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

S ection 172(c)(1) of the Clean Air Act (CAA) provides that state imp lementation 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 ar eas, 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 St ates 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

feasibili ty.” (44 FR 53761, Sept. 17, 1979 )

. In subsequent Federal Register notices, EPA

has addressed how states can mee t the RACT requirements of the CAA

.

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

control authori ties 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 addre ssing 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 Existin g 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 l arge 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 pollutant s (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 int o 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

- 0 7

- 004 ( September 2007)

. 2

Description of Larg e 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 d efined 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

met al 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 dif

ferent 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 use d 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. Environmenta l 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

- 0 7

- 004). Recommendations for controlling VOC emissions from larg e 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

c ombination 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 com pounds, 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. Addit ionally, 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 B ase d 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 emissi on limits are recommended for baked and air

dried 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) , exclu ding water and exem pt 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 0.3 40 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 emis sion limits can also be expressed in terms of mass of V OC 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, 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

Pretreatmen t 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 lubrica nts, 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 incl uded 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 br ush 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 newstandard and requirements for large appliance coating

. This SIP revision amends

Regulation .06 under COMAR 26.11.19

– Volatile Org anic Co mpounds 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 t o 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 a ny person who uses a large appliance coating instal lation m ay 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 co ating applied (excluding water) (0.275 kg/l of coating applied (excluding water)); s hall use control equip ment to achieve an overall VOC emissions reduction of 90 percent or greater from the large appliance coating installation at the affect ed facil i ty; 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

am endments . Although the CTG for la rge 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

ni trogen 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.