# Control Techniques Guidelines for Large Appliance Coatingsii This page intentionally left blank.iii EPA 453/R-07-004 September 2007



# Control Techniques Guidelines for Large Appliance Coatings

U.S. Environmental Protection Agency Office of Air Quality Planning and Standards Sector Policies and Programs Division Research Triangle Park, NCiv This page intentionally left blank.v TABLE OF CONTENTS

I. Introduction..............................................................................................Page 1

II. Background and Overview ......................................................................Page 2

III. Applicability ............................................................................................Page 3

IV. Process Description and S ources of VOC Emissions..............................Page 4 A. Process Description

B. Source of VOC Emissions 1. Coatings 2. Cleaning Materials

V. Available Controls and Exis ting Federal, State, and Local Recommendations/Regulations..........................................................Page 8 A. Available Controls for VOC Emissions from Coatings

1. Pollution Prevention Measures

a. Product Substitution/Reformulation

b. Work Practices 2. Emission Capture and Add-On Control Systems

B. Available Controls for VOC Em issions from Cleaning Materials

1. Pollution Prevention Measures 2. Emission Capture and Add-On Control Systems C. Existing Federal, State, and Local Recommendations/Regulations

1. The 1977 CTG

2. The 1982 NSPS

3. The 2002 NESHAP 4. Existing State and Local VOC Requirements

VI. Recommended Control Options...............................................................Page 18

A. Emissions Limit based on Low-VOC Coatings B. Optional Add-On Controls for Coating Operations C. Work Practices for Coating Operations and Cleaning Materials

VII. Cost Effectiveness of Recommended Control Options ...........................Page 21

VIII. References ................................................................................................Page 22

Appendix A 1977 Large Appliance Coating CTG Document

Appendix B Summary of State-Specific Larg e Appliance Coating Regulationsvi This page intentionally left blank.I. Introduction

Clean Air Act (CAA) section 172(c)(1) pr ovides that state implementation plans (SIPs) for nonattainment areas must include “reasonably available control measures” (RACM), including “reasonably available c ontrol technology” (RAC T), for sources of emissions. Section 182(b)(2)(A) provides that for certain nonattainment areas, States must

revise their SIPs to include RACT for each category of volatile organic compound (VOC) sources covered by a control techniques guidelines (CTG) document issued between November 15, 1990 and the date of attainment.

The United States Environmental Protecti on 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 r easonably available considerin g technological and economic feasibility.” 44 FR 53761 (September 17, 1979). In subsequent Federal Register notices,

EPA has addressed how States can meet the RACT requirements of the Act.

CAA section 183(e) directs EPA to list fo r regulation those categories of products that account for at least 80 percent of the VOC emissions, on a reactivity-adjusted basis, from consumer and commercial products in ar eas that violate the NAAQS for ozone (i.e., ozone nonattainment areas). EPA issued the list on March 23, 1995, and has revised the list periodically. See 60 FR 15264 (March 23, 1995); see also 71 FR 28320 (May 16, 2006), 70 FR 69759 (Nov. 17, 2005); 64 FR 13422 (March 18, 1999). Large appliance coatings are

included on the current section 183(e) list.

This CTG is intended to provide State and local air pollution control authorities

information that should assist them in de termining RACT for VOC from large appliance coatings. In developing this CTG, EPA eval uated the sources of VOC emissions from the large appliance coating industr y and the available control a pproaches for addressing these emissions, including the costs of such approach es. Based on available information and data, EPA provides recommendations for RA CT for large appliance coating.

States can use the recommendations in th is CTG to inform their own determination as to what constitutes RACT for VOC for large appliance coatings in their particular

nonattainment areas. The information contai ned in this document is provided only as guidance. This guidance does not change, or substitute for, requirements specified in applicable sections of the CAA or EPA’s regulat ions; nor is it a regu lation itself. This document does not impose any legally binding re quirements on any entity. It provides only recommendations for State and local air pollu tion control agencies to consider in determining RACT. State and local pollution c ontrol agencies are free to implement other technically-sound approaches that are consis tent with the CAA and EPA’s implementing regulations.

The recommendations contained in this CTG are based on data and information currently available to EPA. These general r ecommendations may not apply to a particular situation based upon the circumstances of a speci fic source. Regardless of whether a State chooses to implement the recommendations contai ned herein through State rules, or to issue State rules that adopt differe nt approaches for RACT fo r VOC from large appliance2 coatings, States must submit their RACT rules to EPA for review and a pproval as part of the SIP process. EPA will evaluate the rule s and determine, through notice and comment rulemaking in the SIP approval process, whet her the submitted rules to meet the RACT requirements of the CAA and EPA’s regulations. To the extent a State adopts any of the recommendations in this guidance into its Stat e RACT rules, interested parties can raise questions and objections about th e substance of this guidance and the appropriateness of the application of this guidance to a particular situation during the development of the State rules and EPA’s SIP approval process.

CAA section 182(b)(2) requires that a CT G issued after November 15, 1990 and the date of attainment include the date by whic h States subject to s ection 182(b) must submit SIP revisions in response to the CTG. A ccordingly, EPA is providing in this CTG a oneyear period for the required submittal. Pursuant to section 182(b)(2), States required to submit rules consistent with section 182(b) must submit their SIP revisions within one year

of the date of issuance of the final CTG for la rge appliance coatings. States subject only to the RACT requirement in CAA section 172(c)(1) may take action in response to this CTG, as necessary to attain.

II. Background and Overview

In December 1977, EPA published a CTG fo r large appliance coating, entitled “Control of Volatile Organic Emissions from Existing Stationary S ources, Volume V: Surface Coating of Large Appliances,” EPA-450/2-77-034 (1977 CTG). The 1977 CTG can

be downloaded from EPA’s website at www. epa.gov/ttn/naaqs/ozone/c tg_act. The cover page of the 1977 CTG is included as Appendix A to this CTG for additional reference. In October 1982, EPA promulgated the National Sta ndards of Performance for New Stationary Sources (NSPS): Standards of Performan ce for Industrial Surface Coating: Large Appliances, 40 CFR part 60, subpart SS ( 1982 NSPS). In 2002, EPA promulgated the

National Emission Standards for Hazardous Ai r Pollutants: Surface Coating of Large Appliances, 40 CFR part 63, subpart NNNN (2002 NESHAP). The 1977 CTG recommends and the 1982 NSPS requires VOC emissions limits based on VOC content of low VOC coating materials. The 2002 NESHAP estab lishes organic hazardous air pollutants (HAP) emissions limits based on the organic HAP cont ent of low organic HAP coating materials.

At least 24 State and local jurisdictions have specific regulations that control VOC emissions from large appliance coating operati ons. A discussion of the applicability and control options found in the Federal actions and State and local rules is presented in Section

V of this document.

EPA developed the recommended approaches contained in this document after reviewing the 1977 CTG, the 1982 NSPS, the 2002 NESHAP, and existing State and local VOC emission reduction approach es and considering informati on obtained since issuance of

the 2002 NESHAP.

The remainder of this document is divided into six sections. Section III describes the scope of sources to which the control recomm endations in this CTG could apply. Section IV describes the large appliance coating pr ocesses and identifies the sources of VOC emissions from those processes. Section V de scribes the available c ontrol approaches for addressing VOC emissions from this product category and summarizes Federal, State and3 local approaches for addressing such emissions . Section VI provides our recommendations for RACT for large appliance coatings. Secti on VII discusses the cost -effectiveness of the recommended control approaches. Secti on VIII contains a list of references.

III. Applicability

This CTG provides control recommendati ons for reducing VOC emissions stemming from the use of coatings in large appliance coating operations. Coatings include paints, sealants, caulks, inks, adhesives, and maskants. 1 This section addresses EPA's recommendations as to the scope of entities to which the RACT recommendations in this CTG should apply. As explained above, th is document is a guidance document and provides information for States to consider in determining RACT. When State and local pollution control agencies devel op RACT rules, they may elect to adopt control approaches

that differ from those described in this docum ent and/or promulgate applicability criteria

that differ from those recommended here.

In terms of applicability, we recommend th at the control approa ches discussed in Section VI of this CTG apply to each large appliance coating unit 2 at a facility where the total actual VOC emissions from all large a ppliance 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 ro lling period, before consideration of controls. We do not recommend these control approaches for facilities that emit below this level because of the very small VOC emission reductions that can be achieved. The recommended threshold level is equivalent to the evaporation of about two gallons of solvent per day. Such a level is considered to be an incidental level of solvent usage that could be expected even in facilities using ex clusively powder or ultr a-violet and electron beam (UV/EB) coatings. Furthermore, based on the 2002 National Emission Inventory (NEI) and the 2004 ozone nonattainment designati ons, we estimated that all of the large appliance surface coating facili ties located in ozone nonattainm ent areas (68 f acilities) emit

at or above this level and would therefore be addressed by our recommendations in the CTG. For purposes of determining whether a facility meets our recommended applicability threshold, aggregate emissions, before consider ation of control, from all large appliance coating operations (inc luding related cleaning ac tivities) at a given facility are included.

