UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

1650 Arch Street

Philadelphia, Pennsylvania 19103

DATE: December 20, 2011

SUBJECT: Technical Support Document for Delaware’s Handling, Storage, and Disposal of 

Volatile Organic Compounds Emissions; Automobile and Light-Duty Truck 

Coating Operations; Paper Coating; Coating of Flat Wood Paneling; Graphic Art 

Systems; and Industrial Cleaning Solvents

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: 

On June 20, 2011, U.S. Environmental Protection Agency (EPA) received a revision to the 

Delaware State Implementation Plan (SIP) submitted by the Delaware Department of Natural 

Resources and Environmental Control (DNREC). The SIP revision updates regulations in 7 DE 

Admin. Code 1124 – Control of Volatile Organic Compound (VOC) Emissions in order to 

implement reasonably available control technology (RACT) controls on emission sources 

covered by EPA’s control techniques guidelines (CTG). The SIP revision amends section 8.0, 

“Handling, Storage, and Disposal of Volatile Organic Compounds,” section 13.0, “Automobile 

and Light-Duty Truck Coating Operations,” section 16.0, “Paper Coating,” section 23.0, “coating 

of flat Wood Paneling,” section 37.0, “Graphic Art Systems,” and section 45.0, “Industrial 

Cleaning Solvents.” The amendments are part of Delaware’s strategy to achieve and maintain 

the 8-hour ozone national ambient air quality standard (NAAQS) throughout the State. The 

effective date of these revised regulations is March 11, 2011. 

Section 182(b)(2) of the Clean Air Act (CAA) requires all ozone nonattainment areas, including 

Delaware, to update relevant regulations for RACT controls and submit the regulations to EPA 

as SIP revisions for emission sources covered by EPA’s CTG documents issued after November 

15, 1990 and prior to the area’s date of attainment. CTGs are intended to provide state and local 

air pollution control authorities information that should assist them in determining RACT for 

VOCs from a specific type of product or source category. In developing these CTGs, EPA, 

among other things, evaluated the sources of VOC emissions and the available control 

approaches for addressing these emissions, including the costs of such approaches. Based on 
2

available information and data, EPA provides recommendations for RACT for VOCs. 

Section 8.0, “Handling, Storage, and Disposal of Volatile Organic Compounds,” section 13.0, 

“Automobile and Light-Duty Truck Coating Operations,” section 16.0, “Paper Coating,” section 

23.0, “coating of flat Wood Paneling,” section 37.0, “Graphic Art Systems,” and section 45.0, 

“Industrial Cleaning Solvents,” of 7 DE Admin. Code 1124 - Control of Volatile Organic 

Compound Emissions was originally developed in the 1990’s based on EPA’s CTGs. From 

September 2006 to September 2008, EPA updated relevant CTGs affecting sections 8.0, 13.0, 

16.0, 23.0, 37.0, and 45.0 in order to reflect technology developments and expand VOC emission 

controls. As a result, DNREC revised sections 8.0, 13.0, 16.0, 23.0, 37.0, and 45.0 to reflect the 

new requirements in EPA’s CTGs into existing Delaware Regulation 1124.

B. STATE SUBMITTAL

Summary of the SIP Revision

Section 8.0 – Handling, Storage, and Disposal of Volatile Organic Compounds 

Delaware’s amendments to section 8.0 add provisions to conform to the Industrial Cleaning 

Solvents CTG issued by EPA in September 2006 (EPA 453/R-06-001). This CTG is intended to 

provide Delaware with information that should assist in determining RACT for industrial 

cleaning solvents.

Section 8.0 was amended to add a new VOC content limit for any facility regulated under 

Regulation 1124 and any facility that emits at least 6.8 kilograms/day (15 pounds/day) of VOC 

before consideration of controls.

Section 8.0 also adds the following definitions and terms: “Cleanup solvent,” “Electrical and 

electronic components,” “Flushing,” “Hand-wiping,” “Medical device,” “Non-manufacturing 

area cleaning,” “Medical Device and Pharmaceutical Manufacturing,” “Pharmaceutical product,” 

“Precision optics,” “Solvent cleaning operation,” “Stripping,” “Surface preparation,” and 

“Surface preparation solvent.”

The SIP revision amends section 8.0 in order to: (1) establish exemptions, (2) update existing 

work practice standards, (3) establish control requirements, and (4) establish test methods, 

procedures and recordkeeping requirements based on EPA CTGs.

