UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

1650 Arch Street

Philadelphia, Pennsylvania 19103

DATE: July 23, 2014

SUBJECT: Technical Support Document for Allegheny County’s Adoption of Control 

Techniques Guidelines for Miscellaneous Metal and/or Plastic Parts Surface 

Coating Processes; Automobile and Light-Duty Truck Assembly Coatings; 

Miscellaneous Industrial Adhesives, and Fiberglass Boat Manufacturing Materials

for Control of Volatile Organic Compound Emissions

/s/

FROM: Irene Shandruk, Physical Scientist 

Office of Air Program Planning 

TO: File

/s/

THRU: Marilyn Powers, Acting Associate Director 

Office of Air Program Planning

A. BACKGROUND 

Section 172(c)(1) of the Clean Air Act (CAA) provides that state implementation plans (SIPs) 

for nonattainment areas must include reasonably available control measures (RACM), including 

reasonably available control technology (RACT), for sources of emissions. Section 182(b)(2)(A) 

provides that for certain nonattainment areas, States must revise their SIPs to include RACT for 

sources of volatile organic compound (VOC) emissions covered by a control techniques 

guidelines (CTG) document issued after November 15, 1990 and prior to the area’s date of 

attainment. 

The United States Environmental Protection Agency (EPA) defines RACT as “the lowest 

emission limitation that a particular source is capable of meeting by the application of control 

technology that is reasonably available considering technological and economic feasibility.” (44 

FR 53761, Sept. 17, 1979). In subsequent Federal Register notices, EPA has addressed how 

states can meet the RACT requirements of the CAA. 

CTGs are intended to provide state and local air pollution control authorities information that 

should assist them in determining RACT for VOCs from various sources, including 

miscellaneous metal and plastic parts surface coatings; automobile and light-duty truck assembly 

coatings; miscellaneous industrial adhesives; and fiberglass boat manufacturing materials. In 

developing these CTGs, EPA, among other things, evaluated the sources of VOC emissions from 

this industry and the available control approaches for addressing these emissions, including the 

costs of such approaches. Based on available information and data, EPA provides 
2

recommendations for RACT for VOCs from miscellaneous metal and plastic parts surface 

coatings; automobile and light-duty truck assembly coatings; miscellaneous industrial adhesives; 

and fiberglass boat manufacturing materials.

In 1977 and 1978, EPA published CTGs for miscellaneous metal and plastic parts surface 

coatings, automobile and light-duty truck assembly coatings, miscellaneous industrial adhesives, 

and fiberglass boat manufacturing materials. After reviewing the 1977/1978 CTGs for these 

industries, conducting a review of currently existing state and local VOC emission reduction 

approaches for these industries, and taking into account any information that has become 

available since then, EPA developed new CTGs entitled Control Techniques Guidelines for 

Miscellaneous Metal and Plastic Parts Coatings (Publication No. EPA 453/R-08-003; 

September 2008); Control Techniques Guidelines for Automobile and Light-duty Assembly 

Coatings (Publication No. EPA 453/R-08-006; September 2008); Control Techniques Guidelines 

for Miscellaneous Industrial Adhesives (Publication No. EPA 453/R-08-005; September 2008); 

Control Techniques Guidelines for Fiberglass Boat Manufacturing Materials (Publication No. 

EPA 453/R-08-004; September 2008).

Description of Miscellaneous Metal and Plastic Parts Surface Coatings

The miscellaneous metal product and plastic parts surface coatings categories under section 

183(e) of the CAA includes the coatings that are applied to the surfaces of a varied range of 

metal and plastic parts and products. Such parts or products are constructed either entirely or

partially from metal or plastic. These miscellaneous metal products and plastic parts include, but

are not limited to, metal and plastic components of the following types of products as well as the

products themselves: fabricated metal products, molded plastic parts, small and large farm

machinery, commercial and industrial machinery and equipment, automotive or transportation

equipment, interior or exterior automotive parts, construction equipment, motor vehicle

accessories, bicycles and sporting goods, toys, recreational vehicles, pleasure craft (recreational

boats), extruded aluminum structural components, railroad cars, heavier vehicles, lawn and

garden equipment, business machines, laboratory and medical equipment, electronic equipment,

steel drums, metal pipes, and numerous other industrial and household products. VOC emissions 

from miscellaneous metal product and plastic parts surface coating processes result from the 

evaporation of the components of the coatings and cleaning materials. 