In developing their RACT rules, State and local agencies should consider carefully

the facts and circumstances of the affected sour ces in their States. As noted above, States can adopt the above recommended 15 lb/day actual VOC emissions or an equivalent applicability threshold, or they can develop othe r applicability criteria that they determine are appropriate considering the facts and circum stances of the sources in their particular

nonattainment areas. EPA will review the St ate RACT rules in the context of the SIP revision process.

1 Decorative, protective, or functional materials that cons ist only of protective oils for metal, acids, bases, or any combination of these s ubstances are not considered metal furniture coatings.

2 A coating unit consists of a series of one or more co ating applicators and any asso ciated 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 subseq uent application of a different coating. It is not necessary for a coating

unit to have an oven or a flash-off area.4 The 2002 NEI and a questionnaire sent to industry by EPA during the 2002 NESHAP development (data requested by EPA in 1997 and 1998) were used as the source

of emissions data and statistical information concerning the large appl iance coating industry as a whole. There were several discrepancie s in the number of facilities reporting in the 2002 NEI versus the 1997 and 1998 NESHAP questi onnaires. During th e evaluation of the 2002 NEI data, it was noted that 14 States had at least one facility that reported emissions from this source category in 1997 but not in 2002 . There were also States that showed a number of facility closures based on the co mparison of 2002 NEI data to the data collected during the 2002 NESHAP development.

Results from the NESHAP questionnaires indi cated that there were 222 facilities that perform large appliance coating operations. These operations were distributed across 38

States and Puerto Rico. The States with the largest number of la rge appliance coating operations were Ohio (19), Te nnessee (16), Illinois (15), Texas (14), Wisconsin (13), and Georgia (10). Although information regarding HAP emissions was the main focus of the NESHAP questionnaires, information regard ing VOC was submitted from 153 of the total 222 facilities surveyed. These facilities reported actual VOC emissions totaling approximately 5,000 tpy for 1997. This total only accounts for the VOC emissions generated by these facilities from coatings. In addition, facilities that were excluded from the final rule (coating of chille rs) were also included in th e total 222 facilities surveyed.

In developing this CTG, the 2002 NEI database was queried for VOC emissions generated by facilities that were listed under the SIC codes 3631, 3632, 3633, 3639, 3582, 3585, and 3589 (those SIC used for the 2002 NESHAP). This query resulted in only 128 facilities compared to the 222 facilities identified during the 1997 and 1998 NESHAP questionnaires. The 128 large appliance coat ing facilities in the 2002 NEI reported total VOC emissions of 6,225 tpy. This total account s for all of the VOC emissions generated by

these facilities and does not specify the amount generated ju st by large appliance coating operations. Of the 128 faciliti es that reported, 44 were lo cated in nonattainment areas.

Based on the industry information submitted during the 2002 NESHAP development, it was anticipated that closer to 200 facilities (e xcluding the number of facilities that reported when chillers were part of the rule development) should have reported during 2002. Based on the fact that only 128 fac ilities reported and the discrepancies noted,

it can be concluded that the 2002 NEI is not as complete as the data collected during the 2002 NESHAP development. Based on the information evaluated for this CTG development, there are an estimated 200 facilitie s. Approximately 68 of these facilities are

believed to be in nonattainment areas. This is based on the fact that 44 facilities out of the 128 large appliance coating fac ilities (34 percent) that repor ted emissions in the 2002 NEI were in nonattainment areas (34 percent of the 200 facilities from the 2002 NESHAP development would be 68 facilities estimated to be in nonattainment ar eas). Baseline VOC

emissions from these 68 facilities are estimated to be 3,300 tpy.

IV. Process Description and Sources of VOC Emissions

A. Process Description

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 large5 appliance parts or products. A la rge appliance part is defined as any organic surface-coated metal lid, door, casing, panel, or other interior or exterior metal 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 oven, refrigerator, freezer, washer, dryer, dishwasher, water heater, or trash compactor manuf actured for household, commercial, or recreational use.

Coatings are a critical constituent to 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 t ype will be exposed to somewhat different corrosive elements. The coatings must al so be durable and ha ve excellent adhesion properties to avoid peeling or chipping. Fi nally, the coatings that are applied on home appliances must have esthetic appeal.

The coating application methods used are typical of surface coating operations in many industries. Air atomized spraying and airless spraying of coatings involve the atomization of a liquid coating in order to apply it to a substrate. Air atomized spraying achieves atomization by the use of compressed ai r and can provide transfer efficiencies of up to 40 percent. Airless spraying uses an ai rless pump system to force the coating through a nozzle designed to atomize the coating and typi cally has a transfer efficiency of 50 to 60 percent. The high-volume low-pressure ( HVLP) system is a newer technology which further reduces overspray because it propels the atomized coating at a lower velocity than the air or airless system.

Most spray applied large appliance coatin gs are applied electrostatically. An electrostatic spray can be genera ted using an air or an airless gun system. In such systems, the transfer efficiency is improved because elec trostatic principles are used to attract the coating to the substrate (up to about 85 percent transfer effi ciency). Other electrostatic application methods include electrostatic bell and disk spray gun systems. The electrostatic bell and disk systems are similar in many respec ts. They use the rapi d rotation of either a bell or disk shaped applicator to mist the co ating. The use of oppos itely charged substrate and coating allows for higher tr ansfer efficiencies (close to 90 percent) and better coating uniformity.

Other application methods commonly used are dip coating, electrodeposition, and flow coating. The dip coating operation i nvolves the immersion of a part into a tank containing the coating and typical transfer efficiencies are near 85 percent. Electrodeposition is a dip coating method in which an electric field is used to facilitate the deposition of the waterborne coating on the substrat e. The substrate to be coated acts as an electrode that is oppositely charged from the coating (p articles) in the dip tank. Electrodeposition has a transfer efficiency closer to 95 percen t. Flow coating is a method that involves the application of the coating directly onto the substrate without atomizing the coating and has a typical transfer efficiency of 85 percent.

In typical liquid spray and di p coating operations the coat ed parts/products typically move from the coating application area thr ough a flash-off area, where solvents in the coating begin to evaporate slowly, thus avoidi ng bubbling of the coating while it is curing in the oven. After being coated by any of the typical coating operations, large appliance6 products are dried and cured usi ng heated dryers or by air dr ying. This step removes any remaining volatiles from the coatings so that the surfaces of the large appliance products meet the hardness, durability, and app earance requirements of customers.

The majority of touch-up operations are performed by using manual air spray guns and a lacquer based coating. This is b ecause the lacquer coating has good drying characteristics that allow for shorter drying ti mes. In some cases, touch-up might include recoating a product entirely, bu t the majority of touch-up consists of manual coating application to a small por tion of the product surface.

B. Sources of VOC Emissions

VOC emissions from large appliance coati ng processes result from the evaporation of the components of the coat ings and cleaning materials. 3 Provided below are further descriptions of these two emission sources.

1. Coatings

The primary VOC emissions from large a ppliance coatings o ccur during coating application (prime, single or topcoat applicatio n)/flash-off and drying/curing of the coatings. The remaining emissions are primarily from mixing and/or thinning. In most cases, VOC emissions from storage, handling, and waste/ wastewater operations related to coating operations are relatively small.

After being coated by any of the typical coa ting operations (such as spray coating or dip coating), the large appliance products are cure d using heated dryers or allowed to air dry. This step removes any remaining volatiles from the coating so that the surfaces of the large appliance product meet the hardness, durabi lity, and appearance requirements of the

customers.

Coating mixing may be performed in an ag itated drum or it may be performed by merging two different coating s upply lines into one. Coati ng mixing is typically performed by the coating manufacturer prior to shipment to a large applia nce manufacturer’s facility.

Some facilities add water or solvent to the co ating (thinning), which may be performed in a small mixing booth or it may be automated. Some facilities combine reclaimed coating from various coating operations and mix the di fferent coatings togeth er in a drum. Mixing also varies depending on the type of coating and usage requirements.

Until the 1970’s, conventional solvent-base d coatings, with high VOC content, were the majority of coatings used in the large ap pliance industry. Due to increased regulation at the State and federal level, the industry has st eadily moved to lower VOC content coatings. These alternative coatings include powder coatings, waterborne coatings, higher solids coatings and ultraviolet coatings. The fo llowing discussion summar izes each of these alternative coating formulations.

