Finishing newsfront: emission guidelines taking shape.

Woodworking companies currently utilizing waterborne or high solids topcoats and using high-transfer efficiency spray guns are on the right track to comply with future environmental finishing regulations, according to a proposal being drafted by a multi-partisan committee.

On Nov. 30 and Dec. 1, the federally-sanctioned Wood Furniture Regulatory Negotiating (Reg Neg) Committee, made up of representatives from the woodworking and finishing supply industries, private environmental groups and state and federal environmental agencies, met in Raleigh, N.C., in an attempt to finalize guidelines for wood finishing operations. The group or "Table" as it is known, has been striving to develop recommendations which will serve as a draft for a National Emission Standard for Hazardous Air Pollutants (NESHAP) and Control Technique Guidelines (CTGs) covering volatile organic compound emissions for the wood finishing industry.

What is NESHAP and CTG?

The NESHAP will set national, minimum standards for emissions of 189 chemicals listed as HAPS by the EPA, as well as determine which materials and methods can be used to meet HAP emissions standards. A HAP is a smog producing chemical that is released into the atmosphere during some finishing and gluing operations. Very few of the HAPS on the EPA's list are present in woodworking operations, although a few such as trichloroethane are present in some finishes and adhesives.

HAPS that are released from adhesives will be included in the final document, but will not be tackled in this Reg-Neg session.

The CTG will cover VOC emissions in geographic areas with high air pollution problems (non-attainment areas) such as Los Angeles, Chicago and High Point, N.C. VOCs are ozone depleting solvents that are found in some conventional wood finishes and adhesives. Unlike NESHAP which is federally regulated, the CTG will be used by individual states in developing their own VOC emission guidelines and determining the Reasonably Available Control Technology (RACT) for non-attainment areas.

States without non-attainment areas can also use the CTG as a basis for their air pollution standards.

John Lingelbach, of CDR Associates, Boulder, Colo., facilitator of the Reg-Neg meetings, said it was hoped that the NESHAP and CTG standards will be completed by the end of December or mid-January. Once completed these recommendations will be turned over to the U.S. Environmental Protection Agency for consideration and public debate.

At press time, there were still a number of areas being debated such as giving companies credit for being under the emissions level in one area of the finishing operation which could be used in another area of the finishing process; creating an annual state-of-the-industry report on releases of harmful emissions; and record keeping issues required of wood finishing operations. The table did tentatively agree to some items. The draft plan, obtained by W&WP, includes:

* Establishing a single, industry-wide guideline rather than segmenting the industry by type of finishing operation such as roll coating, multi coating and long and short spray lines, as had been previously discussed.

* Requiring, with some as yet unresolved exceptions, woodworking companies to use high-volume low-pressure spray guns, as opposed to the use of conventional spray guns, in their finishing operations. One possible exception would be final touchup and repair.

* Incorporating language in the CTG stating that companies can meet future State VOC guidelines by using water-borne topcoats that have a VOC content of 0.8 pounds of VOCs per pound of solids or high-solids with a VOC content of 1.8 pounds of VOCs per pound of solids for topcoats and 1.9 for sealers. According to the National Paint & Coatings Assn., acid-cured varnishes used by the kitchen cabinet industry can not exceed 2.0 pounds of VOCs per pound of solids for topcoats and 2.3 lbs. VOCs/lb. solids for sealers.

* Allowing a woodworking company to comply by using other techniques such as adding-on equipment that controls emissions as long as it can be demonstrated that it can meet VOC emission standards.

* Determining that HAPS and VOC emissions will be measured in terms of pounds of HAPs or VOCs per pound of solids used. For existing sources the emissions level for HAPs will be 1.0 pounds of HAPs per solids, while new sources will need to meet 0.8 lbs. HAPs/lb. solids. According to the draft plan, an existing source can meet levels either by using compliant coatings, averaging across finishing steps, or any other acceptable technique that will achieve these limits.

* A tentative date of May 1, 1995, has been recommended for implementation of these guidelines. An exception may be made for small businesses with fewer than 50 employees. These woodworking companies may be granted additional time for compliance.

POTENTIAL CHANGES IN WORKPLACE STANDARDS

In addition to calling for changes in finishing materials and methods, the Wood Furniture Regulatory Negotiation Committee's draft plan calls for a number of changes in workplace standards. The following is a list of "Work Practices" developed by a subcommittee of the Reg-Neg committee and presented to the full committee at the Nov. 30-Dec. 1 meeting.

Finishing operations

Develop a written inspection and maintenance plan addressing leaks and preventive maintenance for all fluid transfer and application equipment and regular inspection of application equipment performance.

All storage tanks, drums, buckets, and mixing equipment containing solvents or solvent-laden materials (such as rags) shall be kept covered when not in active use in a manner that will minimize emissions.

Gun and line cleaning

Gun and line flushing solvents shall be collected in a container that can be covered.

Keep all containers covered when not in active use.

Spray booth cleaning

Spray booth floors, walls, and ceilings shall be coated with a peelable or strippable material. Solvent shall not be used for booth cleaning except for the cleaning of conveyors or metal filters.

Furniture washoff

Washoff or cleanup material shall not contain any EPA listed known (Type A) or probable (Type B1 or B2) human carcinogen in concentrations greater than OSHA requirements as demonstrated by the Material Safety Data Sheet (MSDS).

Keep washoff tank covered when not in active use.

Minimize dragout by tilting and/or rotating part to drain as much solvent as possible and allowing sufficient drip time to minimize emissions.

General work practice, recordkeeping

All new employees using solvent for coatings, washoff or cleanup shall be trained to minimize emissions. At a minimum, training shall include proper application and cleanup technique, proper equipment setup and adjustment to minimize coating usage and overspray, and proper management of cleanup wastes. All operators (new and existing) shall be re-trained annually.

Maintain a tracking system for wash off operations to track the number and main reason each piece is washed off.

Keep a running log of organic solvents used for cleanup and washoff. Net cleanup and washoff solvent use shall be tallied monthly accounting for solvent sent offsite for recycling or disposal or recovered for reuse onsite. Records shall include the types of solvents used for cleanup or washoff.