# Control Techniques Guidelines for

Metal Furniture Coatings

# EPA 453/R-07-005

September 2007



# Control Techniques Guidelines for

Metal Furniture Coatings

U.S. Environmental Protection Agency

Office of Air Quality Planning and Standards

Sector Policies and Programs Division

Research Triangle Park, NC

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# i TABLE OF CONTENTS

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

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

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

IV. Process Description and Sources of VOC Emissions .............................................. 5

A. Process Description ..................................................................................................... 5

1. Surface Preparation.................................................................................................. 6

2. Coating Application................................................................................................. 6

3. Cleaning activities ................................................................................................... 8

B. Sources of VOC Emissions ......................................................................................... 9

1. Coatings ................................................................................................................... 9

2. Cleaning Materials................................................................................................. 11

V. Available Controls and Regulatory Approaches .................................................. 11

A. Available Controls for VOC Emissions from Coatings ............................................ 11

1. Pollution Prevention Measures.............................................................................. 12

2. Emission Capture and Add-on Control Systems ................................................... 13

B. Available Controls for VOC Emi ssions from Cleaning Materials ............................ 15

1. Product Substitution/ Reformulation ...................................................................... 16

2. Work Practice Procedures...................................................................................... 16

C. Existing Federal, State, and Lo cal Recommendations or Regulations...................... 16

1. The 1977 CTG ....................................................................................................... 16

2. The 1982 NSPS...................................................................................................... 19

3. The 2003 NESHAP................................................................................................ 19

4. Existing State and Local VOC Requirements ....................................................... 21

VI. Recommended Control Options ............................................................................. 22

A. Emission Limit Based on Low-VOC Coatings ......................................................... 23

B. Optional Add-on Controls for Coating Operations ................................................... 24

C. Work Practices for Coating-Related Activities ......................................................... 25

D. Work Practices for Cleaning Materials...................................................................... 25

VII. Cost Effectiveness of Recommended Control Options ......................................... 25

VIII. References ................................................................................................................. 26

Appendix A: 1977 CTG for Metal Furniture Coating

Appendix B: Summary of State and Local Re gulations for Metal Furniture Coating (not

including California)

Appendix C: Summary of California Air Distri ct Regulations for Metal Furniture Coating

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# 1 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 (Sept. 17, 1979). In subsequent Federal Register notices, EPA

has addressed how States can meet the RACT requirements of the CAA.

Clean Air Act section 183(e) directs EPA to list for 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 areas that violat e the NAAQS for ozone

(i.e., ozone nonattainment areas). EPA issu ed 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 (Mar. 18, 1999). Metal Furniture

coatings are included on the cu rrent 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 VOCs from metal furniture

coating. In developing this CTG, EPA, among other things, evaluated the sources of VOC

emissions from the metal furniture coating indus try and the available control approaches for

addressing these emissions, including the cost s of such approaches. Based on available

information and data, EPA provides recommenda tions for RACT for metal furniture coating.

States can use the recommendations in th is CTG to inform their own determination

as to what constitutes RACT for VOCs for metal furniture coatings in their particular

nonattainment areas. There are several hazardous air pollutants (HAPs) that are also VOCs.

The information contained 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 regulations; nor is it a regulati on itself. This document does not impose any

legally binding requirements on any entity. It provides only recommendations for State and

local air pollution control agencies to cons ider in determining RACT. State and local

pollution control agencies are free to implem ent other technically-sound approaches that are

consistent 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 recommendations may not apply to a particular

situation based upon the circumstances of a speci fic source. Regardle ss of whether a State

chooses to implement the recomm endations contained herein thr ough State rules, or to issue

# 2 State rules that adopt differe nt approaches for RACT for VOCs from metal furniture

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, whether the submitted rules 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 ap propriateness of the

application of this guidance to a particular situation during the development of the State

rules and EPA’s SIP approval process.

Clean Air Act section 182( b)(2) requires that a CTG issued between November 15,

1990, and the date of attainment include the date by which States subjec t to section 182(b)

must submit SIP revisions in response to the CTG. Accordingly, EPA is providing in this

CTG a one-year period for the required submittal. Pursuant to section 182(b)(2), States

required to submit rules consistent with sec tion 182(b) must submit their SIP revisions

within one year of the date of issuance of the final CTG for me tal furniture coatings. States

subject only to the RACT requirements in CAA section 172(c)(1) may take action in

response to this CTG, as necessary to achieve attainment of the national primary ambient air

quality standards.

II. Background and Overview

There have been three federal actions th at affect metal furniture surface coating

operations. In December 1977, EPA issued a CTG document (1977 CTG) for controlling

VOC emissions from surface co ating of metal furniture. 1 

# In October 1982, EPA

promulgated the new source performance sta ndards (NSPS) for surface coating of metal

furniture (1982 NSPS). 2 

# In May 2003, EPA promulgated the National Emission Standards

for Hazardous Air Pollutants: Surface Co ating of Metal Furniture (2003 NESHAP). 3



# The 1977 CTG, the 1982 NSPS and the 2003 NESHAP provide a thorough

discussion of the metal furniture coating industr y, the nature of VOC emissions (or in the

case of the 2003 NESHAP, volatile HAP emissi ons) from this industry, available control

technologies for addressing such emissions, the costs of available control options, and other

items. The 1977 CTG recommends and the 1982 NSPS establishes VOC emissions limits,

whereas the 2003 NESHAP establishes organic HAP emissions limits and does not address

non-HAP VOC.

At least 36 States and several local juri sdictions have specif ic regulations that

control VOC emissions from meta l furniture coating (or for me tal parts and products coating

in general). A discussion of the applicab ility and control options found in the federal

actions and State and local rules is pres ented in Section V of this document.

EPA developed the recommended approach es contained in this document after

reviewing the 1977 CTG, the 1982 NSPS, and the 2003 NESHAP and existing State and

local VOC emission reduction approaches.

# 3 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 metal furniture surface coating industry, including the types of metal

furniture products, the coating materials and the coating processes, and identifies the sources

of VOC emissions from those processes. Section V describes the available control

approaches for addressing VOC emissions from this product category and summarizes

Federal, State and local approaches for addres sing such emissions. Section VI provides our

recommendations for RACT for metal furnitur e coating. Section VII discusses the costeffectiveness of the recommended control appr oaches. Section VIII contains a list of

references.

III. Applicability

This CTG provides control recommendations for reducing VOC emissions stemming

from the use of coatings in metal furniture surface coating operations. Coatings include

paints, sealants, caulks, inks, adhesives, and maskants. a 

# 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 appro aches discussed in

section VI of this CTG apply to each metal furniture surface coating unit b 

# at a facility where

the total actual VOC emissions from all metal furniture coating operations, including related

cleaning activities, at that facility are equal to or exceed 6.8 kg/day (15 lb/day), or an

equivalent level such as 3 tons per 12-month 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 approximately two gallons

of solvent per day. Such a level is considered to be an incidental leve l of solvent usage that

could be expected even in facilities that use very low-solvent coatin gs, such as powder or

UV cure coatings (these coatings will be discussed in more de tail in section IV.B.1 of this

document). Furthermore, based on the 2002 NEI data and the 2004 ozone nonattainment

designations, facilities emitting below the recommended threshold level collectively emit

less than 4 percent of the total reported VOC emissions from metal furniture surface coating

facilities in ozone nonattainment areas. For these reasons, we did not extend our

recommendations in this CTG to these low-emitt ing facilities. For pur poses of determining

a 

# 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.

b 

# 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 flash-off area.

# 4 whether a facility meets our recommended appl icability threshold, a ggregate emissions,

before consideration of control, from all metal furniture coating operations (including

related cleaning activities) at a given facility are included.

In developing their RACT rules, State a nd 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 6.8 kg/day (15 lb/day) actual VOC emissions or an

equivalent applicability threshol d, or they can develop other app licability criteria that they

determine are appropriate considering the fact s and circumstances of the sources in their

particular nonattainment areas. EPA will review the State RACT rules in the context of the

SIP revision process.

The 2002 National Emission Inventory (NEI) an d a questionnaire sent to industry by

EPA during the development of the 2003 NESHAP development (data requested by EPA in

1997 and 1998) were used as the source of em issions data and statistical information

concerning the metal furniture surface coating industry as a whole. There were several

discrepancies in the number of facilities reported in the 2002 NEI versus the 1997 and 1998

NESHAP questionnaires.

Results from the NESHAP questionnaires i ndicated that there were approximately

3000 facilities that produce meta l furniture parts or products. These facilities were located

throughout the U.S., with the highest concentra tion of facilities in California, Michigan,

New York, Florida, and Illinois. 4 

# Although information regarding HAP emissions was the

main focus of the NESHAP questionnaires, information regarding VOC emissions was

submitted from 22 of the 85 facilities surveye d. These facilities reported actual VOC

emissions totaling approximately 1,300 tpy for 1997/1998. This total only accounts for

VOC emissions generated by these metal furniture facilities from coatings.

In developing this CTG, the 2002 NEI database was queried for VOC emissions

generated by facilities that were liste d under the following SIC codes: 2514, 2522, 2531,

2542, 2599, 3429, 3469, 3495, 3645, 3646, 3821, and 3843 (the SIC used for the 2003

NESHAP development). This query resulted in 456 facilities as compared to the 3,000

facilities identified during the developmen t of the 2003 NESHAP. The VOC emissions

from the 456 metal furniture surface coating fa cilities in the 2002 NEI totaled approximately

7,980 tpy. This total accounts for all of the VOC emissions generated by these facilities and

does not specify the amount generated by just me tal furniture coating operations. Of the 456

facilities identified in the 2002 NEI, 289 facilities were locate d in ozone nonattainment areas

and 143 of the facilities located in ozone nonattainment areas emit more than the 6.8 kg/day

(15 lb/day) VOC applicability threshold de scribed above. These 143 facilities emitted

approximately 3,400 tons of VOC in 2002.

As stated above, the information presen ted in BID for the 2003 NESHAP indicated

that there are about 3,000 metal furniture facilities in the Unit ed States. This information

was based on 1997 Census data for the Standard Industrial Classifica tion (SIC) codes that

describe the metal furniture industry. In c ontrast, the 2002 Census da ta (obtained using the

North American Industry Classi fication (NAICS) codes that correspond to the previously

# 5 used SIC codes) indicated that there are about 1,000 metal furn iture facilities. We have

found that the NAICS codes are in some cases very broad in th eir description of applicable

products. As a result, some of the NAICS c odes include parts and products that are beyond

the scope of the metal furniture industry as de fined in this document. Thus, the 2002 Census

data for the number of facili ties listed under these NAICS tend to overestimate the number

of metal furniture surface coating facilities by including facilities th at do not manufacture

metal furniture parts or products. Therefore, we believe that the NEI data most accurately

predict the total number of metal furniture facilities.

IV. Process Description and Sources of VOC Emissions

The metal furniture coatings product categ ory under section 1 83(e) of the CAA

includes the coatings that are applied to the su rfaces of metal furniture. A metal furniture

substrate is the furniture or components of furn iture constructed either entirely or partially

from metal. Metal furniture in cludes, but is not limited to, the following types of products:

household, office, institutional, laboratory, hospital, public bui lding, restaurant, barber and

beauty shop, and dental furniture, as well as components of these products. Metal furniture

also includes office and store fixtures, part itions, shelving, lockers, lamps and lighting

fixtures, and wastebaskets. Metal furniture co atings include paints and adhesives and are

typically applied withou t a primer. Higher solids and powder coatings are used extensively

in the metal furniture surface coating industry. Metal furniture coatings provide a covering,

finish, or functional or protec tive layer, and can also provide a decorative finish to metal

furniture.

A. Process Description

Metal furniture coatings serve decorative, protective and functional purposes.

Coatings protect the metal from corrosion by providing resistance to moisture, heat, and

sometimes the outdoor elements. Coatings for each type of metal furniture have special

requirements and contain unique properties becau se each type will be exposed to somewhat

different corrosive elements. The coating must also be durable and have excellent adhesion

properties to avoid peeling or chipping. Fi nally, the coatings for many products provide

decorative appeal.

The metal furniture manufacturing process may be divided into four main unit

operations: (1) raw material preparation, (2) su rface preparation, (3) coating and adhesive

application operations, and (4) assembly. In addition, cleaning activities are performed in

support of the surface coating operation. The ma jority of the raw material preparation

operations and assembly operations are m echanical in nature and involve no VOC

emissions. Surface preparation, coating appl ication operations, and cleaning activities

utilize VOC-containing compounds (i.e., coatings, thinners, and/or cleaning materials) and

are further described below.

# 6 1. Surface Preparation

Before a metal furniture component or pr oduct can be coated, its surface must be

thoroughly cleaned. The cleaning op eration consists of the follo wing basic processing steps:

(1) alkaline or acid cleaning, (2) water rinse, (3) phospha te treatment (typically iron

phosphate), (4) water rinse, and (5) pretreatment and/or water rinse. Th e last step involves

drying the parts in an oven. In general, the cleaning chemicals used in this cleaning

operation contain little VOC and theref ore generate negligible emissions.

In the alkaline or acid cleaning step, meta l furniture components or products are

sprayed with, or immersed in, a cleaning soluti on to dissolve and remove oil, grease, and

dirt. This solution, which can be alkaline or acidic, typically include s one or more other

ingredients such as surfactants or corrosion inhibitors. Gene rally, acid-based solutions are

preferred for removing corrosion and scale from metal pieces. However, because alkaline

formulations are generally somewhat mild er, they are recommended for certain metal

substrates when the corrosivity of acid solutions is a concern.

The cleaning step is followed by a phosphate treatment. The purpose of this

treatment is to provide corrosion resistance to the surface of the metal part. The final

pretreatment step, if utilized, may be a rust inhibitor or adhesion promoter.

Following each treatment step, the metal furn iture component or product is typically

sent through several rinse stag es in series. A counterflow rinsing system is commonly

utilized. A counterflow rinsi ng system is a sequence of rins e steps in which replenished

rinse water moves in the opposite direction of the component or product flow. The

components or products being cleaned progress from dirtier to cleaner rinse water. The

system maximizes water use by adding fresh water only at the final rinse step in the

sequence. Thus, the metal furniture compone nts or products are exposed to the cleanest

rinse water just before proceedi ng to the next treatment step.

An alternate cleaning method pr ior to coating is an enclos ed shot-blasting operation.

The operation uses steel shot (fine particles) to abrasively remove dirt and grease, as well as

to smooth rough edges and welds. The operation can also be used to remove cured coatings

when parts require rework. Although the steel shot is recycled back to the enclosure

containing the metal furniture parts or com ponents, a small amount of particulate matter

emissions is generated by this operation. Ho wever, the cleaning ope ration does not involve

any liquid chemicals, and no wast ewater discharge is produced.

2. Coating Application

Surface coating is accomplished by applying a coating to the metal part, followed by

curing or drying the coating. Th e coating itself may be in the form of a liquid or powder,

and may be applied by spraying or dipping.

There are several different types of applicat ors that may be used to apply coatings.