3 In a previous Federal Register notice, EPA identified specific categories, including large appliances coating, the cleaning operations of which would not be covered by EPA’s 2006 CTG for industrial cleaning solvents. 71 Fed Reg. 44522, 44540 (2006). In that notice, EPA expressed its intention to address cleaning operations associated with these categories in the CTGs for these specified categorie s if the Agency determines that a CTG is appropriate for the respective categories.7 Powder Coatings. The use of powder coating system s in the large appliance industry has increased. Many large appliance coating fa cilities have replaced existing liquid coating operations with powder coating operations. Compared to conven tional liquid coating systems, powder coating produces minimal amounts of VOC emissions because powder coatings are applied as dried particles, no VOC are released during the application operation, and volatile emissions from the curing operati on, if any, are generally much less than the volatile emissions from liquid coating system s. Powder coating is applied via powder delivery systems, which in most cases is an electrostatic spray. Particulate emissions resulting from the application of powde r coatings can be minimized through the implementation of a recovery and recycling pr ocess (reuse of overspray). Depending on the powder formulation, some volatile emissions ma y occur when the powder is heated during the curing step. Powder coating applications are best suited for l ong production runs of consistently sized parts without color changes. In the case of some products with special performance needs (such as dishwasher racks) , a two-step powder co ating process may be used. In these cases, the powder coating is preceded by a low-solids adhesion enhancer.

Waterborne Coatings. Waterborne coatings pr oduce minimal VOC emissions primarily because a large portion of the solvent carrier is replaced with water. The water component can constitute as much as 80 pe rcent of the coating, with the remaining 20 percent being the coating solids.

Higher Solids Coatings. These coatings contain at least 60 percent by volume of coating solids. VOC emissions are reduced th rough the use of these coatings because they contain less solvent per unit volume of solids than conventional solv ent-based coatings. Thus, a lesser amount of VOC emissions are released during coating preparation, application, and curing to deliver a given amount of coating solids.

Ultraviolet Coatings. Ultraviolet (UV) curable liquid and UV curable powder coatings are used for heat sensitive substrates as they allow for low curing temperatures. UV liquid coatings have been used for seve ral decades on parts made of wood, composite, and metal, but are not commonly used in the large appliance industr y. Because the entire coating must be exposed to the UV light s ource to achieve complete curing of the UV coating, UV curable coating applications presen t problems in the large appliance industry. Pigmentation used in the majority of large appliance coatings bloc ks the UV light. The shape of the large appliance also presents curing problems. Many la rge appliance products have bends or are box-shaped, creating areas which would be shaded from the UV light

source.

2. Cleaning Materials

Another main source of VOC emissions from large appliance coating is the cleaning materials. Proper cleaning removes all organic and inorganic soils from the substrate prior to coating, which is critical for achiev ing maximum performance from the coating, especially with powder coating. Cleaning and pr etreatment can consist of numerous stages that include several types of chemical wash es, such as solvent cleaning, an acid wash, a phosphate wash, and a deionized water wash. Fa cilities use various combinations of these stages. Except for solvent cleaning and wetti ng oil treatment, most stages do not emit any VOC emissions. Pretreatment and cleaning re quirements vary depending on the type of coating application and curing, as well as the type of metal to be coated.8 Cleaning materials are also used to clean coating equipment and to touch up the final products. These materials are typically VOC so lvents such as methyl ethyl ketone (MEK) and toluene. However, there has been an in crease in the use of al cohol and water-based

cleaners.

V. Available Controls and Existing Federal, State, and Local Recommendations/Regulations

As previously mentioned, there are two ma in sources of VOC emissions from large appliance coating operations: (1) evaporation of VOC fr om the coatings; and (2) evaporation of VOC from the cleaning materials. This section summarizes the available control options for reducing these VOC em issions and existing State and local VOC requirements.

A. Available Controls for VOC Emissions from Coatings

There are two general types of emissi on control techniques for reducing VOC emissions from large appliance coatings: pollution prevention measures and emission capture and add-on control systems. Polluti on prevention is the most prevalent control technique being used by the large applianc e surface coating industry. Add-on control systems are available to the industry, but fe w facilities utilize this control technique. Provided below is a summary of each of these types of control techniques.

1. Pollution Prevention Measures

Pollution prevention measures applicable to the large appliance industry, including product substitution/reformulation and work practice procedures, may be used to decrease VOC emissions from large appliance coatings. Coatings with low VOC content, such as waterborne coatings, higher so lids solvent-borne coatings an d powder coatings, may be used to reduce VOC emissions from coatings by re ducing or eliminating the organic solvent present in the coatings. Work practice pro cedures may also reduce VOC emissions from coatings during paint mixing, paint stor age, and paint transfer operations.

a. Product Substitution/Reformulation

The use of waterborne, higher solids, and powder coatings has increased since 1977. Paint manufacturers have developed and are continuing to develop waterborne, higher solids, and powder coating formulations that replace conventional solvent-borne coatings. These coatings are generally available and ofte n are not produced and marketed specifically for the large appliance coating industry. C onversion to these coatings can lower VOC emissions greatly, and most co atings operations, including most large appliance coating, are capable of converting to these coatings.

b. Work Practices

Work practice procedures are physical acti ons intended to affect emission reductions. Because work practice procedures are specifica lly tailored to an industry, they may vary from a few manual operations to a complex program.

For the large appliance industry, work pract ice procedures may be appropriate for the following activities:

• Coating Storage and Handling:9 Storage demands vary based on the type of coating and usage requirements. Container size and type vary depending on co ating manufacturer and end user needs. Most coatings are stored in 208 liter (55 gallon) drums. Po wder coatings can also be stored in drums, as long as the temperat ure and the humidity are controlled. Most facilities store powder coatings in 23 k ilogram (50 pound) cardboard boxes that are lined with plastic to preven t moisture absorption, but th e size of the container can vary from 1.4 to 136 kilograms (3 to 300 pounds). These containers should be well maintained to prevent leakage and excessive spillage or material loss during transfer to other containers or coating equipment. They should also remain sealed except when it is necessary to remove material fr om the containers, after which they should be promptly closed again.

• Fluid Handling Equipment: All fluid handling equipment such as co ating supply lines, holding tanks, coating storage containers, or any fluid handling equipment that contains a VOC-containing coating should be well maintained to preven t spills, leaks, or other problems that

would release some of the conten ts of the fluid handling system.

• Mixing Operations: Coating mixing may be performed in an agitated 208 liter drum, or it may be performed by merging two different coati ng supply lines into one. Mixing vessels should have a top that prevents VOC emissi ons during the agitation process. Store mixed coatings and solvents in closed cont ainers when not being combined to reduce

VOC emissions.

Some large appliance coating f acilities, either purs uant to Federal, State and/or local regulations or on their own initi atives, develop and implement wo rk practice plans to control VOC emissions. These plans set forth the steps to be taken to ensure that work practices are implemented properly to minimize VOC emissions during coating processes. Such a plan is a compliance option under the 2002 NESHAP. The use of a work practice plan is a traditional approach for reducing emissions during cleaning operations in various industries, including the large appliance coating industry. As shown by these industries, work practice plans can be easily adopted and managed.

2. Emission Capture and Add-On Control Systems

In addition to pollution prevention measur es, VOC emissions from large appliance surface coating operations can be reduced by the us e of capture systems, in conjunction with add-on control systems that either destroy or recover the VOC in the exhaust streams. As stated previously, although captu re systems and add-on control devices are available to the large appliance surface coating industry, EPA is aware of only a few cases where this control technology is utilized by the industry. The majority of VOC emissions from large appliance coating operations occu r in the spray booth. Spray booths typically exhaust a high

volume of air with a low concen tration of VOC which can result in a high cost of control.

The prevalent method of destruction of orga nic solvent emissions from coatings is thermal oxidation. The organic solvent-containi ng exhaust air is heated to a very high temperature, which converts it to carbon di oxide and water through the process of combustion. There are several options for VOC control by oxidation. They include: (1) direct, gas-fired, thermal recuperative oxidation; (2) direct, gas-fired, thermal10 regenerative oxidation; (3) dire ct, electrically heated, therma l regenerative oxidation; (4) direct, electrically heated, catal ytic oxidation; and (5) direct , gas-fired, cata lytic oxidation.

