UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

1650 Arch Street

Philadelphia, Pennsylvania 19103

DATE: April 13, 2011

SUBJECT: Technical Support Document for Maryland’s Adoption of Control 

Techniques Guidelines (CTG) for Large Appliance Coating

FROM: Gregory Becoat, Environmental Scientist /s/

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 

(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. 

The CTG for large appliance coatings is intended to provide State and local air pollution 

control authorities information that should assist them in determining RACT for VOC 

from large appliance coatings. In developing this CTG, EPA evaluated the sources of 

VOC emissions from the large appliance coating industry and the available control 

approaches for addressing these emissions, including the costs of such approaches. 

Based on available information and data, EPA provides recommendations for RACT for 

large appliance coating.

In December 1977, EPA published a final CTG for large appliance coatings, entitled 

“Control of Volatile Organic Emissions from Existing Stationary Sources, Volume V, 
Surface Coating of Large Appliances,” EPA-450/2-77-034 (December 1977).1

 In 

October 1982, EPA promulgated national standards of performance for new stationary 

sources (NSPS) for large appliances (40 CFR part 60, subpart SS). The 1982 NSPS 

requires VOC emissions limits based on VOC content of low VOC coating materials. In 

July 2002, EPA promulgated a national emission standard for hazardous air pollutants 

(NESHAP) for these industries large appliances (40 CFR part 63, subpart NNNN). The 

2002 NESHAP establishes national emission standards for hazardous air pollutants 

(HAP) for large appliance surface coating facilities and emissions limits based on the 

organic HAP content of low organic HAP coating materials.

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 a new CTG for surface coating of large 

appliances, entitled “Control Techniques Guidelines for Large Appliance Coatings,” EPA 

453/R-07-004 (September 2007).

2

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 surfacecoated 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.

 

1 Control of Volatile Organic Emissions from Existing Stationary Sources, Volume V, Surface 

Coating of Large Appliances. Publication No. EPA-450/2-77-034. U. S. Environmental 

Protection Agency, Research Triangle Park, NC. December 1977. 

2 Control Techniques Guidelines for Large Appliance Coatings. Publication No. EPA 453/R-07-

004. U. S. Environmental Protection Agency, Research Triangle Park, NC. September 2007.
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:

A. 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 airdried coatings. Provided in Table 1 are the recommended emission limits expressed 

in terms of mass of VOC per volume of coating (kilograms per liter (kg/l) or pounds 

per gallon (lb/gal), 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, MultiComponent0.275 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 as shown in Table 2. 
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, MultiComponent0.40 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.

B. STATE SUBMITTAL

On December 15, 2010, Maryland Department of the Environment (MDE) submitted to 

EPA a SIP revision concerning the adoption of the EPA CTGs for large appliance 

coatings. EPA develops CTGs as guidance on control requirements for source categories. 

States can follow the CTGs or adopt more restrictive standards. MDE is adopting a new 
standard and requirements for large appliance coating. This SIP revision amends 

Regulation .06 under COMAR 26.11.19 – Volatile Organic Compounds from Specific 

Processes in order to set the VOC coating standard of 2.3 lbs/gal of coating applied 

(excluding water)/0.275 kg/l of coating applied (excluding water).

Regulation COMAR 26.11.19.06 – Large Appliance Coating is being amended to include 

the definition for large appliance coating. Regulation COMAR 26.11.19.06 is also 

amended to include the coating standard requirements for large appliance coating. These 

standards require that any person who uses a large appliance coating installation may not 

cause or permit the discharge into the atmosphere of any VOC from a large appliance 

coating installation in excess of 2.3 lbs/gal of coating applied (excluding water) (0.275 

kg/l of coating applied (excluding water)); shall use control equipment to achieve an 

overall VOC emissions reduction of 90 percent or greater from the large appliance 

coating installation at the affected facility; and use one or more of the following 

application methods:

 (a) Electrostatic application

 (b) HVLP spray

 (c) Flow coat

 (d) Roller coat

 (e) Dip coat including electrodeposition

 (f) Brush coat

 (g) Other coating application method that has a transfer efficiency equivalent to or 

 better than that achieved by HVLP spraying.

C. EPA EVALUATION

The State of Maryland has adopted the more restrictive 2.3 lbs/gallon VOC coating 

requirement of the CTG for large appliance coating and is revising its SIP to reflect these 

amendments. Although the CTG for large appliance coating provides eight coating 

standards ranging from 2.3 lbs/gal to 3.5 lbs/gal VOC, seven of the coating standards are 

above Maryland’s existing 2.8 lbs/gal VOC standard. As a result, the State of Maryland

adoption of the more restrictive 2.3 lbs/gal VOC coating standard is more protective of 

Maryland’s air quality. The maximum benefit of adopting the CTG for large appliance 

coating will be provided during the ozone season when VOCs readily combine with 

nitrogen oxides to form the pollutant ground level ozone. 

D. CONCLUSIONS AND RECOMMENDED AGENCY ACTION

The adoption of the EPA CTG requirements for large appliance coating by the State of 

Maryland will result in the reduction of VOC emissions from large appliance coating 

facilities. EPA approval of the SIP revision is recommended.