources, RACT, and the CTG. Past uses of this methodology were helpful, particularly for recordkeeping, recording, and monitoring requirements. Therefore, documentation would cover all existing rules. Dr. Serageldin replied that this approach would be very useful, but the EPA does not have time to incorporate it for P-MACT. However, the EPA will consider this approach for MACT.

Mr. Naour stated that it may be helpful to the EPA to request Title V permit applications and emission inventory information from the states to gain a data set more representative of all sectors of the metal furniture industry.

Ms. Mika explained that some states, such as Michigan, do not require HAP speciation in their Title V emission inventories; therefore, this information may not be readily available.

Dr. Serageldin asked for suggestions regarding possible site visits. Mr. Lesnet suggested a possible site visit to either HON's Richmond, VA facility or their Cedartown, GA facility. He stated that the Richmond facility has three coating lines, two of which use coatings with a VOC content of 1.63 kg VOC/liter (2.8 lb VOC/gal), and the third which uses coatings with a VOC content of 1.46 kg VOC/liter (2.5 lb VOC/gal). The third line also uses heat to reduce the viscosity of the paint. The Cedartown, GA facility is an older facility which utilizes automatic application, dip application, and recovers overspray and remanufactures it for reuse. Most of the coatings used at the Cedartown facility have a VOC content of 1.75 kg VOC/liter (3.0 lb VOC/gal).

Ms. Mika suggested a possible site visit to Steelcase's Grand Rapids, MI facilities. Steelcase has a total of nine individual plants in the Grand Rapids area with a wide range of operations. The coating lines utilize coatings with a VOC content range of 1.75 kg VOC/liter (3.0 lb VOC/gal) to approximately 1.46 kg VOC/liter (2.5 lb VOC/gal) with abatement.

Dr. Serageldin questioned why coating VOC content does not typically go below 1.46 kg VOC/liter (2.5 lb VOC/gal). Mr. English explained that both performance and appearance limit VOC content. Mr. Lesnet explained that HON has tried lower VOC content paints at temperatures up to 170°F (to reduce viscosity). This method led to operator safety problems due to the high temperature. Mr. Lesnet expressed concern over the use of acetone, which is not a HAP and is an exempt VOC, as a solvent substitute that may lead to explosion problems with electrostatic equipment. Mr. English cautioned that HVLP has severe limitations due to the low volume of paint delivered, which may result in low line speed and reduced production. Mr. Lesnet stated that the particular solvent added to the coating may directly affect electrostatic performance. Therefore, substituting solvents may reduce transfer efficiency.

Dr. Serageldin presented example process flow diagrams, which detailed how to do a material balance around each unit operation. Ms. Mika expressed concerns that trying to estimate individual emission sources would lead to inaccurate data that may be used inappropriately. She stated that Steelcase simply does not have that level of detail available, and any estimates would be pure guesses. She also questioned the value of these numbers. Dr. Serageldin stated that the questionnaire will not ask for a speciation of HAP at each emission point. He stated that the EPA needs to understand the process to evaluate the significance of each emission point.

Several industry representatives expressed concern over the EPA's focus on the office furniture industry. Based on the current makeup of the Work Team, the database of information developed from these facilities will be office furniture specific and is not fair to other segments of the metal furniture industry who may have different coating types and requirements. One industry representative suggested sending letters to each state Chamber of Commerce requesting them to notify members with the relevant SIC Codes. Mr. Panchakarla stated that Florida will provide information on both point and area sources, but that it will include both metal and wood furniture.

At the close of the meeting, copies of the draft definitions of terms to be used throughout the standards development process were distributed (see Attachment 3).

ACTION ITEMS

The EPA will send the voluntary questionnaire to everyone on the TRIS report list.

The EPA will send the voluntary questionnaire to Work Team members by Tuesday, June 3, 1997.

Tentative site visits will be scheduled to HON in July and to Steelcase in September.

EC/R will contact the states with the highest concentration of metal furniture manufacturing facilities for information on Title V permit applications, emission inventories and RACT/BACT/LAER information.

EC/R will generate a list of trade associations that have been contacted.

The EPA will inform the Work Team members of the date of the next Roundtable meeting.