Direct, gas-fired, therma l recuperative oxidizers usually operate at temperatures of

760 E C (1400 E F) and use a natural gas burner. The residence time for organic solvent rich

air is about 0.5 seconds. This t ype of unit is usually constructed solely of steel and utilizes heat exchangers to recover heat. These oxi dizers can achieve a high VOC destruction (98 percent efficient or better), especially when the VOC concentration in the inlet stream is high. These devices are not the most efficient for heat recove ry, but it is possible to use waste heat to produce steam or heated air. Their all steel construction becomes a problem when hydrochloric acid is produced as a produc t of the combustion of chlorinated organic

solvents.

Direct, gas-fired, therma l regenerative oxidizers utilize ceramic towers in a 3-, 5- or 7-chamber configuration to achieve heat recovery efficiencies in the 80-95 percent range. For this reason, the unit produces less NO X emissions and uses very little natural gas. Regenerative oxidizers can be effective for ai rstreams with flow rates of 280 to 4,250 cubic meters per minute (10,000 to 150,000 cubic feet per minute). Regene rative oxidizers are capable of achieving high destruction efficienci es similar to those of recuperative oxidizers.

Direct, electrically heated, thermal regenerative oxidizers are based on the principle that if enough organic solvent emissions ente r the unit at high con centrations then the combustion process will maintain itself usi ng only the heat of the organic solvent

combustion. Electric coils within the unit ar e used to bring the unit up to its operating temperature (760 E C) as well as to help maintain ope rating temperature when the organic

solvent concentrations in the effluent stream drop below critical levels. The unit itself

creates no NO X , CO, or CO 2 emissions because it operates on electricity instead of the combustion of natural gas or other fuels. Some problems with these t ypes of units include a long startup time and costly operation due to the electricity required to operate them properly. Another problem with this type of oxidizer is that hydrochloric acid from the oxidation of chlorinated organic solvents can destroy the electric coils in the unit.

Direct, electrically heated, catalytic oxidizers use precious metal catalysts as an integral part of the combusti on chamber which allows for lower combustion temperatures in the range of 320 to 430 E C (versus 760 E C for non-catalytic oxidizers). These units use electric coils for startup and temperature mainte nance. These units are typically constructed completely of steel with integrated catalyst units. They do not produce NO X or CO, nor do they require large amounts of el ectricity because they run at re latively low temperatures and they use heat exchangers to pre-heat in coming air. The catalyst must be cleaned periodically. Also, the catalyst effectiven ess may be masked by halogens, metals, nonorganic solvent resins, and other materials. If appropriate materi als are used in the combustion chamber and the electric coils, halogenated solvents can be oxidized.

Direct, gas-fired, catalytic oxidizers are similar to the electric catalytic oxidizers except that they use gas fired bur ners, instead of electric coils, for makeup heat. They also use precious metal catalysts. These oxidizers ut ilize heat exchangers to pre-heat exhaust air, which reduces fuel requirements to relative ly small amounts. If their catalysts are contaminated by halogen resins or high boi ling organic solvents, the units may produce

some NO X or CO emissions.11 Carbon adsorption as a technique for orga nic-solvent recovery has been used commercially for several decades. Spray applied coatings contain a mixture of several organic solvents in order to maximize gloss, tr ansfer efficiency, and other desirable coating properties. Organic solvent recovery is usua lly most effective econom ically and technically when used with air streams containing a few, expensive organic solvents. In a carbon adsorption system with steam desorption, carbon beds adsorb organic solvents from the air stream passing through them. In most cases, one bed is in the adsorption phase while the second bed is in the steam desorption phase. In the desorption phase, steam is passed through the carbon to releas e the collected organic solvent. Once the steam has been passed through the carbon, it is then condensed and the organic solvent is removed through the process of settling or distillation. The carbon desorption phase can be performed on site or the spent carbon can be shipped off-site for rege neration. The efficiency of this type of system can be very high when there are lo w organic solvent concentrations in the air exhausted from the application booths. Advantages of the carbon adsorption/steam desorption system are that they are relatively inexpensive and have been proven effective over the years. They can handle a relatively high volume of air (about 30 to 1,400 cubic meters per minute) efficiently. Also, because the organic solvent is reclaimed there are no carbon monoxide (CO), carbon dioxide (CO 2 ), or nitrogen oxide (NO X ) emissions that are usually associated with the dest ruction of used organic solven t in air streams by combustion. Also, if the recovered organic solvents can be re-used it reduces the demand for production of additional organic solvent. The disadvantag es of these systems result from the difficulty of separating organic solvents from each othe r for re-use. Also, if water soluble organic solvents (i.e., alcohols, etc.) are used, it may be difficult to separate the organic solvents from water. In addition, carbon does not adsorb all organic solvents. Therefore, the blend of organic solvents in use must be determined and considered before choosing this type of system. Another problem with systems of this type is that organic solvent quality can be degraded while the organic solvent is held on the carbon.

B. Available Controls for VOC Emi ssions from Cleaning Materials

Pollution prevention measures and emission capture and add-on control systems are also employed to reduce VOC emissions from cleaning materials used in large appliance coating facilities.

1. Pollution Prevention Measures

Product substitution/reformulation and work practice procedures are pollution prevention measures that may be used to decr ease VOC emissions from cleaning materials. Alternative cleaners, such as alcohols and citr us-based cleaners, may be used to reduce VOC emissions from cleaning operations.

Work practice procedures may also redu ce VOC emissions from materials during cleaning operations. An example of a cleani ng specific work practice involves spraying operations and cleaning. Nozzle maintenan ce, although often overlooked, is a critical component of any metal pretreatment system. In order to keep the system running at maximum efficiency to produce the highest-qua lity finished product, nozzle maintenance must become a regular part of system opera tion. Improperly mainta ined nozzles decrease spray impact and distort spray patterns, reducin g cleaning efficiency. As a result, more time will be spent and more chemicals will be used to accomplish cleaning tasks. Learning to12 identify, solve, and prevent spray nozzle perf ormance problems in a parts washer can cut spray liquid and energy waste, assure better washer perfor mance, and reduce chances of equipment damage. The same holds true fo r coating spray nozzles. Typical cleaning activities involve organic solv ent wipes, dips, and spraying of pure organic solvent which

can contribute to the emissions from a facili ty. The amount of organic solvent emissions

released from these activities can be minimi zed by taking actions such as storing cleaning materials in covered containers, using only the smallest amount of cleaning materials necessary, and collecting and plac ing solvent-laden cleaning materials in closed containers immediately after they are used.

2. Emission Capture and Add-On Control Systems

Carbon adsorption units or oxi dizers can be used to control VOC emissions from cleaning operations as well as coating operati ons. Large appliance coaters can employ addon controls, such as carbon adsorption units or oxidizers, to reduce their VOC emissions from cleaning operations.

C. Existing Federal, State, a nd Local Recommendations/Regulations

Provided below is a summary of EPA actions , as well as State and local regulations, that address VOC emissions from large applia nce coating processes. In addition, Table 1 outlines these Federal, State and local provisions and the bases for these provisions.

1. The 1977 CTG

The 1977 CTG recommended limiting VOC em issions from each large appliance coating unit. A coating unit cons ists of a series of one or mo re coating applicators and any associated drying area and/or oven wherein a coating is a pplied, 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. (Two-step powder coating systems in which the powder coating is preceded by an adhesion enhancer may be considered as a single coating unit.) It is not necessary for a coating unit to have an oven or a flash-off area.

For each coating unit, the 1977 CTG recommended a daily volume-weighted average limit of 0.34 kg/l (2.8 lb/gal) of coating, excludi ng water and exempt compounds, as applied. The emission limit was based on the use of low VOC content coatings and can be achieved with coatings which contain at least 62 volume percent solids or any wa terborne equivalent. It was anticipated that this emission limit would result in approximately an 80 percent

reduction in VOC emissions over conventional so lvent-borne coatings that contain about 25 volume percent solids. An equivalent reducti on could be achieved by use of add-on control

devices such as thermal oxidation or carbon adso rbers. Even greater reductions, 90 percent and more, could be achieved by conversion to electrodeposited waterborne coatings or powder coatings. There was no single control t echnique that was cons idered best for the entire industry since the large appliance industry included a wide variety of products. At the time, it was believed that most facilities would seek to meet future regulations through the use of low VOC content coatings rather th an using to add-on control technologies.13 2. The 1982 NSPS

The 1982 NSPS applies to coating of large a ppliance products and parts at facilities that commence construction, modification, or reconstruction after December 24, 1980. The NSPS defines a large appliance part as any organic surface-coated metal lid, door, casing, panel, or other interior or exterior metal part or accessory that is assembled to form a large appliance product. Parts subject to in-use temperatures in excess of 250 ◦ F are not included in this definition. Large app liance product is defined as any organic surface-coated metal range, oven, microwave oven, refrigerator, freezer, washer, dryer, dishwasher, water heater, or trash compactor manufactured for household, co mmercial, or recreational use. The NSPS establishes a monthly volume-we ighted average VOC limit of 0.90 kg/l (7.5 lb/gal) coating solids deposited for each surface coating opera tion on a large appliance surface coating line.

