UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

	1650 Arch Street

	Philadelphia, Pennsylvania  19103

DATE:	November 23, 2010

SUBJECT:	Technical Support Document for Allegheny County’s Adoption of
Control Techniques Guidelines for Large Appliance and Metal Furniture;
Flat Wood Paneling; Paper, Film, and Foil Surface Coating Processes; and
Revisions to Definitions and an Existing Regulation

			/s/

FROM:	Irene Shandruk, Physical Scientist 

Office of Air Program Planning 

TO:		File

			/s/	

THRU: 	Brian Rehn, Acting Associate Director 

Office of Air Program Planning

A.  BACKGROUND  

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 control techniques guidelines
(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. 

CTGs are intended to provide state and local air pollution control
authorities information that should assist them in determining RACT for
VOCs from various sources, including large appliance coatings, metal
furniture coatings, flat wood paneling coatings, and paper, film, and
foil coatings.  In developing these CTGs, EPA, among other things,
evaluated the sources of VOC emissions from this 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 VOCs from large appliance
coatings, metal furniture coatings, flat wood paneling coatings, and
paper, film, and foil coatings.

In December 1977, EPA published CTGs for large appliance coatings
(EPA-450/2-77-034), surface coating of metal furniture
(EPA-450/2-77-032), and surface coating of paper (EPA-450/2-77-008).  In
June 1978, EPA published a CTG for flat wood paneling coatings
(EPA-450/2-78-034).  These CTGs discuss the nature of VOC emissions from
these industries, available control technologies for addressing such
emissions, the costs of available control options, and other items.  

EPA promulgated national standards of performance for new stationary
sources (NSPS) for these industries:

Large appliances in 1982 (40 CFR part 60, subpart SS)

Surface coating of pressure sensitive tape and labels, which is a subset
of the paper, film, and foil surface coating industry in 1983 (40 CFR
part 60, subpart RR)

Surface coating of metal furniture in 1982 (40 CFR part 60, subpart EE)

EPA also published a national emission standard for hazardous air
pollutants (NESHAP) for these industries:  

Surface coating of large appliances in 2002 (40 CFR part 63, subpart
NNNN)

Surface coating of paper in 2002 (40 CFR part 63, subpart JJJJ)

Surface coating of metal furniture in 2003 (40 CFR part 63, subpart
RRRR)

Surface coating of wood building products, including flat wood paneling
in 2003 (40 CFR part 63, subpart QQQQ)

 

In 2006 and 2007, after conducting a review of currently existing state
and local VOC emission reduction approaches for these industries,
reviewing the 1977/1978 CTGs and the NESHAPs for these industries, and
taking into account the information that has become available since
then, EPA developed new CTGs for: surface coating of large appliances,
entitled Control Techniques Guidelines for Large Appliance Coatings
(Publication No. EPA 453/R-07-004; September 2007); surface coating of
paper, entitled Control Techniques Guidelines for Paper, Film, and Foil
Coatings (Publication No. EPA 453/R-07-003; September 2007); surface
coating of metal furniture, entitled Control Techniques Guidelines for
Metal Furniture Coatings (Publication No. EPA 453/R-07-005; September
2007); and surface coating of flat wood paneling, entitled Control
Techniques Guidelines for Flat Wood Paneling Coatings (Publication No.
EPA 453/R-06-004).

Description of Large Appliance Coatings 

Large appliance coatings include, but are not limited to, materials
referred to as paint, topcoats, basecoats, primers, enamels, and
adhesives used in the manufacture of large appliance parts or products. 
A large appliance part is defined as any organic surface-coated metal
lid, door, casing, panel, or other interior or exterior part or
accessory that is assembled to form a large appliance product.  A large
appliance product is also defined as any organic surface-coated metal
range, oven, microwave, refrigerator, freezer, washer, dryer,
dishwasher, water heater, or trash compactor manufactured for household,
commercial, or recreational use.

Coatings are a critical constituent of the large appliance industry. 
Coatings protect the metal from corrosion by providing resistance to
moisture, heat, detergent, and sometimes the outdoor elements.  Coatings
for each type of large appliance have special requirements and contain
unique properties because each type will be exposed to somewhat
different corrosive elements.  The coatings must also be durable and
have excellent adhesion properties to avoid peeling or chipping. 
Finally, the coatings that are applied on home appliances must have
aesthetic appeal.  

The coating application methods used are typical of surface coating
operations in many industries, and include air atomized spraying, dip
coating, electrodeposition, and flow coating.

VOC emissions from large appliance coating processes result from the
evaporation of the components of the coatings and cleaning materials.  

EPA’s Recommended Control Options for Large Appliance Coatings

EPA issued a CTG for Large Appliance Coatings in September 2007
(Publication No. EPA 453/R-07-004).  Recommendations for controlling VOC
emissions from large appliance coatings are outlined in the CTG.  Three
alternatives are recommended:  (1) emission limits that can be achieved
through the use of low-VOC coatings; (2) equivalent emission limits that
can be achieved through the use of low-VOC coatings or a combination of
coatings and add-on controls; and (3) an overall control efficiency of
90 percent for add-on controls.  The low-VOC coatings recommendation
consists of emission limits in terms of mass of VOC per volume coating,
excluding water and exempt compounds, as applied and the use of
specified application methods.  The equivalent emission limit
recommendation consists of emission limits in terms of mass of VOC per
volume of coating solids, as applied, and the use of specific
application methods.  Additionally, for cleaning materials, work
practices are recommended to reduce VOC emissions.