ATTACHMENT 1

LIST OF ATTENDEES

METAL FURNITURE INTEGRATED RULE DEVELOPMENT

FIRST ROUNDTABLE MEETING

MAY 28, 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
Graham Fitzsimons	EC/R Incorporated	2327 Englert Drive

Suite 100

Durham, NC 27713	(919) 484-0222

ext. 322

fax-(919) 484-0122	gfitz@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
Keith Masterson	Kimball, Inc.	1155 West 12th Avenue

Jasper, IN 47549	(812) 634-3234

fax-(812) 634-3250
Larry Runyan	AFMA	P.O. Box HP-7

High Point, NC 27261	(910) 884-5000

fax-(910) 884-5303	lfrun@aoi.com
Richard Mathis	Metal Creations	P.O. Box 1104

High Point, NC 27261	(910) 889-2083

fax-(910) 885-2442
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
Sherry Stookey	Lilly Industries	P.O. Box 2358

High Point, NC 27261	(910) 802-4305

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
Bob Shepherd	NC State University	Dept. of Chemical Engineering

Box 7905

Raleigh, NC 27695-7905	(919) 515-1883

fax-(919)515-3465	Shepherd@che.ncsu.edu
Mick Durham	Stanley Environmental, Incorporated	225 Iowa Avenue

Muscatine, IA 52761	(319) 264-6342

fax-(319) 264-6658	durhammick@stanleygroup.com
Dwight A. Cohagan	Sherwin Williams	P.O. Box 6027

Cleveland, OH 44101	(216) 566-2918

fax-(216) 566-2730	dacohagan@sherwin.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
Hank Naour	Illinois EPA	Bureau of Air

P.O. Box 19506

Springfield, IL 62794-9506	(217) 785-1716

fax-(217) 524-5023

ATTACHMENT 2

EPA/ECR PRESENTATION

NESHAP

Information Gathering

MACT Floors

Regulatory Alternatives, P-MACT, and MACT

Regulatory Team - Industry and State Agency Involvement

Impact Analyses

Proposal

Promulgation

Implementation Guidance

CONTROL TECHNIQUES GUIDELINES (CTG)

Information Gathering

Regulatory Alternatives, P-BAC

Impact Analyses

CTG Publication

Primary SIC Codes

2514 - Metal Household Furniture

Bookcases	Camp Furniture

Chairs	Frames for Boxsprings

Tables	Cribs

Swings	Cots

Kitchen Cabinets	Garden Furniture

Medical Cabinets	Serving Carts

2522 - Office Furniture, Except Wood

Bookcases	Wall Cases

Chairs	Partitions

Tables	Modular Furniture

Desks	Benches

File Cabinets

2531 - Public Building and Related Furniture

Benches	Theater Seating

Portable Bleacher Seating	Seats for Autos, Vans, Aircraft, Railroad

Stadium Seating	Church Furniture

School Furniture

2542 - Office and Store Fixtures, Partitions, Shelving, and Lockers, Except Wood

Cabinets	Shelving

Counters	Showcases

Display Cases	Sorting Racks

Display Fixtures	Telephone Booths

Lunchroom Fixtures	Bar Fixtures

Secondary SIC Codes

2599 - Furniture and Fixtures, Not Elsewhere Classified

Hospital Beds	Factory Furniture

Bowling Center Furniture	Ship Furniture

Cafeteria Furniture	Restaurant Carts

3429 - Hardware, Not Elsewhere Classified

Furniture Hardware	Convertible Bed Mechanisms

3495 - Wire Springs

Furniture Springs	Spring Units for Seats

3499 - Fabricated Metal Products, Not Elsewhere Classified

Metal Chair Frames	Metal Auto Seat Frames

Metal Furniture Parts

3821 - Laboratory Apparatus and Furniture

Laboratory Furniture	Tables

Benches	Cabinets

3843 - Dental Equipment and Supplies

Dental Cabinets	Dentists' Chairs

3999 - Manufacturing Industries, Not Elsewhere Classified

Beauty Shop and Barber Shop Furniture

7641 - Reupholstery and Furniture Repair

Furniture Repair/Refinishing

Antique Repair Restoration

Source: Standard Industrial Classification Manual. Office of Management and Budget. 1987

SIC Code	Number of

Facilities	Number of Employees
2514	452	138,978
2522	1661	252,014
2531	846	189,159
2542	1301	149,222

California	420

Michigan	294

New York	269

Florida	256

Illinois	235

Indiana	191

Texas	189

Missouri	161

Ohio	154

Pennsylvania	147

Metal Working (stamping, bending, forming, welding)