3. The 2002 NESHAP

EPA promulgated the large appliance surface coating NESHAP on July 23, 2002. Since the rule development was c onducted within the past five (5) years, it was determined that the information collected during the ru le’s development would be consistent with current large appliance coating facilities.

Per the 2002 NESHAP, large appliance surface coating facilities are likely to be included under SIC codes 3631, 3632, 3633, 3639, 3582, 3585, and 3589 (excluding special industry machinery, industrial and commercial machinery a nd equipment, and electrical machinery equipment and supplies not elsewhere classified). Typical NAICS codes for this industry include 335221, 335222, 335224, 335228, 333312, 333415, and 333319 (also excluding special industry machin ery, industrial and commercial machinery and equipment, and electrical machinery equipment and supp lies not elsewhere classified). The large appliance source category includes facilities that apply coat ings to large appliance parts or products. In the NESHAP, large appliances includes “white goods” such as ovens, refrigerators, freezers, dishwashers, laundry e quipment, trash compactors, water heaters, comfort furnaces, and electric heat pumps. The source category also includes most heating, ventilating, and air conditioning (HVAC) e quipment intended for any application. However, the NESHAP did not include inthe source category motor vehicle airconditioning units, heat transf er coils, and large commerci al and industrial chillers.14 Table 1. Summary of Existing Requirements

Existing Regulation Emission Limit Basis for Emission Limit

Large Appliance Coating CTG (December 1977) Recommended VOC emission limit of 2.8 pounds of VOC per gallon of coating, excluding water and exempt compounds, as applied (daily volume-weighted average) (narrow definition of coating unit) Calculated based on the use of higher solids coatings (62 percent solids) with an assumed VOC density of 7.36 lb/gal. Associated with a baseline transfer efficiency of 60 percent.

Large Appliances NSPS (October 27, 1982) VOC emission limit of 7.5 pounds of VOC per gallon of coating solids deposited from any surface coating operation on a large appliance surface coating line (monthly volume-weighted average) (narrow definition of coating operation) Based on the use of higher solids coatings (62 percent by volume solids) with an assumed VOC density of 7.36 lb/gal and a baseline transfer efficiency of 60 percent.

Large Appliances NESHAP (July 23, 2002) Existing sources: HAP emission limit of 1.1 pounds of organic HAP per gallon of coating solids used

New sources: HAP emission limit of 0.18 pounds of organic HAP per gallon of coating solids used MACT level of control based on 2000 survey of coating materials used in the industry

California – South Coast Rule 1107 (Originally adopted June 1, 1979 with last amendment January 6, 2006) VOC emissions limits for the coating of metal parts and products (which includes large appliance coating) of: (1) 2.3 pounds of VOC per gallon (0.275 kilograms per liter) of coating, excluding water and exempt compounds, as applied for general one component coatings (air-dried and baked) and general multi-component baked coatings; and (2) 2.8 pounds of VOC per gallon (0.34 kilograms per liter) of coating, excluding water and exempt compounds, as applied for general multi-component air-dried coating. Includes specific limits for specialty coatings such as extreme high gloss, high temperature, and metallic coatings. Electrostatic application, flow coat, dip coat, roll coat, HVLP spray, hand application methods, or other coating application method capable of achieving a transfer efficiency equivalent or better than that achieved by HVLP spraying required. Similar to the 1977 CTG but using a coating with 69 percent volume solids for general one-component (air-dried and baked) coatings and for general multi-component baked coatings, 62 percent volume solids for general multi-component air-dried coatings and a transfer efficiency of 65 percent15 Table 1. Summary of Existing Requirements (Continued)

Existing Regulation Emission Limit Basis for Emission Limit

California – South Coast Rule

1107 Continued Exempts coatings and operationssuch as stencil coatings, safetyindicating coatings, touch-up coatings and application with

hand-held aerosol cans.

Alternative to the emissions limit and operating equipment requirement allows the use of capture and control equipment to collect at least 90 percent by weight of the VOC emissions generated by the sources of VOC emissions (capture efficiency)

and reduce VOC emissions from

an emission collec tion system by at least 95 percent by weight (control efficiency).

California - Bay Area Regulation 8, Rule 14 (Originally adopted March 7, 1979 with last amendment October 16, 2002) Method of coating application must have a transfer efficiency of 65% or greater. VOC emission limit for baked coatings of 2.3 pounds per gallon (0.275 kilograms per liter) of coating, excluding water and exempt compounds, as applied and for air-dried coatings of 2.8 pounds per gallon (0.34 kilograms per liter) of coating, excluding water and exempt compounds, as applied. Includes specific limits for specialty coatings such as extreme high gloss, high temperature, and metallic coatings. Similar to the 1977 CTG but using a coating with 69 percent volume solids for baked coatings and 62 percent volume solids for air-dried coatings and a transfer efficiency of 65 percent

State Regulations: 22 State rules specifically for large appliance coating operations were identified VOC emission limit of 2.8 pounds of VOC per gallon of coating, excluding water and exempt compounds, as applied, or

an overall emission reduction of 90 percent by utilization of an

add-on control device 1977 CTG16 The NESHAP’s affected source includes all of the activities that involve coatings, thinners, and cleaning materials used in large appliance coati ng operations. These activities

include:

1) Surface preparation of the large appliance parts or products; 2) Preparation of coati ngs for application; 3) Applying the coatings; 4) Flash-off, drying, or curing f the coatings; 5) Cleaning of coating equipment; 6) Storage of coatings, thinne rs, and cleaning materials; 7) Conveying of these materials; and 8) Handling and conveying of waste materi als generated by the coating operation.

For the 2002 NESHAP, EPA selected the pollutants to regulate based on some assumptions generated during the rule devel opment. Emission data collected during the development of the rule showed that th e primary organic HAP emitted from the surface coating of large appliances in cluded xylene, glycol ethers, toluene, methylene diphenyl diisocyanate, and MEK. These compounds accounted for approximately 82 percent of this category’s nationwide organic HAP emissions . However, many other organic HAP are used, or can be used, in large appliance co atings, thinners, and cleaning materials. Therefore, the rule regulated emissions of all organic HAP. Although most of the coatings used in this source category do not contain inorganic HAP, some sp ecial purpose coatings used by this source category were found to contain inorganic HAP such as chromium, cobalt, lead, and manganese. Emissions of th ese materials to the atmosphere are minimal because the facilities in this source category em ploy either water curtains or dry filters that remove overspray particles from the spray booth e xhaust. At the time, it did not appear that emissions of inorganic HAP from this s ource category warranted Federal regulation.

The final rule established different emissi on limits for existing and new sources. For an existing source, the organic HAP emissions limits is no more than 0.13 kilograms per liter (1.1 pounds per gallon) of coating so lids used during each compliance (monthly) period. For a new or reconstructed source, th e organic HAP emissions limit is no more than 0.022 kilograms per liter (0.18 pounds per gallon) of coating solids. The limits apply to the total of all coatings, thinners, and cleaning materials used in coating operations at the affected source. Existing sources had to be in compliance no later than July 25, 2005. New

or reconstructed sources have to be in compliance by this same date or upon startup,

whichever is later. These HAP emission limits take into acc ount products that contain MEK even though in December 2005, EPA amended the list of HAP contained in section 112 of the CAA by removing MEK. It is unclear at this point how MEK be ing delisted as a HAP has affected the large applia nce coatings formulation. Th e NESHAP established three compliance options for meeting the emissions limits.

1) Compliant Material Optio n – Each coating used in the operation mu st meet the limit, and each thinner a nd cleaning material must contain no organic HAP.

2) Emission Rate Without Add-on Controls Option – The facility may average all of the coatings, thinners, and cleaning materials together and demonstrate that the overall emission rate is in compliance with the applicable limit.17 3) Emission Rate With Add-on Controls Option – This option applies to coating operations for which add-on controls are us ed to meet the limit. The facility must meet certain operating limits for th e capture systems and control devices and follow a work practice plan for ma terial storage, mixing, conveying, and spills.

4. Existing State and Local VOC Requirements

Every State has incorporated the large appliance coating Federal regulations described above (1982 NSPS and 2002 NESHAP). In addition, 22 States have specific large appliance coating regulations . 21 states have adopted the 1977 CTG recommended VOC emissions limit of 0.34 kilogram per liter (2.8 pounds per gallon) of co ating, excluding water and exempt compounds, as applied. Five (5) St ates also have equiva lent pound of VOC per gallon of coating solids used emissions limits. Appendix B provides a table which summarizes the large appliance co ating regulations that are speci fic to a State and/or local agency within that State.

