A manufacturer of kraft paper-based products needed to obtain operating permits for several manufacturing lines that use water-based adhesives. The facility uses large quantities of adhesives, typically more than 1,100 gallons per day for various paperbonding and impregnating applications. Even though EPA Method 24 is the only analytical method recognized by EPA, suppliers of these adhesives utilized other methods to determine and report the VOC content of their products to downstream users.
After embarking on its own analytical testing program to determine the VOC content of its water-based adhesives, the facility found that the results were not reliable or reproducible. The results showed that EPA Method 24 has poor precision and did not match the very low VOC concentrations found on technical data sheets and material safety data sheets (MSDSs) provided by the adhesive suppliers.
Mass emission calculations using EPA Method 24 data grossly overestimated facility VOC emissions and could have resulted in the unnecessary purchase of $400,000 of emission-reduction credits. CH2M HILL and the kraft paper-based product manufacturer investigated alternative methods to determine the VOC content and spoke to other organizations that were addressing this problem. After the investigation was completed, the CAQMD was successfully convinced that EPA Method 24 results were not appropriate to calculate VOC emissions for coatings or adhesives with high water content.