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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

	1650 Arch Street

	    Philadelphia ,   Pennsylvania     19103





DATE:	December 7, 2010



SUBJECT:	Technical Support Document for Maryland’s Adoption of Control
Techniques Guidelines (CTG) for Flat Wood Paneling Coatings 

			

FROM:	Gregory Becoat, Environmental Scientist /s/

Office of Air Program Planning 



TO:		File

				

THRU: 	Marilyn Powers, Acting Associate Director /s/

Office of Air Program Planning





A.  BACKGROUND  



What is the flat wood paneling coating CTG?



Section 172(c)(1) of the Clean Air Act (CAA) provides that state
implementation plans (SIPs) for nonattainment areas must include
reasonably available control measures (RACM), including reasonably
available control technology (RACT), for sources of emissions.  Section
182(b)(2)(A) provides that for certain nonattainment areas, States must
revise their SIPs to include RACT for sources of volatile organic
compound (VOC) emissions covered by a CTG document issued after November
15, 1990 and prior to the area’s date of attainment. 



The United States Environmental Protection Agency (EPA) defines RACT as
“the lowest emission limitation that a particular source is capable of
meeting by the application of control technology that is reasonably
available considering technological and economic feasibility.” (44 FR
53761, Sept. 17, 1979).  In subsequent Federal Register notices, EPA has
addressed how states can meet the RACT requirements of the CAA. 



The CTG for flat wood paneling coatings is intended to provide state and
local air pollution control authorities information that should assist
them in determining RACT for VOCs from flat wood paneling coating. In
developing this CTG, EPA, among other things, evaluated the sources of
VOC emissions from the flat wood paneling coating industry and the
available control approaches for addressing these emissions, including
the costs of such approaches. Based on available information and data,
EPA provides recommendations for RACT for flat wood paneling coating.



In June 1978, EPA published a final CTG for flat wood paneling coatings,
entitled “Control of Volatile Organic Emissions from Existing
Stationary Sources, Volume VII, Factory Surface Coating of Flat Wood
Paneling,” EPA-450/2-78-034 (June 1978). Control of Volatile Organic
Emissions from Existing Sources - Volume VII: Factory Surface Coating of
Flat Wood Paneling. Publication No. EPA-450/2-78-032. U. S.
Environmental Protection Agency, Research Triangle Park, NC. June 1978. 

  In September 1979, EPA published guidance to provide assistance to
State and local air pollution control agencies in preparing RACT
regulations for a variety of categories, including flat wood paneling. 
In 2003, EPA promulgated national emission standards for hazardous air
pollutants (NESHAP) covering surface coating of wood building products
(including flat wood paneling).  See 68 FR 31746 (May 28, 2003).



What is flat wood paneling coatings?

Flat wood paneling products are used in construction and can be
classified as three main product types: decorative interior panels,
exterior siding, and tileboard.  Flat wood paneling, like most wood
products, are vulnerable to light, moisture and insects. Coatings are
used for three principal purposes: protection, appearance, and surface
modification. Surface coatings are applied to reduce potential damage
from environmental elements such as moisture and temperature extremes
and other climate-related hazards and from insect infestation. Coatings
are also applied to enhance surfaces to make other coatings more
effective.  Finally, coatings are applied to improve the appearance of
the wood product.  Releases of VOC occur during the coating process as
the coatings are mixed or thinned, as they are applied to the substrate,
and as they dry and the VOC within the coating evaporate into the air. 

A typical flat wood coating facility applies stains and varnishes to
natural plywood panels used for wall coverings.  Other plants print wood
grain patterns on particle board panels that were first undercoated with
an opaque coating to mask the original surface.  Coatings applied to
flat wood paneling include fillers, sealers, “groove” coats,
primers, stains, basecoats, inks and topcoats. Most coatings are applied
by direct roll coating.  Filler is usually applied by reverse roll
coating.  The offset rotogravure process is used where the coating and
printing operation requires precision printing techniques.  Other
coating methods include spray techniques, brush coating and curtain
coating.  A typical flat wood paneling coating line includes a
succession of coating operations.  Each individual operation consists of
the application of one or more coatings followed by a heated oven to
cure the coatings.  A typical production line begins with mechanical
alterations of the substrate (filling of holes, cutting of grooves,
sanding, etc.), followed by the coating operations, and
packaging/stacking for shipment.



This CTG applies to facilities that apply flat wood paneling coatings
that emit at least 6.8 kg/day (15 lb/day) of VOC before consideration of
controls.  Flat wood paneling coatings means wood paneling products that
are any interior, exterior or tileboard (class I hardboard) panel to
which a protective, decorative, or functional material or layer has been
applied.



There are several approaches to reducing VOC emissions from flat wood
coating facilities: (1) the use of low-VOC, waterborne coatings, (2) the
use of ultraviolet cure and electron beam cure coatings, (3)
adding/improving add-on controls, and (4) the implementation of work
practice standards.  