The California South Coast Air Quality Management District (South Coast) has adopted limits for large applianc e coating that are, in part, mo re stringent than the 1977 CTG

recommendation. The VOC emissions limits esta blished by the South Coast for the coating of metal parts and products (w hich includes large appliance coating) are: (1) 275 grams VOC per liter (g VOC/l) (2.3 lb VOC/gal) of coating, excludi ng water and exempt compounds, as applied for general one-compone nt coatings (air-dri ed and baked) and general multi-component baked coatings; and (2) 340 g VOC/l (2.8 lb VOC/gal) of coating, excluding water and exempt compounds, as a pplied for general multi-component air-dried coatings. The South Coast regulation also include s specific limits for specialty coatings such as extreme high gloss, high temperature, and me tallic coatings. The South Coast regulation specifies the following application methods: el ectrostatic application, flow coat, dip coat, roll coat, HVLP spray, hand application met hods, or other coating application method capable of achieving a transfer efficiency e quivalent or better than that achieved by HVLP spraying. Coatings and operations such as st encil coatings, safety -indicating coatings, touch-up coatings and applicati on with hand-held aerosol cans are exempt from the South Coast’s regulation. As an alternative to the emissions limit and operating equipment requirement, the South Coast regulation allows the use of capture and control equipment to collect at least 90 percent by weight of the VOC emissions generated by the sources of VOC emissions (capture efficiency) and reduce VOC emissions from an emission collection system by at least 95 percent by weight (control efficiency).

The California Bay Area Air Quality Mana gement District (Bay Area) has also adopted limits for large applianc e coating that are, in part, mo re stringent than the 1977 CTG recommendation: (1) 275 grams of VOC pe r liter (2.3 pounds of VOC per gallon) of coating, excluding water and exempt compounds, as applied for baked coating; and (2) 340 grams of VOC per liter (2.8 pounds of VOC per gallon) of coating, excluding water and exempt compounds, as applied for air-dried coat ing. Like the South Coast regulations, the Bay Area regulations include specific limits for specialty coatings and exemptions for some coatings and coating operations. In addition, the Bay Area rule requires the use of coating application equipment that can meet a 65 percent or greater transfer e fficiency. Per the Bay Area regulation, compliance with the standard’s 65 percent or great tran sfer efficiency can18 be achieved by properly operated electrostatic application or HVLP spray, flow coat, roller coat, dip coat including elect rodeposition, and brush coat.

VI. Recommended Control Options

Based on a review of the 1977 CTG, the 1982 NSPS, the 2003 NESHAP, and the current State and local requirements discusse d above, we are recommending emission limits for controlling the VOC emissions from the co atings used by large appliance manufacturing facilities and work practices to further reduce VOC emissions from coatings as well as to minimize emissions from cleaning materials used in metal furniture surface coating

processes.

To control VOC emissions from large a ppliance coatings, we are recommending three alternatives: (1 ) emission limits that can be achi eved 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 contro ls. The low-VOC co atings recommendation

consists of emission limits in terms of mass of VOC per volume of co ating, excluding water and exempt compounds, as applied and the us e of specified application methods. The equivalent emission limit recommendation consis ts of emission limits in terms of mass of VOC per volume of coating solids, as applie d, and the use of specific application methods.

We estimate that these recommendations will reduce VOC emissions from large appliance coatings by about 30 percent (a reduction of 1,000 tons of VOC from the nonattainment area facilities). In our analysis of the impacts of the recommended level of control, we have assumed that all facilitie s will choose to utili ze the low-VOC coating materials alternative. We made this assump tion for two reasons. First, we believe that complying low-VOC coating materials are alrea dy widely available at a cost that is not significantly greater than the cost of coating materials with higher VOC contents. Secondly,

the use of add-on controls to reduce emissions from typical spray co ating operations would be a more costly alternative.

For cleaning materials, we are reco mmending work practices to reduce VOC

emissions. We do not have information av ailable regarding curre nt VOC content to determine a RACT limit for cleaning material s used in large appliance surface coating operations. Therefore, we are not recommending the use of a VOC content limit for cleaning materials. We are also not recomme nding the application of add-on controls solely as a means of reducing VOC emissions from cl eaning materials. This would be a very costly alternative because the area to be cont rolled is quite large and a large volume of air would need to be captured and directed to a control device. However, any cleaning activities that occur within a capture device used to control VOC emissions from coating operations would be controlled by the associated control device.

The following paragraphs summarize our specific recommendations for coating operations and cleaning materials used in la rge appliance surface co ating operations.19 A. Emissions Limits based on Low-VOC Coatings

We are recommending emission limits for one-component and multi-component general purpose coatings. In addition, we are recommending specific emission limits for certain specialty coatings. For each of these coating types, we are recommending separate

emission limits for baked and air-dried coa tings. Provided below are our recommended emission limits expressed in terms of mass of VOC per volume of coating, excluding water and exempt compounds, as applied:

The recommended emission limits can also be expressed in te rms of mass of VOC per volume of coating solids, as applied. A facility could use low-VOC coatings or a combination of coatings and add-on contro l equipment on a coating unit to meet the recommended mass of VOC per volume of coat ing solids, as applied, limits. Using an assumed VOC density of 7.36 pounds per gallon, equivalent limits in terms of mass of VOC per volume of solids, as applied, are as follows:

We are also recommending that the following types of coatings and coating operations be exempt from our recommended VOC content limits:

• Stencil coatings

• Safety-indicating coatings

• Solid-film lubricants

• Electric-insulating and th ermal-conducting coatings Baked Air Dried Coating Type 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 0.340 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

Baked Air Dried Coating Type 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 Pretreatment Coatings 0.80 6.7 0.80 6.7

Solar Absorbent 0.61 5.1 0.80 6.720 • Touch-up and repair coatings

• Coating application utilizing hand-held aerosol cans

We are recommending that all VOC-containing materials (i.e., coatings and thinners) used by each large appliance surface coating un it are included when determining the coating unit’s emission rate. In addition, we are reco mmending the use of the following application methods: electrostatic application, HVLP spray, flow coat, roller coat, dip coat including electrodeposition, brush coat, or other coating application me thod capable of achieving a transfer efficiency equiva lent or better than that achieved by HVLP spraying. The

recommendations described above are based on the South Coast’s metal parts and products coating regulation, which in cludes large appliances.

The VOC content limits can be met by averag ing the VOC content of materials used on a single surface coating unit each day (i.e., daily within-coating unit averaging). We do not recommend the use of cross-coating unit averaging (i.e., averaging across multiple coating units) to meet the VOC content limits . However, we have previously provided guidance on cross-line averaging 4 . The guidance is directed to State and local agencies that elect to adopt a discretiona ry economic incentive programs (EIP) and includes guidance on the use of cross-line averaging

. B. Optional Add-On Controls for Coating Operations

Should product performance requirements or other needs dictate the use of higherVOC materials than those that would meet th e recommended emission limit, a facility could choose to use add-on control equipment to meet an overall control efficiency of 90 percent. Alternatively, a facility could use a combina tion of coatings and a dd-on control equipment on a coating unit to meet the recommended mass of VOC per volume of coating solids

limits. Add-on devices include oxidizers and so lvent recovery systems that, coupled with their attendant systems to capture the VOC bei ng released at the aff ected facilities, can

achieve an overall control effi ciency of 90 percent. This control option, like the options noted above, applies to all coatings and thinners applied to large appliances.

C. Work Practices for Coating Op erations and Cleaning Materials

In addition to the control options above, this CTG recommends work practices to further reduce emissions from the coatings as well as to minimize emissions from the cleaning materials used for large applian ce coating operations. Although VOC reductions achieved by implementing the work practice r ecommendations may not be quantifiable, we believe they are beneficial to the overall goal of reducing VOC emissions. We recommend implementing work practices for solvent storage, mixing operations, and handling operations for coatings, thinners, cleaning materi als, and waste materials. Specifically, we recommend the following work practices: st ore all VOC-containing co atings, 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 ve ssels that contain VOC

4 Improving Air Quality with Economic Incentive Programs. U.S. Environmental Protection Agency. Research Triangle Park, NC. EPA-452/R-01-001. January 2001.21 coatings and other materials except when specifi cally in use; and minimize usage of solvents during cleaning of storage, mixi ng, and conveying of equipment.