The most common types of coating applicat ors include: air atom ized spray coating,

# 7 electrostatic spray co ating, high volume/low pressure ( HVLP) spray coating, dip coating,

flow coating, roll coating, elec trocoating, and autophoretic coating. 4



# Spray coating is an application process where co atings are spray applied in a booth

by manual or automatic means. In some instances, productivity is maximized by using

automatic application followed by manual touchup. Typically, overspray is collected within

the booth on either dry filter media or a wate rwash booth. Air flow in a booth equipped with

dry filter media generally passes from the spray applicator, over the metal furniture

component or product, and through a dry filte r bank. Waterwash booths are less commonly

used in the metal furniture industry. In a waterwas h booth, air is drawn through a

continuous curtain of moving wate r and overspray is removed by contact with the water. In

addition, overspray hits the booth walls and is washed down by the water flow. In booths

equipped with dry filters and waterwash booths, th e overspray can be collected on a series of

baffles in front of the the dry filters or waterwash, and the colle cted overspray can be reused.

This recycling method substantially reduces bo th air emissions and waste (including spent

dry filters) generated by the co ating application operation.

In electrostatic spraying , the coating is charged and the part is grounded thereby

attracting the atomized coating to the part. Nearly all metal furniture spray coatings are

electrostatically applied.

HVLP systems have improved nozzles which pr ovide better air and fluid flow, and

allows for gentler atomization of the air st ream. These nozzles or atomizers shape the

air/spray pattern and guide the atomized co ating particles to the product being coated.

Dip coating is another available method for appl ying liquid coating. It is typically

used on parts that do not require a high-quality appearance, such as interior components of a

filing cabinet. The metal furn iture components or products to be coated are manually or

automatically dipped into a tank containing the coating. The metal furniture components or

products are then withdrawn from the tank and a ny excess coating is allowed to drain, thus

achieving very high coating transfer efficienci es. Typical systems have some means of

recirculation of the tank contents, filters to remove paint sediment and solid contaminants,

and means for controlling viscosity of the fl uid. Because the tank opening exposes a large

surface area of liquid coating, so lvent losses occur from the tank. To maintain the desired

coating viscosity in the tank, these losses are compensated by adding thinner (water or

solvent, depending on the coating used).

Flow coating is similar to dip coating and i nvolves conveying the metal furniture

component or product over an enclosed sink, wher e the coating is applied at low pressure as

the item passes under a series of nozzles. Ex cess coating drains back into the sink, is

filtered, and pumped back into a coating hol ding tank. A typical fl ow coater tank is

enclosed and is smaller than the equivalent dip coating tank. As a result, less coating is used

and less solvent is evaporated th an in dip tank operations. This application method results in

an increase in production rate.

# 8 Roll coating application is used for high viscosity coatings, particularly adhesives,

and for small surface areas. In most instances, the adhesive is activated by pressure, not

heat. The adhesive is typically spray applied to both the substr ate and laminate, and then the

two parts are assembled.

Electrocoating (electrodeposition) is a special ized form of dip coating where

opposite electric charges are app lied to the waterborne coating and the part. The coating is

deposited on the part by means of electrical attraction, which produces a more uniform

coating on the part than tr aditional dip application.

Autophoretic coating consists of a series of dip tanks in which the parts to be coated

are immersed and cleaned. After cleaning, the coating solids are deposited on the surface of

the parts via chemical reaction. The coating so lids are then heat cu red. The only reported

use of autophoretic coatings for metal furnitu re applications was a black coating, which

effectively limits its use to parts hidden from view.

Powder coatings are applied almost exclusiv ely by means of electrostatic spray in the

metal furniture surface coating industry. The electrostatic spray gun directs the flow of

powder to the product. If a powder recovery system is used, the oversprayed powder is

recovered and recycled. Powder coatings ma y also be applied us ing a dip application

operation. The part to be coated is first he ated to a temperature above the powder's melting

point. The hot part is then immersed in a fl uidized bed of the powder, melting the powder in

contact with it and forming a c ontinuous coating on the part.

After each of the liquid and powder coating ap plications described above, the applied

coating is heat dried or cured or air dried or cured after application, with the exception of

adhesives which are activated by pressure. Fo r liquid spray and dip coating operation, the

coated parts are typically fi rst slowly moved through a fl ash-off area after the coating

application operation to allow solvents in the coating to evaporate slowly and thus avoid

bubbling of the coating while it is curing in th e oven. After applicati on of powder coatings,

the coated metal furniture components or products are conveyed directly to an oven (there is

no flash-off area for powder coatings) and heated to cure the powder. This curing process

melts the powder, forming a continuous coati ng. Following the curing step, the final unit is

assembled (if necessary) and packaged for shipment.

3. Cleaning activities

Cleaning activities other than surface prep aration also occur at metal furniture

surface coating facilities. Cleaning materials are used during these activities to remove

coating residue or other unwante d materials from equipment related to coating operations, as

well as the cleaning of spray guns, transfer lines (e.g., tubing or pi ping), tanks, and the

interior of spray booths. These cleaning ma terials are typically mixtures of VOCcontaining solvents.

# 9 B. Sources of VOC Emissions

Primarily, VOC emissions from metal furniture surface coating processes result from

the evaporation of the volatile component s of the coatings and cleaning materials. c 

# In most

cases, VOC emissions from surface preparati on, storage, handling, and waste/wastewater

operations are relatively small. The followi ng discussion describes these primary emission

sources (coatings and cleaning materials).

1. Coatings

The primary VOC emissions from metal furniture coatings occur during coating

application/flash-off and drying/curing of the coatings. The remaining emissions are

primarily from mixing and/or th inning. The VOC emissions fr om mixing and thinning of

coatings occur from displacement of VOC-laden air in containers used to mix coatings

containing solvents (thinners) prior to coating application. The displacement of VOC-laden

air can also occur during filling of containers and can be caused by changes in temperature,

changes in barometric pressu re, or agitation during mixing.

The VOC emissions from coating applica tion occur when solvent evaporates from

the coating as it is being applied to the part. The transfer efficiency (the percent of coating

applied to the metal furniture component or pr oduct) of a coating app lication method affects

the amount of VOC emitted during coating ap plication. The more efficient a coating

application method is in transfer ring coatings to the metal furniture component or product,

the lower the volume of coatings (and ther efore solvents) needed per given amount of

production; thus resulting in lower VOC em issions. Conventional air atomized spray

equipment utilizes high atomizing air pressure wi th typical transfer efficiencies of 25 to 40

percent. 4



# After being coated by any of the typical coating methods (e.g., spray coating or dip

coating), the metal furniture components or prod ucts are dried/cured. Prior to entering the

ovens, solvents in the coatings evaporate sl owly in the flash-off area to prevent bubble

formation during curing. The amount of VOC emissions from the flash-off area depends on

the type of coating used, how quickly the component or product moves through the flash-off

area, and the distance between the applicati on area and the bake oven. For liquid spray

applications, it is estimated that 65-80 percent of the volatiles are emitted during the

application and flash-off operati ons, and the remaining 20-35 pe rcent from the drying/curing

operation.

For powder coatings, the curing/drying step melts the powder and forms a

continuous coating on the metal furniture compone nt or product. For liquid coatings, this

c 

# In a previous notice, EPA identified specific categor ies, including metal furniture surface coating, the

cleaning operations of which would not be covered by EPA’s 2006 CTG for industrial cleaning solvents

(71 FR 44522, 44540, October 5, 2006). In the notice, EPA expressed its intention to address cleaning

operations associated with these categories in the CTGs for these specified categories if the Agency determines

that a CTG is appropriate for the respective categories.

# 10 step removes any remaining volatiles from th e coating. The cured coatings provide the

desired decorative and/or pr otective characteristics. The VOC emissions during the

curing/drying process re sult from the evaporation of the remaining solvents in the dryer.

Until the 1970’s, conventional solvent-base d coatings, with high VOC content, were

the majority of coatings used in the metal furniture 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 follo wing discussion summarizes each of these

alternative coating formulations.

Powder Coatings. The use of powder coating systems in the metal furniture

manufacturing industry has increased. Many me tal furniture manufact uring facilities have

replaced existing liquid coati ng operations with powder coat ing operations. Compared to

conventional liquid coating systems, powde r coating produces minimal amounts of VOC

emissions because powder coatings are applie d as dried particles, no VOC are released

during the application operati on, and volatile emissions from the curing operation, if any,

are generally much less than the volatile emi ssions from liquid coating systems. Powder

coating is applied via powder de livery systems, which in most cases is an electrostatic spray.

Particulate emissions resulting from the appli cation of powder coatings can be minimized

through the implementation of a recovery and recycling process (reuse of overspray).

Depending on the powder formulation, some vola tile emissions may occur when the powder

is heated during the curing step. Powder coating applications are best suited for long

production runs of consistently sized parts without color changes.

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. Waterborne coatings are used widely in other industries,

most often when there is a primer applied to the substrate prior to the waterborne coating.

The use of waterborne coatings is limited in the metal furniture manufacturing industry

because they tend to corrode mild steel and so me stainless steels, and the primer keeps the

water from contacting the metal substrate. Becau se primers are used only rarely in the metal

furniture industry, the use of waterborne coatings is more limited in this industry.

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 metal furniture industr y. Because the entire

coating must be exposed to the UV light s ource to achieve complete curing of the UV

# 11 coating, UV curable coating applications presen t problems in the metal furniture industry.

Pigmentation used in the majority of metal furniture coatings blocks the UV light. The

shape of the metal furniture also presents curing problems. Me tal furniture products

typically have bends or are box-shaped, creating areas which would be shaded from the UV

light source.

2. Cleaning Materials

Cleaning materials are another source of VOC emitted by metal furniture surface

coating operations. The VOC are emitted wh en solvents evaporate from the cleaning

materials during use.

Cleaning materials with low-VOC compos ite vapor pressure and/or low-VOC

content generate less VOC emissions than materi als with higher VOC va por pressure and/or

content. The VOC composite vapor pressure of a cleaning materi al is a weighted average of

the vapor pressures of the VOC components of that cleaning material. The vapor pressure

of each VOC component is weighted by the mo le fraction of that VOC component in the

whole cleaning material, incl uding non-VOC components such as water or exempt

compounds. d 

# Water and exempt compounds ther eby reduce the VOC composite vapor

pressure of cleaning materials in which they are present. Although use of lower pressure

cleaning materials may reduce VOC emissions, li ttle information is available regarding the

use of cleaning materials with low VOC compos ite vapor pressure in the metal furniture

surface coating industry. Similarly, cleani ng materials with low VOC content would

generate less VOC emissions than material s with high VOC content; however, little

information is available regarding the use of cleaning materials with low VOC content in

this industry.

V. Available Controls and Regulatory Approaches

As previously mentioned, there are two ma in sources of VOC emissions from metal

furniture surface coating operations: (1) eva poration of VOC from the coatings; and (2)

evaporation of VOC from the cleaning materials. This section summarizes the available

control options for reducing these VOC emissions and existing federal, State, and local VOC

recommendations or requirements that address these emissions.

A. Available Controls for VOC Emissions from Coatings

There are two general emission control tec hniques for reducing VOC emissions from

metal furniture coatings: pollution preventi on measures, and emission capture and add-on

control systems. Pollution prev ention is the most prevalent control technique being used by

the metal furniture surface coating industry. Add-on control systems are available to the

d 

# Exempt compounds are those classified by EPA as having negligible photochemical reactivity as listed in 40

CFR 51.100 (s). Exempt compounds are not considered to be VOC.

# 12 industry, but few facilities utilize this control technique. Provided below is a summary of

these control techniques.

1. Pollution Prevention Measures

Pollution prevention measures applicable to the metal furniture manufacturing

industry, including product subs titution/reformulation, work practice procedures, and

equipment substitution, may be used to decreas e VOC emissions from coating application

operations. Lower VOC content coatings, such as powder coatings, hi gher solids coatings

and waterborne coatings, may be used to re duce VOC emissions by reducing or eliminating

the organic solvent present in the coating. Wo rk practice procedures may also result in

VOC emission reductions during th e coating process by reducing co ating waste. The use of

efficient coating application equipment can reduce VOC emission by increasing the coating

transfer efficiency (i.e., the pe rcentage of coating solids used that is deposited onto the

substrate).

Product substitution/Reformulation

One pollution prevention measure is to substitute higher-solvent coatings with

coatings containing little or no solvents. As previously discussed, these coatings include

powder coatings, waterborne coatings, higher so lids coatings, UV coatings, electrocoatings,

and autophoretic coatings. The use of higher solids, powder and waterborne coatings has

increased since 1977. Manufacturers have de veloped and are continuing to develop

waterborne and powder coating formulations that replace conventional organic solventborne coatings. These coatings are genera lly available and often are not produced and

marketed specifically for metal furniture su rface coating. Conversion to powder coatings

(for example) can lower VOC emissions greatly, and most metal furniture coating operations

are capable of converting to these coatings. However, th e currently available low-VOC

coatings or coatings with no solvents do not meet the performance requirements of some

metal furniture and therefore are not viab le options for these products' production.

Work Practices

Work practice procedures are physical actions intended to affect emission reductions.

Because work practice procedures are specifically tailored to an industry, they may vary

from a few manual operations to a complex program.

Coating waste is generated during coating material preparation, coating application,

and equipment cleaning. If co ating waste is reduced, overall VOC emissions from coating

operations will be reduced because less VOC coati ng material will be needed for production.

Coating waste may be reduced by effectively controlling material preparation, maximizing

the amount of coating transferred to the part through the use of app lication methods with

higher transfer efficiencies and proper form (spray technique), and using proper equipment

maintenance procedures.

# 13 Equipment Substitution

The use of the more effective applicati on equipment also reduces VOC emissions.

Conventional air atomized application system s utilize high atomizing air pressure with

typical transfer efficiencies of 25 to 40 percent.

More modern technologies, such electros tatic and high volume/low pressure (HVLP)

spray equipment, can achieve much higher transf er efficiencies. The increase in transfer

efficiency translates to a decrease in usage of materials containing VOC.

In electrostatic spraying, the coating is charged and the part is grounded thereby

attracting the atomized coating to the part. Tr ansfer efficiencies of up to 90 percent may be

achieved depending on the product shape, size, a nd substrate. Nearly all metal furniture

spray coatings are electr ostatically applied.

HVLP systems have improved nozzles which provide better air and fluid flow, and

allows for gentler atomization of the air st ream. These nozzles or atomizers shape the

air/spray pattern and guide the atomized coat ing particles to the product being coated.

2. Emission Capture and Add-on Control Systems

In addition to pollution prevention measur es, VOC emissions from metal furniture

surface coating application operations can be reduced by the use of capture systems, in

conjunction with add-on control systems that either destroy or recover the VOC in the

exhaust streams. As stated previously, a lthough capture systems and add-on control devices

are available to the metal furniture surface coating industry, EPA is aware of only a few

cases where this control technol ogy is utilized by the industry. 4 

# The majority of VOC

emissions from metal furniture coating opera tions occur in the spray booth. Spray booths

typically exhaust a high volume of air with a low concentration of VOC which can result in

a high cost of control.

Capture Systems

Capture systems, such as hoods and en closures, collect solvent-laden air from

process vents ( e.g. , spray booth or bake oven vents) and/or fugitive emissions ( e.g. , flash-off

area) and direct the captured ai r to a control device. The majority of VOC emissions from

metal furniture surface coating occur in the spray booth. These emissions can be ducted

from the spray booth directly to the control device. Simila rly, bake oven exhaust can be

ducted directly to the contro l device. Spray booths and ba ke ovens are the principal

elements of the capture system. In addition, hoods, floor sweeps or enclosures can be used

to collect fugitive emissions from solvents that evaporate in flash-off areas and route them to

a control device.

