UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

	1650 Arch Street

	Philadelphia, Pennsylvania  19103

DATE:	June 23, 2015

SUBJECT:	Technical Support Document for Maryland’s Adoption of Control
Techniques Guidelines (CTG) for Metal Furniture and Miscellaneous Metal
Parts Coatings

FROM:	Ellen Schmitt

Office of Air Program Planning

TO:	File	

				

THRU: 	Cristina Fernandez, Associate Director  /s/

		Office of Air Program Planning

A.  BACKGROUND  

Section 172(c)(1) of the Clean Air Act (CAA) provides that State
Implementation Plans (SIP) 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 SIP to include RACT for sources of volatile organic
compound (VOC) emissions covered by a control techniques guideline (CTG)
document issued after November 15, 1990 and prior to the Area’s date
of attainment.  The 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 documents issued by EPA that provide state and local air
pollution control authorities information that should assist them in
determining RACT for VOC from various sources.  EPA may issue a CTG in
lieu of a national regulation as RACT for a product category where EPA
determines that the CTG will be substantially as effective as
regulations in reducing emissions of VOC in ozone nonattainment areas. 
The recommendations in the CTG are based upon available data and
information and may not apply to a particular situation based upon the
circumstances.  States can follow the CTG and adopt state regulations to
implement the recommendations contained therein, or they can adopt
alternative approaches.  In either case, states must submit their RACT
rules to EPA for review and approval as part of the SIP process.  

EPA will evaluate the rules and determine, through notice and comment
rulemaking in the SIP approval process, whether the submitted rules meet
the RACT requirements of the CAA and EPA’s regulations. 

Metal Furniture Coating CTG (EPA 453/R-07-005, September 2007)

In December 1977, EPA issued a CTG document for controlling VOC
emissions from the coating of metal furniture.  In October 1982, EPA
promulgated the new source performance standards (NSPS) for the Surface
Coating of Metal Furniture, and in May 2003, EPA promulgated the
National Emission Standards for Hazardous Air Pollutants (NESHAP) for
the Surface Coating of Metal Furniture.  After reviewing the 1977 CTG,
the 1982 NSPS, and the 2003 NESHAP, and existing state and local VOC
emission reduction approaches, EPA developed a CTG entitled, “Control
Technique Guidelines for Metal Furniture Coatings” (EPA 453/R-07-005).

Coatings used in metal furniture coating operations include paints,
sealants, caulks, ink, adhesives, and maskants.  It is recommended that
the control approaches discussed herein apply to each metal furniture
coating unit at a facility where the total actual VOC emissions from all
metal furniture coating operations, including related cleaning
activities, at that facility, are equal to or exceed 6.8 kg/day (15
lb/day), or an equivalent level such as 3 tons per 12-month rolling
period, before consideration of controls.  These control approaches are
not recommended for facilities that emit below this level.  

The metal furniture coatings product category under section 183(e) of
the CAA includes the coatings that are applied to metal furniture.  A
metal furniture substrate is the furniture or components 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 coating
industry.  Metal furniture coatings provide a covering, finish, or
functional or protective layer, and can also provide a decorative finish
to metal furniture.  

Applicability

The September 2007 CTG for Metal Furniture coatings provides
recommendations for reducing VOC emissions from the use of coatings
applied to each metal furniture coating unit at a facility where the
total actual VOC emissions from all metal furniture coating operations,
including related cleaning activities, at that facility, are equal to or
exceed 6.8 kg/day (15 lb/day), or an equivalent level such as 3 tons per
12-month rolling period, before consideration of controls.  As mentioned
previously, states can adopt the above recommended 6.8 kg/day (15
lb/day) actual VOC emissions or an equivalent applicability threshold,
or they can develop other applicability criteria that they determine are
appropriate considering the facts and circumstances of the sources in
their particular nonattainment areas.  

Sources of VOC Emissions

Primarily, emissions from metal furniture coating operations result from
the evaporation of the VOC components of the coatings and cleaning
materials.  In most cases, VOC emissions from the surface preparation,
storage, handling, and waste/wastewater operations are relatively small.
 The primary VOC emissions from metal furniture coatings occur during
coating application/flash-off and drying/curing of the coatings.  The
remaining emissions are primarily from mixing and/or thinning.  The VOC
emissions from mixing and thinning of coatings occur from the
displacement of VOC-laden air in containers used to mix coatings
containing solvents (thinners) prior to coating application.  The
displacement of VOC-laden air can also occur during filling of
containers and can be caused by changes in temperature, changes in
barometric pressure, or agitation during mixing.