EPA’s Recommended Control Options for Miscellaneous Metal and Plastic Parts Surface 

Coatings

Recommendations for controlling VOC emissions from miscellaneous metal product and plastic 

parts surface coatings are outlined in the CTG, which was issued in 2008. Three alternatives are 

recommended: (1) emission limits that can be achieved through the use of low-VOC coatings; 

(2) equivalent emission limits that can be achieved through the use of low-VOC coatings or a

combination of coatings and add-on controls; and (3) an overall control efficiency of 90 percent 

for add-on controls. 

A. Recommended Option 1 for Reducing Coating Emissions: VOC Content Limits Based on 

Low-VOC Coatings
3

EPA recommended separate sets of emission limits for metal parts coatings, plastic parts

coatings, automotive/transportation and business machine plastic parts, and pleasure craft

coatings. For the metal parts coatings, EPA recommended separate emission limits for baked

and air-dried coatings. Provided in the following five tables are the recommended emission

limits expressed in terms of mass of VOC per volume of coating (excluding water and exempt

compounds, as applied).

Table 1. Metal Parts and Products VOC Content Limits (kilograms per liter or kg/l and pounds 

per gallon or lb/gal)

Coating Category Air Dried Baked

kg VOC/l 

Coating

lb VOC/ gal 

Coating

kg VOC/l 

Coating

lb VOC/ gal 

Coating

General One Component 0.34 2.8 0.28 2.3

General Multi-Component 0.34 2.8 0.28 2.3

Camouflage 0.42 3.5 0.42 3.5

Electric-Insulating Varnish 0.42 3.5 0.42 3.5

Etching Filler 0.42 3.5 0.42 3.5

Extreme High-Gloss 0.42 3.5 0.36 3.0

Extreme Performance 0.42 3.5 0.36 3.0

Heat-Resistant 0.42 3.5 0.36 3.0

High Performance Architectural 0.74 6.2 0.74 6.2

High Temperature 0.42 3.5 0.42 3.5

Metallic 0.42 3.5 0.42 3.5

Military Specification 0.34 2.8 0.28 2.3

Mold-Seal 0.42 3.5 0.42 3.5

Pan Backing 0.42 3.5 0.42 3.5

Prefabricated Architectural 

Multi-Component

0.42 3.5 0.28 2.3

Prefabricated Architectural One 

Component

0.42 3.5 0.28 2.3

Pretreatment 0.42 3.5 0.42 3.5

Repair and Touch-Up 0.42 3.5 0.36 3.0

Silicone Release 0.42 3.5 0.42 3.5

Solar-Absorbent 0.42 3.5 0.36 3.0

Vacuum-Metalizing 0.42 3.5 0.42 3.5

Drum Coating, New, Exterior 0.34 2.8 0.34 2.8

Drum Coating, New, Interior 0.42 3.5 0.42 3.5

Drum Coating, Reconditioned, 

Exterior

0.42 3.5 0.42 3.5

Drum Coating, Reconditioned, 

Interior

0.50 4.2 0.50 4.2
4

Table 2. Plastic Parts and Products VOC Content Limits

Coating Category kg VOC/l Coating lb VOC/ gal Coating

General One Component 0.28 2.3

General Multi-Component 0.42 3.5

Electric Dissipating and Shock-Free 0.80 6.7

Extreme Performance (2-pack coatings) 0.42 3.5

Metallic 0.42 3.5

Military Specification (1-pack coatings) 0.34 2.8

Military Specification (2-pack coatings) 0.42 3.5

Mold-Seal 0.76 6.3

Multi-colored Coatings 0.68 5.7

Optical Coatings 0.80 6.7

Vacuum-Metalizing 0.80 6.7

Table 3. Automotive/Transportation and Business Machine Plastic Parts VOC Content Limits