The design of the capture system can great ly contribute to the overall VOC control

efficiency. An efficient capture system maxi mizes the capture of emissions and minimizes

the capture of dilution air. Spray booth a nd bake oven design and air management can

# 14 reduce the volume of exhaust air and increase the VOC concentration of the exhaust air

which can reduce the cost of control. Faci lities may combine several captured VOC-laden

streams and duct them to a single control device.

Add-on Control Systems

Add-on controls reduce the amount of VO C emissions by either destruction or

recovery with or without recycling of VOC em ission in the exhaust st reams. Two categories

of add-on control devices are typically used by the metal furniture surface coating industry:

combustion (thermal or catalytic oxidation) and recovery (adsorption and absorption).

While many control devices can be used to reduce VOC emissions, the following summary

covers those control devices known to be us ed with surface coati ng operations: oxidation,

adsorption, and absorption. In addition, there are other control measures known to reduce

VOC emissions, but are not currently being us ed in the metal furniture surface coating

industry. These alternative control t echnologies are also discussed below.

Oxidation destroys VOC emissions in an exha ust stream by exposing the stream to

an oxidizing atmosphere at hi gh temperatures. Oxidizers may be of thermal or catalytic

design and combust VOC-containi ng exhaust streams. Catalytic oxidizers are similar to

thermal oxidizers but employ a catalyst to aid in the oxidation reaction. As a result, catalytic

oxidizers operate at lower combustion temperat ures relative to that required in thermal

oxidizers. Both types of oxidi zers generally utilize either regenerative or recuperative

techniques to preheat inlet gas in order to decrease energy costs associated with high

oxidation temperatures. They may also use pr imary or secondary heat recovery to reduce

energy consumption. In general, oxidizers may achieve destruction efficiencies of greater

than 95 percent as applied to coating application operati ons with high and constant

concentrations of VOC.

Adsorption occurs when the unbalanced molecu lar forces on the surface of solids

(the adsorbant) attract and retain gases and particulate matter that come in contact with the

solid. Several materials are widely used as th e adsorbent, such as activated carbon, organic

resin polymer, and inorganic materials. Each has substantial surface area per unit volume.

Carbon adsorbers are most commonly used in the metal furniture su rface coating industry.

In a carbon adsorber, activated car bon is used as the adsorbent in a regenerable fixed bed. In

a typical carbon adsorber, VOC-laden air is pass ed through a fixed bed of granular activated

carbon. Adsorber beds are typi cally operated in parallel to avoid interruption of VOC

control. In this arrangement, when the adsorption capacity of one bed is exhausted, it can be

removed from service and a second adsorber be d can be put into service, ensuring that a

control device is operating at all times. The spent carbon bed in the first adsorber bed is

then regenerated and can be put into service again.

Carbon adsorption systems can achieve cont rol device efficiencies greater than 95

percent. 5 

# In contrast to combus tion, carbon adsorption does not destroy the VOC it removes

from the air stream. Carbon adsorbers used in metal furniture surface coating are thermally

regenerated, usually by passi ng steam through the carbon beds. 6 

# The VOC are removed

from the carbon (desorbed) and transferred to the steam. The VOC-containing steam is then

# 15 condensed, and the VOC solvent is separated from the water. The recovered solvent can

then be decanted for sale or reuse. Regenerati on can also be achieved with hot air. Hot-air

regeneration can be quite attractive when dealing with water soluble solvents. 6 

# Carbon

adsorption is most amenable to coatings that use a single solvent; if solvent mixtures are

collected by adsorbers, they us ually are distilled for reuse. 7



# There are two options for disposing recove red solvents that can not be reused. The

first is to sell the material back to the solven t supplier or an independent firm that specializes

in reclaiming contaminated solvents. The other option is to use the recovered solvent as a

fuel in coating ovens or in boilers. However, many coating ovens and boilers are gas-fired

and would require burner modifications to bur n solvent. Carbon adsorption is generally

economically attractive only if the recove red solvent can be reused directly. 6



# Carbon adsorbers are most suitable for solven ts that are immiscible with water, such

as toluene and xylene, but are not recomme nded for water-soluble VOC, such as methyl

ethyl ketone and methyl isobutyl ketone. In the case where a water-soluble VOC is present,

the water vapor will be adsorbed and desorb ed along with the VOC vapor, and the VOC

may require subsequent purificati on if it is to be reused.

The presence of solid particles or polymeri zable substances in the inlet air stream to

a carbon adsorber may require pretreatment of th e inlet air. In additi on, adsorption is usually

used for coating application exhaust streams at ambient te mperature up to approximately

38°C (100°F). Therefore, cooling and de humidification may also be required as

pretreatment in some cases. 5 

# Adding equipment, such as a dehumidification system,

increases the costs associated with th e use of a carbon adsorption system.

Absorption is the process by which a gas stream is contacted with a liquid so that one

or more of the components of the gas stream will dissolve in the liquid. Water is the most

common absorbent, but organic solvents may also be used. Removal efficiency can be

enhanced by the addition of reactive chemical additives to the absorbent to increase

solubility of the absorbed polluta nt or change the equilibrium.

Alternative control technologies, such as condensation, biodegradation, and UV

oxidation are applicable for control of VOC emis sions from coatings. However, EPA is not

aware of any metal furniture surface coating fa cilities currently using these types of control

technologies. 4



# B. Available Controls for VOC Emi ssions from Cleaning Materials

Pollution prevention is the most common emission control technique for reducing

VOC emissions from cleaning materials. The pollution prevention measures applicable to

the metal furniture industry include product s ubstitution/reformulation and work practice

procedures. Cleaning materials with low or no VOC content or low-VOC composite vapor

pressure may be used to reduce or eliminate VOC emissions from using these materials.

Work practice procedures may also redu ce VOC emission during cleaning operations by

reducing the amount of VOC that can evaporate due to exposure to air.

# 16 No add-on control techno logies are being used sp ecifically for reducing VOC

emissions from cleaning operations associated with metal furniture surface coating.

However, if cleaning operations are performed wi thin a capture system that is ducted to an

add-on control system, such as a PTE routed to a thermal oxidizer, the VOC emissions from

the cleaning operations would be reduced by destruction in the thermal oxidizer.

1. Product Substitution/Reformulation

Reducing the composite VOC vapor pre ssure or VOC content of the cleaning

material used, either by substitution or refo rmulation, is one pollution prevention measure

that is used to reduce VOC emissions from cl eaning operations. However, little information

is available regarding the types of low-VOC or VOC-free cleaning materials that could be

used in the metal fu rniture industry.

2. Work Practice Procedures

Work practice procedures are commonly us ed in the metal furniture industry to

reduce VOC emissions from cleaning operations . The following work practice procedures

are used to reduce VOC emissions from metal furniture cleaning operations:

• Cover mixing and storage vessels for VOC-containing cleaning materials, and

cleaning waste materials except when adding, removing, or mixing contents;

• Use closed containers or pipes to st ore and convey VOC-containing cleaning and

cleaning waste materials;

• Minimize spills of VOC-containing cleaning and cleaning waste materials; and

• Minimize VOC emissions during cleaning operations.

C. Existing Federal, State, and Lo cal Recommendations or Regulations

The following discussion is a summary of three EPA actions, as well as State and

local regulations, that address VOC emissions from metal furniture coating processes.

Table 1 outlines these Federal, State and local provisions and th e bases for these provisions.

In addition, appendices B and C summari ze the State and local provisions.

1. The 1977 CTG

The 1977 CTG recommended limiting VOC emissions from each metal furniture

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. 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 0.36 kg/l (3.0 lb/gal) of coating, excludi ng water and exempt compounds, as applied.

# 17 Table 1. Summary of Existing Requirements

Existing Regulation Emission Limit Basis for Emission Limit

Metal Furniture Coating CTG

(December 1977) Recommended VOC emission

limit of 3.0 lb VOC/gal 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 (59.2

percent by volume solids) with an

assumed VOC density of 7.36

lb/gal. Associated with a baseline

transfer efficiency of 60 percent

Metal Furniture NSPS

(October 29, 1982) VOC emission limit of 7.5 lb

VOC/gal of coating solids

deposited from any surface

coating operation on a metal

furniture 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.

Metal Furniture NESHAP

(May 23, 2003) Existing sources: HAP emission

limit of 0.83 lb organic HAP/ gal

coating solids used MACT level of control based on

1997/1998 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 metal

furniture 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 airdried 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 onecomponent (air-dried and baked)

coatings and for general multicomponent baked coatings, 62

percent volume solids for general

multi-component air-dried

coatings and a transfer efficiency

of 65 percent

# 18 Table 1. Summary of Existing Requirements

Existing Regulation Emission Limit Basis for Emission Limit

California – South Coast Rule

1107 (Continued) Exempts coatings and operations

such 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 and then a VOC

emission limit for baked coatings

of 2.3 lb/gal (0.275 kg/l) of

coating, excluding water and

exempt compounds, as applied

and for air-dried coatings of 2.8

lb/gal (0.34 kg/l) 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:

36 State and local jurisdiction

rules specifically for metal

furniture coating operations were

identified VOC emission limit of 3.0 lb

VOC/gal 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 CTG

# 19 The emission limit was based on the use of low VOC content coatings and is approximately

equivalent to the use of conventional high solv ent content coatings in conjunction with an

add-on control system with an overall control efficiency (taking into account capture and

control) of 81 percent. At th e time, it was believed that most metal furniture facilities would

seek to meet future regulations through the us e of low-VOC coatings rather than using addon control technologies. Cleaning material s were not addresse d in the 1977 CTG.

Equivalent solid-based limits for metal fu rniture coating opera tions were presented

in A Guideline for Surface Coating Calculations” (EPA-340/1-86-016). 8 

# For metal

furniture surface coating operations, the 1977 CTG-equivalent limit was 0.60 kg/l

(5.1 lb/gal) of solids. These equivalent li mits were calculated using an assumed VOC

density of 0.88 kg/l (7.36 lb/gal). This assumed VOC density is the same as that used in

calculating the limits recommended in the 1977 CTG.

2. The 1982 NSPS

The 1982 NSPS applies to metal furniture surface coating operations that

commenced construction, modification, or reconstruction after November 28, 1980. The

1982 NSPS defines surface coating operations in th e rule to include prime coat and topcoat

operations, and the standards apply to the coa ting application station, flash-off area, and

curing oven. Any metal furniture surface coa ting operation that uses less than 3,842 l /yr

coating (as applied) is required to keep records of coating usag e but is exempt from the other

NSPS provisions. The 1982 NSPS establishes a monthly volume-wei ghted average VOC

limit of 0.90 kg VOC/l (7.5 lb VOC/gal) coating so lids deposited. This limit was based on

the use of coatings with around 62 volume per cent solids, applied at 60 percent transfer

efficiency, and using an assumed VO C density of 0.88 kg/l (7.36 lb/gal).

The 1982 NSPS applies to the same metal fu rniture surface coating operations as the

1977 CTG: the coating application area, the flas h-off area, and the curing oven. Because the

1982 NSPS VOC emission limit is in terms of coating solids deposit ed and the 1977 CTGequivalent limit is in terms of coating solids used, it is difficult to directly compare the two

limits. During the implementation of the 1977 CT G, a baseline of 60 percent (i.e. 0.60 gal

of coating solids deposited per gal coating solids used) 8 

# was used to estimate an as-applied

CTG-equivalent limit. By applying the 60-pe rcent transfer efficiency to the 1977 CTGequivalent limit of 0.60 kg VOC/l (5.1 lb VOC/gal ) solids used, the CTG-equivalent limit

would be 1.01 kg VOC/l (8.4 lb VOC/gal) coati ng solids deposited. Based on this baseline

transfer efficiency, the 1982 NSPS limit is more stringent than the 1977 CTG-equivalent

limit when converted to a solids deposited basis. Cleaning materials were not addressed in

the 1982 NSPS.

3. The 2003 NESHAP

The 2003 NESHAP applies to “major” sources of HAP emissions, which are

stationary sources that emit or have the potential to emit 10 tpy or more of any one HAP, or

25 tpy or more of any combin ation of HAP. In contra st to the 1977 CTG and the 1982

# 20 NSPS, the 2003 NESHAP covers the collection of all of the following operations and

equipment at a facility:

• coating operations (which are defined to include equipment used for surface

preparation, coating applicat ion, and equipment cleaning);

• storage containers and mixing vessels in which coatings, thinners, and cleaning

materials are stored or mixed;

• manual and automated equipment and cont ainers and pumps and piping used for

conveying coatings, thinners, and cleaning materials; and

• storage containers, pumps and piping, a nd manual and automated equipment and

containers used for conveying waste mate rials generated by a coating operation.

The 2003 NESHAP imposes an organic HAP emission limitation of 0.10 kg organic

HAP/l (0.83 lb organic HAP/gal) of coating solids used for sources in operation on or before

April 24, 2002 (existing sources ), and no organic HAP emissions are allowed for new

sources (sources which started up after Ap ril 24, 2002). For purposes of determining

compliance, the organic HAP emissions are the total emissions from coatings, thinners, and

cleaning materials.

Compliance with the 2003 NESHAP can be demonstrated by any of three methods:

(1) compliant coatings option, where all coatings used have organic HAP contents that

individually meet the organic HAP emission lim it, and all thinners and cleaning materials

contain no organic HAP; (2) emission rate without add-on controls option, where the

monthly average organic HAP em ission rate is equal to or less than the organic HAP

emission limit; or (3) emission rate with add-on controls option, where the monthly

emission rate, taking into account the emission reduction achieved throug h the use of one or

more control devices, is equal to or le ss than the organic HAP emission limit.

If a facility is demonstrating complian ce by using the emission rate with add-on

controls option, the 2003 NESHAP requires the facility to deve lop a work practice plan to

minimize organic HAP emissions from the st orage, mixing, and conveying of coatings,

thinners and cleaning materials used in th e coating operations, as well as organic HAP

emissions from waste materials generated by such operations. At a minimum, the work

practice plan must include the following elements:

• All organic-HAP-containing coatings, thi nners, cleaning materials, and waste

materials must be stored in closed containe rs. Ensure that these containers are kept

closed at all times except when depositi ng or removing these materials from the

containers.

• Spills of organic-HAP-containing coatings, thinners, cleaning materials, and waste

materials must be minimized.

• Organic-HAP-containing coatings, thinners, cleaning materials, and waste materials

must be conveyed from one location to a nother in closed containers or pipes.

• Mixing vessels which contain organic-HAP-c ontaining coatings and other materials

must be closed except when adding t o, removing, or mixing the contents.

# 21 • Emissions of organic HAP must be mini mized during cleaning of storage, mixing,

and conveying equipment.

4. Existing State and Local VOC Requirements

In addition to the EPA actions describe d above, at least 36 States and local

jurisdictions have regu lations that control VOC emissions from metal furniture coating (or

for metal parts and products coating in genera l). The vast majority of these States (32

States) have incorporated the 1977 CTG VOC emissions limit of 0.36 kg VOC/l (3.0 lb

VOC/gal) of coating applied (mi nus water). Two States inco rporated the CTG-equivalent

limit of 0.60 kg VOC/l solids used. Appendix B summarizes the appli cable rules for all

States except California. The applicable ru les for all of the California Districts are

summarized in Appendix C. Generally, complia nce with the State and local jurisdiction

emission limits can be achieved using coatings that meet the VOC emission limits or by the

installation of a capture and add-on control system. Some states specify the use of

incinerators and/or carbon adsorbers.

