UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

1650 Arch Street

Philadelphia, Pennsylvania  19103

DATE:	July 19, 2011

SUBJECT:	Technical Support Document for Maryland’s Adoption of Drum
and Pail Coating Standards 

			/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 drum and pail surface coating
operations.  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 miscellaneous metal
product and plastic parts surface coating.

In June 1978, EPA published a CTG for controlling VOC emissions from
surface coating of miscellaneous metal and plastic products
(EPA-450/2-78-015).  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 miscellaneous metal parts and products
surface coating (40 CFR part 63, subpart MMMM).

In 2008, 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 miscellaneous metal and plastic parts
products, entitled Control Techniques Guidelines for Miscellaneous Metal
and Plastic Parts Coatings (Publication No. EPA 453/R-08-003).

Description of Miscellaneous Metal and Plastic Parts Coatings

The miscellaneous metal product and plastic parts surface coatings
categories under section 183(e) of the CAA includes the coatings that
are applied to the surfaces of a varied range of metal and plastic parts
and products.  Such parts or products are constructed either entirely or
partially from metal or plastic.  The CTG applied to manufacturers of
miscellaneous metal and plastic parts that surface-coat the parts they
produce.  The CTG also applies to facilities that perform surface
coating of miscellaneous metal and plastic parts on a contract basis. 

Miscellaneous metal product and plastic parts surface coatings serve
decorative, protective, and functional purposes.  Coatings protect metal
parts from corrosion by providing resistance to moisture, heat, and
sometimes the outdoor elements.  Plastic parts may be coated to provide
color, texture, or protection, thus improving appearance and durability,
and can also function to attenuate electromagnetic interference/radio
frequency interference signals, and to conceal mold lines and flaws in
substrate surface.

The miscellaneous metal product and plastic parts surface coating
process may be divided into three main unit operations:  (1) surface
preparation, (2) coating application operations, and (3) cleaning
activities.  These three types of activities utilize VOC-containing
compounds (i.e., coatings, thinners, and/or cleaning materials).  The
CTG provides control recommendations for reducing VOC emissions from the
use of these activities.  

The VOC emissions from miscellaneous metal product and plastic parts
surface coating processes result from the evaporation of the volatile
components of the coatings and cleaning materials used in these
operations.  In most cases, VOC emissions from surface preparation,
storage, handling, and waste/wastewater operations are relatively small.
 

EPA’s Recommended Control Options for Miscellaneous Metal and Plastic
Parts Coatings

EPA issued a CTG for miscellaneous metal and plastic parts coatings in
September 2008 (Publication No. EPA 453/R-08-003).  EPA recommends that
the control approaches outlined below apply to each miscellaneous metal
product and plastic parts surface coating unit at a facility where the
total actual VOC emissions from all miscellaneous metal product and
plastic parts surface coating operations, including related cleaning
activities, at that facility are equal to or exceed 6.8 kilograms
(kg)/day (15 pounds (lbs)/day), or an equivalent level of 2.7 tons per
12-month rolling period, before consideration of controls.  

The Control Techniques Guidelines for Miscellaneous Metal and Plastic
Parts Coatings document recommends emission limits for various metal and
plastic coatings and those emission limits that apply to this particular
SIP revision are shown in Table 1.

Table 1.  VOC Content Limits

	Air Dried	Baked

Coating Category	kg VOC/liter coating	lbs VOC/gallon coating	kg
VOC/liter coating	lbs VOC/gallon coating

Drum Coating, New, Exterior	0.34	2.8	0.34	2.8

Drum Coating, New, Interior	0.42	3.5	0.42	3.5

Drum Coating, Reconditioned, Exterior	0.42	3.5	0.42	3.5

Drum Coating, Reconditioned, Interior	0.50	4.2	0.50	4.2



B.  STATE SUBMITTAL

On June 22, 2011, Maryland Department of the Environment (MDE) submitted
to EPA a SIP revision concerning the adoption of the emission limits for
drum and pail coatings, part of the EPA miscellaneous metal and plastic
parts coatings CTG.  EPA develops CTGs as guidance on control
requirements for source categories.  States can follow the CTGs or adopt
more restrictive standards.  The State of Maryland has adopted EPA’s
CTG standards for drum and pail coating processes and this regulation is
found in COMAR 26.11.19, Volatile Organic Compounds from Specific
Processes.  This revision amends the existing regulation by making it
specific to drum and pail coating processes only.  Specifically, this
revision amends the existing regulation at section 26.11.19.13 by
removing several definitions and adding several new definitions,
amending the applicability and exemptions, amending the emission
standards, and adding application methods.  Work practice procedures for
coating can be found in COMAR 26.11.19.02.  Specifically, requirements
for cleaning activities can be found in COMAR 26.11.19.02(I) and these
have previously been approved into Maryland’s SIP.

The following changes are being made to COMAR 26.11.19.13, Volatile
Organic Compounds from Specific Processes:

The title of Section 26.11.19.13 is being changed from “Miscellaneous
Metal Coating” to “Drum and Pail Coating.”  The following terms
are being removed from Section 26.11.19.13(A), Definitions:  clear
coating, high performance coating, and standard coating.  Definitions
for the following terms are added to Section 26.11.19.13(A):  drum,
pail, and reconditioned drums or pails.  

Section 26.11.19.13(B), Applicability and Exemptions, is being amended
to apply to any drum or pail coating operations at a premises where the
total VOC emissions exceed 15 pounds (6.8 kilograms) per day.  It does
not apply to coatings applied using a hand-held, pressurized,
non-refillable container which expels coatings from the container in a
finely divided spray when a valve on the container is depressed (a) To
recoat portions of a previously coated product which has sustained
mechanical damage to the coating following normal painting operation, or
(b) To cover minor coating imperfections appearing after the main
coating operation.

Section 26.11.19.13(C), Emission Standards, is amended to explain that
any person subject to Regulation 26.11.19.13 may not exceed the
applicable VOC emission standards in Table 2.

Table 2.  Drum and Pail Coating Standards

Coating Types	lbs VOC/gallon coating (minus water)	kg VOC/liter coating
(minus water)

New, Exterior	2.8	0.34

New, Interior	3.5	0.42

Reconditioned, Exterior	3.5	0.42

Reconditioned, Interior	4.2	0.50



Section 26.11.19.13(D), Application Methods, is added to the regulation.
 This section lists the application methods subject to this regulation. 
They are:  electrostatic application, high volume low pressure (HVLP)
spray, flow coat, roller coat, dip coat including electrodeposition,
brush coat, or a coating application method capable of achieving a
transfer efficiency equivalent to or better than the efficiency achieved
by HVLP spraying.  The above application requirements do not apply to
the following drum or pail coating operations:  (a) Coating applied in
order to recoat portions of a previously coated product which has
sustained mechanical damage to the coating following normal painting
operation, or (b) Coatings applied in order to cover minor coating
imperfections appearing after the main coating operation.

C.  EPA EVALUATION

MDE has adopted the standards and requirements of the CTG for drum and
pail coating applications and is amending the Maryland 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, emissions of
VOCs from drum and pail coatings are expected to be reduced by 35
percent nationally from facilities above the recommended 6.8 kg/day
threshold, which include those in Maryland, as a result of this
rulemaking. Therefore, this revision will help Maryland 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 drum and pail coating
standards by the State of Maryland will result in the reduction of VOC
emissions from drum and pail coatings.  EPA’s approval of the SIP
revision is recommended.

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