Section 13.0 – Automobile and Light-Duty Truck Coating Operations

Delaware’s amendments to section 13.0 add and update regulations to reflect EPA’s CTG 

recommendations for Automobile and Light-Duty Truck Assembly Coatings issued in September 

2008 (EPA-453/R-08-006). This CTG is intended to provide Delaware with information that 

should assist in determining RACT for VOCs from automobile and light-duty truck assembly 
3

coatings. In developing this CTG, EPA evaluated the sources of VOC emissions from the 

automobile and light-duty truck assembly coating industry and the available control approaches 

for addressing these emissions. Section 13.0 was revised in order to set more stringent VOC 

emission limits for coating operations used in new automobile and light-duty truck coating 

operations to reflect the CTG recommendation.

Section 13.0 was amended to establish applicability for each prime coat operation, each electrodeposition prime coat operation, each primer-surfacer operation, each topcoat operation, each 

combined primer-surfacer and topcoat operation, each final repair operation, and each 

miscellaneous motor vehicle materials operation. Section 13.0 also adds a transition period for 

existing permitted sources for every owner or operator of any automobile or light-duty truck 

assembly plant. Owners or operators must comply with all new provisions of section 13.0 on and 

after January 1, 2011.

Section 13.0 adds the following definitions and terms: “Adhesive,” “Automobile and light-duty 

truck adhesive,” “Automobile and light-duty truck bedliner,” “Automobile and light-duty truck 

cavity wax,” “Automobile and light-duty truck deadener,” “Automobile and light-duty truck 

gasket/gasket sealing material,” “Automobile and light-duty truck glass bonding primer,” 

“Automobile and light-duty truck lubricating wax/compound,” “Automobile and light-duty truck 

sealer,” “Automobile and light-duty truck interior coating,” “Automobile and light-duty truck 

underbody coating,” “Automobile and light-duty truck weatherstrip adhesive,” “In-line Repair,” 

“Primer-surfacer,” and “Primer-surfacer and topcoat protocol.” The following definitions were 

amended to reflect the CTG: (1) Electro-deposition (EDP), (2) Final repair operation, (3) 

Primer-surfacer operation, (4) Solids turnover ratio (RT), (5) Topcoat, and (6) Volume design 

capacity. The definition of “Topcoat protocol” was deleted.

The SIP revision amends section 13.0 in order to: (1) update daily-weighted average limitation 

and control devices, (2) update compliance procedures for EDP prime coat operations, (3) and 

update test methods, procedures and recordkeeping requirements.

Section 16.0 – Paper Coating

Delaware’s amendments to section 16.0 add “film and foil coating” to the regulated category in 

order to reflect EPA’s CTG recommendations for Paper, Film, and Foil Coatings issued in 

September 2007 (EPA 453/R-07-003). The SIP revision expands the regulated capacity from 

only paper coating to “paper, film, and coating.” This CTG is intended to provide Delaware with 

information that should assist them in determining RACT for VOCs from paper, film, and foil 

coatings.

The title of section 16.0 was amended to add “Film, and Foil,” now entitled “Paper, Film, and 

Foil Coating.” This SIP revision applies to any paper, film, or foil coating unit. Section 16.0 

was amended to add exemptions for any coating unit in-line with any offset lithographic, screen, 

letterpress, flexographic, rotogravure, or digital printing operations. Section 16.0 also adds a 
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transition period for existing permitted sources for every owner or operator of any paper coating 

unit. Owners or operators must comply with all new provisions of section 16.0 on and after 

January 1, 2011.

Section 16.0 adds the definition of “Coating,” and updates the following definitions: (1) Paper, 

film, or foil coating line and (2) Paper, film, or foil coating unit.

Section 16.0 was amended to set standards by which no application of any coating on that unit 

with VOC content in excess of 0.40 kilogram VOC/kilogram of solid applied. In addition, for 

pressure sensitive tape and label surface coating, no application of any coating on that unit with 

VOC content in excess of 0.40 kilogram VOC/kilogram of solid applied.

The SIP revision amends section 16.0 in order to: (1) update daily-weighted average limitation 

and control devices, (2) and update recordkeeping and reporting requirements.

Section 23.0 – Coating of Flat Wood Paneling

Delaware’s amendments to section 23.0 add and update regulations in order to establish more 

stringent emission limits. EPA’s CTG for flat wood paneling coatings was issued in September 

2006 (EPA 453/R-06-004) and intended to provide Delaware with recommendations for RACT for 

flat wood paneling coating. 

Delaware amended section 23.0 by deleting a regulation that did not require Class I hardboard 

paneling finishes, particle board used in furniture, insulation board, exterior siding, tileboard, and 

softwood plywood coating lines to apply to flat wood paneling coating standards.