The California South Coast Air Quality Management District (South Coast) has

adopted limits for metal furniture coating that are more stringent than the 1977 CTG

recommendation. The VOC emission limits established by the South Coast for the surface

coatings of metal parts and products (which in cludes metal furniture coating) are: (1) 275

grams VOC per liter (g VOC/l) (2.3 lb VOC/g al) of coating, excluding water and exempt

compounds, as applied for general one-component 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 in cludes specific limits for specialty coatings,

such as extreme high gloss, high temperature, and metallic coatings. The South Coast

regulation specifies the use of the following ap plication methods: elect rostatic application,

flow coat, dip coat, roll coat, HVLP spray, hand application methods, or other coating

application method capable of achie ving a transfer efficiency equi valent or better than that

achieved by HVLP spraying. Coatings and opera tions such as stencil coatings, safetyindicating coatings, touch-up coatings and a pplication with hand-held aerosol cans are

exempt from the South Coast regulations. 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 percen t by weight of the VOC emissions generated

by the sources of VOC emissions (capture effi ciency) and to 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 metal furniture coating that are more stringent than the 1977 CTG

recommendation: (1) 275 g VOC/l (2.3 lb VOC/gal ) of coating, excluding water and exempt

compounds, as applied, for baked coatings; and (2) 340 g VOC/l (2.8 lb/gal) of coating,

excluding water and exempt compounds, as app lied, for air-dried coating. Like the South

Coast regulations, the Bay Area re gulations include specific limits for specialty coatings and

exemptions for some coatings and coating operations. In additi on, the Bay Area rule

requires the use of coating a pplication equipment that can meet a 65 percent or greater

# 22 transfer efficiency. Per the Bay Area regulation, compliance with the standard's 65 percent

of greater transfer efficiency can be achieved by properly oper ated electrostatic application

or HVLP spray, flow coat, roller coat, dip co at including electrodepos ition, and brush coat.

Several jurisdictions in California have requirements to regulate the VOC emissions

from cleaning materials used in the meta l furniture surface coating industry. These

regulations are aimed at reducing VOC emi ssions from cleaning materials by combining

work practice standards with limits on the VOC content or composite va por pressure of the

solvent being used. In some cases, the jurisdic tions allow the use of add-on controls as an

alternative to the VOC content/vapor pressure limits. The different air pollution control

authorities in California have established sim ilar work practice standa rds. However, the

cleaning material VOC content/vapor pressure li mits vary by jurisdicti on, as do the overall

control efficiency required when add-on c ontrols are used as an alternative.

There are ten States that have cleaning ma terial regulations that apply to metal

furniture surface coating operations. Of these, nine States do not limit the VOC

content/vapor pressure of clean ing materials. Instead, they have established equipment

standards, work practices, and/ or recordkeeping requirements. There is one State that

requires work practices as well as limiting the vapor pressure of th e cleaning materials.

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 metal furniture 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 meta l furniture surface coatings, we are

recommending three alternatives: (1) emission li mits that can be achieved through the use of

low-VOC coatings; (2) equivalent emission lim its that can be achieved through the use of

low-VOC coatings or a combination of coati ngs and add-on controls ; and (3) an overall

control efficiency of 90 percent for a dd-on controls. The low-VOC coatings

recommendation consists of emission limits in terms of mass of VOC per volume of coating,

excluding water and exempt compounds, as app lied and the use of specified application

methods. The equivalent emission limit reco mmendation consists of emission limits in

terms of mass of VOC per volume of coating solids, as applied, and the use of specific

application methods.

We estimate that these recommendations will reduce VOC emissions from metal

furniture coating by about 35 percent (a reduction of 1,200 tpy of VOC) from the

nonattainment area facilities above the recomm ended 6.8 kg/day (15 lb/day) threshold. In

our analysis of the impacts of the recommended level of control, we have assumed that all

facilities will choose to utilize the low-VOC co ating materials alterna tive. We made this

assumption for two reasons. First, we believe that complying low-VOC coating materials

# 23 are already widely available at a cost that is not significantly gr eater than the cost of coating

materials with higher VOC contents. Sec ondly, the use of add-on controls to reduce

emissions from typical spray coating operati ons would be a more costly alternative.

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

emissions. We are not recommending the applica tion of add-on controls in conjunction with

these work practices for the same reasons stat ed above for coating ap plication, the use of

add-on controls to reduce emissions from cleaning operations at metal furniture surface

coating facilities would be a cost ly alternative because the area to be controlled is quite large

and a large volume of air would be captured and directed to a control device. However, as

mentioned previously, any cleani ng activities that occur within a capture system would be

controlled by the associated control device. Furthermore, we do not have information

available regarding current VOC content or VOC composite vapor pressure usage to

determine a RACT limit for cleaning material s used in metal furniture surface coating

operations. Therefore, we are not recommending the use of a VOC content or VOC

composite vapor pressure limit for cleaning materials

The following discussion summarizes our specific recommendations for coating

operations and cleaning materials used in me tal furniture surface coating operations.

A. Emission Limit 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):

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

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 co ating solids limits. Using an assumed VOC

density of 7.36 pounds per gallon, the equivalent limits in terms of mass of VOC per volume

of solids, as applied, are as follows:

# 24 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 6.7

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

• 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 metal furniture surf ace coating unit are included when determining the coating

unit's emission rate. In addition, we are r ecommending the use of one or more of the

following application methods: electrostatic application, HVLP spray, flow coat, roller coat,

dip coat including electrodeposition, or ot her coating applicati on method capable of

achieving a transfer efficiency equivalent or better than that achieved by HVLP spraying.

The recommendations described above are ba sed on the South Coast's metal parts and

products coating regulation, which includes metal furniture.

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. 9 

# 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 orother needs dictate the use of higherVOC materials than those that would meet the recommended emission limits, a facility

could choose to use add-on control equipment w ith an overall control efficiency of 90

percent. Alternatively, a fac ility could use a combination of coatings and add-on control

equipment on a coating unit to meet the reco mmended mass of VOC per volume of coating

# 25 solids limits. Add-on devices include oxidize rs and solvent recovery systems, which

coupled with capture systems to collect the VOC being released at the a ffected facilities, can

achieve an overall control effi ciency of 90 percent. This control option, like the options

noted above, applies to all coatings and thinne rs applied to metal furniture components or

products.

C. Work Practices for Coating-Related Activities

In addition to the control options above, this CTG recommends work practices to

further reduce VOC emissions from metal furn iture surface coating-re lated activities.

Although VOC reductions achieved by implementi ng the recommended work practices may

not be quantifiable, they are beneficial to the overall goal of reducing VOC emissions. We

recommend work practices for storage, mi xing operations, and handling operations for

coatings, thinners, and coating-related waste materials. Specifically, we recommend the

following work practices: (1) store all VOC-c ontaining coatings, th inners, and coatingrelated waste materials in closed containers; (2) ensure that mixing and storage containers

used for VOC-containing coatings, thinners, and coating-related waste materials are kept

closed at all times except when depositing or removing these materials; (3) minimize spills

of VOC-containing coatings, thinners, and coat ing-related waste materials; and (4) convey

VOC-containing coatings, thinners, and coating- related waste materials from one location to

another in closed containers or pipes.

D. Work Practices for Cleaning Materials

This CTG recommends work practices to reduce VOC emissions from cleaning

materials used in metal furniture surface coating operations. Although VOC reductions

achieved by implementing the recommended work practices may not be quantifiable, they

are beneficial to the overall goal of re ducing VOC emissions. We recommend work

practices for storage, mixing operations, and handling operations for cleaning materials.

Specifically, we recommend the following work practices: (1) store all VOC-containing

cleaning materials and used shop towels in cl osed containers; (2) ensure that mixing and

storage containers used for VOC -containing cleaning materials ar e kept closed at all times

except when depositing or removing these mate rials; (3) minimize spills of VOC-containing

cleaning materials; (4) conve y VOC-containing cleaning materi als from one location to

another in closed containers or pipes; a nd (5) minimize VOC emission from cleaning of

storage, mixing, and conveying equipment.

VII. Cost Effectiveness of Recommended Control Options

We used the 2002 National Emissions Inve ntory (NEI) database to estimate the

number of metal furniture manufacturing facil ities. Based on the 2002 NEI, we estimated

that there are a total of 456 metal furniture facilities in the U.S. Using the 2004 ozone

nonattainment designations, we estimated that a total of 289 of these f acilities are in ozone

nonattainment areas. Based on the NEI VOC emissions data, 143 of the 289 facilities in

ozone nonattainment areas emitted at or above the 6.8 kg/day (15 lb/day) recommended

VOC emissions applicability threshold. Thes e 143 facilities emitted a total of about 3,100

# 26 Mg of VOC per year (Mg/yr) ( 3,400 tons per year (tpy)), or an average of about 21 Mg/yr

(23 tpy) of VOC per facility.

As previously mentioned, the recommendati ons in this CTG are similar to the South

Coast regulations governing me tal furniture surface coati ng operations. The cost

effectiveness related to the implementation of these regulations was not estimated during

their development. Therefore, cost-effectiv eness estimates for the recommended control

levels were determined using the approach used during the 2003 NE SHAP development.

Although the 2003 NESHAP regulates organic HAP, the 2003 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

metal furniture coatings and cleaning material s as those recommended in this CTG.

In our analysis of the impacts of implemen ting the recommended levels of control in

this CTG, we have assumed that all metal furn iture surface coating facilities will choose to

utilize the low-VOC coating materials altern ative. We made this assumption for two

reasons. First, we believe that low-VOC coa ting materials that can meet the levels of

control recommended in this CTG are already 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 is a

more costly alternative.

According to studies performed for the development of the 2003 NESHAP, the cost

averaged across all sizes of faciliti es, was as high as $1,670 per facility. 4 

# We believe that

this estimate also represents the cost of implementing this CTG’s recommended VOC limits

because the NESHAP is based on similar c ontrol measures. For the 143 facilities we

identified as emitting more than 6.8 kg/day (15 lb/day) in ozone nonattainment areas, we

therefore estimate the total annual cost to be $240,500. We estimate that the

recommendations in this CTG will reduce VOC emissions from metal furniture coating by

about 35 percent. This is a reduction of 1,100 Mg/yr (1,200 tpy of VOC) from the 143

facilities. Therefore, we estimate the cost effectiveness to be about $220 per Mg ($200 per

ton) of VOC emission reduction.

We believe that the work practice recomme ndations in this CTG will result in a net

cost savings. Implementing work practices reduces the amount cleaning materials used by

reducing the amount that eva porates and is wasted.

VIII. References

1. Control of Volatile Organic Emissions from Existing Stationary Sources - Volume

III: Surface Coating of Metal Furniture. Publication No. EPA-450/2-77-032. U. S.

Environmental Protection Agency, Resear ch Triangle Park, NC. December 1977.

The 1977 CTG is included as Appendix A to this CTG.

2. U.S. Environmental Protection Agenc y. Standards of Performance for Surface

Coating of Metal Furniture. 40 CFR part 60, subpart EE. October 29, 1982.

# 27 3. U.S. Environmental Protection Agency. National Emission Standards for Hazardous

Air Pollutants: Metal Furn iture Surface Coating. 40 CF R part 63, subpart RRRR.

May 23, 2003.

4. National Emission Standards for Hazardous Air Pollutants (NESHAP) for Source

Category: Metal Furniture Surface Coating – Background Information for

Proposed Standards. Publication No. EPA-453/R-01-010. U.S. Environmental

Protection Agency, Research Tr iangle Park, NC. October 2001.

5. Handbook: Control Technologies for Hazardous Air Pollutants. EPA-625/6-91-014,

U.S. Environmental Protection Agency, Cincinnati, Ohio. June 1991.

6. Pressure Sensitive Tape and Label Sur face Coating Industry--Background

Information for Proposed Standards. EPA-450/3-80-003a, U.S. Environmental

Protection Agency, Research Triangle Pa rk, North Carolina. September 1980. pp. 3-

14 to 3-15.

7. Compilation of Air Pollutant Emission Factors (AP-42), Volume I (Fifth Edition)

. U.S. Environmental Protection Agency, Re search Triangle Park, North Carolina.

January 1995. p. 4.2.2.6-3.

8

. 

# A Guideline for Surface Coating Calculations. U.S. Environmental Protection

Agency, Washington, D.C. Publica tion No. EPA-340/1-86-016. July 1986.

9

. 

# Improving Air Quality with Economic Incentive Programs. U.S. Environmental

Protection Agency. Research Triangl e Park, NC. EPA-452/R-01-001. January

2001.

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# Appendix A

1977 CTG for Metal Furniture Coating

# This page intentionally left blank.

# A-1

# A-2 This page intentionally left blank.

# Appendix B

Summary of State and Local Re gulations for Metal Furniture

Coating (not including California)