Metal Finishing (plating, anodizing, phosphating)

Cleaning (parts cleaning, spray gun cleaning, spray booth cleaning)

Paint Application and Curing/Drying

Touch-up and Repair

Storage, Handling, and Mixing of Solvents and Coatings

Wastewater Treatment

SUMMARY OF TRIS EMISSIONS DATA

Hazardous Air Pollutant	Non-point Emissions

(kg/yr)	Point Emissions

(kg/yr)
Xylene	295,921	1,267,253
Toluene	119,202	518,310
Glycol Ethers	63,439	157,882
1,2,4-Trimethylbenzene	72,070	141,438
Ethyl Benzene	29,566	158,348
Methyl Ethyl Ketone	31,001	125,390
Dichloromethane	53,386	91,126
n-Hexane	37,518	78,870
Methanol	34,871	74,750
1,1,1-Trichloroethane	46,572	19,992
Methyl Isobutyl Ketone	15,770	36,621
Trichloroethylene	3,293	13,173
Styrene	8,946	5,070
Formaldehyde	95	9,094
Cumene	3,115	1,144
Hydrochloric Acid	1,746	90
Manganese and Compounds	627	113
Naphthalene	0	579
Nickel and Compounds	510	0
Chromium and Compounds	247	2
Phthalic Anhydride	113	113
Diisocyanates	77	3
2,4-Toluene Diisocyanate	0	48
Ethylene Glycol	0	12
TOTAL (Mg/yr)	818	2,699

0.36 kg of organic solvent emitted per liter of coating (minus water and exempt compounds)

3.0 lbs of organic solvent emitted per gallon of coating (minus water and exempt compounds)

0.9 kg of VOC per liter of coating solids (non-
volatiles) as applied

The metal furniture source category includes any facility engaged in the surface coating and manufacture of metal furniture parts or products. Such products may include chairs, tables, cabinets, and bookcases.

"Metal Furniture" includes any furniture made of metal or any metal part which will be assembled with other metal, wood, fabric, plastic or glass parts to form a furniture piece.

30 States generally follow the guidelines established in "Control of Volatile Organic Emissions from Existing Sources Volume III: Surface Coating of Metal Furniture"; December 1977.

15 States have no VOC limits specific to Metal Furniture.

3 States have less stringent limits than set forth in the CTG.

1 State has more stringent limits than set forth in the CTG.

1 State has VOC limits not directly converted to the units in the CTG.

Date	Activity
May 97	First site visit
May 97	Roundtable #1
July 97	Second/third site visits
July 97	Roundtable #2
August 97	Initial pre-MACT established
September 97	Roundtable options meeting
September 97	Pre-MACT established
December 98	Complete all data gathering efforts
December 99	MACT floors established
April 99	Select basis for standards
June 99	Draft proposed standard
August 99	Work Group review
December 99	Proposed rule published in Federal Register
December 00	Promulgation of standard

ATTACHMENT 3

LIST OF DEFINITIONS

DRAFT DEFINITIONS

(REVISED FEBRUARY 9, 1998)

METAL FURNITURE INTEGRATED RULE DEVELOPMENT

First Roundtable Meeting

May 28, 1997

Abatement or recovery device (see Add-on control device)

Add-on control device means an air pollution control device installed at the end of a process vent exhaust stack or stacks that reduces the quantity of a pollutant that is emitted to the air. The device may destroy or secure the pollutant for subsequent recovery. Examples are incinerators, condensers, carbon adsorbers, and bioreactor units which reduce the pollution in an exhaust gas. Transfer equipment and ductwork are not considered in and of themselves add-on air pollution control devices. The control device usually does not affect the process being controlled and thus is "add-on" technology as opposed to a scheme to control pollution through making some alteration to the basic process.

Add-on control device efficiency means the ratio of the emissions collected or destroyed by an add-on air pollution control device to the total emissions that are introduced to the control device, expressed as a percentage.

Administrator means the Administrator of the United States Environmental Protection Agency (U.S. EPA) or his or her authorized representative.

Affected source means, with reference to a stationary source, any apparatus to which a standard is applicable. Any operation or process line that is subject to a regulation or standard.

Alternative method means any method of sampling and analyzing for an air pollutant that is not a reference or equivalent method but has been demonstrated to the Administrator's satisfaction to, in specific cases, produce results adequate for a determination of compliance.