Specific recommendations for coating operations and cleaning materials
used in large appliance surface coating operations are summarized below:

Emissions Limits Based on Low-VOC Coatings:  Emission limits for
one-component and multi-component general purpose coatings are
recommended.  In addition, specific emission limits for certain
specialty coatings are recommended.  For each of these coating types,
separate emission limits are recommended for baked and air-dried
coatings.  Provided below are the recommended emission limits expressed
in terms of mass of VOC per volume of coating (kilograms per liter or
pounds per gallon), excluding water and exempt compounds:

Table 1:  Recommended Emission Limits (mass of VOC per volume of
coating) for Large Appliance Coatings

Coating Type	Baked	Air Dried

	kg/l	lb/gal	kg/l	lb/gal

General, One Component	0.275	2.3	0.275	2.3

General, Multi-Component	0.275	2.3	0.340	2.8

Extreme High Gloss	0.360	3.0	0.340	2.8

Extreme Performance	0.360	3.0	0.420	3.5

Heat Resistant	0.360	3.0	0.420	3.5

Metallic	0.420	3.5	0.420	3.5

Pretreatment Coatings	0.420	3.5	0.420	3.5

Solar Absorbent	0.360	3.0	0.420	3.5



The recommended emission limits can also be expressed in terms of mass
of VOC per volume of coating solids:  

Table 2:  Recommended Emission Limits (mass of VOC per volume of coating
solids) for Large Appliance Coatings

Coating Type	Baked	Air Dried

	kg/l	lb/gal	kg/l	lb/gal

General, One Component	0.40	3.3	0.40	3.3

General, Multi-Component	0.40	3.3	0.55	4.5

Extreme High Gloss	0.61	5.1	0.55	4.5

Extreme Performance	0.61	5.1	0.80	6.7

Heat Resistant	0.61	5.1	0.80	6.7

Metallic	0.80	6.7	0.80	6.7

Pretreatment Coatings	0.80	6.7	0.80	6.7

Solar Absorbent	0.61	5.1	0.80	6.7



The following types of coatings and coating operations are recommended
to be exempt from the recommended VOC content limits:  stencil coatings,
safety-indicating coatings, solid-film lubricants, electric-insulating
and thermal-conducting coatings, touch-up and repair coatings, and
coating application utilizing hand-held aerosol cans.

It is recommended that all VOC-containing materials used by each large
appliance surface coating unit be included when determining the coating
unit’s emission rate.  Additionally, the following application methods
are recommended:  electrostatic application, high volume/low pressure
(HVLP) spray, flow coat, roller coat, dip coat including
electrodeposition, or brush coat.  

B.  Optional Add-On Controls for Coating Operations:  Should product
performance requirements or other needs dictate the use of higher VOC
materials than those that would meet the recommended emission limits, a
facility could choose to use add-on control equipment to meet an overall
efficiency of 90 percent.  

C.  Work Practices for Coating Operations and Cleaning Materials:  Work
practices to further reduce emissions from the coatings as well as
minimize emissions from cleaning materials used for large appliance
coating operations are recommended, and they are:  store all
VOC-containing coatings, thinners, and cleaning materials in closed
containers; minimize spills of VOC-containing coatings, thinners, and
cleaning materials; clean up spills immediately; convey any coatings,
thinners, and cleaning materials in closed containers or pipes; close
mixing vessels that contain VOC coatings and other materials except when
in use; and minimize usage of solvents during cleaning of storage,
mixing, and conveying of equipment.

Description of Metal Furniture Coatings

The metal furniture coatings product category under section 183(e) of
the CAA includes the coatings that are applied to the surfaces of metal
furniture.  A metal furniture substrate is the furniture or component of
furniture constructed either entirely or partially from metal.  Metal
furniture includes, but is not limited to, the following types of
products:  household, office, institutional, laboratory, hospital,
public building, restaurant, barber and beauty shop, and dental
furniture, as well as components of these products.  Metal furniture
also includes office and store fixtures, partitions, shelving, lockers,
lamps and lighting fixtures, and wastebaskets.  Metal furniture coatings
include paints and adhesives and are typically applied without a primer.
 Higher solids and powder coatings are used extensively in the metal
furniture surface coating industry.  Metal furniture coatings are used
extensively in the metal furniture surface coating industry.  

Metal furniture coatings serve decorative, protective, and functional
purposes.  Coatings protect the metal from corrosion by providing
resistance to moisture, heat, and sometimes the outdoor elements. 
Coatings for each type of metal furniture have special requirements and
contain unique properties because each type will be exposed to somewhat
different corrosive elements.  The coating must also be durable and have
excellent adhesion properties to avoid peeling or chipping.  Finally,
the coatings for many products provide decorative appeal.