# This page intentionally left blank.Table B-1. Summary of State and Local Regulations for Metal Furniture Coating (not including California)B-1State/LocalityOperationsCoveredVOC NumericalLimit (minuswater and exemptcompounds) Compliance Method CitationAlabama(Jefferson County)Metalfurniturecoating0.36 kg/l (3.0 lb/gal)as applied(excluding water)For sources located in Jefferson County:1.use low solvent coating technology; or2.a capture and control system that have anoverall VOC emission reduction that meet theapplicable emission limit each day; or3.use powder coating technology; or4.average two or more coatings on a coating linethat has no add-on VOCcontrol equipment if:a.The coating is the same type of operation(source category) and issubject to the samelimits; andb.the coatings are on the same coating line; andc.the coatings are averaged on the basis ofpounds of VOC emitted per gallon of coatingsolids applied to the substrate; andd.The compliance demonstration is on a 24-hour period (calendar day); ande.The VOC emissions shall be equal to or lessthan those emitted when all the surfacecoatings delivered to the application systemcomply with the applicable regulated VOCemission rate restriction.Exemption:55 gallons of “low-use coatings” maybe exempted on an annual rolling basisAlabama DEM AirDivision Chapter335-3-6-.24 and335-3-6-.32(3)Table B-1. Summary of State and Local Regulations for Metal Furniture Coating (not including California)B-2State/LocalityOperationsCoveredVOC NumericalLimit (minuswater and exemptcompounds) Compliance Method CitationAlabama (exceptJefferson County)Metalfurniturecoating0.36 kg/l (3.0 lb/gal)as applied(excluding water)For sources NOT located in Jefferson County:1.use low solvent coating technology; or2.90 percent emission reduction usingincineration; or3.another equivalent control technologyExemptions:Sources with the potential to emitless than 100 ton VOC/yrAlabama DEM AirDivision Chapters335-3-6-.01 and335-3-6-.11(3)AlaskaaArizona Incorporated by Reference, 40 CFR 60, Subpart EE (NSPS) and 40 CFR 63, Subpart RRRR (NESHAP)Arizona/Pima Incorporated by Reference, 40 CFR 60,Subpart EE (NSPS) and 40 CFR 63, Subpart RRRR (NESHAP)Arizona/Pinal Incorporated by Reference, 40 CFR 60,Subpart EE (NSPS) and 40 CFR 63, Subpart RRRR (NESHAP)aAlaska does not have applicable air regulations.Table B-1. Summary of State and Local Regulations for Metal Furniture Coating (not including California)B-3State/LocalityOperationsCoveredVOC NumericalLimit (minuswater and exemptcompounds) Compliance Method CitationMetalfurniturecoating0.36 kg/l (3.0 lb/gal)as appliedApply all coatings containing more than 240 gVOC/l (2 lb/gal), minus exempt cmpds using:1.Low pressure spray gun; or2.An electrostatic system; or3.hydraulic pressure atomizer (including airlessand air assisted airless); or4.non-atomizing or non-spraying applicationmethods; or5.alternate methods approved by regulatoryauthoritiesUse control systems meeting the following:1.Prevent at least 85% of the VOC emitted,except as controlled using the alternative forvery dilute streams (see 3 below)2.Use an 87% efficient capture system;3.Use a 90% efficient control system or for VOCinput less than 100 ppm –control to less than20 mg VOC/M3and the control system gets85% controlExemptions:Coatings and solvents with a VOCcontent less than 18g VOC/l (0.15 lb VOC/gal).Coatings containing less than 0.14 lb/gal VOC.Regulation III, Rule336, section 301through 306Arizona/MaricopaCleaningMaterials35 mm Hg at 20oC Work practices to minimize emissions ofapplicable equipmentArkansasbbArkansas does not have applicable air regulations.Table B-1. Summary of State and Local Regulations for Metal Furniture Coating (not including California)B-4State/LocalityOperationsCoveredVOC NumericalLimit (minuswater and exemptcompounds) Compliance Method CitationColorado Metalfurniturecoating0.36 kg/l (3.0 lb/gal) 1.Use compliant coatings;2.Use emissions averaging;3.Use a capture system approved by theauthority or a system that meets the NSPS forMagnetic Tape4.Use an add-on control system to meet the limitExemptions:metal furniture coating operationswith uncontrolled actual emissions (includingfugitives) are less than 6.8 kg/day (15 lb/day) and1.4 kg/hr (3 lb/hr).No cleaning materials regulations.CO DPHEAQCCRegulation No. 75 CCR 1001-9Section IX.HConnecticut Metalfurniturecoating0.36 kg/l (3.0 lb/gal)as applied1. Compliant coatings;2. Daily-weighted average coating content;3. Install capture and control system that reducesemissions by 95 percentExemptions: any premises with uncontrolledactual emissions from all coating units are less than6.8 kg VOC per day (15 lb/day) combinedNo cleaning materials regulations.RSCA Title 22aSection 22a-174-20(p)Delaware Metalfurniturecoating0.35 kg/l (2.9 lb/gal)as applied1.Compliant coatings;2.Daily weighted average coating content3.Install capture and control system that reducesemissions by 95 percentExemptions: any coating unit with uncontrolledactual emissions from all coating units are less than15 lb VOC/dayDNREC Regulation24, Section 19Table B-1. Summary of State and Local Regulations for Metal Furniture Coating (not including California)B-5State/LocalityOperationsCoveredVOC NumericalLimit (minuswater and exemptcompounds) Compliance Method CitationCleaningMaterialsDoes not apply to hand-wipe cleaning operationsUse work practices to minimize emissions.Perform a solvent usage study to determine permitrequirements. User-defined and operation specific.Florida Metalfurniturecoating0.36 kg/l (3.0 lb/gal)as applied(excluding water)1. use of compliant coatings;2. use of incineration that reduces VOC emissionsby 90 percent.Exemptions:all emission units subject to thesame limitation that emit less than 6.8 kg VOC perday (15 lb/day) and 1.4 kg/hr (3 lb/hr) combinedNo cleaning material regulations.FAC Chapter 62-296.500, 505Table B-1. Summary of State and Local Regulations for Metal Furniture Coating (not including California)B-6State/LocalityOperationsCoveredVOC NumericalLimit (minuswater and exemptcompounds) Compliance Method CitationGeorgia Metalfurniturecoating3.0 lb/gal(excluding water)5.06 lb/gal coatingsolids as applied1.use low solvent compliant coating technology2.use 24-hr weighted average of low solventcoating on a single coating line that meets5.06 lb VOC/gal coating solids (averagingacross coating lines is not allowed)3.use capture and control that reduces VOCemissions by 90 percent and overall VOCemissions do not exceed 5.06 lb VOC/galcoating solidsExemptions:Sources located outside Cherokee,Clayton, Cobb, Coweta, DeKalb, Douglas, Fayette,Forsyth, Fulton, Gwinnett, Henry, Paulding, andRockdale counties with potential VOC emissionsare less than 100 tons per year; Sources locatedwithin Cherokee, Clayton, Cobb, Coweta, DeKalb,Douglas, Fayette, Forsyth, Fulton, Gwinnett,Henry, Paulding, or Rockdalecounties with actualVOC emissions are less than 15 lb/day; total use ofcoatings, inks and other VOC-containing materialsis less than 55 gal/yrNo cleaning materials regulations.GDNROGCA 12-9-1391-3-1-.02(2)(y)HawaiicIdaho Incorporated by Reference, 40 CFR 60, Subpart EE (NSPS) and 40 CFR 63, Subpart RRRR (NESHAP)cHawaii does not have applicable air regulations.Table B-1. Summary of State and Local Regulations for Metal Furniture Coating (not including California)B-7State/LocalityOperationsCoveredVOC NumericalLimit (minuswater and exemptcompounds) Compliance Method CitationIllinois (notincluding Chicagoand Metro Eastareas)Metalfurniturecoating0.36 kg/l (3.0 lb/gal) 1.control emissions by an afterburner systemwhich provides an overall 81% VOC emissionfrom the coating line, and 90% of thenonmethane VOC (measured as totalcombustible carbon) which enters theafterburner.2.the combined actual emissions from selectedcoating lines (not including those constructedor modified after 7/1/79), is less than or equalto the combined allowable emissions calculatedusing the formula provided in the regulation.Exemptions:Coating plants in whichuncontrolled VOC emissions are limited by theoperating permit to 22.7 Mg/yr (25 tpy); or thetotal coating usage does not exceed 9,463 l/yr(2,500 gal/yr); or touch-up and repair coatings usedby a coating source if the source-wide volume isless than 0.95 l (1 quart)per eight-hour period orexceeds 209 l/yr (55 gal/yr) for any rolling twelvemonth period.No cleaning materials regulations.Title 35, Subtitle B,Chapter I;Subchapter c, Part215, Subpart F,sections 215.204(g),215.205(b) and215.206 (a) and (b)Table B-1. Summary of State and Local Regulations for Metal Furniture Coating (not including California)B-8State/LocalityOperationsCoveredVOC NumericalLimit (minuswater and exemptcompounds) Compliance Method CitationMetalfurniturecoating, airdried0.34 kg/l (2.8 lb/gal)Illinois (Chicagoareas)Metalfurniturecoating,baked0.28 kg/l (2.3 lb/gal)1.apply coatings that,during each day, do notexceed the daily-weighted average VOCcontent limit2.use a capture and control system which has anoverall VOC emission reduction of 81% andthe control device has a 90% efficiency3.capture and control system reduces VOCemissions to meet the applicable VOCemission limit.Exemptions:Coating plants in which combinedactual uncontrolled VOC emissions do not exceed6.8 kg/day (15 lb/day); or touch-up and repaircoatings used by a coating source if the sourcewide volume is less than0.95 l (1 quart) per eighthour period or exceeds 209 l/yr (55 gal/yr) for anyrolling twelve-month period.No cleaning material regulations.Title 35, Subtitle B,Chapter I;Subchapter c, Part218, Subpart F,sections 218.204(g),218.205(h),218.207(b),218.208(a) and (c)Table B-1. Summary of State and Local Regulations for Metal Furniture Coating (not including California)B-9State/LocalityOperationsCoveredVOC NumericalLimit (minuswater and exemptcompounds) Compliance Method CitationMetalfurniturecoating, airdried0.34 kg/l (2.8 lb/gal)Illinois (MetroEast areas)Metalfurniturecoating,baked0.28 kg/l (2.3 lb/gal)1.apply coatings that,during each day, do notexceed the daily-weighted average VOCcontent limit2.use a capture and control system which has anoverall VOC emission reduction of 81% andthe control device has a 90% efficiency3.capture and control system reduces VOCemissions to meet the applicable VOCemission limit.Exemptions:Coating plants in which combinedactual uncontrolled VOC emissions do not exceed6.8 kg/day (15 lb/day); or touch-up and repaircoatings used by a coating source if the sourcewide volume is less than0.95 l (1 quart) per eighthour period or exceeds 209 l/yr (55 gal/yr) for anyrolling twelve-month period.No cleaning materials regulations.Title 35, Subtitle B,Chapter I;Subchapter c, Part219 Subpart F,sections 219.204(g),219.205(a),219.207(b),219.208(a) and (c)Table B-1. Summary of State and Local Regulations for Metal Furniture Coating (not including California)B-10State/LocalityOperationsCoveredVOC NumericalLimit (minuswater and exemptcompounds) Compliance Method CitationIndiana Metalfurniturecoating0.36 kg/l (3.0 lb/gal)(excluding water)1.use compliant coatings2.carbon adsorption3.incineration4.higher solids coatings5.waterborne coatings6.equivalent emission limitation based ontransfer efficiencyExemptions:Facilities existing before 1/1/80 notlocated in Clark, Elkhart, Floyd, Lake, Marion,Porter, and St. Joseph Counties which havepotential emissions lessthan 90.7 Mg/yr (100 tpy);Facilities constructed after 1/1/80 located in anycounty with potential emissions less than22.7 Mg/yr (25 tpy), Facilities existing before7/1/90 and not located in Clark, Elkhart, Floyd,Lake, Marion, Porter, and St. Joseph Counties andfacilities constructed after 7/1/90 and located inany county with actual uncontrolled emissions lessthan 15 lb VOC/dayNo cleaning material regulations.IDEM Air PollutionControl Board title326326 IAC 8-1-2,8-2-1, 8-2-6, 8-2-11Iowa Incorporated by Reference, 40 CFR 60, Subpart EE (NSPS) and 40 CFR 63, Subpart RRRR (NESHAP)Kansas Metalfurniturecoating3.0 lb/gal 1.use compliant coatings2.use coatings that meet limit on a daily weightedaverage basis3.capture and control system with an overallemission reduction of at least 90%Exemptions: Facility with facility-wide VOC PTEless than 3 tpy. Facilitieslocated outside of ozonenonattainment areas.Kansas AQR 28-19-73(c), (f), (k)Table B-1. Summary of State and Local Regulations for Metal Furniture Coating (not including California)B-11State/LocalityOperationsCoveredVOC NumericalLimit (minuswater and exemptcompounds) Compliance Method CitationKentucky Metalfurniturecoating3.0 lb/gal for newsources or 15 % byweight of VOCs netinput into thefacility for existingsourcesExemptions:Coatings with VOC content less than0.36 kg/l (3.0 lb/gal). Facility with actualuncontrolled emissions less than 3 lb/hr; 15 lb/day;or 10 tpy based on maximum production and 8,760hr/yr. Low use coating if plantwide consumption isless than or equal to55 gal/previous 12 months.No cleaning materials regulations.401 KAR 61:120Table B-1. Summary of State and Local Regulations for Metal Furniture Coating (not including California)B-12State/LocalityOperationsCoveredVOC NumericalLimit (minuswater and exemptcompounds) Compliance Method CitationLouisiana Metalfurniturecoating0.36 kg/l (3.0 lb/gal)(minus water andexempt solvent)1.capture system with at least 80% efficiency2.Low solvent coating3.incinerator with at least 90% control efficiency4.carbon adsorptionExemptions: All emission units subject to thesame limitation that emit less than 6.8 kg VOC perday (15 lb/day) and 1.3 kg/hr (3 lb/hr) combined.Surface coating facilities in Ascension, Calcasieu,East Baton Rouge, Iberville, Livingston, PointeCoupee, and West Baton Rouge parishes that whencontrolled have a potential to emit a combinedweight (total from the property) of VOCs less than10 tons in any consecutive 12 calendar months areexempt from the provisions of Subsection C.Surface coating facilitieson any property inparishes other than Ascension, Calcasieu, EastBaton Rouge, Iberville, Livingston, Pointe Coupee,and West Baton Rouge that when uncontrolledhave a potential to emit a combined weight ofVOCs less than 100 pounds (45 kilograms) in anyconsecutive 24-hour period are exempt from theprovisions of Subsection C.No cleaning materials regulations.LAC Title 332123.A, CTable B-1. Summary of State and Local Regulations for Metal Furniture Coating (not including California)B-13State/LocalityOperationsCoveredVOC NumericalLimit (minuswater and exemptcompounds) Compliance Method CitationMaine Metalfurniturecoating0.36 kg/l (3.0 lb/gal) 1.Low solvent coating2.Capture and control system that gets 95%control or 4.9 lb/gal solidsExemptions:maximum theoretical VOCemissions from all coating units, lines or operationsunder the same surface coating category less than10 