As-applied means the condition of a coating at the time of application to the substrate, including any thinning solvent.

As-supplied means the condition of a coating before any thinning, as sold and delivered by the coating manufacturer to the user.

BAC means Best Available Controls.

Baseline conditions means the conditions that exist prior to an affected source implementing controls, such as a control system.

Batch means the product of an individual production run of a coating manufacturer's process. A batch may vary in composition from other batches of the same product.

Capture means the containment or recovery of emissions from a process for direction into a duct, which may be exhausted through a stack or sent to an abatement or recovery device before exiting through a stack.

Capture efficiency means the fraction of all organic vapors, HAP emissions, or other pollutants generated by a process that are directed to an add-on air pollution control device expressed as a percentage.

Capture system means a hood, enclosed room, of other means of collecting organic HAP emissions into a closed-vent system that exhausts to a control device.

Captured emissions means all emissions that are delivered to a control device.

Clean Air Act-- The Clean Air Act, as amended, provides the foundation for EPA's efforts to improve air quality. The Clean Air Act, building on earlier legislation, was passed in 1970, and was most recently amended in 1990.

Cleaning activity means the physical removal of foreign material from the substrate being cleaned. Includes actions such as wiping, brushing, flushing, or spraying applied within an operation.

Cleaning of parts means solvent engulfs the entire surface of the item (part) as it is dipped in a container of solvent, or the part is cleaned above the container by a cleaning activity such as spraying or wiping. Equipment, the "unit operation," where this might take place, includes part washers, batch-loaded cold cleaners, ultrasonic cleaners, and spray gun washers.

Cleaning operations means operations, such as, spray-gun and flush cleaning operations, in which organic solvent is used to remove coating materials or adhesives from equipment used in coating manufacturing operations.

Cleaning solvent means a liquid material used for hand-wipe, spray gun, or flush cleaning. This definition does not include solutions that contain no VOC.

Closed-loop recycling (in-process recycling) means the reuse or recirculation of a chemical material within the boundaries used to develop a material balance around a "unit operation system." A recovery or reclamation (R or R) unit operation may be within the boundaries selected for the primary unit operation system if it is:

1.	Solely dedicated. The chemical is reused only for cleaning the primary unit operation.

2.	Physically integrated. The R or R operation is connected to the primary unit operation by means of piping, so that it is not possible to perform the material balance around the primary unit operation system without including it.

Coater or coating applicator means the apparatus used to apply a coating to a continuous base substrate.

Coating means a protective, decorative, or functional film applied as a thin layer to a substrate or surface and which cures to form a continuous solid film (see Primer, Topcoat). This term often applies to paints such as lacquers or enamels, but also is used to refer to films applied to paper, plastics, or foil.

Coating application means the process by which the coating mix is applied to the base substrate.

Coating application station means the part of a coating operation where the coating is applied. In a spray operation it is the spray booth and is distinguished from the flash off area and oven.

Coating line means any number or combination of coating applicators, flash off areas, and ovens which coat a substrate.

Coating operation means, for the purposes of this rule, those activities in which a coating is applied to a substrate and is subsequently air dried, cured in an oven, or cured by radiation.

Coating solids means the part of the coating which remains after the coating is dried or cured; solids (nonvolatile) content is determined using data from EPA Method 24, or an equivalent or alternative method.

Coating station means a work station on which a coating operation is conducted.

Compliant coating means a coating whose volatile organic compound or hazardous air pollutant content does not exceed that allowed by regulation. Compliant coatings may be waterborne, low solvent (higher solids), or powder.

Control in the air pollution field means the abatement of pollutants which might be exhausted into the atmosphere. It often refers to the collection or destruction efficiency using various technologies, including incinerators or carbon adsorbers as opposed to capture of the pollutants into the device.

Control device (see Add-on control device)

Control efficiency (see Add-on control device efficiency)

Control system means the combination of capture systems and add-on control devices used to reduce emissions to the atmosphere. For example, 100% capture efficiency and 95% destruction efficiency amounts to 95% control.

Control Techniques Guidelines (CTG) means a series of documents prepared by the EPA to assist states in defining reasonably available control technology (RACT) for major sources of volatile organic compound (VOC) material. The documents provide information on the economic and technological feasibility of available techniques; and, in some cases, suggest limits on VOC emissions.

