Economic impact of VOC reductions.

Pending review of two separate studies, the EPA has delayed announcement of control technique guidelines for curbing wood finishing emissions.

The cost for cleaner air is going to be expensive for wood finishers, according to a study commissioned by four industry trade groups. According to the study, depending on how great a reduction of volatile organic compounds is required by the EPA, the woodworking industry could lose between 930 and 2,015 plants and 5,787 to 62,774 jobs. Capital expenditures for implementing VOC controls could total $53 million to $624 million annually.

Because of this and other potential economic impact information obtained from the study, the EPA is reassessing its draft recommendations for control technique guidelines (CTGs) for non-attainment areas. Public comment for these guidelines is tentatively set for the fall, said Karen Catlett, EPA project director for Control Technique Guidelines for the woodworking industry. CTGs, which are intended to provide non-attainment states and areas with a basis for proceeding with reasonably available control technology (RACT) guidelines, are scheduled for implementation by November 1993.

Background

Although wood finishing accounts for less than 1 percent of the nation's VOC emissions problem, it has come under attack by regulating agencies seeking to limit the amount of discharge from furniture, cabinet and other wood products facilities.

The Clean Air Act Amendments of 1990 require that states with non-attainment areas, i.e., those areas exceeding the National Ambient Air Quality Standard of 0.12 parts per million of VOCs, implement a plan for VOC reduction. This plan must utilize existing guidelines with regards to reasonably available control technology (RACT).

In this process, the EPA determines a control technique guideline specifying a certain percentage baseline reduction of VOC emissions; baseline figures are the levels of VOCs emitted from finishing prior to implementation of any VOC control reductions. The EPA will then list a series of RACTs, such as switching to waterborne or UV-cured finishes, which it deems technologically feasible to obtain the specified VOC reduction level. Individual states and local air pollution agencies in non-attainment zones are encouraged to use the EPA-developed RACTs, although they can develop their own technology requirements.

The area with the strictest VOC reduction rules in effect is Southern California, due primarily to the Los Angeles area's ranking as the nation's top non-attainment zone. Under the phase-in program implemented by South Coast Air Quality Management District Rule 1136, by 1996 woodworkers will be required to use topcoats, fillers and coatings with 2.3 or less pounds per gallon of VOC, high solids stains or sealers with maximum limits of 2.0 and equipment demonstrating 65 percent transfer efficiency.

Other areas with regulations in effect include:

* Material: Texas, Washington, New Jersey and Illinois (for six county area).

* Equipment: Indiana, Michigan, Ohio, New Jersey, Pennsylvania, New York and Illinois.

EPA assessing industry's study

The EPA is assessing the economic impacts extrapolated from a survey of 154 woodworking companies which was commissioned by the Joint Industry Steering Committee. The survey was intended to provide the EPA with industry input in determining possible impacts of 10 to 80 percent baseline VOC reductions. The survey was conducted by ENSR Consulting and Engineering and National Economic Research Associates Inc. and included representatives from the residential furniture, office furniture and kitchen cabinet industries. The JISC is comprised of American Furniture Manufacturers Assn., Business & Institutional Furniture Manufacturers Assn., Kitchen Cabinet Manufacturers Assn. and National Paint & Coatings Assn.

A comparison of economic impacts between the JISC's and the EPA's studies is unavailable. The EPA has not yet extrapolated its own information to determine economic impact on industry, Catlett said, because of the lack of quantitative results received by the EPA, which totalled 20 responses. "We know that it does not represent the industry as a whole, though we tried to survey a variety of companies within the industry," she added.

The EPA will also look at the different equipment and materials evaluated in the separate studies. The JISC study concluded high-volume, low-pressure (HVLP) sprayers to be a viable alternative for lowering VOC emissions. However, although the EPA examined four primary sources during its evaluation -- spray booths, flashoff areas, ovens and cleanup operations -- it does not consider applications equipment as viable methods for compliance, said Catlett.

"We don't give credit for transfer efficiency as an emissions reduction technology," she added. "We recognize that in every case, one applications method will be better than another. It all depends on the part that is sprayed, the operator, the spray booth, etc. So we probably will not make a recommendation for equipment in the CTGs. We have toyed with the idea of not allowing air spray since it is so inefficient, but nothing has been decided yet."

Variances in material types were also found between the two studies. The EPA included in its data polyesters and polyurethane finishes as viable VOC emission reduction/reformulation methods, whereas the JISC study did not consider them as options. Polyesters and polyurethane finishes are not used by too many people in the industry and have limited market usage," said Larry Runyan of AFMA. However, he did not rule out their possibility as a viable means of VOC reduction within the industry.