The standards of section 23.0 were amended to add tileboard panels and exterior sidings to the flat 

wood paneling product category and establish VOC emission limits. The SIP revision also establishes

more stringent emission limits to previously existing flat wood paneling products: printed interior 

panels, natural finish panels, and Class II finish panels. The standards require that no owner or 

operator of a flat wood paneling coating line subject to the regulation for flat wood paneling coating 

shall allow VOC emissions in excess of the emission limits in Table 1.

Table 1. VOC Emission Limits from Flat Wood Paneling Coatings

Flat Wood Paneling Product Category

VOC Content Limits in Coatings, 

Inks, or Adhesives Being Applied

pounds/gallon 

(lb/g)

grams/liter

(g/L)

Printed interior panels made of hardwood, 

plywood, or thin particleboard

2.1* 250

Natural finish hardwood plywood panels 2.1 250

Class II finishes on hardboard panels 2.1 250

Tileboard 2.1 250

Exterior siding 2.1 250
5

*This limit of 2.1 lb/gal is equivalent to 5.0 lb VOC per 1,000 square feet coating area.

The SIP revision amends section 23.0 in order to: (1) add work practice standards, (2) update 

control devices, and (3) update test methods and efficiency of control systems, and recordkeeping

and reporting requirements.

Section 37.0 – Graphic Arts Systems

Delaware’s amendments to section 37.0 add provisions to conform to the Flexible Package 

Printing CTG issued by EPA in September 2006 (EPA 453/R-06-003). This CTG is intended to 

provide Delaware with guidance and recommendations in determining RACT for VOCs from 

flexible package printing facilities.

This SIP revision applies to any packaging rotogravure, publication rotogravure, or flexographic 

printing press at any facility whose maximum theoretical emissions of VOCs without control 

devices from all printing presses is greater than or equal to 7.7 tons per year on and after March 

11, 2011 (effective date of this SIP revision). Section 37.0 also adds a transition period for 

existing permitted sources for every owner or operator of any flexible package printing facility. 

Owners or operators must comply with all new provisions of section 37.0 on and after January 1, 

2011. 

Section 37.0 adds the following definitions and terms: “Add-on air pollution control device 

(APCD),” “Flexible packaging,” and “Flexible packaging printing.”

Section 37.0 establishes efficiency requirements for control systems to be installed on the 

flexible packaging printing presses. The revision requires any individual flexible packing 

printing press with the potential-to-emit before controls greater than 25 tons of VOC per year an 

overall emission reduction efficiency specified in regulations.

The SIP revision amends section 37.0 in order to update recordkeeping and reporting 

requirements.

Section 45.0 – Industrial Cleaning Solvents

Delaware’s amendments to section 45.0 update the applicability for the industrial use of organic 

cleaning solvents based on the Industrial Cleaning Solvents CTG issued by EPA in September 

2006 (EPA 453/R-06-001). This SIP revision amends the regulation to clarify that the 

requirements of section 45.0 are triggered based on a limit of VOC emissions rather than 

cleaning solvent used. 

C. EPA EVALUATION

These regulations conform to the updated CTGs issued by EPA in order to reflect technology 
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developments and expand VOC emission controls. The revisions to the SIP will reduce VOC 

emissions from industrial cleaning solvents facilities, automobile and light-duty truck coating 

operations, paper, film and foil coating units, flat wood paneling products, and flexible packaging

printing presses. 7 DE Admin Code 1124, sections 8.0, 13.0, 16.0, 23.0, 37.0, and 45.0 meet and 

reflect the RACT requirements in EPA’s CTGs.

D. CONCLUSIONS AND RECOMMENDED AGENCY ACTION

Amendments to the control of VOC emissions (7 DE Admin. Code 1124) in section 8.0, 

“Handling, Storage, and Disposal of Volatile Organic Compounds,” section 13.0, “Automobile 

and Light-Duty Truck Coating Operations,” section 16.0, “Paper Coating,” section 23.0, “coating 

of flat Wood Paneling,” section 37.0, “Graphic Art Systems,” and section 45.0, “Industrial 

Cleaning Solvents,” adopted by the State of Delaware will result in the reduction of VOC 

emissions from the affected sources. The SIP revisions meet the applicable requirements of the 

CAA and the applicable EPA regulations, guidance and policy and can be approved. The SIP 

revisions will help Delaware in attaining compliance with the 8-hour ozone NAAQS.

EPA’s approval of the SIP revisions is recommended.