Criteria pollutant means a pollutant for which a criteria document has been issued as described by section 108 of the Clean Air Act. Criteria pollutants are nitrogen oxides, sulfur dioxides, ozone, particulate matter, and carbon monoxide. A National Ambient Air Quality Standard (NAAQS) exists for each criteria pollutant.

Cure Volatiles means reaction products which are emitted during the chemical reaction which takes place in some coating films at the cure temperature. These emissions are other than those from the solvents in the coating and may, in some cases, comprise a significant portion of total VOC and/or volatile HAP emissions.

Dip coating means a method of applying a coating in which the substrate is dipped into a tank of coating and then withdrawn.

Electrodeposition means a dip coating method in which an electric field is used to promote the deposition of the coating onto the part. The part being painted acts as the electrode which is oppositely charged from the coating particles in the dip tank.

Electrostatic spray is produced when opposite electrical charges are applied to the substrate and the coating. The coating is attracted to the object by the electrostatic potential between them. The coating may be applied by either a spray gun (nonrotational method) or a gun with a rotating bell or disk applicator (rotational method).

Emission control system means a combination of capture system and add-on control device used to reduce emission to the atmosphere. System efficiency is the product of capture efficiency and destruction efficiency (e.g., 95% capture efficiency X 95% destruction efficiency = 90% overall efficiency).

Emission reduction means the decrease in HAP or VOC material emitted when (1) a low solvent containing coating is used in place of a higher solvent containing coating or (2) an add-on control device (such as a carbon adsorber or incinerator) is used. Emission reduction is often expressed as a percentage.

Equivalent method means any method of sampling and analyzing for an air pollutant that has been demonstrated to the Administrator's satisfaction to have a consistent and quantitatively known relationship to the reference method, under specific conditions.

Exempt compound means specific organic compounds that are not considered volatile organic compounds due to negligible photochemical reactivity. Exempt compounds are specified in 40 CFR 51.100(s).

Existing source means any stationary source of air pollution other than a new source.

Face velocity means the velocity of air through a paint spray booth. Where people are working, health regulations usually require this velocity to be at least 30.5 meters per minute (100 feet per minute). When electrostatic spraying is used a face velocity of 18 meters per minute (60 feet per minute) is permitted.

Faraday Cage Effect means a condition that may exist on a substrate due to its geometric configuration that may inhibit the electrostatic application of powder particles at that specific localized area, such as cavities or recesses.

Facility means all contiguous or adjoining property that is under common ownership or control, including properties that are separated only by a road or other public right-of-way.

Film former means the part of a coating that remains on the substrate after the cure (nonvolatiles). Some film formers may be liquid but polymerize to form a solid when coating is baked to the requisite curing temperature.

Film thickness means the thickness of the dry cured coating on the substrate.

Flash off area means the portion of a coating operation between the coater and the drying oven where solvent begins to evaporate from the coated base substrate.

Flow coating means a method of applying coating in which the coating is poured onto the part.

Fugitive emissions means emissions that do not pass through a stack or duct that allows for their measurement.

Hazardous Air Pollutant (HAP) means any air pollutant listed in or pursuant to Section 112(b) of the Clean Air Act.

Higher-nonvolatiles (solids) coating means coatings containing a considerably higher solids content than conventional coatings. These coatings typically contain greater than 60 percent solids by volume.

High volume-low pressure (HVLP) spray means spray equipment that is used to apply coating by means of a spray gun that operates at 69.0 KPa (10.0 psig) or less of atomizing air pressure at the air cap.

Hood or enclosure means devices used to capture emissions and direct them to an abatement or recovery device.

Major source means any source that emits or has the potential to emit 9.1 megagrams (10 tons) per year or more of any one HAP or 22.7 megagrams (25 tons) per year or more of any combination of HAP.

Manufacturer's formulation means a list of substances or component parts of coatings as described by the maker of the coatings.

Mass percent solids means the portion of a coating which remains as part of the cured film expressed as percent by weight. This contrasts to another convention of expressing content by volume percent.

Material balance means a calculation based on conservation of mass (i.e., the mass of material going into a process is equal to the mass of material which leaves the process). This relationship is often used to estimate solvent losses from coating operations.

New source means any stationary source the construction or reconstruction of which commences after a specified date, usually the proposal or promulgation of an applicable standard of performance.

New Source Performance Standard (NSPS) means standards for emission of air pollutants from new, modified, or reconstructed stationary emission sources which reflects the degree of emission limitation achievable through the application of the best system of emission reduction which (taking into account the cost of achieving such reduction) the Administrator determines has been adequately demonstrated. The Clean Air Act usually refers to these as standards of performance for new stationary sources.