The metal furniture manufacturing process can be divided into four main
unit operations:  (1) raw material preparation, (2) surface preparation,
(3) coating and adhesive application operations, and (4) assembly.  In
addition, cleaning activities are performed in support of the surface
coating operation.  The majority of the raw material preparation
operations and assembly operations are mechanical in nature and involve
no VOC emissions.  Surface preparation, coating application operations,
and cleaning activities utilize VOC-containing compounds (i.e. coatings,
thinners, and/or cleaning materials).

VOC emissions from metal furniture surface coating processes result from
the evaporation of the volatile components of the coatings and cleaning
materials.  In most cases, VOC emissions from surface preparation,
storage, handling, and waste/wastewater operations are relatively small.

EPA’s Recommended Control Options for Metal Furniture Coatings

EPA issued a CTG for Metal Furniture Coatings in September 2007
(Publication No. EPA 453/R-07-005).  Recommendations for controlling VOC
emissions from metal furniture coatings are outlined in the CTG.  Three
alternatives are recommended:  (1) emission limits that can be achieved
through the use of low-VOC coatings; (2) equivalent emission limits that
can be achieved through the use of low-VOC coatings or a combination of
coatings and add-on controls; and (3) an overall control efficiency of
90 percent for add-on controls.  The low-VOC coatings recommendation
consists of emission limits in terms of mass of VOC per volume coating,
excluding water and exempt compounds, as applied and the use of
specified application methods.  The equivalent emission limit
recommendation consists of emission limits in terms of mass of VOC per
volume of coating solids, as applied, and the use of specific
application methods.  Additionally, for cleaning materials, work
practices are recommended to reduce VOC emissions.

Specific recommendations for coating operations and cleaning materials
used in metal furniture surface coating operations are summarized below:

Emissions Limits Based on Low-VOC Coatings:  Emission limits for
one-component and multi-component general purpose coatings are
recommended.  In addition, specific emission limits for certain
specialty coatings are recommended.  For each of these coating types,
separate emission limits are recommended for baked and air-dried
coatings.  Provided below are the recommended emission limits expressed
in terms of mass of VOC per volume of coating, excluding water and
exempt compounds:

Table 3:  Recommended Emission Limits (mass of VOC per volume of
coating) for Metal Furniture Coatings

Coating Type	Baked	Air Dried

	kg/l	lb/gal	kg/l	lb/gal

General, One Component	0.275	2.3	0.275	2.3

General, Multi-Component	0.275	2.3	0.340	2.8

Extreme High Gloss	0.360	3.0	0.340	2.8

Extreme Performance	0.360	3.0	0.420	3.5

Heat Resistant	0.360	3.0	0.420	3.5

Metallic	0.420	3.5	0.420	3.5

Pretreatment Coatings	0.420	3.5	0.420	3.5

Solar Absorbent	0.360	3.0	0.420	3.5



The recommended emission limits can also be expressed in terms of mass
of VOC per volume of coating solids, applied.  A facility could use
low-VOC coatings or a combination of coatings and add-on control
equipment on a coating unit to meet the recommended mass of VOC per
volume of coating solids limits.  Using an assumed VOC density of 7.36
pounds per gallon, the equivalent limits in terms of mass of VOC per
volume of solids, as applied, are as follows:  

Table 4:  Recommended Emission Limits (mass of VOC per volume of
coating) for Metal Furniture Coating Solids

Coating Type	Baked	Air Dried

	kg/l	lb/gal	kg/l	lb/gal

General, One Component	0.40	3.3	0.40	3.3

General, Multi-Component	0.40	3.3	0.55	4.5

Extreme High Gloss	0.61	5.1	0.55	4.5

Extreme Performance	0.61	5.1	0.80	6.7

Heat Resistant	0.61	5.1	0.80	6.7

Metallic	0.80	6.7	0.80	6.7

Pretreatment Coatings	0.80	6.7	0.80	6.7

Solar Absorbent	0.61	5.1	0.80	6.7



The following types of coatings and coating operations are recommended
to be exempt from the recommended VOC content limits:  stencil coatings,
safety-indicating coatings, solid-film lubricants, electric-insulating
and thermal-conducting coatings, touch-up and repair coatings, and
coating application utilizing hand-held aerosol cans.

It is recommended that all VOC-containing materials used by each metal
furniture surface coating unit be included when determining the coating
unit’s emission rate.  Additionally, the following application methods
are recommended:  electrostatic application, HVLP spray, flow coat,
roller coat, dip coat including electrodeposition, or brush coat.  

B.  Optional Add-On Controls for Coating Operations:  Should product
performance requirements or other needs dictate the use of higher VOC
materials than those that would meet the recommended emission limits, a
facility could choose to use add-on control equipment to meet an overall
efficiency of 90 percent.  Alternatively, a facility could use a
combination of coatings and add-on control equipment on a coating unit
to meet the recommended mass of VOC per volume of coating solid limits.

C.  Work Practices for Coating Operations and Cleaning Materials:  Work
practices to further reduce emissions from the coatings as well as
minimize emissions from cleaning materials used for large appliance
coating operations are recommended, and they are:  store all
VOC-containing coatings, thinners, and cleaning materials in closed
containers; minimize spills of VOC-containing coatings, thinners, and
cleaning materials; clean up spills immediately; convey any coatings,
thinners, and cleaning materials in closed containers or pipes; close
mixing vessels that contain VOC coatings and other materials except when
in use; and minimize usage of solvents during cleaning of storage,
mixing, and conveying of equipment.