VII. Cost Effectiveness of Recommended Control Options

As previously mentioned, the recommendati ons in this CTG are similar to the South Coast regulations govern ing large appliance coating operati ons. Unfortunately, the costeffectiveness of these regulations was not esti mated during those regula tions’ development. Therefore, cost-effectiveness estimates for th e recommended control levels were determined based on information collected during the 1977 CTG and the 2002 NESHAP development. Although the 2002 NESHAP regulates organic HAP, the 2002 NESHAP cost estimates are

relevant to this CTG’s recommended levels of control because they are based on the use of the similar control measures (i.e., product subs titution/reformulation a nd work practices) for large appliance coatings and cleaning material s as those recommended in this CTG. In addition, the 2002 NESHAP provides data regarding large applia nce coating f acilities that

are more current than the 1977 CTG.

During the development of the 2002 NESHAP, it was estimated that no facility within the industry would install add-on control devices as a result of the standard. The capital costs and annual operating costs of add- on control devices us ually make them less desirable than other compliance options for reducing VOC emissions from spray coating operations.

In the 1977 CTG, the cost effectiveness for a medium-sized facility using waterborne prime and higher solids topcoat was estimated to be $141 per megagram ($128 per ton) of VOC reduced. This would be approxim ately $425 per ton in 2006 dollars based on

historical CPI data from www.inflationdata.com . The 2002 NESHAP presented a control cost of $480,000 for 1,191 tons of HAP reduction from 74 facilities expected to be subject to the rule ($403 per ton HAP reduced, about $480 per ton in 2006 do llars). For, the recommendations in this CTG, we therefore es timate a cost-effectiveness of $500 per ton of

VOC reduced. We estimate the total annua l cost of the estimate d 1,000 tpy of emission reduction to be $500,000.22 VIII. References

1. Control of Volatile Organic Emissions from Existing Sources - Volume V: Surface Coating of Large Appliances. Publ ication No. EPA-450/2-77-034. U. S. Environmental Protection Agency, Resear ch Triangle Park, NC. December 1977.

2. Bay Area (California) Air Quality Mana gement District Regulation 8, Organic Compounds, Rule 14, Surface Preparation and Coating of Large Appliances and Metal Furniture. Amended October 16, 2002.

3. South Coast (California) Air Quality Mana gement District Re gulation XI, Source Specific Standards, Rule 1107, Coating of Metal Parts and Products. Amended January 6, 2006.

4. National Emission Standards for Hazardous Air Pollutants (NESHAP) for Source Category: Large Appliances Surface Co ating Operations - Background Information for Promulgated Standards. EPA-453/R- 02-004. U. S. Environmental Protection Agency, Research Triangle Park, NC. April 2002.

5. Industrial Surface Coating: Appliances – Background Information for Proposed

Standard. EPA-450/3-80-037a. U. S. E nvironmental Protection Agency, Research Triangle Park, NC. November 1980.

6. Improving Air Quality with Economic Incentive Programs. U.S. Environmental Protection Agency. Research Triangl e Park, NC. EPA-452/R-01-001. January

2001.

## Appendix A: 1977 Large App liance Coating CTG DocumentThis page intentionally left blank.This page intentionally left blank.