A further summary of the two studies follows.

EPA focuses on material reformulation

The EPA focused on four methods of material reformulation for lowering VOC emissions: waterborne (80-88 percent reduction), hybrid waterborne, which utilizes some solventborne materials (54-59 percent reduction), polyester/polyurethane (48-56 percent reduction), and a hybrid polyester/polyurethane system, utilizing some waterborne materials (49-84 percent reduction).

Using what the EPA considers a typical plant setup, it then determined that while a full waterborne system is currently feasible for the office furniture and cabinet industries as well as residential furniture companies using a short finishing sequence (stain, washcoat, sealer and topcoat), it is not technically feasible for those residential companies using a long finishing sequence (stain, washcoat, filler, wiping stain/glaze, sealer, highlight and topcoat). However, all other systems are said to be technically feasible for all types of plants.

From this, the EPA then determined nine possible RACT (reasonably available control technology) options. They include:

1. Full waterborne systems used where possible, with a hybrid waterborne system used elsewhere. A hybrid waterborne system uses a combination of both waterborne and conventional solventborne coatings, i.e,, solventborne stains and washcoat used in conjunction with a waterborne sealer and topcoat.

2. All facilities switch to a hybrid waterborne system.

3. All facilities with more than 50 employees would switch to a polyester/polyurethane coating system (sealer, topcoat) in conjunction with solventborne coatings for the remaining steps. All facilities with 50 or less employees would switch to a hybrid waterborne coating system.

4. All facilities with more than 50 employees switch to a hybrid polyester/polyurethane system. In a hybrid polyester/polyurethane system, waterborne materials are used in conjunction with a polyester/polyurethane sealer topcoat and filler. All facilities with 50 or less employees would switch to a hybrid waterborne coating system.

5. A hybrid waterborne coating system is used by all, with add-on controls implemented by facilities with 50 or more employees.

6-9. Four different add-on control devices were considered: recuperative thermal incineration, regenerative thermal incineration, catalytic incineration and combined adsorption/recuperative thermal incineration.

Final RACT determination will take place following development of the CTGs, Catlett said.

JISC provides industry viewpoint

The JISC study provides a more comprehensive look at the industry as a whole. In addition to the 154 survey responses, visits to more than two dozen plants were conducted by ENSR and NERA; this compares to six made by the EPA. Based on technical review, at least one of the following methods, if not all, were found by ENSR and NERA to be feasible:

* Full waterborne system

* Hybrid waterborne systems

* UV curable coatings

* Unicarb coatings/system

* HVLP spray guns

* Thermal or catalytic incineration

* Carbon adsorption 

* Combined adsorption/incineration

"There's no one answer that's good for everybody," said C. Richard Titus, executive vice president of the KCMA. "The whole industry is categorized by a lot of diversity and the diverse nature of the materials merely adds to this."

Annual capital and operating expenses, per ton of material, for the control technologies range from $1,800 for HVLP, to $8,600 for a full waterborne system, up to a possible $87,300 for incineration. These cost estimates are sourced in An Evaluation of VOC Emissions Control Technologies for the Wood Furniture and Cabinet Industries, Vol. 1.

Financial implications of these technologies, used alone or in combination to reach 10 to 80 percent reductions, were then determined by ENSR and NERA with regards to profit margins and capital investment requirements.

From there, said Mark Berkman, senior consultant at NERA, the likelihood of plant closures and job losses was assessed. In a worst case scenario, if the EPA implements an 80 percent baseline reduction, projected plant closures are at 2,015 plant closures and 62,774 employment losses (See chart).

Future remains uncertain

It is still too early to tell the impact of the studies' findings on the industry, said Titus. "These put into one place some very key issues and identify the practicality of the different options," he added.

"Our concern is that once the CTGs are developed, the individual states will adopt guidelines whether they are in attainment or non-attainment zones," said AFMA's Runyan.

It is because of this concern that the JISC is pursuing regulatory negotiations with the EPA to determine effective CTGs for wood finishing operations, said Sue Perry, BIFMA's directer of government affairs.

Federal CTG regulation will affect non-attainment areas only, according to the EPA. As it stands, CTG sources include all wood finishing operations including companies which finish rattan and wicker. However, VOC emissions from wood furniture manufacturing facilities resulting from operations other than finishing, such as VOCs released from glues, will not be covered by the CTG for wood furniture coating.

The CTG is scheduled for implementation by November 1993.

