POLLUTION PREVENTION REPORT
Swiss Plywood Corporation has worked with members of the Indiana Pollution Prevention and Safe Materials Institute (IPPI) since 1990. The Swiss Plywood/IPPI team began work in early 1996 to reduce the use of hazardous air pollutants (HAPs) in the company's wood finishing process. The company also requested assistance from the Institute in compiling and submitting data pertinent to the Title V air permit rules and regulations.
Swiss Plywood Corporation is located in Tell City, Indiana, and employs approximately 100 people. The company manufactures and finishes quality furniture cabinets for pianos and organs for companies such as Kawai, Lowrey, and Hammond-Suzuki. Swiss also manufactures fine quality curios and display cabinets for large, private-label furniture companies.
Swiss Plywood furniture is manufactured from solid hardwood lumber in its milling room. The constructed furniture is then sent to the finish department where it undergoes a seven- to eleven-step staining and lacquer finish coating process.
The finish coating is designed to bring out the natural beauty of the hardwood. It is the quality of the furniture's finish coating which defines the product's competitive position in the marketplace. Thus, the finish coating is the most important step in the entire manufacturing process. Swiss Plywood's coating line and finish system achieves a showroom-quality finish on its superbly crafted furniture.
The finish coating process involves the application of highly specialized coatings--all designed to work as a system to protect and beautify the wood. A typical finish system involves the following steps:
While the above delineates seven points, there are seven to eleven, distinct, coating steps in the process, depending upon the number of final lacquer coats applied.
Traditionally, finish coating systems have been formulated with fast-drying, volatile organic solvents. Generally, coatings for companies such as Swiss are developed especially for the manufacturer's unique finish coating lines. The solvent formulations are uniquely modified to suit the mechanized coating lines at Swiss Plywood so that the coatings can wet-out, flow, develop gloss, and dry in the allotted production time. The entire multiple-step finish coating process must work as a system to maintain consistent quality and demanding production rates.
The wood furniture industry is among the first of America's industries to be subjected to the Environmental Protection Agency's (EPA's) new hazardous air pollutant Maximum Achievable Control Technology (MACT) guidelines. The MACT guidelines for wood furniture coatings call for all finish coating material to be formulated so that hazardous air pollutant chemical concentration in the coatings is reduced. The current EPA MACT regulations will require major air pollution sources (users of very large quantities of wood coating material) to convert to new, HAP-compliant coatings or install expensive air pollution control equipment. These very large major source emitters ((50 tons a year of HAPs) must convert to the new HAP-compliant coatings by November 1997. Major source emitters who emit smaller amounts must convert by December 1998.
Major sources are defined as companies that have the potential to emit 100 tons per year of criteria pollutants (such as volatile organic compounds [VOCs]) and/or ten tons per year of any single HAP and/or twenty-five tons per year of any combination of HAPs.
The aforementioned MACT Standard rules and regulations also require numerous reports and documentation to be developed regarding HAP use and emissions by major source companies. Naturally, it benefits a company (from a regulatory standpoint) to keep usage levels of HAPs below major source threshold limits. Swiss Plywood's objective was to minimize its use of HAPs in order to remain below major source threshold limits.
The finish coating step is the most important step in the manufacture of quality furniture, as previously mentioned. Companies resist changing any item in the process because changing one item usually causes a cascade of change throughout the coating line and risks product quality.
The Swiss Plywood/IPPI team analyzed the company's use of hazardous air pollutant chemicals. The team found that six sealer/topcoat coating systems--the last coatings applied in the finish coating line--were responsible for 70% of the company's HAPs emissions. This finding indicated that changes could be made only in the last part of the finishing process, leaving the rest of the system unchanged. Thinners and cleaning solvents were responsible for another 14%. A testing program was set up to analyze HAP-compliant coatings which could be substituted for the six key sealers and topcoats. Swiss Plywood contacted its supplier, Valspar Corporation, and requested formulation changes in the coatings to reduce the HAP content. Valspar supplied a variety of coating alternatives, all formulated to Swiss's specific coating requirements. Swiss Plywood then tested the HAP-compliant coatings on its production line. Six HAP-compliant coating systems were subsequently approved, along with one reformulated thinning solvent. This all occurred within three months of the testing program's inception. Swiss found that the HAP-reduced sealers' and topcoats' performance was equal to or better than that of the coatings they replaced.
POTENTIAL ENVIRONMENTAL AND COST BENEFITS
The new HAP-compliant sealers, topcoats, and thinners allowed Swiss Plywood to reduce its HAP emissions by nearly 20,000 pounds per year. This represents an overall reduction of nearly 40% in hazardous air pollutant emissions.
Swiss Plywood has incurred no significant cost increase in its switch to HAP-compliant coatings. Indeed, savings are realized due to reduced regulatory burdens. The company's hazardous air pollutant emissions are low enough to qualify for a FESOP (Federally Enforceable State Operating Permit). This means that the company can opt-out of the full, Title V air permit--saving, perhaps, $15,000 in consultant processing and filing costs. Further, the company believes that the reduction in HAPs will reduce the amount of time that personnel spend on regulatory compliance issues by 25%. This translates into savings of approximately $3,000 per year. Swiss Plywood will be required to keep detailed coating usage calculations and records, but other regulatory reporting requirements will be greatly reduced.
MACT standard regulations have been approved by the EPA. The regulations will take effect in November 1997 for large emitters and December 1998 for smaller emitters. Swiss Plywood has voluntarily adopted the new HAP-compliant coatings years before it becomes mandatory. The company has found that the Valspar HAP-compliant coatings perform as well (or better) than the replaced coating systems. Swiss has also discovered that there is no significant raw material cost increase in the purchase of the new HAP-compliant coatings. This fact dispels many concerns regarding "potential, significant cost increases" for new HAP-compliant sealers and topcoats. Many companies are waiting until the last moment before they make the switch to the new coatings because of the concern of increased costs.
Swiss Plywood's early adoption of HAP-compliant coatings insures that they have a wide margin for growth potential within the FESOP (Federally Enforceable Standard Operating Permit), and it puts them ahead of the regulatory curve. The payback to Swiss Plywood is reduced regulatory burden and assurance that they can continue to produce quality products, yet comply with the new air pollution regulations.
4 (c) Purdue University Research Foundation, 1996