Nonvolatiles means the film-forming material of a coating; also termed solids.

Offsite recycling means a recovery or reclamation unit operation system located outside of the plant boundaries.

Onsite recycling means a recovery or reclamation unit operation located within the plant boundaries from which the recycled material is returned to a process other than that which generated the waste material.

Oven means a chamber which uses heat or irradiation to bake, cure, polymerize, or dry a surface coating.

Permanent total enclosure means a permanently installed enclosure that completely surrounds a source of emissions such that all emissions are captured and contained for discharge through a control device. For additional information, see Guidelines for Determining Capture Efficiency, January 1994. (Docket No. A-93-10, Item No. IV-B-
1).

Photochemical reactivity means the measure of the rate at which an organic compound reacts in the presence of ultraviolet radiation to form photochemical oxidants.

Pigmented means containing finely ground insoluble powder dispersed to give a characteristic color.

Pollution Prevention means practices or process changes that decrease or eliminate the creation of emissions or waste at the source of pollution (e.g., a paint spray booth). Such prevention techniques include use of new materials, modification of equipment, and changes in work practices that result in emission reduction at the source.

Powder coating means a coating applied as a dry powder which, when baked at sufficiently high temperature, flows out to form a continuous film. Powder coatings may emit VOC/HAP cure volatiles.

Primer means the first layer or layers of identically formulated coating applied to a surface, usually prior to the subsequent application of a topcoat.

Primary heat recovery means a method of conserving energy by using heat from incinerator exhaust gases to preheat the inlet gas to the incinerator.

Process (process line) means the sum of unit operations that result in the production of individual or groups of products.

Process fugitives means air emissions emanating from the process line that are not captured.

Product substitution means replacement of any product or raw material intended for an intermediate or final use with another. This substitution is a source reduction activity if either the VOC emissions or the quantity of waste generated at the source is reduced.

Reasonably Available Control Technology (RACT) means the lowest emission limit that a particular source is capable of meeting by the application of control technology that is reasonably available considering technological and economic feasibility. RACT is usually applied to existing sources in nonattainment areas and in most cases is less stringent than new source performance standards.

Reclaim means a material that is processed or regenerated to recover a usable product (see recycle).

Recovered solvent means solvent which is extracted from a process or exhaust stream usually by adsorption or condensation.

Recovery or regeneration (R or R) unit operation means a device for purifying solvent that may use any of a variety of techniques, including extraction, distillation, filtration, adsorption, or absorption.

Recycled means used, reused, or reclaimed (40 CFR 261.1(b)(7)). A material is "used or reused" if it is employed as an ingredient (including its use as an intermediate) to make a product. For example, when solvent recovered by distillation is reused in the plant.

Rework means touch-up (see touch-up and repair operation) that is performed after the part has been cured.

Secondary heat recovery means the use of heat from an incinerator exhaust for uses within a plant such as heating an oven or a room. This is distinguished from primary heat recovery which is the use of the hot incinerator exhaust gases to heat the inlet gases to the incinerator.

SIC code means Standard Industrial Classification, a numerical identification system developed by the U.S. Government for statistical purposes and widely used by business firms. Industries are grouped into similar categories and each category is given a number representing the category.

Solids (see nonvolatiles or coating solids)

Solvent means a liquid used in a coating to dissolve or disperse constituents and/or to adjust viscosity. It generally evaporates during drying and, therefore, does not become part of the dried film.

Solventborne coating means a coating that contains only organic solvents. If water is present, it is only in trace quantities.

Solvent recovery device means, for the purposes of this subpart, an add-on control device in which HAP material is captured rather than destroyed. Examples include carbon adsorption systems and condensers.

Source reduction (or pollution prevention) means any activity or treatment that reduces or eliminates the generation of VOC/HAP emissions (or waste) at the source of pollution, including product substitution or elimination.

Stack means a contained air stream (excluding storage tanks), which is a point through which emissions exit the facility.

Surface coating operation means the application of a film which covers the surface of an object. Painting and varnishing are common surface coating operations as are coatings applied to large appliance, metal furniture, fabric, paper, plastic film, and metallic foil.

Surface preparation means the removal of contaminants from the surface of a substrate or component or the activation or reactivation of the surface in preparation for the application of a coating.