Coating Application

Surface coating of metal furniture is applied by applying a coating to
the metal furniture component or product.  After being coated by any of
the typical coating methods (e.g., spray coating or dip coating), the
metal furniture components or products are dried/cured.  Prior to
entering the ovens, solvents in the coatings evaporate slowly in the
flash-off area to prevent bubble formation during curing.  The coating
itself may be in the form of a liquid or powder, and may be applied by
spraying or dipping.  The amount of VOC emissions from the flash-off
area depends on the type of coating used, how quickly the component or
product moves through the flash-off area, and the distance between the
application area and the bake oven.  For liquid spray applications, it
is estimated that 65-80 percent of the volatiles are emitted during the
application and flash-off operations, and the remaining 20-35 percent
from the drying/curing operation.

For powder coatings, the curing/drying step melts the powder and forms a
continuous coating on the metal furniture component or product.  For
liquid coatings, this step removes any remaining volatiles from the
coating.  The cured coatings provide the desired decorative and/or
protective characteristics.  The VOC emissions during the curing/drying
process result from the evaporation of the remaining solvents in the
dryer.

There are several different types of applicators that may be used to
apply coatings.  The most common types of coating applicators include: 
Air atomized spray coating, electrostatic spray coating, high volume/low
pressure (HVLP) spray coating, dip coating, flow coating, roll coating,
electrocoating, and autophoretic coating.

CTG Recommended Control Options

As stated previously, there are two main sources of VOC emissions from
metal furniture coating operations:  (1) evaporation of VOC from the
coatings; and (2) evaporation of VOC from the cleaning materials.  To
control VOC emissions from metal furniture coatings, the CTG recommends
three options:  (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 (Option 1)
consists of emission limits in terms of mass of VOC per volume of
coating, excluding water and exempt compounds, as applied, and the use
of specified application methods.  The equivalent emission limit
recommendation (Option 2) 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 coating operations are summarized below.

Emissions Limits Based on Low-VOC Coatings-Option

The CTG recommends emission limits for one-component and multi-component
general purpose coatings.  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.  Table 1 provides the recommended emission limits expressed in
terms of mass of VOC per volume of coating (excluding water and exempt
compounds, as applied) for option 1, content limits based on low-VOC
coatings.

Table 1.  Metal Furniture Coating VOC Content Limits – VOC Content
Limits are Expressed as Mass (Kilogram (kg) or Pound (lb)) Per Volume
(Liter (l) for Gallon (gal)) of Coating Less Water and Exempt Compounds,
as Applied

Coatings Type	Baked	Air Dried

	kg VOC/l coating	lb VOC/gal coating	kg VOC/l coating	lb VOC/gal coating

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 following types of coatings and coating operations are 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
applications utilizing hand-held aerosol cans.

The CTG recommends that all VOC-containing materials used by each metal
furniture 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.

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.

Miscellaneous Metal and Plastic Parts Coatings CTG (EPA 453/R-08-003,
September 2008)

In June 1978, EPA issued a CTG document for controlling VOC emissions
from the coating of miscellaneous metal parts and products.  In January
1988, EPA promulgated the NSPS for the Surface Coating of Plastic Parts
for Business Machines.  In February 1994, EPA issued an Alternative
Control Techniques (ACT) document for controlling VOC emissions from the
coating of automotive/transportation and business machine plastic parts.
 In January 2004, EPA promulgated the NESHAP for Miscellaneous Metal
Parts and Products Surface Coating.  In April 2004, EPA promulgated the
NESHAP for Plastic Parts and Products Surface Coating.  After reviewing
the 1978 CTG, the 1988 NSPS, the 1994 ACT, and existing state and local
VOC emission reduction approaches, EPA developed a new CTG combining the
requirements for miscellaneous metal and plastic parts coatings into a
single CTG,  entitled “Control Techniques Guidelines for Miscellaneous
Metal and Plastic Parts Coatings” (EPA 453/R-08-003, September 2008).