Description of Flat Wood Paneling Coatings

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.

Flat wood paneling, like most wood products, are vulnerable to light,
moisture and insects.  Coatings are used for three 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 VOCs 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 VOCs within the
coating evaporate into the air.

Emissions of VOCs from flat wood coating facilities occur primarily at
the coating line, although some emissions also occur at paint mixing and
storage areas.  To assist facilities and regulatory agencies in
estimating emissions, VOC emission factors for conventional solvent
based coatings applied to interior printed panels are as follows
(expressed as kilograms of VOCs per 100 square meters (m2) coated):  3.0
for filler, 0.5 for sealer, 2.4 for basecoat, 0.3 for inks, and 1.8 for
topcoats.

EPA’s Recommended Control Options for Flat Wood Paneling Coatings

EPA issued a CTG for Flat Wood Paneling Coatings in September 2006
(Publication No. EPA 453/R-06-004).  Recommendations for controlling VOC
emissions from flat wood paneling coatings are outlined in the CTG and
are as follows:

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. 
These limits are expressed in different units but are equivalent.  

A.  Emissions Limits 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 grams (g) VOC/l (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 g of VOC per liter solids (2.9 lb of VOC per gal of
solids).  The default VOC density used for making this conversion was
0.88 kg/l (7.36 lb/gal).

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 above, a facility could choose to use
add-on control equipment to meet an overall control efficiency of 90
percent.  Add-on devices include oxidizers and solvent recovery systems,
which coupled with their attendant systems to capture the VOC being
released at the affected facilities, can achieve an overall control
efficiency of 90 percent.  This control option, like the low VOC
material option noted above, applies to surface coatings, inks, and
adhesives applied to all types of flat wood paneling. 

C.  Work Practices:  Recommended work practices 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 5:  Recommended Emission Limits for Flat Wood Paneling Operations

Surface Coatings, Inks, or Adhesives Applied to the Following Flat Wood
Paneling Categories	Should Meet One of These Emission Limits

	lb VOC/ gal material (g VOC/ liter material) [excluding water and
exempt compounds]	lb VOC/ gal solids (g VOC/ 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%

Tileboards	2.1 (250)	2.9 (350)	90%

Exterior siding	2.1 (250)	2.9 (350)	90%



Description of Paper, Film, and Foil Coatings

The paper, film, and foil product category listed under section 183(e)
of the CAA includes coatings that are applied to paper, film, or foil
surfaces in the manufacturing of several major product types for the
following industry sectors:  pressure sensitive tape and labels;
photographic film; industrial and decorative laminates; abrasive
products; and flexible packaging. The category also includes coatings
applied during miscellaneous coating operations for several products
including:  corrugated and solid fiber boxes; die-cut paper paperboard
and cardboard; converted paper and paperboard not elsewhere classified;
folding paperboard boxes, including sanitary boxes; manifold business
forms and related products; plastic asceptic packaging; and carbon paper
and inked ribbons.

Coating performed on or in-line with any offset lithographic, screen,
letterpress, flexographic, rotogravure, or digital printing press is not
part of the paper, film, and foil coating category.  In addition, size
presses and on-machine coaters that function as part of an in-line
papermaking system are not part of the paper, film, and foil coating
category.  

The paper, film, and foil surface coating process can be described as a
web coating process, which is a process that applies a continuous layer
of coating material across essentially the entire width or any portion
of the width of a web substrate to:  (1) provide a covering, finish,
functional or protective layer to a substrate; (2) saturate a substrate
for lamination; or (3) provide adhesion between two substrates for
lamination.  The web coating operations and emission control techniques
do not vary significantly among the sectors of the paper, film, and foil
surface coating industry.

VOC emissions from paper, film, and foil surface coating operations
primarily result from the evaporation of volatile components of the
coatings and cleaning materials.  The majority of VOC emissions from
these materials occur during coating application/flash-off, coating
curing/drying, and cleaning.  The remaining VOC emissions are from
cleaning operations.

EPA’s Recommended Control Option for Paper, Film, and Foil Coatings

EPA issued a CTG for Paper, Film, and Foil Coatings in September 2007
(Publication No. EPA 453/R-07-003).  The following summarizes
recommendations for controlling VOC emissions from paper, film, and foil
coatings:

A.  Coatings:  To control VOC emissions from coatings used in paper,
film, and foil surface coating, an overall VOC control efficiency of 90%
for each coating line is recommended.  Alternatively, emission limits
that are equivalent to 90 percent overall control is recommended. 
Applying the control recommendations only to individual surface coating
lines with the potential to emit, prior to controls, at least 25 tpy of
VOC from coatings is recommended.  The coating line is defined as a
series of coating applicators, flash-off areas, and any associated
curing/drying equipment between one or more unwind/feed stations and one
or more rewind/cutting stations.  It’s also recommended that paper,
film, and foil surface coating facilities be provided with the option of
using an enforceable limitation on potential emissions to keep an
individual paper, film, and foil surface coating line below the 25 tons
per year (tpy) potential to emit threshold.