Coating Category kg VOC/l Coating lb VOC/ gal Coating

Automotive/Transportation Coatings*

I. High Bake – Interior and Exterior Parts

Flexible Primer 0.54 4.5

Non-Flexible Primer 0.42 3.5

Basecoat 0.52 4.3

Clearcoat 0.48 4.0

Non-Basecoat/Clearcoat 0.52 4.3

II. Low Bake/Air Dried – Exterior Parts

Primer 0.58 4.8

Basecoat 0.60 5.0

Clearcoat 0.54 4.5

Non-Basecoat/Clearcoat 0.60 5.0

III. Low Bake/Air Dried – Interior Parts 0.60 5.0

IV. Touch-Up and Repair 0.62 5.2

Business Machine Coating

I. Primers 0.35 2.9

II. Topcoat 0.35 2.9

III. Texture Coat 0.35 2.9

IV. Fog Coat 0.26 2.2

V. Touch-Up and Repair 0.35 2.9

*For red, yellow, and black automotive coatings, except touch-up and repair coatings, the limit is 

determined by multiplying the appropriate limit in this section of the table by 1.15.
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Table 4. Pleasure Craft Surface Coating VOC Content Limits

Coating Category kg VOC/l Coating lb VOC/ gal Coating

Extreme High-Gloss Topcoat 0.49 4.1

High-Gloss Topcoat 0.42 3.5

Pretreatment Wash Primers 0.78 6.5

Finish Primer/Surfacer 0.42 3.5

High-Build Primer Surfacer 0.34 2.8

Aluminum Substrate Antifoulant 0.56 4.7

Other Substrate Antifoulant 0.33 2.8

All Other Pleasure Craft Surface Coatings 

for Metal or Plastic

0.42 3.5

Table 5. Motor Vehicle Materials VOC Content Limits

Coating Category kg VOC/l Coating lb VOC/ gal Coating

Motor Vehicle Cavity Wax 0.65 5.4

Motor Vehicle Sealer 0.65 5.4

Motor Vehicle Deadener 0.65 5.4

Motor Vehicle Gasket/Gasket Sealing 

Materials

0.20 1.7

Motor Vehicle Underbody 0.65 5.4

Motor Vehicle Truck Interior 0.65 5.4

Motor Vehicle Bedliner 0.20 1.7

Motor Vehicle Lubricating 

Wax/Compound

0.70 5.8

B. Recommended Option 2 for Reducing Coating VOC Emissions: Emission Rate Limits

Based on Low-VOC Coatings and Add-on Controls - VOC per Volume Solids

Option 2 is intended for facilities that use a combination of low-VOC coatings and add-on 

control equipment on a coating unit. 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 provided in 

the following three tables.

