UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

1650 Arch Street

Philadelphia, Pennsylvania  19103

DATE:	February 15, 2011

SUBJECT:	Technical Support Document for Pennsylvania’s Adoption of
Control Techniques Guidelines for Flat Wood Paneling Surface Coating
Processes 

			/s/

FROM:	Irene Shandruk, Physical Scientist 

Office of Air Program Planning 

TO:	File

			/s/	

THRU: 	Cristina Fernandez, 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 flat wood paneling surface coating
processes.  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 flat wood paneling
surface coating processes.

In June 1978, EPA published a CTG for flat wood paneling coatings
(EPA-450/2-78-034).  This CTG discusses the nature of VOC emissions from
this industry, available control technologies for addressing such
emissions, the costs of available control options, and other items.  EPA
also published a national emission standard for hazardous air pollutants
(NESHAP) for 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 this industry, reviewing
the 1978 CTG and the NESHAP for this industry, and taking into account
the information that has become available since then, EPA developed a
new CTG for surface coating of flat wood paneling, entitled Control
Techniques Guidelines for Flat Wood Paneling Coatings (Publication No.
EPA 453/R-06-004).

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 1:  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%



B.  STATE SUBMITTAL

On January 4, 2011, Pennsylvania Department of Environmental Protection
(PADEP) submitted to EPA a SIP revision concerning the adoption of the
EPA flat wood paneling surface coating processes CTG.  EPA develops CTGs
as guidance on control requirements for source categories.  States can
follow the CTGs or adopt more restrictive standards.  The Commonwealth
of Pennsylvania has adopted EPA’s CTG standards for flat wood paneling
surface coating processes.  These regulations are in 25 Pa. Code Chapter
121— General Provisions and in Chapter 129— Standards for Sources. 
Specifically, this revision amends the existing regulations at §§
121.1, 129.51 and 129.66, and adds new § 129.52c.  Section 129.52c,
which covers control of VOC emissions from flat wood paneling surface
coating processes, supersedes the requirements of a RACT permit issued
to the owner or operator of a source subject to § 129.52(c)(a) prior to
January 1, 2012 under §§ 129.91 – 129.95 to control, reduce, or
minimize VOC emissions from a flat wood paneling surface coating
process, except to the extent the RACT permit contains more stringent
requirements.

Chapter 121:  General Provisions

Section 121.1:  Definitions

Definitions for the following terms are added to support the addition of
§ 129.52c:  “Class II hardboard paneling finish,” “decorative
interior panel,” “engineered wood panel product,” “exterior
siding,” “exterior trim,” “flat wood paneling coating,”
“flat wood paneling product,” “hardboard,” “hardwood
plywood,” “MDF—medium density fiberboard,” “natural-finish
hardwood plywood panel,” “particleboard,” “premium interior wall
paneling product,” “plywood,” “printed interior panel,”
“thin particleboard,” “tileboard” and “waferboard.”

Chapter 129: Standards for Sources – Sources of VOCs

Section 129.51:  General

Section 129.51(a) is amended to extend its coverage to flat wood
paneling surface coating processes.  Section 129.51(a) also provides an
alternative method for owners and operators of facilities to achieve
compliance with air emission limits.

Section 129.52c:  Control of VOC emissions from flat wood paneling
surface coating processes

This section includes VOC emission limits, work practices, and
recordkeeping and reporting requirements, all of which are consistent
with EPA’s CTG for flat wood paneling surface coating processes.  The
requirements in section 129.52c supersede the requirements in 129.52
relating to control of VOC emissions from flat wood paneling surface
coating processes beginning January 1, 2012.  

Subsection (a) establishes applicability for the emission limits.  The
emission limits apply to the owner or operator of a flat wood paneling
surface coating process if the total actual VOC emissions from all flat
wood paneling surface coating operations at the facility are equal to or
greater than 15 pounds (6.8 kilograms) per day, before consideration of
controls.  

Subsection (b) explains that the requirements of section 129.52c
supersede the requirements of a RACT permit from a flat wood paneling
surface coating operation already issued to the owner or operator
subject to section129.52c unless the RACT permit contains more stringent
requirements.

Subsection (c) establishes VOC emission limits which take effect
beginning January 1, 2012.  The emission limits are shown in Table 2.

Table 2:  Emission Limits of VOCs for Flat Wood Paneling Surface
Coatings

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

	lb VOC/ gal coating solids	 g VOC/ liter coating solids

Printed interior panels made of hardwood, plywood, or thin particleboard
2.9	350

Natural finish hardwood plywood panels	2.9	350

Class II finishes on hardboard panels	2.9	350

Tileboards	2.9	350

Exterior siding	2.9	350



Subsection (d) establishes compliance monitoring procedures and
identifies daily records that must be kept in order to demonstrate
compliance. 

Subsection (e) establishes recordkeeping and reporting requirements.

Subsection (f) explains that VOCs may not be emitted into the atmosphere
from the application of flat wood paneling surface coatings, unless the
coatings are applied using one or more of the following coating
application methods:

Offset rotogravure coating

Curtain coating

Direct roll coating

Reverse roll coating

Hand brush or hand roller coating

High volume—low pressure (HVLP) spray coating

Airless spray coating

Air-assisted airless spray coating

Electrostatic coating

Subsection (g) exempts coatings which are used exclusively for
determining product quality and commercial acceptance if 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 and if the owner or operator of the facility requests this
exemption in writing and PADEP approves, in writing, the exemption prior
to use of the coating.

Subsection (h) establishes work practice requirements for
coating-related activities.

Subsection (i) establishes work practice requirements for cleaning
materials.

Section 129.66:  Compliance schedules and final compliance dates

This section is amended by establishing a 1-year compliance date for
owners or operators of a source newly subject to section 129.52, the
existing surface coatings regulation, as a result of revised
applicability requirements.  The amendment is intended to ensure that
this flexibility is extended to owners and operators of sources newly
subject to the expanding collection of surface coating regulations
resulting from this CTG rulemaking, as well as three other CTG
rulemakings, namely the large appliance, metal furniture, and paper,
film and foil surface coating processes.  The amendment will allow
compliance for sources newly subject to the requirements within 1 year
or by the compliance date specified in the new regulation, whichever is
later.

C.  EPA EVALUATION

PADEP has adopted the standards and requirements of the CTG for flat
wood paneling 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 nitrogen oxides (NOx) to form ground-level ozone. 
Specifically, a maximum range of about 5 to 21 tons of additional annual
VOC emission reductions are anticipated from the flat wood paneling
surface coatings facilities in Pennsylvania as a result of this
rulemaking.  Therefore, this revision will help Pennsylvania attain and
maintain the National Ambient Air Quality Standards (NAAQS) for ozone.  

D.  CONCLUSIONS AND RECOMMENDED AGENCY ACTION

The adoption of the EPA CTG requirements for flat wood paneling surface
coating processes by the Commonwealth of Pennsylvania will result in the
reduction of VOC emissions from flat wood paneling surface coating
processes.  EPA’s approval of the SIP revision is recommended.

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