tpy. Or Coating units, lines or operations whosetotal actual coatings usage from all coating units,lines or operations underthe same surface coatingcategory is less than 50 gal/yr of coatings. ORfacilities that use powder coatings or other nonVOC coating methods.No cleaning materials regulations.06 096 Chapter 1291.A, 1.E, 3.DTable B-1. Summary of State and Local Regulations for Metal Furniture Coating (not including California)B-14State/LocalityOperationsCoveredVOC NumericalLimit (minuswater and exemptcompounds) Compliance Method CitationMaryland Metalfurniturecoating0.36 kg/l (3.0 lb/gal) 1.use low VOC coatings or adhesives;2.use a control device that, results in an emissionreduction equal to or greater than the emissionreduction that would have been achieved bycomplying low use VOC coatings3.reduce emissions by using water-basedcoatings, resins, inks, orsimilar products thatcontain less than 25 percent VOC by volume ofthe volatile portion of the product; or4.an alternative method approved by authorityNo cleaning materials regulations.ACM Subtitle 1126.11.19.02 and .08Massachusetts Metalfurniturecoating5.1 lb/gal solidsapplied1.Use low/no solvent coatings2.Use add-on controls3.Use daily weighted averagingExemptions:facilities for which the total amountof all coatings exemptedis less than 55 gal on a 12-month rolling period and facilities withuncontrolled VOC emissions less than 15 lb/dayKeep records of cleaning materials usage.310 CMR 7.18(3)Table B-1. Summary of State and Local Regulations for Metal Furniture Coating (not including California)B-15State/LocalityOperationsCoveredVOC NumericalLimit (minuswater and exemptcompounds) Compliance Method CitationMichigan Metalfurniturecoating3.0 lb/gal (asapplied, minuswater), or8.4 lb/gal coatingsolids applied1.Use compliant coatings2.Use volume weighted average emissionscoating content3.Use add-on controls combined with volumeweighted averageExemptions:Facilities witha combined actualVOC emission rate less than 100 lb/day or2,000 lb/month and facilities may exclude low-usecoatings that total 55 gallons or less per rolling 12-month period.No cleaning materials regulations.R336.1610(2), (7),(8), (11)Minnesota Incorporated by Reference, 40 CFR 60, Subpart EE (NSPS) and 40 CFR 63, Subpart RRRR (NESHAP)Mississippi Incorporated by Reference, 40 CFR 60, Subpart EE (NSPS) and 40 CFR 63, Subpart RRRR (NESHAP)Missouri Metalfurniturecoating3.0 lb/gal (asapplied, minuswater)1.Comply with daily volume-weighted average,as applied, on a lb/gal coating basis2.comply with daily volume-weighted average,as applied, on a lb/gal coating solids basis;3.comply with a combination of capture andcontrol system and daily volume-weightedaverage.Exemptions:Doesnot apply to sources locatedoutside of Clay, Jackson, and Platte counties. Andsources with total uncontrolled potential VOCemissions is less than 6.8 kg/day (2.7 tpy)No cleaning materials regulations.10 CSR 10-2.230(1)(A) and (B),(4) and (5)Montana Incorporated by Reference, 40 CFR 60, Subpart EE (NSPS) and 40 CFR 63, Subpart RRRR (NESHAP)Table B-1. Summary of State and Local Regulations for Metal Furniture Coating (not including California)B-16State/LocalityOperationsCoveredVOC NumericalLimit (minuswater and exemptcompounds) Compliance Method CitationNebraska Incorporated by Reference, 40 CFR 60, Subpart EE (NSPS) and 40 CFR 63, Subpart RRRR (NESHAP)NevadadNew Hampshire Metalfurniturecoating0.36 kg/l (3.0 lb/gal) 1.use compliant coatings2.add-on control deviceor bubble and complywith solids-based emission rateExemptions:Minor VOC sources with total VOCemissions less than 5 tpy. Sources that alreadymeet or exceed RACT requirements. Facilitieswith VOC PTE less than 10 tpy.No cleaning materials regulations.NHCAR, ChapterENV-A 1200,1204.02(b), (c), (d),1204.12New Jersey Metalfurniturecoating0.36 kg/l (3.0 lb/gal)(minus water)1.Control emissions by 90 percent2.control emissions such that the hourly VOCemission rate does not exceed a calculated maxhourly emission rateExemptions:Total surface coating formulationcontaining VOC are appliedat a rate less than 1⁄2gallon per hour and 2 1⁄2 gallons per day. Surfacecoating operations with VOCPTE less than 3 lb/hr.No cleaning materials regulations.NJAC Title 7,Chapter 27,subchapter 167:27-16.7New MexicoeIncorporated by Reference, 40 CFR 60, SubpartEE (NSPS) and 40 CFR 63, Subpart RRRR (NESHAP)dNevada has no air regulations applicable to the Metal Furniture industry.eNew Mexico has a local agency with air regulations, but they could not be accessed on the Internet.Table B-1. Summary of State and Local Regulations for Metal Furniture Coating (not including California)B-17State/LocalityOperationsCoveredVOC NumericalLimit (minuswater and exemptcompounds) Compliance Method CitationNew York 3.0 lb/gal 1.Use a VOC incinerator that with 80% removalefficiency2.determine overall removal efficiency of an aircleaning device on a solids as applied basisunless the air cleaning device has an 85%removal efficiencyExemptions:Low-use coatings where thecombined facility-wide usage is less than 55gallons on a 12-month rolling averageUse work practices to minimize VOC emissionsfrom cleaning materials.NY ECL part 228Sections 228.1, 3,and 7North Carolina Metalfurniturecoating5.1 lb/gal coatingsolids, as applied orif using a controldevice, 3.0 lb/galcoating, as appliedExemptions:Sources with VOC emissions lessthan 15 lb/dayNo cleaning materials regulations.NCAC 2D.0922North DakotafIncorporation by Reference, 40 CFR 60, Subpart EE (NSPS)fNorth Dakota does not have applicable air regulations.Table B-1. Summary of State and Local Regulations for Metal Furniture Coating (not including California)B-18State/LocalityOperationsCoveredVOC NumericalLimit (minuswater and exemptcompounds) Compliance Method CitationOhio (Ashtabula,Butler, Clark,Clermont,Cuyahoga,Delaware,Franklin, Geauga,Greene, Hamilton,Lake, Licking,Lorain, Lucus,Mahoning,Medina, Miami,Montgomery,Portage, Stark,Summit,Trumbull, Warren,and WoodCounties)Metalfurniturecoating3.0 lb/gal coatingOR5.1 lb/gal solids (ifusing a controlsystem)1.Use compliant coatings; or2.Use a capture and control system that meets the5.1 lb VOC/gal solids limit; or3.Use a capture and control system with anoverall VOC emission reduction greater than81%, by weight, in the overall VOC emissionsfrom the coating line; and the controlequipment has an VOC emission reductionefficiency of 90% by weight; or4.An alternative emission limitation based upona transfer efficiency (determined using a testmethod) greater than 60 percent.Exemptions:Total VOC emissions from coatingoperations are less than 15 lb/day before add-oncontrol.OAC 3745-21-09(I)Table B-1. Summary of State and Local Regulations for Metal Furniture Coating (not including California)B-19State/LocalityOperationsCoveredVOC NumericalLimit (minuswater and exemptcompounds) Compliance Method CitationOhio (remaining64 counties)Metalfurniturecoating3.0 lb/gal coatingOR5.1 lb/gal solids (ifusing a controlsystem)1.Use compliant coatings; or2.Use a capture and control system that meets the5.1 lb VOC/gal solids limit; or3.Use a capture and control system with anoverall VOC emission reduction greater than81%, by weight, in the overall VOC emissionsfrom the coating line; and the controlequipment has an VOC emission reductionefficiency of 90% by weight; or4.An alternative emission limitation based upona transfer efficiency (determined using a testmethod) greater than 60 percent.Exemptions:Existing facilities (for whichconstruction or modification commenced beforeOctober 19, 1979) and have the potential to emitless than 100 tpy VOC. Total VOC emissionsfrom coating operations are less than 15 lb/daybefore add-on control.OAC 3745-21-09(I)OklahomaAttainment areasMetalfurniturecoating,variouscoatingtypes4.8 – 6.5 lb/gal 1.compliant coatings2.incineration, absorption, adsorption, or otherprocess so long as emissions are no more thanthey would be using compliant coatingsExemptions: sources that emit less than 100lb/day of VOC.Include VOC emissions from cleanup indetermining complianceTitle 252, Chapter100, 252:100-37-25Table B-1. Summary of State and Local Regulations for Metal Furniture Coating (not including California)B-20State/LocalityOperationsCoveredVOC NumericalLimit (minuswater and exemptcompounds) Compliance Method CitationOklahomaTulsa CountyMetalfurniturecoating,variouscoatingtypes3.0 – 4.3 lg/gal 1.compliant coatings2.incineration, absorption,or other equipment solong as emissions are no more than they wouldbe using compliant coatings, and at least 85%overall control efficiencyInclude VOC emissions from cleanup indetermining compliance.Title 252, Chapter100, 252:100-39-46Oregon Metalfurniturecoating3.0 lb/gal(as applied)1.Use low solvent coatings;2.Use an incineration system that gets 90%control or3.An equivalent means of controlExemptions:Sources whose potential VOCemissions are less than 10 tpy (or 3 lb VOC/hr or15 lb VOC/day actual).Keep records of cleaning materials usage.OAR 340-232-0160Table B-1. Summary of State and Local Regulations for Metal Furniture Coating (not including California)B-21State/LocalityOperationsCoveredVOC NumericalLimit (minuswater and exemptcompounds) Compliance Method CitationPennsylvania Metalfurniturecoating0.61 kg/l coatingsolids(5.06 lb/gal coatingsolids)1.Use compliant coatings, as applied.2.Use combination of compliant coatings andcapture and control systemsExemptions:A facility that has had actual VOCemissions less than 1.4 kg/hr (3 lb/hr), 7 kg/day(15 lb/day) or 2,455 kg/yr(2.7 tpy) during anycalendar year since January 1, 1987No cleaning materials regulations.129-52Rhode Island 5.06 lb/gal coatingsolids or3.0 lb/gal coating(excluding waterand exemptsolvents)1.Reduce VOC emissions by 95% using a controlsystem;2.Use compliant coatings;3.Use control systems to meet coating contentlimits;4.Use daily-weighted averaging5.Use an approved alternative methodExemptions:Actual uncontrolled VOC emissionsare less than 15 lb/day since 12/31/89.Keep records of cleaning materials usageAir PollutionControl RegulationNo. 19South Carolina Metalfurniturecoating0.36 kg/l (3.0 lb/gal)as applied1.Low solvent technology2.incineration that reduces VOC emissions by 90percent3.carbon bed solvent recovery or4.alternative technologyExemptions:plants with total potential VOCemissions less than 550 pounds (250 kilograms) inany one day (nominal size- 100 tons per year) ormore than 150 pounds (68 kilograms) in any onehour.Keep records of cleanup materials.62.5, St. 5, Part DTable B-1. Summary of State and Local Regulations for Metal Furniture Coating (not including California)B-22State/LocalityOperationsCoveredVOC NumericalLimit (minuswater and exemptcompounds) Compliance Method CitationSouth Dakota Incorporated by Reference, 40 CFR 63, Subpart RRRR (NESHAP)Tennessee Metalfurniturecoating0.36 kg/l(3.0 lb/gal),excluding waterand/or exemptcompounds, asapplied1.Use compliant coatings;2.Meet limit using weighted average VOCcontent3.Reduce emissions by 95% using capture andcontrol systemExemptions:Facilities located in Davidson,Rutherford, Sumner, Williamson, or WilsonCounty with actual uncontrolled VOC emissionsfrom all metal furniture coating operations lessthan 6.8 kg (15 lb) per day or whose maxtheoretical VOC emissions from all paper coatingoperations are less than 10 tpy. Facilities inHamilton or Shelby County with potential VOCemissions from all metal furniture coatingoperations less than 25 tpy, Facilities located inany other county with potential VOC emissionsfrom all metal furniture coating operations lessthan 100 tpy.No cleaning materials regulations.1200-3-18-17Table B-1. Summary of State and Local Regulations for Metal Furniture Coating (not including California)B-23State/LocalityOperationsCoveredVOC NumericalLimit (minuswater and exemptcompounds) Compliance Method CitationTexasgUtah Metalfurniturecoating0.36 kg/l (3.0 lb/gal)coating or5.1 lb/gal coatingsolids1.use low solvent technology coatings;2.reduce VOC emissions by 90% using anincinerator3.use a carbon adsorber4.use water-borne electrodeposition5.use water-borne spray, dip, or flowcoat6.use powder coatings7.use higher solids coatingsExemptions:Sources whose VOC emissions areless than 6.8 kg (15 lb) in any 24 hour period, normore than 1.4 kg (3 lb) in any one hourWork practices to minimize VOC emissions fromcleaning materials.R307-340-2, 5, and11Vermont Metalfurniturecoating,variouscoatings3.0 – 4.3 lb/gal 1.Daily weighted average of VOC content mustcomply with VOC limit.2.install capture and control device where theoverall reduction efficiency is greater than orequal to the required reduction efficiency (anefficiency is not specified).Exemptions:Metal furnitue coating sources thathave actual uncontrolled VOC emissions less than5 lb/day.No cleaning materials regulations.5-253.13gCould not access Texas air regulations website.Table B-1. Summary of State and Local Regulations for Metal Furniture Coating (not including California)B-24State/LocalityOperationsCoveredVOC NumericalLimit (minuswater and exemptcompounds) Compliance Method CitationVirginia Metalfurniturecoating3.0 lb/gal, asapplied (excludingwater)1.Use of waterborne or electrodepositedwaterborne coatings;2.Use of high-solids coatings;3.Use of powder coatings;4.Carbon adsorption;5.Incineration; or6.Any technology with an equivalent controlefficiency when compared to the use of acoating complying with the VOC limitNo cleaning materials regulations.9 VAC 5-40-4610,4630, 4640Washington Incorporated by Reference, 40 CFR 60,Subpart EE (NSPS) and 40 CFR 63, Subpart RRRR (NESHAP)Metalfurniturecoating0.36 kg/l (3.0 lb/gal)coating1.Daily weighted emission limitation2.use a capture and control system with anoverall emission reduction of 95%Exemptions:coating operations at facilities withuncontrolled actual VOC emissions less than6.8 kg (15 lb) per day.West VirginiaCleaningmaterials6.8 kg/day(15 lb/day)Use work practices to minimize emissions.Do not use VOCs for cleanup activities unlessequipment is used to collect the cleaningcompounds and to minimize their evaporation tothe atmosphere.§45-21-16Table B-1. Summary of State and Local Regulations for Metal Furniture Coating (not including California)B-25State/LocalityOperationsCoveredVOC NumericalLimit (minuswater and exemptcompounds) Compliance Method CitationWisconsin Metalfurniturecoating0.36 kg/l (3.0 lb/gal)coating1.Use of low solvent coatings2.Use a vapor recovery system3.Use incinerator witha 90% emission reduction4.Daily volume-weighted averageExemptions:coating operations at facilities withuncontrolled actual VOC emissions less than0.68 kg (15 lb) per day.No cleaning materials regulations.NR 422.04 , 10Wyoming Incorporated by Reference, 40 CFR 60, Subpart EE (NSPS) and 40 CFR 63, Subpart RRRR (NESHAP)