Table 6. Metal Parts and Products VOC Content Limits

Coating Category Air Dried Baked

kg VOC/l 

Coating

lb VOC/ gal 

Coating

kg VOC/l 

Coating

lb VOC/ gal 

Coating

General One Component 0.54 4.52 0.40 3.35

General Multi-Component 0.54 4.52 0.40 3.35

Camouflage 0.80 6.67 0.80 6.67

Electric-Insulating Varnish 0.80 6.67 0.80 6.67

Etching Filler 0.80 6.67 0.80 6.67

Extreme High-Gloss 0.80 6.67 0.61 5.06
6

Extreme Performance 0.80 6.67 0.61 5.06

Heat-Resistant 0.80 6.67 0.61 5.06

High Performance Architectural 4.56 38.0 4.56 38.0

High Temperature 0.80 6.67 0.80 6.67

Metallic 0.80 6.67 0.80 6.67

Military Specification 0.54 4.52 0.70 3.35

Mold-Seal 0.80 6.67 0.80 6.67

Pan Backing 0.80 6.67 0.80 6.67

Prefabricated Architectural 

Multi-Component

0.80 6.67 0.40 3.35

Prefabricated Architectural One 

Component

0.80 6.67 0.40 3.35

Pretreatment 0.80 6.67 0.80 6.67

Silicone Release 0.80 6.67 0.80 6.67

Solar-Absorbent 0.80 6.67 0.61 5.06

Vacuum-Metalizing 0.80 6.67 0.80 6.67

Drum Coating, New, Exterior 0.54 4.52 0.54 4.52

Drum Coating, New, Interior 0.80 6.67 0.80 6.67

Drum Coating, Reconditioned, 

Exterior

0.80 6.67 0.80 6.67

Drum Coating, Reconditioned, 

Interior

1.17 9.78 1.17 9.78

Table 7. Plastic Parts and Products VOC Content Limits

Coating Category kg VOC/l Coating lb VOC/ gal Coating

General One Component 0.40 3.35

General Multi-Component 0.80 6.67

Electric Dissipating and Shock-Free 8.96 74.7

Extreme Performance (2-pack coatings) 0.80 6.67

Metallic 0.80 6.67

Military Specification (1-pack coatings) 0.54 4.52

Military Specification (2-pack coatings) 0.80 6.67

Mold-Seal 5.24 43.7

Multi-colored Coatings 3.04 25.3

Optical Coatings 8.96 74.7

Vacuum-Metalizing 8.96 74.7

Table 8. Automotive/Transportation and Business Machine Plastic Parts VOC Content Limits

Coating Category kg VOC/l Coating lb VOC/ gal Coating

Automotive/Transportation Coatings*

I. High Bake – Interior and Exterior Parts

Flexible Primer 1.39 11.58

Non-Flexible Primer 0.80 6.67

Basecoat 1.24 10.34

Clearcoat 1.05 8.76
7

Non-Basecoat/Clearcoat 1.24 10.34

II. Low Bake/Air Dried Coatings – Exterior Parts

Primer 1.66 13.80

Basecoat 1.87 15.59

Clearcoat 1.39 11.58

Non-Basecoat/Clearcoat 1.87 15.59

III. Low Bake/Air Dried – Interior Parts 1.87 15.59

IV. Touch-Up and Repair 2.13 17.72

Business Machine Coating

I. Primers 0.57 4.80

II. Topcoat 0.57 4.80

III. Texture Coat 0.57 4.80

IV. Fog Coat 0.38 3.14

V. Touch-Up and Repair 0.57 4.80

*For red, yellow, and black automotive coatings, except touch-up and repair coatings, the limit is 

determined by multiplying the appropriate limit in this section of the table by 1.15.

Table 9. Pleasure Craft Surface Coating VOC Content Limits

Coating Category kg VOC/l Coating lb VOC/ gal Coating

Extreme High-Gloss Topcoat 1.10 9.2

High-Gloss Topcoat 0.80 6.7

Pretreatment Wash Primers 6.67 55.6

Finish Primer/Surfacer 0.80 6.7

High-Build Primer Surfacer 0.55 4.6

Aluminum Substrate Antifoulant 1.53 12.8

Other Substrate Antifoulant 0.53 4.4

All Other Pleasure Craft Surface Coatings 

for Metal or Plastic

0.80 6.7

C. Recommended Option 3 for Reducing Coating VOC Emissions: Add-on Controls In Lieu 

of Low-VOC Coatings and Specified Application Methods

Should product performance requirements or other needs dictate the use of higher-VOC

materials than those that would meet the recommended emission limits, a facility could choose to 

use add-on control equipment with an overall control efficiency of 90 percent in lieu of using

low-VOC coatings and specified application methods. This control option, like the two options

described above, applies to all coatings and thinners applied to miscellaneous metal and plastic

part components or products, except as described above for motor vehicle materials. For both 

recommended options 2 and 3, available add-on devices include, for example, oxidizers, 

adsorbers, absorbers, and concentrators. Add-on devices coupled with capture systems to collect 

the VOC being released at the affected facilities can achieve an overall control efficiency of 90 

percent.