QUALITY CABINET REMAINS A CALIFORNIA FIXTURE

California's strict air quality regulations, have forced many firms to either shut down or move their finishing facilities elsewhere. But neither was considered an option for San Diego-based Quality Cabinet & Fixture Co. This architectural millwork and store fixture firm made the decision to switch to water-based stains, a low-VOC emitting lacquer and HVLP sprayers in order to remain compliant.

Although Quality Cabinet is already compliant with 1994 material requirements, it is receiving a push from local Air Quality Management officials to set an example by becoming compliant with 1996 levels, by 1994, said Tim Paradise, finance administrator. The San Diego area is following the measures set by South Coast Air Quality Management District Rule 1136, which specifies, by 1996, 2.0 pounds/gallon of VOCs for stains and 2.3 pounds/gallon for clear topcoats, he added. Quality Cabinet currently uses water-based stains from Amity and Hydrocote and Sherwin-Williams Chem-Var lacquer and is experimenting with a water-based lacquer as well.

"We haven't switched completely to a water-based topcoat yet," said Frank Borg, Quality Cabinet operations manager, because of the difficulty in obtaining a consistent finish. "Instead, we use a heat exchange finishing system which warms up the air in the gun, expanding the solvents in the material, so you don't end up using as much," he added. The company uses a non-turbine DeVilbiss HVLP gun to apply the materials.

"An excellent finish is mandatory," said Borg in reference to the high-end clientele served by Quality Cabinet & Fixture. These include: Gucci, Bullochs, I. Magnin, CitiCorp Bank, and the Viking Serenade cruise ship.

AMISH CABINET COMPANY FLIES THE COOP

It wasn't just chickens which drew Martin Graber to the coop 23 years ago. his destiny as a cabinetmaker had come home to roost.

Working without electricity, using only diesel power, Graber designed and built cabinets in his coop for three years. Twenty years later, through "a lot of hard work and the blessing of the Lord," Dutch Made Kitchens' domain is 120,000 square feet of space divided into five buildings -- not one of which is a coop.

Separate buildings are used for the Genesis frameless line and face frame cabinetry. The frameless line uses a composite board box with a solid wood door. The framed version is completely solid wood construction. Finishing for the two lines is similar, however.

To comply with Indiana regulations governing VOC emissons, this Amish custom cabinet shop uses airless sprayers to apply Guardsman catalyzed paints and varnishes; 40, 60 and 100 sheens are used. Products are then airdried for one week prior to buffing. "We do hand buffing on the 100 sheen to achieve the high-tech, glossy, wet-lacquer look," said Graber. "Most people are using polyesters to achieve that look. But a lot of people have found that polyesters are hard to work with and a lot are scared to use them. We've worked with and developed ureas to achieve the same look."

Although ureas are compliant under current state regulations, Graber said Dutch Made is experimenting with water-based finishes. "We stay on top of what's happening and what we'll need to do in the future. There's no use fighting it, so we might as well be right there when it happens," he added.

HIGH-GLOSS DISTINGUISHES ASHLEY

Ashley Furniture likes to gloss over its products -- literally. The Arcadia, Wis.-based firm claims the distinction of being one of the few U.S. residential furniture companies to use a true polyester finish.

Ashley uses a 95 percent solids, polyester finish from Crown Metro which emits only 2 percent to 10 percent VOCs, said Jerry Pauer, vice president of design. The company first began using polyester finishes in the United States approximately five years ago and now uses it exclusively on its high-end Millennium line. "However, switching to polyesters was very capital intensive," Pauer said. Since the finish is chemically incompatible with nitrocellulose -- a potential explosive hazard -- Ashley spent millions of dollars to build a new polyester-finishing facility and underwent re-evaluation by the Wisconsin EPA. "We had to get re-permitted (as a new finishing source). But the technology is extremely friendly to the environment. It will already pass 1996 Southern California regulations (Rule 1136)," Pauer said.

In addition to the cost for the new facility and subsequent equipment, the company also had to retain workers on application methods. "Most solvents are applied in very thin coatings, have low gloss, and dry quickly in a hot air oven. With polyesters, you usually have a thick coat, high gloss and they're cured in UV ovens."

The finish is more expensive than standard solvents, but it produces "a tremendous build which can be as thick as glass," Pauer said.

DEFINITIONS

Baseline emissions: The levels of VOCs emitted from finishing prior to implementing any VOC control methods.

CTGs (Control technique guidelines): These are intended to provide non-attainment areas with a basis for determining and implementing either EPA suggested or their own RACT guidelines for VOC emissions control.

RACT (Reasonably available control technology): Current control methods which are technologically and economically feasible for the industry.