Miscellaneous metal products parts coatings include, but are not limited
to, the coatings that are applied to the surfaces of a varied range of
metal parts.  These parts or products are constructed either entirely or
partially from metal.  They include, but are not limited to, metal
components of the following types of products as well as the products
themselves:  Fabricated metal products, small and large farm machinery,
commercial and industrial machinery and equipment, automotive or
transportation equipment, interior or exterior automotive parts,
construction equipment, motor vehicle accessories, bicycles and sporting
goods, toys, recreational vehicles, pleasure craft (recreational boats),
extruded aluminum structural components, railroad cars, heavier
vehicles, lawn and garden equipment, business machines, laboratory and
medical equipment, electronic equipment, steel drums, metal pipes, and
numerous other industrial and household products (hereinafter
collectively referred to as “miscellaneous metal parts”).  The CTG
applies to manufacturers of miscellaneous metal parts that surface-coat
the parts they produce.  Miscellaneous metal parts coatings do not
include coatings that are a part of other product categories listed
under section 183(e) of the CAA for which CTGs have been published
and/or coatings addressed by other CTGs.  These other categories that
are not part of the miscellaneous metal products coatings categories
include shipbuilding and repair coatings; aerospace coatings; wood
furniture coatings; metal furniture coatings; large appliance coatings;
automobile and light-duty truck assembly coatings; flatwood paneling
coatings; miscellaneous industrial adhesives; fiberglass boat
manufacturing materials; and paper, film, and foil coatings.  Can
coatings, coil coatings, and magnet wire coatings were not listed under
section 183(e) of the Act, but were addressed by earlier CTGs, and are
also not included in the miscellaneous metal parts coatings categories
addressed by this CTG.

Applicability

The September 2008 CTG for Miscellaneous Metal and Plastic Parts
Coatings provides recommendations for reducing VOC emissions from the
use of coatings in a miscellaneous metal products coating unit at a
facility where the total actual VOC emissions from all miscellaneous
metal parts coating operations, including related cleaning activities,
at that facility, are equal to or exceed 6.8 kg/day, 15 lb/day, or an
equivalent level of 2.7 tons per 12-month rolling period, before
consideration of controls.  A coating unit consists of a series of one
or more coating applicators and any associated drying area and/or oven
where a coating is applied, dried, and/or cured.  A coating unit ends at
the point where the coating is dried or cured, or prior to any
subsequent application of a different coating.  As mentioned previously,
states can adopt the above recommended 6.8 kg/day (15 lb/day) actual VOC
emissions, or an equivalent applicability threshold, or they can develop
other applicability criteria that they determine are appropriate
considering the facts and circumstances of the sources in their
particular nonattainment areas.  EPA will review the state RACT rules in
the context of the SIP revision process.  For facilities that coat
bodies and/or body parts for new heavier vehicles, EPA recommends that
these facilities have the option of meeting either the state RACT
requirements for miscellaneous metals parts coatings or the state RACT
requirements for auto and light-duty truck coatings.

Sources of VOC Emissions

Primarily, VOC emissions from miscellaneous metal products parts coating
operations result from the evaporation of volatile components from the
coatings and cleaning materials. The majority of VOC emissions from
these materials occur during coating application/flash-off and
drying/curing of the coatings.  The remaining emissions are primarily
from mixing and/or thinning.  In most cases, VOC emissions from surface
preparation, storage, handling, and waste/wastewater operations are
relatively small.

Coating Application    

Surface coating of miscellaneous metal products parts surfaces is
applied by applying a coating to the metal followed by curing or drying
the coating.  The coating itself may be in the form of a liquid or
powder.  Several different types of application technologies are used to
apply liquid coatings, and the selection of the application technology
can have a significant effect on the amount of coating used and the
resulting VOC emissions from the operation.  The most common types of
liquid coating applicators include:  Air atomized spray coating,
electrostatic spray coating, HVLP spray coating, dip coating, flow
coating, roll coating, electrocoating, and autophoretic coating.  Powder
coatings can be applied through electrostatic spraying or dipping.  An
alternative to the coating techniques outlined in EPA’s CTG for this
source category would need to be approved by the State and EPA.