Temporary total enclosure means an enclosure that meets the requirements of §63.805(e)(1)(i) through (iv) and is not permanent, but constructed only to measure the capture efficiency of pollutants emitted from a given source. Additionally, any exhaust point from the enclosure shall be at least four equivalent duct or hood diameters from each natural draft opening. For additional information, see Guidelines for Determining Capture Efficiency, January 1994. (Docket No. A-93-1, Item No. IV-B-1).

Thermal incinerator means a device for oxidizing waste material via flame and heat. This contrasts with a catalytic incinerator which incorporates a catalyst to aid the combustion.

Thinning solvent means a solvent added to thin a coating for the purpose of lowering the coating's viscosity and that evaporates before or during the cure of a film.

Thinning ratio means the volumetric ratio of thinner to coating.

Threshold Limit Values (TLV) means the air concentrations of chemical substances to which it is believed that workers may be exposed without adverse effect.

Topcoat means a coating applied to a bare substrate or over a primer to provide protective and/or decorative properties to a part.

Total enclosure means an enclosure around the coating head of a wet coating line or other coating application device so that all HAP and VOC from the coating application and flash off operations are collected and ducted through a stack or into the oven. With a total enclosure on a coating line there will be no fugitive emissions, only stack emissions. Some air pollution regulations may require a total enclosure so that all HAP and VOC emitted by the process can be measured. The only openings in a total enclosure are forced makeup air and exhaust ducts and any natural draft openings such as those that allow raw materials to enter and exit the enclosure for processing. All access doors or windows are closed during routine operation of the enclosed source. Brief, occasional openings of such doors or windows to accommodate process equipment adjustments are acceptable, but if such openings are routine or if an access door remains open during the entire operation, the access door must be considered a natural draft opening. The average inward face velocity across the natural draft openings of the enclosure must be calculated including the area of such access doors. The drying oven itself may be part of the total enclosure. An enclosure that meets the requirements found in §63.750(g)(4) is a permanent total enclosure.

Touch-up and repair operation means that portion of the coating operation that is the incidental application of coating used to cover minor imperfections in the coating finish or to achieve complete coverage. This definition includes out-of-sequence or out-of-cycle coating.

Transfer efficiency means the ratio of the amount of coating solids (nonvolatiles) deposited onto the surface of the coated part to the total amount of coating solids used.

Treatment means any method, technology, or process designed to remove solids and/or pollutants from solid or liquid wastes, waste streams, effluents, or air emissions.

Unit operation means an industrial operation, classified or grouped according to its function in an operating environment (i.e., a paint mixing vessel, a spray booth, etc.).

Unit operation system (UOS) means the ensemble on which the material balance is performed.

Viscosity means a measure of a coating's resistance to flow.

Volatile organic compound (VOC) means any compound defined as VOC in 40 CFR 51.100(s). This includes any organic compound other than those determined by the EPA to be an exempt solvent.

Volume percent solids means the portion of a coating which remains as part of the cured film expressed as percent by volume. This contrasts to another convention of expressing solids content by mass percent. Often a percentage is given without specifying whether volume or mass. This is confusing and leads to errors in coating calculations.

Waste handling means processing or treatment of waste (liquid or solid) that is generated as a by-product of either the coating process or cleaning activities/operations.

Waste handling device means equipment that is used to separate solvent from solid waste (e.g., filter dryers) or liquid (e.g., pot stills and thin film evaporators). The solvents are recovered by heating, condensing, and collection.

Waste management means the handling, treatment, storage, and disposal of solid or liquid waste products.

Waste minimization means the reduction, to the extent feasible, of hazardous waste that is generated or subsequently treated, stored or disposed. It includes any source reduction or recycling activity undertaken by a generator that results in either the reduction of total volume or quantity of hazardous waste, or both, so long as reduction is consistent with the goal of minimizing present and future threats to human health and the environment. In order of preference, these activities include: source reduction, recycling, and treatment.

Wastewater discharge means the water phase that is discharged from the separator in a wastewater treatment system.

Waterborne coating means a coating that contains more than 5 percent by mass water in its volatile fraction.

Work practice means specific human activities within industry that lead to a reduction in VOC emissions (or waste). The activities include increased operator training, management directives, segregation of waste solvent, and practices that lead to a reduction in cleaning frequency. It does not include the use of specialized equipment, such as solvent dispensers.