Work Practice Recommendations
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EPA recommended the following work practices for coating-related activities: (1) store all 

VOC-containing coatings, thinners, and coating-related 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 coating-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.

Additionally, EPA recommended that, at a minimum, the work practices for cleaning materials

include the following: (1) store all VOC-containing cleaning materials and used shop towels in 

closed containers; (2) ensure that storage containers used for VOC-containing cleaning materials 

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

spills of VOC-containing cleaning materials; (4) convey VOC-containing cleaning materials 

from one location to another in closed containers or pipes; and (5) minimize VOC emission from 

cleaning of application, storage, mixing, and conveying equipment by ensuring that equipment 

cleaning is performed without atomizing the cleaning solvent and all spent solvent is captured in 

closed containers.

Description of Automobile and Light-Duty Truck Assembly Coatings

The automobile and light-duty truck assembly coatings product category under section

183(e) of the CAA includes the primary coatings that are applied to (1) new automobile or new

light-duty truck bodies, or body parts for new automobiles or new light-duty trucks, and (2) other

parts that are coated along with these bodies or body parts. The category also includes additional

coatings applied during the vehicle assembly process. Automobile and light-duty truck assembly 

coatings most commonly are applied at automobile or light-duty truck assembly plants. 

However, this 183(e) category also includes coatings used in facilities that perform these coating

operations on a contractual basis. In addition to the coating applications described above, 

automobile and light-duty truck assembly coating facilities may have separate coating lines on 

which coatings are applied to other parts intended for use in new automobiles or new light-duty 

trucks (e.g., application of spray primer, color and clear coat to fascia or bumpers) or to 

aftermarket repair or replacement parts for automobiles or light-duty trucks. The separate 

coating of these other parts and aftermarket or replacement parts is included in the Miscellaneous 

Metal Products and Plastic Parts Coatings categories under section 183(e) and covered in the 

CTG for those categories.

The VOC emissions from automobile and light-duty truck assembly coating operations are

primarily a result of evaporation of the VOC contained in the coatings and cleaning materials 

used in these operations. The primary VOC emissions from automobile .and light-duty truck 

assembly coatings occur during coating application/flash-off and drying/curing of the coatings. 

The remaining emissions occur mainly from mixing and/or thinning.

EPA’s Recommended Control Options for Automobile and Light-Duty Truck Assembly 

Coatings

EPA’s 2008 CTG recommends the following VOC reduction measures: VOC emission limits for
9

coating operations; work practices for storage and handling of coatings, thinners, and coating

waste materials; and work practices for the handling and use of cleaning materials. 

Recommended VOC emission limits are the same as those adopted by Allegheny County and are 

shown in Tables 10-11.

Description of Miscellaneous Industrial Adhesives

The miscellaneous industrial adhesives product category includes adhesives (including adhesive 

primers used in conjunction with certain types of adhesives) used at industrial manufacturing and 

repair facilities for a wide variety of products and equipment that operate adhesives application 

processes. The miscellaneous industrial adhesives product category does not include adhesives 

that are addressed by CTGs already issued for categories listed under CAA section 183(e) or by

earlier CTGs. These include the CTGs issued under section 183(e) for aerospace coatings; metal

furniture coatings; large appliance coatings; flat wood paneling coatings; paper, film, and foil

coatings; offset lithographic printing and letterpress printing; and flexible package printing. Coil

coating, fabric coating, and rubber tire manufacturing were not listed under CAA section 183(e),

however, they were the subject of earlier CTGs which address adhesives used in those processes. 