CTG Recommended Control Options

As stated previously, there are two main sources of VOC emissions from
miscellaneous metal parts coating operations:  (1) evaporation of the
VOC components of the coatings; and (2) evaporation of VOC from the
cleaning materials.  To control VOC emissions from miscellaneous metal
parts coatings, the CTG recommends these three options:  (1) VOC content
limits for each coating category based on the use of low-VOC content
coatings and specified application methods to achieve good transfer
efficiency; (2) equivalent VOC emission rate limits based on the use of
a combination of low-VOC coatings, specified application methods, and
add-on controls; or (3) an overall VOC control efficiency of 90 percent
for facilities that choose to add-on controls instead of low-VOC content
coatings and specified application methods.  The low-VOC coatings
recommendation (Option 1) consists of VOC content limits in terms of
mass of VOC per volume of coating, as applied, excluding water and
exempt compounds, and the use of specified application methods.  The
equivalent emission rate limit recommendation (Option 2) consists of
emission rate limits in terms of mass of VOC emitted per volume of
coating solids, as applied, and the use of specific application methods.
 This option is intended only for facilities using a combination of
low-VOC coatings, specific application methods, and add-on control
equipment on a coating unit to meet the recommended limits for mass of
VOC emitted per volume of coating solids.  

In addition, it is recommended that one or more of the following coating
application methods be used in conjunction with the use of low-VOC
content coatings in Options 1 and 2:  Electrostatic application, HVLP
spray, flow coat, roller coat, dip coat (including electrodeposition),
airless spray, air-assisted airless spray, or other coating application
methods capable of achieving a transfer efficiency equivalent to or
better than that achieved by HVLP spraying.  Under an add-on control
option, (Option 3), a facility would use an emission capture system and
add-on control device to achieve an overall emission capture and control
efficiency of at least 90 percent.  The facility would not have to limit
the VOC content of the coating materials and would not need to use any
particular coating application method.   

The first two options are expected to achieve equivalent VOC emission
reductions.  The third option provides facilities the flexibility to use
a high efficiency add-on control in lieu of low-VOC coatings and
specified application methods, especially when the use of high VOC
coatings is necessary or desirable.  The third option is expected to
achieve an emission reduction at least as great as the first two
options.

Additionally, work practices to further reduce VOC emissions from
coatings as well as to minimize emissions from cleaning materials used
in the coating process are recommended.

Consistent with the state rules which are the basis for the recommended
VOC limits, the CTG recommends VOC limits and application methods not
apply to certain types of coatings and coating operations.  For all
coating operations, it is recommended that the VOC limits and
application methods not apply to aerosol coatings products or powder
coatings.  Aerosol coatings are a separate category under Section 183(e)
of the CAA, and powder coatings are an inherently low-VOC alternative to
many liquid coatings.

The CTG recommends that for all metal parts coatings, only the
recommended work practices, but not the recommended VOC limits and
application methods, apply to the following types of coatings and
coating operations:  Stencil coatings, safety indicating coatings,
solid-film lubricants, electric-insulating and thermal-conducting
coatings, magnetic data storage disk coatings, and plastic extruded onto
metal parts to form a coating.  In addition, for all metal parts
coatings, it is recommended that the recommended application methods not
apply to touch-up coatings, repair coatings, and textured finishes, but
that the recommended VOC limits and work practices apply.

For cleaning materials, the CTG recommends that work practices be used
with all three of the control options to reduce VOC emissions.  The
application of add-on controls in conjunction with these work practices
is not recommended.  In addition, the use of a VOC content or VOC
composite vapor pressure limit for cleaning materials is not
recommended.

Under option 1, VOC content limits based on low-VOC coatings, separate
sets of emission limits for metal parts coatings, plastic parts
coatings, automotive/transportation and business machine plastic parts,
and pleasure craft coatings are recommended.  Separate emission limits
for baked and air-dried coatings is recommended.  Table 2 provides the
recommended emission limits expressed in terms of mass of VOC per volume
of coating (excluding water and exempt compounds, as applied) for option
1.

Table 2.  Metal Parts and Products VOC Content Limits – VOC Content
Limits are Expressed as Mass (Kilogram (kg) or Pound (lb)) Per Volume
(Liter (l) or Gallon (gal)) of Coating Less Water and Exempt Compounds,
as Applied

	Air Dried	Baked

Coating Category	kg VOC/l coating	lb VOC/gal coating	kg VOC/l coating	lb
VOC/gal coating