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# Appendix C

Summary of California Air District Regulations for Metal Furniture

Coating

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Summary of California Air District Regulations for Metal Furniture CoatingC-1Operation MaterialVOClimitation Compliance Requirements CitationAntelope Valley Air Pollution Control DistrictGeneral coatings,air driedContent limitof 340 g/l asapplied (lesswater andexemptcompounds)General coatings,bakedContent limitof 275 g/l asapplied (lesswater andexemptcompounds)Specialty coatings(non-military), airdriedContent limitof 420 g/l asapplied (lesswater andexemptcompounds)Specialty coatings(non-military),bakedContent limitof 275-420 g/las applied (lesswater andexemptcompounds)Metal coatingSolvent cleaningmaterialsContent limitof 950 g/l(7.9l g/gal) andVOCcompositepartial pressureof 35 mm Hg@20oC (68oF)1.Use compliant coatings; or use an collection system that has a captureefficiency of at least 90%, by weight and the control device has anemission reduction efficiency of 95% by weight or to an outletconcentration of 50 ppmv (as carbon)2.Coatings must be applied using the following types of equipment:electrostatic attraction, flow, roll, dip, HVLP, or hand application.Alternative coating methods must be approved and achieve at least65% transfer efficiency.3.Solvent cleaning must use one of the following: wipe cleaning; closedcontainers or hand held spray bottles w/out propellant-induced force;cleaning equipment which has a solventcontainer that is closed at alltimes (except when adding or removing parts or during repair); remotereservoir cleaner; non-atomized solvent flow where solvent is collectedin a container or collection system thatis closed at all times except forsolvent collection and pressure relief (as needed) openings; and solventflushing methods where solvent is collected in a container or collectionsystem that is closed at all times except for solvent collection andpressure relief (as needed) openings (discharged solvent must becollected into containers without atomizing into the air and solventmay be flushed through the system by air or hydraulic pressure or bypumping).4.All VOC-containing solvents must be stored in non-absorbent, nonleaking containers which must be keptclosed at all times, except whenfilling or emptying. Cloth and paper containing with VOC-ladensolvents should be stored in closed, non-absorbent, non-leakingcontainers.5.Use closed containers for disposal of cloth or paper used in strippingcured coatings that are impregnated with solvent containing VOCAVAQMD Rule 1107and 1171Table C-1. Summary of California Air District Regulations for Metal Furniture CoatingC-2Operation MaterialVOClimitation Compliance Requirements CitationBay Area Air QualityManagement DistrictAir dried coatings Content limitof 340 g/l(2.8 lb/gal), asapplied (lesswater)Baked coatings Content limitof 275 g/l(2.3 lb/gal), asapplied (lesswater)Specialtycoatings, air driedContent limitof 420 g/l(3.5 lb/gal), asapplied (lesswater)MetalfurniturecoatingSpecialtycoatings, bakedContent limitof 360-420 g/l(3.0-3.5 lb/gal), asapplied (lesswater)1.Use an approved control system.2.Use low-solvent coatings that meet the content limit.3.Use closed containers to store or dispose of cloth or paper laden withorganic compounds that is used for surface preparation, cleanup orcoating removal.4.Close containers of fresh solvent, coating, or catalyst when not in use.5.Materials used for cleanup of spray equipment and surface preparationmust contain no more than 50 g/l (0.42 lb/gal) VOC.BAAQMD 8-14Table C-1. Summary of California Air District Regulations for Metal Furniture CoatingC-3Operation MaterialVOClimitation Compliance Requirements CitationEl Dorado County Air Quality Management DistrictAny that comeinto contact witha flame, or arebaked, heat cured,or heatpolymerized inthe presence of O215 lb/day and3 lb/hrMachinery,process, oroperation withthe potentialto emitorganiccompoundsAny that areconducted at orbelow ambienttemperatures40 lb/day and8 lb/hr(emissionsfrom air orheat drying forthe first 12hours must beincluded)1.Reduce VOC emissions by 85% or more; or equip process with BACT2.Do not dispose or allow the release of organic compounds fromstorage or transfer operations of more than 1.5 gal of liquid (orequivalent amount of vapor).Exemptions:(1) stationary storage containers less than 250 gal; (2) anysingle use or operation which annually uses a total volume of VOC which isless than the emission limits, unless it is part of a large operation subject otregulation; and (3) sources in existence before March 1, 1984.EDCAQMD Rule 216Solvents used onsubstrates duringthe manufacturingprocess or forsurfacepreparation70 g VOC/lmaterialSolventCleanersSolvents used formaintenance andrepair900 g VOC/lmaterial and acompositepartial pressureof 20 mm Hgor less at 20oC(68oF)1.Use complaint cleaning materials AND Use one of the followingcleaning devices or methods:a.Wipe cleaning;b.Non propellant spray bottles or containersc.Cleaning equipment which has a solvent container that can be, andis, closed during cleaning operations, except when depositing andremoving objects, and is closed during non-operation with theexception of maintenance and repair to the cleaning equipmentitself;d.Non-atomized solvent flow methodwhere the cleaning solvent iscollected in a container or a collection system which is closedexcept for solvent collection openings and, if necessary, openingsto avoid excessive pressure build-up inside the container; orEDCAQMD Rule 235Table C-1. Summary of California Air District Regulations for Metal Furniture CoatingC-4Operation MaterialVOClimitation Compliance Requirements CitationSolvents used forcleaning coatingsor adhesivesapplicationequipment950 g VOC/lmaterial and acompositepartial pressureof 35 mm Hgor less at 20oC(68oF)Solvents used forcleaning polyesterresin applicationequipment200 g VOC/lmaterial; or1,100 g VOC/land compositepartial pressureof 1.0 mm Hgor less at 20oC(68oF) orsolventreclamationsysteme.Solvent flushing method where the cleaning solvent is dischargedinto a container which is closed except for solvent collectionopenings and, if necessary, openings to avoid excessive pressurebuild-up inside the container. The discharged solvent from theequipment must be collected into containers without atomizinginto the open air. The solvent may be flushed through the systemby air or hydraulic pressure, or by pumping.2.Use a collection and control systemthat collects at least 90 percentof the emissions and reduces VOC emissions by at least 95 percent orhas an outlet concentration less than 50 ppmw (as carbon)Table C-1. Summary of California Air District Regulations for Metal Furniture CoatingC-5Operation MaterialVOClimitation Compliance Requirements CitationGreat Basin Unified Air Pollution Control DistrictAny that comeinto contact witha flame, or arebaked, heat cured,or heatpolymerized inthe presence of O215 lb/day and3 lb/hrPhotochemicallyreactive solvent(except solventsthat are baked,heat cured orheatpolymerized)40 lb/day and8 lb/hr(emissionsfrom air orheat drying forthe first 12hours must beincluded)Organicsolvents orsolventcontainingmaterialsNonphotochemicallyreactive solvent(except solventsthat are baked,heat cured orheatpolymerized)3,000 lb/dayand 450 lb/hr(emissionsfrom air orheat drying forthe first 12hours must beincluded)1.Reduce VOC emissions by 85% or more2.Control emissions by incineration with an emission reduction of 90%or use adsorption, or another approved method of control.Exemptions:(1) transport of storage of organic containing materials; (2)the volatile content of materials consists of only water and nonphotochemically reactive organic solvents containing less than 20% byvolume of VOC, and does not come into contact with a flame; (3) thevolatile content of materials consists of only water and nonphotochemically reactive organic solvents and more than 50% by volume ofVOC is evaporated prior to entering a chamber heated above ambienttemperature, and does not come intocontact with a flame; and (4) thesolvent content is less than 5% by volume of non-photochemically reactiveorganic solvents, and does not come into contact with a flame.GBUAPCD Rule 417Table C-1. Summary of California Air District Regulations for Metal Furniture CoatingC-6Operation MaterialVOClimitation Compliance Requirements CitationImperial County Air Pollution Control DistrictAny that comeinto contact witha flame, or arebaked, heat cured,or heatpolymerized inthe presence of O215 lb/day and3 lb/hrOrganicsolvents orsolventcontainingmaterialsPhotochemicallyreactive solvent(except solventsthat are baked,heat cured orheatpolymerized)40 lb/day and8 lb/hr(emissionsfrom air orheat drying forthe first 12hours must beincluded)1.Emissions from cleanup with photo-chemically reactive solvents mustbe included in compliance determination2.Reduce VOC emissions by 85% or more using a capture and controlsystem (an incinerator must have an emission reduction of 90% ormore).Exemptions:(1) transport of storage of organic containing materials; and(2) the volatile content of materials consists of only water and nonphotochemically reactive organic solvents containing less than 20% byvolume of VOC, and does not come intocontact with a flame; and (3) use,application, evaporation, or drying halogenated hydrocarbons orperchloroethylene.ICAPCD Rule 417Table C-1. Summary of California Air District Regulations for Metal Furniture CoatingC-7Operation MaterialVOClimitation Compliance Requirements CitationKern County Air Pollution Control DistrictGeneral coatings,air driedContent limitof 420 g/l (3.5lb/gal) (lesswater andexemptcompounds)General coatings,bakedContent limitof 275 g/l (2.3lb/gal) (lesswater andexemptcompounds)Specialtycoatings, air driedContent limitof 340-420 g/l(2.8-3.5 lb/gal)(less water andexemptcompounds)Specialtycoatings, bakedContent limitof 275-420 g/l(2.3-3.5 lb/gal)(less water andexemptcompounds)MetalCoatingsSurface cleaningand strippingmaterialsContent limitof 200 g/l (1.7lb/gal) (lesswater andexemptcompounds)1.Use compliant coatings.2.Use air pollution control equipmentwith a capture efficiency of atleast 85% and a control deviceefficiency of at least 90%.3.Coatings must be applied using electrostatic, electrodeposition,HVLP, brush, dip, roll, or other method that achieves at least 65%transfer efficiency.KCAPCD Rule 410-4Table C-1. Summary of California Air District Regulations for Metal Furniture CoatingC-8Operation MaterialVOClimitation Compliance Requirements CitationCoatingapplicationequipmentcleaning materialsContent limitof 950 g/l (7.9lb/gal) (lesswater andexemptcompounds)and VOCpartial pressure<35 mmHg at20 ̊CTable C-1. Summary of California Air District Regulations for Metal Furniture CoatingC-9Operation MaterialVOClimitation Compliance Requirements CitationMojave Desert Air Quality Management DistrictGeneral coatings,air driedContent limitof 420 g/l (3.5lb/gal) (lesswater andexemptcompounds)General coatings,bakedContent limitof 360 g/l (3.0lb/gal) (lesswater andexemptcompounds)Specialty coatings(non-military), airdriedContent limitof 420-520 g/l(3.5-4.3 lb/gal)(less water andexemptcompounds)Metal partsand productsSpecialty coatings(non-military),bakedContent limitof 275-420 g/l(2.3-3.5 lb/gal)(less water andexemptcompounds)1.Use compliant coatings.2.Use air pollution control equipment with combined capture and controlefficiency of at least 85%.3.Cleanup solvent must be collected in closed container.4.Coating application equipment must be disassembled and cleaned in anenclosed system.5.Coatings must be applied using electrostatic, HVLP, dip, handapplication, or other equivalent method.MDAQMD Rule 1115Table C-1. Summary of California Air District Regulations for Metal Furniture CoatingC-10Operation MaterialVOClimitation Compliance Requirements CitationSurfacepreparation andcleanup solventContent limitof 200 g/l(1.67 lb/gal)(less water andexemptcompounds);orBoiling point >190 ̊C; orTotal VOCvapor pressure<20 mmHg at20 ̊CTable C-1. Summary of California Air District Regulations for Metal Furniture CoatingC-11Operation MaterialVOClimitation Compliance Requirements CitationMonterey Bay Unified Air Pollution Control DistrictAny that comeinto contact witha flame, or arebaked, heat cured,or heatpolymerized at atemperature of194oF (90oC) inthe presence of O215 lb/dayOrganicsolvents orsolventcontainingmaterialsAny that do notcome into contactwith a flame, orare not baked,heat cured, orheat-polymerized40 lb/day(emissionsfrom air orheat drying forthe first 12hours must beincluded)1.Emissions from cleanup with solvents must be included in compliancedetermination2.Reduce VOC emissions by 85% or more using a capture and controlsystem (an incinerator must have an emission reduction of 90% ormore).Exemptions:(1) transport or storage of solvent materials; (2) any source inexisting prior to March 19, 2001 with actual VOC emissions less than 15lb/day (solvents that are baked, heat-cured, heat-polymerized or exposed toflame) or 40 lb/day (solvents that are not baked, heat-cured, heatpolymerized or exposed to flame)MBUAPCD Rule 416General coatings,air driedContent limitof 420 g/l (3.5lb/gal) (lesswater andexemptcompounds)General coatings,bakedContent limitof 360 g/l (3.0lb/gal) (lesswater andexemptcompounds)Metal partsand productsSpecialtycoatings, airdriedContent limitof 420-780 g/l(3.5-6.5 lb/gal)(less water andexemptcompounds)1.Use compliant coatings.2.Use air pollution control equipment with combined capture and controlefficiency of at least 90%.Exemptions: facilities that use less than 55 gallons of coating per yearMBUAPCD Rule 434Table C-1. Summary of California Air District Regulations for Metal Furniture CoatingC-12Operation MaterialVOClimitation Compliance Requirements CitationSpecialtycoatings, bakedContent limitof 360-780 g/l(3.0-6.5 lb/gal)(less water andexemptcompounds)Table C-1. Summary of California Air District Regulations for Metal Furniture CoatingC-13Operation MaterialVOClimitation Compliance Requirements CitationPlacer County Air Pollution Control DistrictAny that comeinto contact witha flame, or arebaked, heat cured,or heatpolymerized inthe presence of O215 lb/day and3 lb/hrPhotochemicallyreactive solvent(except solventsthat are baked,heat cured orheatpolymerized)40 lb/day and8 lb/hr(emissionsfrom air orheat drying forthe first 12hours must beincluded)Nonphotochemicallyreactive solvent(except solventsthat are baked,heat cured orheatpolymerized)3,000 lb/dayand 450 lb/hr(emissionsfrom air orheat drying forthe first 12hours must beincluded)Organicsolvents orsolventcontainingmaterialsPhenolic resincoating1.75 lbVOC/galcoating asapplied (exceptfor water andexemptcompounds)1.Reduce VOC emissions by 85% or more by incineration (if incineratorhas an emission emission reduction of 90% or more), adsorption, oranother approved method of control.3.Do not dispose or allow the release of organic compounds from storageor transfer operations of more than 1.5 gal of liquid (or equivalentamount of vapor).4.Emissions from cleanup with solvents must be included in compliancedeterminationExemptions:(1) transport of storage of organic containing materials; (2)the volatile content of materials consists of only water and nonphotochemically reactive organic solvents containing less than 20% byvolume of VOC, and does not come intocontact with a flame; and (3) thesolvent content is less than 20% by volume of non-photochemicallyreactive organic solvents, and does not come into contact with a flame.PLAAPCD Rule 219Table C-1. Summary of California Air District Regulations for Metal Furniture CoatingC-14Operation MaterialVOClimitation Compliance Requirements CitationSolvents used onsubstrates duringthe manufacturingprocess or forsurfacepreparation70 g VOC/lmaterialSolvents used formaintenance andrepair900 g VOC/lmaterial and acompositepartial pressureof 20 mm Hgor less at 20oC(68oF)Solvents used forcleaning coatingsor adhesivesapplicationequipment950 g VOC/lmaterial and acompositepartial pressureof 35 mm Hgor less at 20oC(68oF)SolventCleanersSolvents used forcleaning polyesterresin applicationequipment200 g VOC/lmaterial; or1,100 g VOC/land compositepartial pressureof 1.0 mm Hgor less at 20oC(68oF) orsolventreclamationsystem1.Use complaint cleaning materials AND Use one of the followingcleaning devices or methods:a.Wipe cleaning;b.Non propellant spray bottles or containersc.No spray discharge into open air2.Use a collection and control system that collects at least 90 percent ofthe emissions and reduces VOC emissions by at least 95 percent orhas an outlet concentration less than 50 ppmw (as carbon)PLAAPCD Rule 240Table C-1. Summary of California Air District Regulations for Metal Furniture CoatingC-15Operation MaterialVOClimitation Compliance Requirements CitationSacramento Metropolitan AirQuality Management DistrictAir