An overall VOC control efficiency of 90 percent is recommended as RACT
for each paper, film, and foil surface coating line.  However, as an
alternative to an overall 90 percent control efficiency, VOC
content-based emission limits that are equivalent to 90 percent overall
control are recommended, which can be met by use of low VOC content
materials or combinations of materials and controls.  To determine these
equivalent content-based emission limits for this product category
(except for pressure sensitive tape and label surface coating lines), 20
weight percent solids and 80 weight percent solvent was used.  Using
this baseline coating content, the VOC content-based emission limits
equivalent to 90 percent emission reduction are 0.40 kg VOC/kg (0.40 lb
VOC/lb) solids applied and 0.08 kg VOC/kg (0.08 lb VOC/lb) coating
applied.  

As an alternative to 90 percent emission reduction, a limit of 0.20 kg
VOC/kg (0.20 lb VOC/lb) solids applied is recommended, and an additional
equivalent limit of 0.067 kg VOC/kg (0.067 lb VOC/lb) of coating is RACT
for pressure sensitive tape and label surface coating lines.  

Table 6:  Recommended Emission Limits for Paper, Film, and Foil Coatings

Units	RACT Limits

	Pressure Sensitive Tape and Label Surface Coating	Paper, Film, and Foil
Surface Coating (Not including Pressure Sensitive Tape and Label)

Emission Reduction (%)	90	90

kg VOC/kg solids

(lb VOC/lb solids)	0.20	0.40

kg VOC/kg coating

(lb VOC/lb coating)	0.067	0.08

 

The VOC content limits can be met by averaging the VOC content of
materials used on a single surface coating line each day (i.e. daily
within-line averaging).  

B.  Cleaning Materials:  To control VOC emissions from cleaning
materials used in paper, film, and foil surface coating, it is
recommended that facilities implement work practices to ensure that VOC
emissions are minimized from mixing, storage, and handling of cleaning
materials, and cleaning-related waste materials.  Specifically, the
following is recommended:  (1) store all VOC-containing cleaning
materials in closed containers; (2) ensure that mixing and storage
containers used for VOC-containing materials are kept closed at all
times except when depositing or removing these materials; (3) minimize
spills of VOC-containing cleaning materials; (4) convey VOC-containing
cleaning materials from one location to another in closed containers or
pipes; and (6) minimize VOC emissions from cleaning of storage, mixing,
and conveying equipment.

Additional Revisions

In addition to adopting the CTGs discussed above, definitions arising
from these CTG regulations were added to Article XXI (section 2101.20)
and therefore being added to the Allegheny County portion of the
Pennsylvania SIP.  Also, changes were also made to an existing
regulation (section 2105.10), making any limits pertaining to these CTG
regulations void after January 1, 2011.

B.  STATE SUBMITTAL

On July 23, 2010, Pennsylvania Department of Environmental Protection
(PADEP) submitted to EPA a SIP revision concerning the adoption of the
EPA CTGs for large appliance and metal furniture, flat wood paneling,
and paper, film, and foil surface coating processes in Allegheny County.
 EPA develops CTGs as guidance on control requirements for source
categories.  States can follow the CTGs or adopt more restrictive
standards.  Allegheny County is adopting EPA’s CTG standards for large
appliance and metal furniture, flat wood paneling, and paper, film, and
foil surface coating processes.  These regulations are contained in the
Allegheny County Health Department (ACHD) Rules and Regulations, Article
XXI, Air Pollution Control Sections 2105.77, 2105.78, and 2105.79,
respectively, and County Ordinance 16782.  This SIP revision also
includes revisions to existing regulations for surface coating processes
in Section 2105.10 and related definitions in Section 2101.20.

 

I.  Large Appliance and Metal Furniture Surface Coating Processes

Allegheny County combined the CTGs for large appliance surface coatings
and metal furniture surface coatings into a single rule in Article XXI,
Air Pollution Control Section 2105.77.  The new regulation is summarized
below:

Section 2105.77:  Control of VOC Emissions from Large Appliance and
Metal Furniture Surface Coating Processes

a.  Applicability:  Beginning January 1, 2011, this section applies to
the owner or operator of a large appliance or metal furniture surface
coating process, where the total actual VOC emissions from all large
appliance or metal furniture surface coating operations, including
related cleaning activities, at that facility are equal to or greater
than 15 pounds (6.8 kilograms) per day or 2.7 (2,455 kilograms) per
twelve month rolling period.  The limits from section 2105.10 and Table
section 2105.10 no longer apply to the large appliance and metal
furniture surface coating process as of January 1, 2011.

b.  Limitations:  A person may not cause or permit the emission into the
outdoor atmosphere of VOCs from a large appliance or metal furniture
surface coating process unless one of the following limitations is met:

1.  The VOC content of each applied coating is equal to or less than the
standard specified in Table 2105.77.

2.  The overall weight of VOCs emitted to the atmosphere is reduced
through the use of vapor recovery or incineration or another method
which is acceptable under section 2105.01 (Equivalent Compliance
Techniques).  The overall efficiency of a control system, as determined
by the test methods and procedures specified in Part G, shall be no less
than 90%. 