## Appendix B: Summary of St ate-Specific Large Appliance Coating RegulationsThis page intentionally left blank.State County/Area VOC Limit Applies To VOCLimit Emission Limitation Achieved ByAL JeffersonApplication area(s), flash-off area(s), andoven(s) of coating lines involved in prime,single, or topcoat coating operations. Doesnot apply to the use of quick-dryinglacquers for repair of scratches and nicksthat occur during assembly, provided thatthe volume of coating does not exceed 757liter/yr (200 gal/yr).0.34 kg/liter (2.8 lb/gal) ofcoating, excluding water,delivered to the coatingapplicator from prime, single,or topcoat coating operations.AZ MaricopaApplication of coating, coatingpreparation/mixing at the facility applyingthe coating, & thecleanup of coatingapplication equipment. Does not apply tocoatings with VOC content, minus exemptcompounds, of less than 0.15 lb VOC/gal(18 g/liter) nor to solvents having a VOCcontent of material less than 0.15 lbVOC/gal.2.8 lb/gal or 0.34 kg/liter ofcoating (minus water)For coating containing more than 2 lb VOC/gal(240 g/liter) minus exempt compounds:1. Low-pressure spray gun2. Electrostatic system3. Atomizing system by hydraulic pressure,including "airless" and air-assisted airless"4. Non-atomizing or non-spraying applicationssuch as dipping, rolling, or brushing5. Any method approved by the Federal EPAAdministrator and Control Officer having atransfer efficiency of 65% or greaterCABay AreaDoes not apply to the use of any coatingused in volumes less than 75.7 liters/yr (20gal/yr) (facility limited to 208.1 liters or 55gallons total coating/yr). Also does notapply to surface preparation of electricaland electronic components, stripping ofcured inks, coatings and adhesives orcleaning of resin, coating, ink and adhesivemixing, molding and application equipment,or surface preparation associated withresearch and development operations;performance testing to determine coating,adhesive or ink performance; or testing forQA/QC purposes.Method of coating applicationmust have a transfer efficiencyof 65% or greater and then aVOC emission limit for bakedcoatings of 2.3 lb/gal(275 g/L) and for air-driedcoatings of 2.8 lb/gal(340 g/L) of coating,excluding water. Includesspecific limits for specialtycoatings such as extreme highgloss, high temperature, andmetallic coatings.State County/Area VOC Limit Applies To VOCLimit Emission Limitation Achieved BySouth CoastApplies to all metal coatings operationsexcept those performed on aerospaceassembly, magnet wire, marine craft, motorvehicle, metal container, and coil coatingoperations. This rule does not apply to thecoating of architectural components coatedat the structure siteor at a temporaryunimproved location designated exclusivelyfor the coating of structural components.2.3 lb/gal (0.275 kg/liter) ofcoating, excluding water andexempt compounds, as appliedfor general one componentcoatings (air-dried and baked)and general multi-componentbaked coatings; and 2.8 lb/gal(0.34 kg/liter) of coating,excluding water and exemptcompounds, as applied forgeneral multi-component airdried coating. Includesspecific limits for specialtycoatings such as extreme highgloss, high temperature, andmetallic coatings.Electrostatic application, flowcoat, dip coat, roll coat, HVLPspray, hand applicationmethods, or other coatingapplication method capable ofachieving a transfer efficiencyequivalent or better than thatachieved by HVLP sprayingrequired.COCoating line; prime, single or topcoatapplication area, flash-off area, and oven0.34 kg/liter coating or 2.8lb/gal coating (minus water)State County/Area VOC Limit Applies To VOCLimit Emission Limitation Achieved ByDEAny large appliance coating unit. Does notapply to a facility whose actual emissionsw/out control devices from all largeappliance coating units w/in the facility are<6.8 kg VOC/day (15 lb VOC/day) or theuse of quick-drying lacquers for repairs ofscratches & nicks that occur duringassembly, provided that the volume ofcoating does not exceed 0.95 liter/any 8-hrperiod (0.25 gal/any 8-hr period).0.34 kg/liter (2.8 lb/gal) ofcoating (minus water &exempt compounds)1. Installing and operation a capture system2. Installing and operation a control device3. Determining the overall emission reductionefficiency for each day needed to demonstratecompliance4. Demonstration each day that the overallemission reduction efficiency achieved for thatday is greater than or equal to the overallemission reduction efficiency required for thatdayFLApplication areas, flash-off areas, and ovensof coating lines involved in prime, single, ortopcoat coating operations.0.34 kg/liter (2.8 lb/gal) ofcoating (excluding water)1. Application of low solvent content coatingtechnology2. Incineration, provided that 90% of the VOCwhich enter the incinerator are oxidized tocarbon dioxide and waterILDoes not apply to use of quick-dryinglacquers for repair of scratches & nicks thatoccur during assembly, provided that thevolume of coating does not exceed 0.95liter/any one 8-hr period (1 qt/any 1 8-hrperiod)0.34 kg/liter (2.8 lb/gal) ofcoating (minus water &exempted compounds)INCoating application (prime, single, ortopcoat coating operations). Does not applyto use of quick-drying lacquers for repair ofscratches & nicks that occur duringassembly (limited to 1 gal in an 8-hrperiod).0.34 kg/liter (2.8 lb/gal) ofcoating (minus water)State County/Area VOC Limit Applies To VOCLimit Emission Limitation Achieved ByKYApplies to facilities commenced before6/29/79 located in a ozone nonattainmentcounty. Does not apply to any affectedfacility:1) if the VOC content of the coating is<0.34 kg/liter (2.8 lb/gal) (minus water orexempt solvent)2) repair coating operations3) total VOC emissions are less than orequal to 3 lb/hr actual, 15 lb/day actual, or10 ton/yr potential before control4) low-use coatings if plantwideconsumption of these coatings in theaggregate is less than or equal to 55 galsduring the previous 12 monthsNo facility discharge of VOCinto the atmosphere more that15% by weight of the VOCnet input into the facilityMDDoes not apply to use of quick-dryinglacquers for repair of scratches & nicks thatoccur during assembly.0.34 kg/liter (2.8 lb/gal) ofcoating (minus water)MIThe primer surface or topcoat coatingincludes an anti-chip, blackout, or spotprimer coating if this coating is applied aspart of the primer surface or topcoat coatingoperation. Does not apply to coatings thatare used for the repair of scratches & nicks.Exceptions also include coating lines w/in astationary source with actual VOCemissions <100 lb/day or 2,0000 lb/monthand excludes low-use coatings that total 55gallons or less per rolling 12-month period.2.8 lb VOC/gal of coating(minus water) or 7.5 lbVOC/gal of applied coatingsolidsState County/Area VOC Limit Applies To VOCLimit Emission Limitation Achieved ByNJSurface coating operation located at a majorVOC facility having the potential to emit 3lb VOC/hr or more.0.34 kg/liter (2.8 lb/gal) ofcoating (minus water)May apply to alternative maximum allowableVOC limit per volume of surface coatingformulation provided that the surface coatingformulation is applied ata transfer efficiency ofgreater than 60 percent.NCApplication area(s), flashoff area(s), andoven(s) of coating lines involved in prime,single, or topcoat coating operations. Doesnot apply to the use of quick-dryinglacquers for repair of scratches and nicksthat occur during assembly, if the volume ofcoating does not exceed 1 qt in any 8-hrperiod.4.5 lb VOC/gal of solidsdelivered to the coatingapplicator from prime, single,or topcoat coating operations.If controlled by approved airpollution control equipment,the limit is 2.8 lb VOC/gal ofcoating (excluding water &exempt compounds).OHPrime coat, single coator topcoat coatingline, as follows:(a) in 24 counties [listed in OAC rule 3745-21-09(A)(1)], to existing and new coatinglines;(b) in the other 64 counties, to any newcoating line and to existing and new coatinglines at a facility with potential to emitequal to or greater than 100 tons VOC peryear.A new coating line is a coating line forwhich construction of modificationcommenced on or after October 19, 1979.The emission limitation does not apply tothe use of quick drying lacquers for repairof scratches and nicks that occur duringassembly, provided that the maximumusage of such lacquers does not exceed onequart in any eight hour period.2.8 lb VOC/gal of coating(excluding water & exemptsolvents) or, if control systemis employed, 4.5 lb VOC/galof solids(a) complying coatings, or(b) control system that meets either 4.5 lbsVOC/gal solids or an overall 81% reductionwith a control device efficiency of at least 90%,or(c) an alternative emissions limitation basedupon a “tested” transferefficiency greater than60%.State County/Area VOC Limit Applies To VOCLimit Emission Limitation Achieved ByORDoes not apply to sources whose potentialto emit from coatingof VOC are <10 tpy(or 3 lb VOC/hr or 15 lb VOC/day actual)or research facilities.2.8 lb/gal (excluding water &exempt solvents)1. Application of low solvent content coatingtechnology2. Incineration, provided that 90% of the VOCwhich enter the incinerator are oxidized tocarbon dioxide and water3. Equivalent means of VOC removal.Meaning it must be approved by properauthority (Dept. of Env. and Nat. Res. or EPA)RIDoes not apply to the use of quick dryinglacquers for repair of scratches & nicks thatoccur during assembly, provided that thevolume of coating does not exceed 0.25 galsin any one 8-hr period.2.8 lb VOC/gal of coating(minus water) or 4.52 lbVOC/gal of solidsCompliance with emission limitation shall beachieved through:1. Installation of an approved control systemsuch that the total emission reduction is 95% orgreater over uncontrolled VOC emissions2. Coating reformulation such that theemission limitation is met for all coatings3. Installation of control equipment to reduceemissions to the equivalent of the emissionlimitations as calculated on a solids appliedbasis4. Use of daily-weighted averaging5. An alternative, approved equivalent methodof controlSCApplies to the prime, single or topcoat froma coating application system. Does notapply to the use of quick-drying lacquers forrepair of scratches & nicks that occur duringassembly, provided that the volume ofcoating does not exceed 1 qt (0.95 liter) inany one 8-hr period.2.8 lb/gal (0.34 kg/liter) ofcoating (excluding water &exempt solvents)1. Application of low solvent content coatingtechnology2. Incineration, provided that 90% of thenonmethane VOC which enter the incineratorare oxidized to CO2 and water3. Carbon bed solvent recovery system4. Alternative controls as allowed in Section I,Part CState County/Area VOC Limit Applies To VOCLimit Emission Limitation Achieved ByTNDoes not apply to the use of quick-dryinglacquers for repair of scratches & nicks thatoccur during assembly, provided that thevolume of coating does not exceed 0.95 liter(0.25 gal) in any one 8-hr period and anylarge appliance coating line w/in a facility:1) in Davidson, Rutherford, Sumner,Williamson, or Wilson County whose actualemissions w/our control are <6.8kg (15 lb)VOC per day or whose max emissions fromall large appliance coating lines are <10 tonVOC/yr2) in Hamilton or Shelby County whosepotential VOC emissions from all largeappliance coating lines are <25 ton VOC/yr3) in any other county whose potential VOCemissions from all large appliance coatinglines are <100 ton VOC/yr0.34 kg/liter (2.8 lb/gal) ofcoating (excluding water &exempt compounds)TXBeaumont/PortArthurDallas/Fort WorthEl PasoHouston/GalvestonGregg CountyNueces CountyVictoria CountyVOC emissions from the application, flashoff, and oven areas during the coating oflarge appliances (prime and topcoat, orsingle coat).2.8 lb/gal (0.34 kg/liter) ofcoating (minus water &exempt solvent) delivered tothe application systemState County/Area VOC Limit Applies To VOCLimit Emission Limitation Achieved ByUTApplication areas, flash-off areas, and ovensof coating lines involved in prime, singe ortop coating operations.0.34 kg/liter (2.8 lb/gal) ofcoating (excluding water &exempt solvents) or 4.5 lbVOC/gal solids1. Application of low solvent contenttechnology2. Incineration, provided that 90% of thenonmethane VOC which enter the incineratorare oxidized to CO2 and water3. Use of water-borne electrodeposition4. Use of water-borne spray, dip or flowcoat5. Use of powder6. Use of higher solids spray7. Carbon adsorptionWAThe operation of a coater and dryer, thatmay serve one or more process lines, shallcomply if the uncontrolled emissions ofVOC from the coater, flash-off areas, anddryer would be >18 kg (40 lb) in any given24-hr period. The emission limits anduncontrolled emission quantity shall includethe additional quantity of emissions fromthe dryer during the 12-hr period after theapplication of the coating.0.34 kg/liter (2.8 lb/gal) ofcoating (minus water)WVDoes not apply to any coating line w/in afacility whose actual emissions w/outcontrol from all large appliance coatinglines w/in the fenceline are <6.8 kg (15 lb)VOC/day or the use of quick-dryinglacquers for repair of scratches & nicks thatoccur during assembly, provided that thevolume of coating does not exceed 0.95 liter(0.25 gal) in any one 8-hr period.0.34 kg/liter (2.8 lb/gal) ofcoating (minus water &exempt compounds) as appliedAs an alternative to the emission limit:1. Installation and operation of a capturesystem2. Installation and operation of a control device3. Determination each day of the overallemission reduction efficiency needed todemonstrate compliance4. Demonstration each day that the overallemission reduction efficiency achieved for thatday is greater than or equal to the overallemission reduction efficiency required for thatdayState County/Area VOC Limit Applies To VOCLimit Emission Limitation Achieved ByWIApplication areas, flash-off areas, and ovensof coating lines involved in single, prime ortopcoat coating operations. Does not applyto the use of quick-drying lacquers forrepair of scratches & nicks that occur duringassembly, provided that the volume ofcoating does not exceed 0.95 liter (1 qt) inany one 8-hr period for any appliancecoating line.0.34 kg/liter (2.8 lb/gal) ofcoating (excluding water)deliveredUnited StatesEnvironmental ProtectionAgencyOffice of Air Quality Planning and StandardsSector Policies and Programs DivisionResearch Triangle Park, NCPublication No. EPA 453/R-07-004September 2007