Motor vehicle adhesives, glass bonding primers, and weatherstrip adhesives that are used at a 

facility that is not an automobile or light-duty truck assembly coatings facility, are addressed in 

the 2008 CTG for miscellaneous industrial adhesives.

The VOC emissions from miscellaneous industrial adhesives result from evaporation of the 

solvents contained in many of the primers, adhesives and cleaning materials during adhesive

application and drying processes, as well as during surface preparation and cleaning processes

associated with adhesives application. The primary VOC emissions from miscellaneous

industrial adhesives occur during application and flash-off.

EPA’s Recommended Control Options for Industrial Adhesives

EPA’s 2008 CTG recommends the following VOC reduction measures: VOC emission limits for

industrial adhesives; work practices for storage and handling of industrial adhesives; and work 

practices for the handling and use of cleaning materials. Recommended VOC emission limits 

are the same as those adopted by Allegheny County and are shown in Table 12.

Description of Fiberglass Boat Manufacturing Materials

The CTG for fiberglass boat manufacturing materials provides control recommendations for 

reducing VOC emissions from the use of gel coats, resins, and materials used to clean

application equipment in fiberglass boat manufacturing operations. This CTG applies to 

facilities that manufacture hulls or decks of boats from fiberglass, or build molds to make 

fiberglass boat hulls or decks (hereinafter referred to as “fiberglass boat manufacturing 

facilities”). Recommendations in this CTG do not extend to facilities that manufacture solely 

parts of boats (such as hatches, seats, or lockers), or boat trailers, but do not manufacture hulls or 

decks of boats from fiberglass, or build molds to make fiberglass boat hulls or decks. If a facility 

manufactures hulls or decks, or molds for hulls or decks, then the manufacture of all other 

fiberglass boat parts, including small parts such as hatches, seats, and lockers is also covered. 
10

EPA recommends that the control approaches discussed in section VI of this CTG apply to each 

fiberglass boat manufacturing facility where the total actual VOC emissions from all fiberglass 

boat manufacturing operations covered by the recommendations in section VI of this CTG are 

equal to or exceed 6.8 kg/day (15 lb/day). An alternative equivalent threshold would be 2.7 tons 

per 12-month rolling period. Cleaning materials should be included in determining whether total 

actual VOC emissions exceed this level. If a facility has add-on controls, then emissions before 

the add-on controls should be used in determining if a facility meets this threshold.

EPA’s Recommended Control Options for Fiberglass Boat Manufacturing Materials

EPA’s 2008 CTG recommends that the following operations are covered:

• Open molding resin and gel coat operations (these include pigmented gel coat,

clear gel coat, production resin, tooling gel coat, and tooling resin);

• Resin and gel coat mixing operations; and

• Resin and gel coat application equipment cleaning operations.

EPA’s 2008 CTG recommends the following VOC reduction measures: VOC emission limits for

industrial adhesives; work practices for storage and handling of industrial adhesives; and work 

practices for the handling and use of cleaning materials. Recommended VOC emission limits 

are the same as those shown in Table 2105.86.

B. STATE SUBMITTAL

On November 15, 2013, Pennsylvania Department of Environmental Protection (PADEP) 

submitted to EPA on behalf of the Allegheny County Health Department (ACHD) a SIP revision 

concerning the adoption of the EPA CTGs for miscellaneous metal and/or plastic parts surface 

coating processes, automobile and light-duty truck assembly coatings, miscellaneous industrial 

adhesives, and fiberglass boat manufacturing materials in Allegheny County. EPA develops 

CTGs as guidance on control requirements for source categories. States can follow the CTGs or 

adopt more restrictive standards. Allegheny County is adopting EPA’s CTG standards for 

miscellaneous metal and/or plastic parts surface coating processes, automobile and light-duty 

truck assembly coatings, miscellaneous industrial adhesives, and fiberglass boat manufacturing 

materials. These regulations are contained in the ACHD Rules and Regulations, Article XXI, 

Air Pollution Control sections 2105.83, 2105.84, 2105.85, and 2105.86. This SIP revision also 

includes revisions to existing regulations for surface coating processes in section 2105.10 and 

related definitions in section 2101.20. The revisions are summarized below.