3.  A combination of the methods listed in paragraphs 1 and 2.

c.  Records:  A facility, regardless of the facility’s annual emission
rate, which contains large appliance or metal furniture surface coating
processes, shall maintain records sufficient to demonstrate compliance
with this section.  The records shall be maintained for 2 years and
shall be submitted to the Department on a schedule reasonably prescribed
by the Department.

d.  Exempt Solvents:  The solvents methyl chloroform
(1,1,1-tricholoethane) and methylene chloride are exempt from control
under this Section.  No large appliance or metal furniture surface
coating process which seeks to comply with this Section through the use
of an exempt solvent may be included in any alternative standard
approved pursuant to this Article. 

e.  Application Techniques:  A person may not cause or permit the
emission into the outdoor atmosphere of VOCs from the application of
large appliance or metal furniture surface coatings unless the coatings
are applied using one or more of the following coating application
methods:

	1.  Electrostatic spraying;

	2.  Roller coating;

	3.  Flow coating;

	4.  Dip coating, including electrodeposition;

	5.  High volume-low pressure (HVLP) spraying;

	6.  Brush coating;

7.  Other coating application method that the person demonstrates and
the Department determines achieves emission reductions equivalent to
HVLP or electrostatic spray application methods.

f.  Emission Limitations:  If more than one emission limitation in Table
2105.77 for large appliances or metal furniture applies to a specific
coating, the least stringent emission limitation applies.

g.  Exempt Other:  The VOC coating content standards in Table 2105.77
for large appliances or metal furniture do not apply to a coating used
exclusively for stencil coatings, safety-indicating coatings, solid-film
lubricants, electric-insulating coatings, thermal-conducting coatings,
touch-up and repair coatings, coating applications using hand-held
aerosol cans, coatings used exclusively for determining product quality
and commercial acceptance, and other small quantity coatings if the
coating meets the following criteria:

1.  The quantity of coating used does not exceed 50 gallons per year for
a single coating and a total of 200 gallons per year for all coatings
combined for the facility.

2.  The owner or operator of the facility requests, in writing, and the
Department approves, in writing, the exemption prior to use of the
coating.

h.  Housekeeping:  The following work practices for coating-related
activities and cleaning materials apply to the owner or operator of a
large appliance or metal furniture surface coating process:

	

Store all VOC-containing coatings, thinners, coating-related waste
materials, cleaning materials and used shop towels in closed containers.

Ensure that mixing and storage containers used for VOC-containing
coatings, thinners, coating-related waste materials and cleaning
materials are kept closed at all times except when depositing or
removing these materials.

Minimize spills of VOC-containing coatings, thinners, coating-related
waste materials and cleaning materials, cleaning up spills immediately.

Convey VOC-containing coatings, thinners, coating-related waste
materials and cleaning materials from one location to another in closed
containers or pipes.

Minimize VOC emissions from cleaning of storage, mixing and conveying
equipment.

Table 2105.77:  Emissions Limits of VOCs for Large Appliance and Metal
Surface Coatings (Weight of VOC per Volume of Coating Solids)

	Baked	Air Dried

Surface Coating Process Category	kg/l	lb/gal	kg/l	lb/gal

1.  Large Appliance coating	0.40	3.3	0.40	3.3

(a) general, one component	0.40	3.3	0.55	4.5

(b) general, multi-component	0.55	4.62	0.55	4.62

(c) extreme high gloss	0.55	4.62	0.55	4.62

(d) extreme performance	0.55	4.62	0.55	4.62

(e) heat resistant	0.55	4.62	0.55	4.62

(f) metallic	0.55	4.62	0.55	4.62

(g) pretreatment coatings	0.55	4.62	0.55	4.62

(h) solar absorbent	0.55	4.62	0.55	4.62

2.  Metal Furniture coating	0.40	3.3	0.40	3.3

(a) general, one component	0.40	3.3	0.55	4.5

(b) general, multi-component	0.61	5.06	0.55	4.5

(c) extreme high gloss	0.61	5.06	0.61	5.06

(d) extreme performance	0.61	5.06	0.61	5.06

(e) heat resistant	0.61	5.06	0.61	5.06

(f) metallic	0.61	5.06	0.61	5.06

(g) pretreatment coatings	0.61	5.06	0.61	5.06

(h) solar absorbent	0.61	5.06	0.61	5.06



II.  Flat Wood Paneling Coating Processes

Section 2105.78 Control of VOC Emissions from Flat Wood Paneling Coating
Processes

a.  Applicability:  Beginning January 1, 2011, this section applies to
the owner or operator of a flat wood paneling coating process, where the
total actual VOC emissions from all flat wood panel surface coating
operations, including related cleaning activities, at the facility are
equal to or greater than 15 pounds (6.8 kilograms) per day or 2.7 tons
(2,455 kilograms) per twelve month rolling period.

b.  Limitations:  A person may  not cause or permit the emission into
the outdoor atmosphere of VOCs from a flat wood paneling coating
process, unless one of the following limitations is met: 

1.  The VOC content of each as applied coating is equal to or less than
2.9 lbs. VOC per gallon of coating solids (0.35 kg VOC per liter of
coating solids).