EPA’s Recommended Emissions and Control Options for Flat wood Paneling
Coatings



EPA issued a CTG for Flat wood Paneling Coatings on June 1978
(EPA-450/2-78-034).  EPA recommended emission limits for the inks,
coatings and adhesives used by the flat wood paneling coating facilities
and work practices for cleaning materials used.  The recommended
emission limits for inks, coatings, and adhesives can be achieved either
by using materials with VOC contents low enough to achieve the limits
during application, or by reducing the amount of VOC emitted through the
use of add-on controls.  There are two alternative limits recommended
for the use of low VOC inks, coatings and adhesives.  Table 1 summarizes
the VOC emission limits recommended in this CTG.



A. Emissions Limit based on Low-VOC Coatings for Inks, Coatings and
Adhesives 



The low-VOC materials recommendation for inks, coatings and adhesives
include an emissions limit of 250 g VOC/liter (2.1 lb VOC/gal) of
material (minus water and exempt compounds).  An equivalent limit,
expressed as units of weight of VOC per volume of solids in all coatings
is 350 grams of VOC per liter solids (2.9 lb of VOC per gal of solids). 




B. Optional Add-On Controls for Inks, Coatings and Adhesives 



Should product performance requirements or other needs dictate the use
of higher-VOC coatings than specified in Table 1, a facility could
choose to use add-on control equipment to meet an overall control
efficiency of 90 percent. 



C. Work Practices 



The recommended work practice plan include steps to ensure that VOC
emissions are minimized from mixing operations, storage tanks and other
containers, and handling operations for coatings, thinners, cleaning
materials, and waste materials. Examples of work practice standards
include: storing all VOC coatings, thinners, and cleaning materials in
closed containers, minimizing spills of VOC containing coatings,
thinners, cleaning up spills immediately, conveying any coatings,
thinners, and cleaning materials in closed containers or pipes, closing
mixing vessels which contain VOC coatings and other materials except
when specifically in use, and minimizing emissions of VOC during
cleaning of storage, mixing, and conveying equipment.



Table 1. Recommended Emission Limits for Flat Wood Paneling Coating
Operations





Surface Coatings, Inks, or Adhesives Applied to the Following Flat Wood
Paneling Categories

Should Meet One of These Emission Limits:lb VOC per

gallon material

(grams VOC per

liter material)

[excluding water and exempt compounds ]lb VOC per

gallon solids

(grams VOC per

liter solids)Overall Control Efficiency Using an Add-On Control Device:

Printed interior panels made of hardwood, plywood, or thin particleboard
2.1 (250) 2.9 (350) 

90% 

Natural finish hardwood plywood panels 2.1 (250) 

2.9 (350) 

90% 

Class II finishes on hardboard panels 2.1 (250) 

2.9 (350) 

90% 

Tileboard 2.1 (250) 

2.9 (350) 

90% 

Exterior siding 

2.1 (250) 2.9 (350) 90% 



B.  STATE SUBMITTAL



On April 23, 2010, Maryland Department of the Environment (MDE)
submitted to EPA a SIP revision concerning the adoption of the EPA CTG
for flat wood paneling coatings.  EPA develops CTGs to provide States
with guidance on control requirements for source categories.  States can
follow the CTGs or adopt more restrictive standards.  MDE is adopting
EPA’s CTG standards for flat wood paneling coatings (see
EPA-450/2-78-034, June 1978).  This SIP revision includes new regulation
.33 under COMAR 26.11.19, Volatile Organic Compounds from Specific
Processes.  This action affects facilities that apply stains and
varnishes to natural plywood panels used for wall coverings.  This SIP
revision also includes amendments to regulation .32 under COMAR
26.11.19; however, on November 12, 2010, MDE submitted a letter to
withdraw this portion because Maryland had not previously submitted
COMAR 26.11.19.32 to be approved as part of the SIP.  



COMAR 26.11.19.33 – Control of Volatile Organic Compounds (VOCs)
Emissions from Flat Wood Paneling Coatings is being added:



Section .33(A):  Includes definitions for the following terms pertaining
to flat wood paneling coatings: (1) “Class II finishes on hardboard
panels,” “Exterior siding,” “Flat wood paneling,” “Hardwood
plywood,” “Natural finish hardwood plywood panels,” “Printed
interior panels,” “Thin particleboard,” and “Tileboard.” 



Section .33(B):  Incorporates by reference ANSI A135.5-2004, Prefinished
Hardwood Paneling and ANSI A135.4-2004, Basic Hardboard.



Section .33(C):  Describes the applicability of this regulation.



Section .33(D):  Includes the requirements for flat wood paneling
coating.  Any person who applies flat wood paneling coatings, including
inks and adhesives, where total precontrol VOC emissions from all flat
wood paneling coating operations at a premises is 15 pounds or more per
day (6.8 kg/day) shall meet the coating standards or overall control
efficiency specified in Table 1.



C.  EPA EVALUATION



The State of Maryland has adopted the standards and requirements of the
CTG for flat wood paneling coating and is revising its SIP to reflect
these amendments.  The maximum benefit from these amendments will be
provided during the ozone season when VOCs readily combine with nitrogen
oxide to form ground-level ozone.  Therefore, this revision will help
Maryland attain and maintain the national ambient air quality standard
for ozone.  



D.  CONCLUSIONS AND RECOMMENDED AGENCY ACTION



The adoption of the EPA CTG requirements for flat wood paneling coating
by the State of Maryland will result in the reduction of VOC emissions
from flat wood coating facilities.  EPA approval of the SIP revision is
recommended.