Upon review of the November 15, 2013 submittal, EPA found that in section 2105.86 – Control 

of VOC Emissions from Fiberglass Boat Manufacturing Materials – under “Limitations”, Table 

2105.86 (average monomer VOC content limit) was referenced, however, the table was not 

included in the submittal. ACHD indicated that the table had not been included as part of the 

regulation that went out to public hearing. Given that the table of VOC emission limits is a 

significant part of the regulation, and that this omission is inconsistent with EPA’s procedures 

for SIP revisions set forth at 40 CFR section 51.102(d)(2), which requires the availability of the 

entire plan for public inspection, ACHD was notified that they would need to amend their 
11

regulation, following all appropriate state and Federal notice and comment procedures, and 

submit to EPA the missing table. While ACHD works to amend the regulation, EPA offered to 

take action on the November 15, 2013 SIP submittal by conditionally approving the SIP 

submittal under CAA section 110(k)(4). 

On July 17, 2014, EPA received a letter dated July 16, 2014 from PADEP committing to revising 

Article XXI, Section 2105.86, which is before EPA for action, by amending the regulation and 

submitting the missing content (i.e. Table 2105.86, which is shown below) within one year from 

the Federal Register publication of final notice of conditional approval of ACHD’s November 

15, 2013 CTG SIP submittal (ACHD SIP number 74). In the letter, ACHD indicated that it is 

confident that this commitment can be met for the following reasons.

(1) The amount of technical work necessary for the measures to be adopted is minimal. The 

content of the table already exists in the CTG and must merely be placed into Article 

XXI, Section 2105.86.

(2) Adoption of the measure is not expected to be controversial because there are no related 

regulated sources in Allegheny County.

(3) The regulation revision can be adopted in at the County level, and reviewed by PADEP 

and forwarded to EPA in less than one year.

Table 2105.86: Monomer VOC Content Limitations for Open Molding Resin and Gel Coat 

Operations

Materials Application Method Weight Average Monomer VOC 

Content Limit (weight percent)

Production Resin Atomized (spray) 28

Production Resin Nonatomized 35

Pigmented Gel Coat Any Method 33

Clear Gel Coat Any Method 48

Tooling Resin Atomized 30

Tooling Resin Nonatomized 39

Tooling Gel Coat Any Method 40

ACHD understands that this commitment will result in a conditional approval by EPA of the 

previously submitted CTG SIP revision number 74 for Allegheny County. Upon EPA’s approval 

of the SIP revision satisfying the rulemaking commitments, EPA’s conditional approval to the 

Allegheny portion of the Pennsylvania SIP will become a full approval.

I. Miscellaneous Metal and/or Plastic Parts Surface Coating Processes

Beginning January 1, 2014, this section applies to the owner or operator of a miscellaneous metal 

parts and/or plastic parts surface coating process, where the total actual VOC emissions from all 

miscellaneous metal parts and/or plastic parts surface coating processes, including related 

cleaning activities, at that facility are equal to or greater than 15 pounds (6.8 kilograms) per day 

or 2.7 (2,455 kilograms) per twelve month rolling period, before controls. 
12

The provisions of this rule do not apply to (1) shipbuilding and repair coatings; (2) Aerospace 

coatings; (3) wood furniture coatings; (4) metal furniture coatings; (5) large appliance coatings; 

(6) auto and light-duty truck assembly coatings; (7) flat wood paneling coatings; (8) 

miscellaneous industrial adhesives; (9) fiberglass boat manufacturing materials; (10) paper, film, 

and foil coatings; or (11) can, coil, or magnet wire coatings which are not listed under section 

183(e) of the Clean Air Act, but were addressed by regulation section 2105.10.