2.  The overall weight of VOCs emitted to the atmosphere is reduced
through the use of vapor recovery or incineration or another method
which is acceptable under section 2105.01 (Equivalent Compliance
Techniques).  The overall efficiency of a control system, as determined
by the test methods and procedures specified in Part G, shall be no less
than 90%. 

	3.  A combination of the methods listed in paragraphs 1 and 2. 

c.  Records:  A facility, regardless of the facility’s annual emission
rate, which contains flat wood paneling coating processes, shall
maintain records sufficient to demonstrate compliance with this section.
 The records shall be maintained for 2 years and shall be submitted to
the Department on a schedule reasonably prescribed by the Department.

d.  Exempt Solvents:  The solvents methyl chloroform
(1,1,1-tricholoethane) and methylene chloride are exempt from control
under this Section.  No flat wood paneling coating process which seeks
to comply with this Section through the use of an exempt solvent may be
included in any alternative standard approved pursuant to this Article. 

e.  Application Techniques:  A person may not cause or permit the
emission into the outdoor atmosphere of VOCs from the application of
flat wood paneling coatings unless the coatings are applied using one or
more of the following coating application methods:

	1.  Electrostatic spraying;

	2.  Airless coating;

	3.  Curtain coating;

	4.  Roller coating;

	5.  Flow coating;

	6.  Dip coating, including electrodeposition;

	7.  High volume-low pressure (HVLP) spraying;

	8.  Hand brush or roller coat;

9.  Other coating application method that the person demonstrates and
the Department determines achieves emission reductions equivalent to
HVLP or electrostatic spray application methods.

f.  Exempt Other:  The VOC coating content standard of 2.9 lbs. VOC per
gallon of coating solids (0.35 kg VOC per liter of coating solids) do
not apply to a coating used exclusively for stencil coatings, touch-up
and repair coatings, coating applications using hand-held aerosol cans,
air atomized sprays that apply cosmetic specialty coatings, if the
volume of the cosmetic specialty coatings is less than 5% by volume of
the total coating used at the source or to apply final repair coatings,
coatings used exclusively for determining product quality and commercial
acceptance and other small quantity coatings if the coatings meet the
following criteria:

	

1.  The quantity of coating used does not exceed 50 gallons per year for
a single coating and a total of 200 gallons per year for all coatings
combined for the facility.

2.  The owner or operator of the facility requests, in writing, and the
Department                           approves, in writing, the exemption
prior to use of the coating.

g.  Housekeeping:  The following work practices for coating-related
activities and cleaning materials apply to the owner or operator of a
flat wood paneling coating process:

Store all VOC-containing coatings, thinners, coating-related waste
materials, cleaning materials and used shop towels in closed containers.

Ensure that mixing and storage containers used for VOC-containing
coatings, thinners, coating-related waste materials and cleaning
materials are kept closed at all times except when depositing or
removing these materials.

Minimize spills of VOC-containing coatings, thinners, coating-related
waste materials and cleaning materials, cleaning up spills immediately.

Convey VOC-containing coatings, thinners, coating-related waste
materials and cleaning materials from one location to another in closed
containers or pipes.

Minimize VOC emissions from cleaning of storage, mixing and conveying
equipment.

III.  Paper, Film, and Foil Coating Processes

Section 2105.79:  Control of VOC Emissions from Paper, Film, and Foil
Surface Coating Processes

a.  Applicability:  Beginning January 1, 2011, this section applies to
the owner or operator of a paper, film, and foil surface coating
process, where the total actual VOC emissions from all paper, film, and
foil surface coating operations, including related cleaning activities,
at that facility are equal to or greater than 15 pounds (6.8 kilograms)
per day or 2.7 tons (2,455 kilograms) per twelve month rolling period. 
The limits from section 2105.10 and Table section 2105. 10 no longer
apply to the paper, film, and foil surface coating process as of January
1, 2011.

b.  Limitations:  A person may not cause or permit the emission into the
outdoor atmosphere of VOCs from a paper, film, and foil surface coating
process unless one of the following limitations is met:

1.  The VOC content of each as applied coating is equal to or less than
the standard specified in Table 2105.79. 

2.  The overall weight of VOCs emitted to the atmosphere is reduced
through the use of vapor recovery or incineration or another method
which acceptable under section 2105. 01 (Equivalent Compliance
Techniques).  The overall efficiency of a control system, as determined
by the test methods and procedures specified in Part G, shall be no less
than 90%.