General 

One Component	

0.34	

2.8	

0.28	

2.3

General 

Multi-Component	0.34	2.8	0.28	2.3

Camouflage	0.42	3.5	0.42	3.5

Electric-Insulating Varnish	0.42	3.5	0.42	3.5

Etching Filler	0.42	3.5	0.42	3.5

Extreme High-Gloss	0.42	3.5	0.36	3.0

Extreme Performance	0.42	3.5	0.36	3.0

Heat Resistant	0.42	3.5	0.36	3.0

High Performance Architectural	0.74	6.2	0.74	6.2

High Temperature	0.42	3.5	0.42	3.5

Metallic	0.42	3.5	0.42	3.5

Military Specification	0.34	2.8	0.28	2.3

Mold-Seal	0.42	3.5	0.42	3.5

Pan Backing	0.42	3.5	0.42	3.5

Prefabricated Architectural 

Multi-Component	0.42	3.5	0.28	2.3

Prefabricated Architectural 

One-Component	0.42	3.5	0.28	2.3

Pretreatment Coatings	0.42	3.5	0.42	3.5

Repair and Touch up	0.42	3.5	0.36	3.0

Silicone Release	0.42	3.5	0.42	3.5

Solar-Absorbent	0.42	3.5	0.36	3.0

Vacuum Metalizing	0.42	3.5	0.42	3.5



Work Practices for Coating Operations and Cleaning Materials

In addition to the control options mentioned above, the CTG recommends
work practices to further reduce VOC emissions from miscellaneous metal
parts coating-related activities.  Specifically, at a minimum, the
following work practices are recommended:  (1) store all VOC-containing
coatings, thinners, and coating-related waste materials in closed
containers; (2) ensure that storage containers used for VOC-containing
cleaning 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 (5) minimize
VOC emissions from cleaning of application, storage, mixing, and
conveying equipment, by ensuring that equipment cleaning is performed
without atomizing the cleaning solvent and all spent solvent is captured
in closed containers. 

B.  STATE SUBMITTAL	

On July 28, 2014, Maryland Department of the Environment (MDE) submitted
a SIP revision to EPA adopting the requirements of EPA’s CTGs for
metal furniture, and miscellaneous metal parts.  EPA develops CTGs as
guidance on control requirements for source categories.  States can
follow the recommendations of a CTG and adopt state regulations to
implement the recommendations contained therein, or they can adopt
alternative approaches.  With one exception, MDE is adopting EPA’s CTG
standards for the coating of miscellaneous metal, and metal furniture,
and incorporating them into their Regulation .08 under COMAR 26.11.19.  

Maryland’s SIP submission included one alternative approach for
meeting VOC RACT, by adding robotic application of heavy-duty engine
coatings as an appropriate method for coating applications as long as
the transfer efficiency is equivalent or better than the efficiency
achieved by HVLP spraying.  

The following changes are being made to COMAR 26.11.19.08 in the
Maryland SIP:

The title of section 26.11.19.08 is being changed from “Metal
Furniture Coating” to “Metal Parts and Products Coating”

Definitions for the following are added in section 26.11.19.08(A): 
Adhesion promoter, air-dried coating, baked coating, camouflage coating,
electric-insulating and thermal-conducting coating, electric-insulating
varnish, etching filler, extreme high gloss coating, extreme performance
coating, heat-resistant coating, high performance architectural coating,
high temperature coating, magnetic data storage disk coating, metal
parts and products coating, metallic coating, military specification
coating, mold-seal coating, multi-component coating, one-component
coating, pan-backing coating, prefabricated architectural component
coating, pretreatment coating, repair coating, robotic application of
heavy-duty engine coatings, safety-indicating coating, silicone release
coating, stencil coating, touch-up coating, and vacuum-metalizing
coating. 

The existing section 26.11.19.08(B), Emission Standards, is being
removed. 

Section 26.11.19.08(B), Incorporation by Reference, is added,
incorporating the following documents for incorporation by reference: 
AAMA 2604-05 Voluntary Specification, Performance Requirements and Test
Procedures for High Performance Organic Coatings on Aluminum Extrusions
and Panels; and AAMA 2605-05 Voluntary Specification, Performance
Requirements and Test Procedures for Superior Performing Organic
Coatings on Aluminum Extrusions and Panels. 