dried coatings Content limitof 340 g/l (2.8lb/gal) (lesswater andexemptcompounds)Baked coatings Content limitof 275 g/l (2.3lb/gal) (lesswater andexemptcompounds)Strippers Content limitof 200 g/l (1.7lb/gal) (lesswater andexemptcompounds)Metal partsand productsSolvent forcleanup ofapplicationequipment andsurfacepreparationContent limitof 72 g/l (0.6lb/gal) (lesswater andexemptcompounds)1.Use compliant coatings.2.Use emission control equipment with anoverall control efficiency of atleast 85%.3.Use closed containers for disposal of cloth, paper, or sponges.4.Do not use VOC-containing material for cleaning coating applicationequipment unless cleanup solvent VOCcontent limit is met or cleaningis performed in an enclosed cleaner.5.Coatings must be applied using roll, dip, electrostatic, flow, HVLP,LVLP, hand application, or other approved method.SMAQMD Rule 451Table C-1. Summary of California Air District Regulations for Metal Furniture CoatingC-16Operation MaterialVOClimitation Compliance Requirements CitationSolventCleaningMaterialsGeneral cleaningactivities, productcleaning duringmanufacturing orsurfacepreparation forcoatings,adhesives,sealants, or inkapplication;Repair andmaintenancecleaning50 g VOC/l(0.42 lb/gal)3.Use complaint cleaning materials AND Use one of the followingcleaning devices or methods:a.Wipe cleaning;b.Cleaning with closed containers or by using hand held spraybottles or containers without a propellant-induced force;c.Using cleaning equipment which has a solvent container that isclosed during cleaning operations, except when depositing andremoving objects, and is closed during non-operation with theexception of maintenance and repair to the cleaning equipmentitself;d.Using a remote reservoir degreaser, non-vapor degreaser, or vapordegreaser used as required under Rule 454.e.Using solvent flushing method where the cleaning solvent isdischarged into a container which is closed except for solventcollection openings and, if necessary, openings to avoid excessivepressure build-up inside the container. The discharged solventfrom the equipment must be collected into containers withoutatomizing into the open air. The solvent may be flushed throughthe system by air or hydraulic pressure, or by pumping.4.Use a collection and control system that collects at least 90 percent ofthe emissions and reduces VOC emissions by at least 95 percent orhas an outlet concentration less than 50 ppmw (as carbon)KCAPCD Rule 466Table C-1. Summary of California Air District Regulations for Metal Furniture CoatingC-17Operation MaterialVOClimitation Compliance Requirements CitationSan Diego County Air Pollution Control DistrictGeneral coatings,air driedContent limitof 340 g/l (lesswater andexemptcompounds)General coatings,bakedContent limitof 275 g/l (lesswater andexemptcompounds)Specialtycoatings, air driedContent limitof 420 g/l (lesswater andexemptcompounds)Metal partsand productsSpecialtycoatings, bakedContent limitof 360-420 g/l(less water andexemptcompounds)1.Use compliant coatings or reduce VOC emissions using a controlsystem with a combined collection and abatement efficiency of 85% byweight or more.2.Cleaning of coating application equipment alternatively can be carriedout in a manner that minimizes emissions or within enclosedequipment.Exemption:Any coating operation that uses less than 20 gallons of coatingper consecutive 12-month period.SDAPCD Rule 67.3Table C-1. Summary of California Air District Regulations for Metal Furniture CoatingC-18Operation MaterialVOClimitation Compliance Requirements CitationSurfacepreparation andcleanup solventContent limitof 200 g/l(1.67 lb/gal)(less water andexemptcompounds);orBoiling point >190 ̊C; orTotal VOCvapor pressure<20 mmHg at20 ̊CTable C-1. Summary of California Air District Regulations for Metal Furniture CoatingC-19Operation MaterialVOClimitation Compliance Requirements CitationSan Joaquin Valley Unified AirPollution Control DistrictGeneral coatings,air driedContent limitof 340 g/l (2.8lb/gal) (lesswater andexemptcompounds)General coatings,bakedContent limitof 275 g/l (2.3lb/gal) (lesswater andexemptcompounds)Specialtycoatings, air driedContent limitof 420 g/l (3.5lb/gal) (lesswater andexemptcompounds)Specialtycoatings, bakedContent limitof 360-420 g/l(3.0-3.5 lb/gal)(less water andexemptcompounds)Metal partsand productsSurfacepreparation,repair, andmaintenancesolventsContent limitof 50 g/l (0.42lb/gal) (lesswater andexemptcompounds)1.Use compliant coatings or reduce VOC emissions using a controlsystem with a combined collection and abatement efficiency of 90% byweight or more.2.Cleaning of coating application equipment alternatively can be carriedout in a manner that minimizes emissions or within enclosedequipment.3.Coatings must be applied using the following application equipment:electrostatic, electrodeposition, HVLP, flow, roll, dip, brush,continuous, or other method that achieves at least 65% transferefficiency.Exemption:Any coating operation that uses less than 20 gallons of coatingper consecutive 365-day period.SJVUAPCD Rule 4603Table C-1. Summary of California Air District Regulations for Metal Furniture CoatingC-20Operation MaterialVOClimitation Compliance Requirements CitationCoatingapplicationequipmentcleaning solventsContent limitof 550 g/l (4.6lb/gal) (lesswater andexemptcompounds)Table C-1. Summary of California Air District Regulations for Metal Furniture CoatingC-21Operation MaterialVOClimitation Compliance Requirements CitationSan Luis Obispo County Air Pollution Control DistrictGeneral coatings,air driedContent limitof 340 g/l (2.8lb/gal) (lesswater andexemptcompounds)General coatings,bakedContent limitof 275 g/l (2.3lb/gal) (lesswater andexemptcompounds)Specialtycoatings, air driedContent limitof 340-800 g/l(2.8-6.7 lb/gal)(less water andexemptcompounds)Metal partsand productsSpecialtycoatings, bakedContent limitof 275-800 g/l(2.3-6.7 lb/gal)(less water andexemptcompounds)1.Must apply coatings using electrostatic, flow, dip, HVLP, orequivalent.2.VOC-containing materials must be stored in closed containers.3.Cannot use VOC-containing materials for spray equipment cleanupunless an enclosed gun washer is used or a gun washer using a solventwith a vapor pressure less than 45 mmHg (0.87 psi) at 20 ̊C (68 ̊F).Exemptions:(1) coatings used in volumes of less than 20 gal/yr;(2) sources using not more than 4 gal/day (monthly average) of solventcontaining materials; (3) sources using a control device demonstrated tohave the same emission reduction as this rule.SLOCAPCD Rule 411Table C-1. Summary of California Air District Regulations for Metal Furniture CoatingC-22Operation MaterialVOClimitation Compliance Requirements CitationSanta Barbara County Air Pollution Control DistrictGeneral coatings,air driedContent limitof 340 g/l (lesswater andexemptcompounds)General coatings,bakedContent limitof 275 g/l (lesswater andexemptcompounds)Industrialmaintenancecoatings, air driedContent limitof 420 g/l (lesswater andexemptcompounds)Metal partsand productsPowder coatings Content limitof 50 g/l (lesswater andexemptcompounds)1.Use add-on control system with atleast 90% capture efficiency and95% control efficiency.2.Apply coatings using the following methods: electrostatic, flow, dip,HVLP, electrodeposition, hand application, touch-up guns, or otherapproved method that achieves atleast 65% transfer efficiency.3.Store reactive VOC-containing materials in closed containers.4.Organics in coating thinners and reducers shall not be photochemicallyactive.Exemptions:(1) coatings used in volumes less than 20 gal/day; total of allsuch coatings not to exceed 55 gal/yr.SBAPCD Rule 322, 330Table C-1. Summary of California Air District Regulations for Metal Furniture CoatingC-23Operation MaterialVOClimitation Compliance Requirements CitationShasta County Air QualityManagement DistrictAny that comeinto contact witha flame, or arebaked, heat cured,or heatpolymerized inthe presence of O2at temperaturesabove 400oF15 lb/dayPhotochemicallyreactive solvent(except solventsthat are baked,heat cured orheatpolymerized)40 lb/dayOrganicsolvents orsolventcontainingmaterialsAnyphotochemicallyreactive substance40 lb/day1.Reduce VOC emissions by 85%2.Include emissions from the cleanupwith photochemically reactivesolvents in compliance determinationExemptions:(1) use, application, evaporation, or drying halogenatedhydrocarbons or perchloroethylene.SHAAQMD Rule 3:4Table C-1. Summary of California Air District Regulations for Metal Furniture CoatingC-24Operation MaterialVOClimitation Compliance Requirements CitationSouth Coast Air Quality Management DistrictGeneral coatings,one component(air-dried andbaked)Content limitof 275 g/l asapplied(excludingwater andexemptcompounds)General coatings,multicomponent,air driedContent limitof 340 g/l asapplied (exceptwater andexemptcompounds)General coatings,multicomponent,bakedContent limitof 275 g/l asapplied(excludingwater andexemptcompounds)Specialtycoatings, air driedand bakedContent limitof 275-420 g/las applied(excludingwater andexemptcompounds)Metal partsand productsCleaningmaterialsContent limitof 25 g/l (0.21lb/gal)1.Use compliant materials ; or use ancollection system that has a captureefficiency of at least 90% by weight and the control device has anemission reduction efficiency of 95% by weight or to an outletconcentration of 5 ppmv VOC.2.Coatings must be applied using hand application methods, HVLPspray, flow, roll, dip. Alternative coating methods must be approved.3.Containers and mixing tanks must be free from leaks and coveredexcept when adding or removingmaterials, cleaning or when thecontainer is empty.4.Solvent cleaning must use one of the following: wipe cleaning; closedcontainers or hand held spray bottles w/out propellant-induced force;cleaning equipment which has a solventcontainer that is closed at alltimes (except when adding or removing parts or during repair); remotereservoir cleaner; non-atomized solvent flow where solvent is collectedin a container or collection system thatis closed at all times except forsolvent collection and pressure relief (as needed) openings; and solventflushing methods where solvent is collected in a container or collectionsystem that is closed at all times except for solvent collection andpressure relief (as needed) openings (discharged solvent must becollected into containers without atomizing into the air and solvent maybe flushed through the system by air or hydraulic pressure or bypumping).5.All VOC-containing solvents must be stored in non-absorbent, nonleaking containers which must be keptclosed at all times, except whenfilling or emptying. Cloth and paper containing with VOC-ladensolvents should be stored in closed, non-absorbent, non-leakingcontainers.6.Use closed containers for disposal of cloth or paper used in strippingcured coatings that are impregnated with solvent containing VOC.7.Stripping materials limited to 200 g/lExemption:Any application process that has VOC emissions less than14.3 lb (6.5 kg) per daySCAQMD Rule 1107and 1171Table C-1. Summary of California Air District Regulations for Metal Furniture CoatingC-25Operation MaterialVOClimitation Compliance Requirements CitationTehama County Air Pollution Control DistrictAny that comeinto contact witha flame, or arebaked, heat cured,or heatpolymerized inthe presence of O2at temperaturesabove 400oF15 lb/dayPhotochemicallyreactive solvent(except solventsthat are baked,heat cured orheatpolymerized)40 lb/dayOrganicsolvents orsolventcontainingmaterialsAnyphotochemicallyreactive substance40 lb/day1.Reduce VOC emissions by 85%2.Include emissions from the cleanupwith photochemically reactivesolvents in compliance determinationExemptions:(1) use, application, evaporation, or drying halogenatedhydrocarbons or perchloroethylene.TCAPCD Rule 4:22Table C-1. Summary of California Air District Regulations for Metal Furniture CoatingC-26Operation MaterialVOClimitation Compliance Requirements CitationVentura County Air Pollution Control DistrictGeneral coatings,air driedContent limitof 340 gROC/l (2.8lb/gal), asapplied(excludingwater andexemptcompounds)General coatings,bakedContent limitof 275 gROC/l (2.3lb/gal), asapplied(excludingwater andexemptcompounds)Metal partsand productsSpecialtycoatings, air driedContent limitof 340-420 gROC/l (2.8-3.5lb/gal), asapplied(excludingwater andexemptcompounds)1.Use compliant materials or reduceemissions by a combined captureand destruction efficiency of 85%.2.Apply coatings using electrostatic, flow, dip, HVLP, hand, or otherapproved method that achieves atleast 65% transfer efficiency.3.Use enclosed gun washer and solvent with a vapor pressure of <45mmHg at 20 ̊C.Exemptions: (1) source that emits <200 lb ROC/rolling 12-month period;(2) Cleaning solvent ROC limit does not apply where total usage ofnoncomplying cleaners does not exceed 5 gal/rolling 12-month period.VCAPCD Rule 74.12Table C-1. Summary of California Air District Regulations for Metal Furniture CoatingC-27Operation MaterialVOClimitation Compliance Requirements CitationSpecialtycoatings, bakedContent limitof 275-420 gROC/l (2.3-3.5lb/gal), asapplied(excludingwater andexemptcompounds)Surfacepreparation andcleanup solvents70 g ROC/lmaterial usedTable C-1. Summary of California Air District Regulations for Metal Furniture CoatingC-28Operation MaterialVOClimitation Compliance Requirements CitationYolo-Solano Air Quality Management DistrictGeneral coatings,air driedContent limitof 340 gROC/l (2.8lb/gal), asapplied(excludingwater andexemptcompounds)General coatings,bakedContent limitof 275 gROC/l (2.3lb/gal), asapplied(excludingwater andexemptcompounds)Metal partsand productsSpecialtycoatings, air driedContent limitof 420 gROC/l (3.5lb/gal), asapplied(excludingwater andexemptcompounds)1.Use capture and control system with overall control efficiency of atleast 85%.2.Do not use VOC-containing materials for cleanup unless collected in aclosed container or guns cleaned in an enclosed washer.3.Use closed container for disposal of cloth, paper, and other materialscontaining solvents.4.Apply coatings using electrostatic, HVLP, flow, dip, hand, or roll.Exemptions:(1) coatings used in volumes less than 55 gal/yrTable C-1. Summary of California Air District Regulations for Metal Furniture CoatingC-29Operation MaterialVOClimitation Compliance Requirements CitationSpecialtycoatings, bakedContent limitof 360-420 gROC/l (3.0-3.5lb/gal), asapplied(excludingwater andexemptcompounds)Surfacepreparationsolvents200 g/lSolvents used onsubstrates duringthe manufacturingprocess or forsurfacepreparation200 g VOC/lmaterialSolvents used formaintenance andrepair900 g VOC/lmaterial and acompositepartial pressureof 20 mm Hgor less at 20oC(68oF)SolventCleanersSolvents used forcleaning coatingsor adhesivesapplicationequipment950 g VOC/lmaterial and acompositepartial pressureof 35 mm Hgor less at 20oC(68oF)2.Use complaint cleaning materials AND Use one of the followingcleaning devices or methods:a.Wipe cleaning;b.Spray bottles or containers with a maximum capacity of 16 fluidounces without a propellant-induced force;c.Cleaning equipment which has a solvent container that can be, andis, closed during cleaning operations, except when depositing andremoving objects, and is closed during non-operation with theexception of maintenance and repair to the cleaning equipmentitself;d.Cleaning device or mechanism which has been determined by theAir Pollution Control Officer to result in equivalent or loweremissions;e.Remote reservoir cold cleaner usedf.Non-atomized solvent flow methodwhere the cleaning solvent iscollected in a container or a collection system which is closedexcept for solvent collection openings and, if necessary, openingsto avoid excessive pressure build-up inside the container; org.Solvent flushing method where the cleaning solvent is dischargedinto a container which is closed except for solvent collectionYSAQMD 2.31,Section 300Table C-1. Summary of California Air District Regulations for Metal Furniture CoatingC-30Operation MaterialVOClimitation Compliance Requirements CitationSolvents used forcleaning polyesterresin applicationequipment200 g VOC/lmaterial; or1,100 g VOC/land compositepartial pressureof 1.0 mm Hgor less at 20oC(68oF) orsolventreclamationsystemopenings and, if necessary, openings to avoid excessive pressurebuild-up inside the container. The discharged solvent from theequipment must be collected into containers without atomizinginto the open air. The solvent may be flushed through the systemby air or hydraulic pressure, or by pumping.3.Use a collection and control system that collects at least 90 percent ofthe emissions and reduces VOC emissionsby at least 95 percent or hasan outlet concentration less than 50 ppmw (as carbon)United StatesEnvironmental ProtectionAgencyOffice of Air Quality Planning and StandardsSector Policies and Programs DivisionResearch Triangle Park, NCPublication No. EPA 453/R-07-005September 2007