3.  A combination of the methods listed in paragraphs 1 and 2. 

c.  Records:  A facility, regardless of the facility’s annual emission
rate, which contains paper, film, and foil surface coating processes,
shall maintain records sufficient to demonstrate compliance with this
section.  The records shall be maintained for 2 years and shall be
submitted to the Department on a schedule reasonably prescribed by the
Department.

d.  Exempt Solvents:  The solvents methyl chloroform
(1,1,1-tricholoethane) and methylene chloride are exempt from control
under this Section.  No flat wood paneling coating process which seeks
to comply with this Section through the use of an exempt solvent may be
included in any alternative standard approved pursuant to this Article. 

e.  Application Techniques:  A person may not cause or permit the
emission into the outdoor atmosphere of VOCs from the application of
paper, film, and foil surface coatings unless the coatings are applied
using one or more of the following coating application methods:

	1.  Rotogravure (web-fed gravure)

	2.  Reverse roll coating

	3.  Slot die coating

	4.  Knife coating

	5.  Flexographic coating

	6.  Mayer rod or wire-wound rod coating

	7.  Dip and squeeze coating

	8.  Extrusion coating, including calendaring

f.  Emission Limitations:  If more than one emission limitation in Table
2105.79 for paper, film, and foil surface coating applies to a specific
coating, the least stringent emission limitation applies.

g.  Exempt Other:  The VOC coating content standards in Table 2105.79
for paper, film, and foil surface coatings do not apply to a coating
used exclusively for stencil coatings, touch-up and repair coatings,
coating applications using hand-held aerosol cans, coatings used
exclusively for determining product quality and commercial acceptance
and other small quantity coatings if the coating meets the following
criteria:

1.  The quantity of coating used does not exceed 50 gallons per year for
a single coating and a total of 200 gallons per year for all coatings
combined for the facility.

2.  The owner or operator of the facility requests, in writing, and the
Department approves, in writing, the exemption prior to use of the
coating.

h.  Housekeeping:  The following work practices for coating-related
activities and cleaning materials apply to the owner or operator of a
flat wood paneling coating process:

Store all VOC-containing coatings, thinners, coating-related waste
materials, cleaning materials and used shop towels in closed containers.

Ensure that mixing and storage containers used for VOC-containing
coatings, thinners, coating-related waste materials and cleaning
materials are kept closed at all times except when depositing or
removing these materials.

Minimize spills of VOC-containing coatings, thinners, coating-related
waste materials and cleaning materials, cleaning up spills immediately.

Convey VOC-containing coatings, thinners, coating-related waste
materials and cleaning materials from one location to another in closed
containers or pipes.

Minimize VOC emissions from cleaning of storage, mixing and conveying
equipment.

Table 2105.79:  Emissions Limits of VOCs for Paper, Film, and Foil
Surface Coatings (Weight of VOC per Weight of Solids or Coating Applied)

Surface Coating Process Catergory	Solids Applied

kg VOC/kg solids	Coating Applied

kg VOC/kg coatings

Pressure Sensitive Tape and Label	0.20	0.067

Paper, Film, and Foil (Not including pressure sensitive tape and labels)
0.40	0.08



IV.  Additional Revisions

In addition to adopting the CTGs discussed above, definitions arising
from these CTG regulations were added to Article XXI (section 2101.20)
and are being added to the Allegheny County portion of the Pennsylvania
SIP.  They are as follows:

Section 2101.20:  Definitions:

“Exterior panels” means panels made of solid wood, hardboard or
waferboard.  Paneling made of solid wood or hardboard is typically
primed at the manufacturing facility and finished in the field, although
some finishing may be performed during manufacturing.  (effective
January 1, 2011)

“Interior panels” means interior wall paneling that is usually
grooved, frequently embossed and sometimes grain printed to resemble
various wood species.  Interior panels are typically manufactured at the
same facilities as tileboard, although in much smaller quantities.  The
substrate can be hardboard, plywood, medium density fiberboard (MDF) or
particleboard.  (effective January 1, 2011)

“Flat wood panel coating” means protective, decorative or functional
materials applied to flat wood panel products, including interior
panels, exterior panels or tileboard (Class I hardboard).  (effective
January 1, 2011)

“Tileboard” means a premium interior wall paneling product made of
hardboard that is used in high moisture areas of the home including
kitchens and bathrooms.  Tileboard meets the specifications for Class I
hardboard approved by the American National Standards Institute. 
(effective January 1, 2011).

Changes were also made to an existing regulation, Section 2105.10,
Surface Coating Processes, making any limits pertaining to these CTG
regulations void after January 1, 2011.  The specific language added is
as follows:

The limits from section 2105.10 and Table section 2105.10, number 7 for
metal furniture coating and number 9 for large appliance coating, no
longer apply to the large appliance and metal furniture surface coating
process as of January 1, 2011.  

The limits from section 2105.10 and Table section 2105.10, number 5 for
Paper coating, no longer apply to the paper, film, and foil surface
coating process as of January 1, 2011.

C.  EPA EVALUATION

Allegheny County has adopted the standards and requirements of the CTGs
for large appliance and metal furniture, flat wood paneling, and paper,
film, and foil surface coating processes and is amending the
Pennsylvania SIP to reflect these amendments.  The maximum benefit from
these amendments will be provided during the ozone season when VOCs
readily combine with NOx to form ground-level ozone.  Therefore, this
revision will help Pennsylvania attain and maintain the NAAQS for ozone.
 

D.  CONCLUSIONS AND RECOMMENDED AGENCY ACTION

The adoption of the EPA CTG requirements for large appliance and metal
furniture, flat wood paneling, and paper, film, and foil surface coating
processes by the State of Pennsylvania will result in the reduction of
VOC emissions from large appliance and metal furniture, flat wood
paneling, and paper, film, and foil surface coating processes.  EPA
approval of the SIP revision is recommended.

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