Section 26.11.19.08(C), Applicability and Exemptions, is added.  Section
26.11.19.08(C) defines to whom the regulation applies and in what
instances it does not.  In line with the recommendations found in the
Metal Furniture and Miscellaneous Metal and Plastic Parts CTGs,
Maryland’s regulation applies to those who own or operate a metal
furniture coating installation, and to a metal parts and products
coating operation at a premise where the total VOC emissions from all
metal parts and products surface coating operations, including emissions
from related cleaning activities, exceeds 15 lb/day (6.8 kg/day).  This
section clarifies that regulation .08 does not apply to those coatings
for product categories which are already covered by previously in place
state regulations.  The product category coatings which are listed as
not applying under regulation .08, and the applicable state regulation
which covers each product category type, include the following: 
Automotive and light duty truck coating (COMAR 26.11.19.03), can coating
(COMAR 26.11.19.04), coil coating (COMAR 26.11.19.05), large appliance
coating (COMAR 26.11.19.06), paper, fabric, film, and foil coating
(COMAR 26.11.19.07), plastic parts and business machine coatings (COMAR
26.11.19.07-2), cold and vapor degreasing (COMAR 26.11.19.09),
industrial solvent cleaning operations other than cold and vapor
degreasing (COMAR 26.11.19.09-1), drum and pail coating (COMAR
26.11.19.13), aerospace coating (COMAR 26.11.19.13-1), brake shoe
coating (COMAR 26.11.19.13-2), structural steel coating (COMAR
26.11.19.13-3), refinishing of motor vehicles (COMAR 26.11.19.23),
marine vessel coating (COMAR 26.11.19.27), and pleasure craft coating
(COMAR 26.11.19.27-1). 

Section 26.11.19.08(D), Emission Standards, is added and includes
emission standards for the following metal furniture coatings:  Extreme
high gloss, extreme performance, one-component and multi-component
general, metallic, pretreatment, and solar absorbent.  Table 3 shows
Maryland’s maximum applicable VOC emission standards (expressed in
terms of mass VOC per volume coating excluding water and exempt
compounds) allowed when applying one of the listed coating types to
metal furniture.  

 

Table 3. Maryland’s Adopted Standards for Metal Furniture Coatings

Coating	Air-Dried	Baked

	kg VOC/l coating	lb VOC/l coating	kg VOC/l coating	lb VOC/l coating

Extreme high gloss	0.340	2.8	0.360	3.0

Extreme performance	0.420	3.5	0.360	3.0

General, multi-component	0.340	2.8	0.275	2.3

General, one-component	0.275	2.3	0.275	2.3

Metallic	0.420	3.5	0.420	3.5

Pretreatment	0.420	3.5	0.420	3.5

Solar absorbent	0.420	3.5	0.360	3.0



Maryland’s adopted maximum VOC emission standards for metal furniture
coating types are all equal to or more stringent than the applicable
recommended maximum coating standards found in the Metal Furniture
Coatings CTG and in Table 1 of this document. 

Section 26.11.19.08(D), Emission Standards, also includes the emission
standards for the following miscellaneous metal parts coatings: 
Adhesion promoter, camouflage, electric insulating varnish, etching
filler, extreme high-gloss, extreme performance, one-component general,
multi-component general, heat-resistant, high performance architectural,
high temperature, military specification, metallic, mold-seal, pan
backing, prefabricated architectural multi-component, prefabricated
architectural one-component, pretreatment, repair coating, silicone
release, solar absorbent, touch up coating, and vacuum-metalizing. 
Table 4 shows Maryland’s maximum applicable VOC emission standards
(expressed in terms of mass VOC per volume coating excluding water and
exempt compounds) allowed when applying one of the listed coating types
to miscellaneous metal parts.

Table 4. Maryland’s Adopted Standards for Miscellaneous Metal Parts
Coatings

Coating	Air-Dried	Baked

	kg VOC/l coating	lb VOC/l coating	kg VOC/l coating	lb VOC/l coating

Adhesion promoter	0.479	4.0	0.479	4.0

Camouflage	0.340	2.8	0.420	3.5

Electric insulating varnish	0.340	2.8	0.420	3.5

Etching filler	0.340	2.8	0.420	3.5

Extreme high-gloss	0.420	3.5	0.360	3.0

Extreme performance	0.420	3.5	0.360	3.0

General, multi-component	0.340	2.8	0.275	2.3

General, one-component	0.340	2.8	0.275	2.3

Heat-resistant	0.420	3.5	0.360	3.0

High performance architectural	0.420	3.5	0.360	3.0

High temperature	0.340	2.8	0.420	3.5

Military specification	0.340	2.8	0.280	2.3

Metallic	0.340	2.8	0.420	3.5

Mold-seal	0.340	2.8	0.420	3.5

Pan backing	0.340	2.8	0.420	3.5

Prefabricated architectural

multi-component	0.420	3.5	0.280	2.3

Prefabricated architectural one-component	0.420	3.5	0.280	2.3

Pretreatment	0.340	2.8	0.420	3.5

Repair coating	0.420	3.5	0.360	3.0

Silicone release	0.340	2.8	0.420	3.5

Solar absorbent	0.420	3.5	0.360	3.0

Touch up coating	0.420	3.5	0.360	3.0

Vacuum-metalizing	0.340	2.8	0.420	3.5



Maryland’s adopted maximum VOC emission standards for miscellaneous
metal parts coating types are all equal to or more stringent than the
applicable recommended maximum coating standards found in the
Miscellaneous Metal and Plastic Parts Coatings CTG and in Table 2 of
this document. 

Section 26.11.19.08(E), Application Methods, is added and includes the
following application methods as appropriate when applying a coating: 
Electrostatic application, HVLP, 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 HLVP spraying.  These application methods to
do apply to repair coatings, touch-up coatings, coatings applied to
create a textured finish, or robotic application of heavy-duty engine
coatings. 

C.  CONCLUSIONS AND RECOMMENDED AGENCY ACTION:

This SIP revision satisfies all requirements for an acceptable SIP. 
EPA’s evaluation shows that Regulation .08 under COMAR 26.11 contains
the required elements for a federally enforceable rule:  Emission
limitations, compliance procedures and test methods, compliance dates
and record keeping provisions.  Maryland’s SIP revision contains
special provisions that establishes definitions, specifies
applicability, establishes standards, specifies exemptions, specifies
control devices, and specifies general testing, compliance,
recordkeeping, and reporting requirements.  The amendments to Regulation
.08 meet the applicable requirements of the CAA, and the applicable EPA
regulations and policy and can be approved.

EPA approval of the SIP revision is recommended.  The regulations reduce
the VOC contents of currently regulated coatings, regulate additional
coating categories, require the use of coating application equipment
that provides for high transfer efficiency, and require that clean-up
solvent emissions be included in regulatory applicability
determinations.  The reduction of VOC emissions will reduce the
formation of ozone, and thereby protect public health and welfare.

 Decorative, protective, or functional materials that consist only of
protective oils for metal, acids, bases, or any combination of these
substances are not considered metal furniture coatings.

 A coating unit consists of a series of one or more coating applicators
and any associated drying area and/or oven wherein a coating is applied,
dried, and/or cured.  A coating unit ends at the point where the coating
is dried or cured, or prior to any subsequent application of a different
coating.  It is not necessary for a coating unit to have an oven or
flash-off area.

 Maryland used option 1, limits based on low-VOC coatings, from the
control options listed in the Metal Furniture Coatings CTG (EPA
453/R-07-005, September 2007) and only the emission limits for option 1
are listed in this TSD.  Further details of the other control options
and the accompanying emission limits per coating type can be found in
the CTG for metal furniture coatings. 

 Maryland previously submitted, and EPA approved, a SIP revision to meet
the requirements to adopt RACT for plastic part coatings covered by the
CTG for Miscellaneous Metal and Plastic Parts Coatings. See 76 FR 64020
(October 17, 2011).

 Maryland previously submitted, and EPA approved, a SIP revision to meet
the requirements to adopt RACT for pleasure craft coatings covered by
the CTG for Miscellaneous Metal and Plastic Parts Coatings.  See 78 FR
59240 (September 26, 2013). 

 Heavier vehicles includes all vehicles that meet the definition of the
term “other motor vehicles,” as defined in the National Emission
Standards for Surface Coating of Automobile and Light-Duty Trucks at 40
CFR 63.3176.

 Maryland’s SIP submission to meet requirements as recommended by the
CTG for Miscellaneous Metal and Plastic Parts Coatings includes heavier
vehicle coatings as a type of miscellaneous metal coating.   

 Maryland used option 1 from the control options listed in the
Miscellaneous Metal and Plastic Parts Coatings CTG (EPA 453/R-08-003,
September 2008).  Only the emission limits for option 1, and for metal
parts coatings, are listed in this TSD.  Further details of the other
control options and the accompanying emission limits per coating type
for miscellaneous metal parts can be found in the CTG. 

 PAGE   

 PAGE   1 