This section establishes emission limits, recordkeeping and housekeeping requirements, as well 

as exemptions. Emission limits of VOCs from miscellaneous metal and/or plastic surface 

coating processes are as follows:

1. The VOC content of each applied coating is equal to or less than the standard 

specified in Tables 1-5.

2. The VOC content limitations based on low-VOC coatings as specified in Tables 6-9, 

the use of add-on pollution control equipment to meet the VOC content limitations, 

and the use of an application method specified in subsection e of this rule.

3. The overall weight of VOCs emitted to the atmosphere is reduced through the use of

an oxidizer, adsorber, absorber, concentrator, or another add-on control which is 

acceptable under section 2105.01. The overall control system, as determined by the 

test methods and procedures specified in Part G, shall be no less than 90%.

II. Automobile and Light-Duty Truck Assembly Coatings

Beginning January 1, 2014, this section applies to the owner or operator of an automobile and/or 

light-duty truck assembly coating operation, where the total actual VOC emissions from all 

automobile and/or light-duty truck assembly coating operations, including related cleaning 

activities, at the facility are equal to or greater than 15 pounds (6.8 kilograms) per day or 2.7 tons 

(2,455 kilograms) per twelve month rolling period, before controls.

This section establishes emission limits, recordkeeping and housekeeping requirements, as well 

as exemptions. Emission limits of VOCs from automobile and light-duty truck assembly 

coatings are as follows:

1. The VOC content of each assembly coating process and applied material coating is 

equal to or less than the standard specified in Tables 10-11.

2. The overall weight of VOCs emitted to the atmosphere is reduced through the use of 

an oxidizer, adsorber, or another add-on control which is acceptable under section 

2105.01 (Equivalent Compliance Techniques). The overall control system, as determined 

by the test methods and procedures shall be no less than 85%.
13

Table 10. VOC Emission Limits for Automobile and/or Light-duty Truck Assembly Coatings

Assembly Coating Process VOC Emission Limit

lb/gal g/l

Electrodeposition primer operation when solids turnover 

ratio (RT) ≥ 0.16 (including application area, spray/rinse 

stations, and curing oven)

0.7 84

Electrodeposition primer operation when 0.040 ≤ (RT) < 

0.16 (including application area, spray/rinse stations, and 

curing oven)

0.7*3500.160-R

T 84*3500.160-RT

Electrodeposition primer operation when (RT) < 0.040 

(including application area, spray/rinse stations, and curing 

oven)

No VOC emission limit

Primer-surfacer operations (including application area, 

flash-off area, and oven)

12.0 1,440

Topcoat operation (including application area, flash-off 

area, and oven)

12.0 1,440

Final repair operation 4.8 580

Combined primer-surfacer and topcoat operations 12.0 1,440

Table 11. VOC Emission Limits for Miscellaneous Materials Used at Automobile and/or Lightduty Truck Assembly Coating Facilities

Material VOC Emission Limits

lb/gal g/l

Automobile and light-duty truck glass bonding primer 7.5 900

Automobile and light-duty truck adhesive 2.1 250

Automobile and light-duty truck cavity wax 5.4 650

Automobile and light-duty truck sealer 5.4 650

Automobile and light-duty truck deadener 5.4 650

Automobile and light-duty truck gasket/gasket sealing material 1.7 200

Automobile and light-duty truck underbody coating 5.4 650

Automobile and light-duty truck trunk interior coating 5.4 650

Automobile and light-duty truck bedliner 1.7 200

Automobile and light-duty truck weatherstrip adhesive 6.3 750

Automobile and light-duty truck lubricating wax/compound 5.8 700

III. Miscellaneous Industrial Adhesives

Beginning January 1, 2014, this section applies to the owner or operator of a miscellaneous 

industrial adhesive application process, where the total actual VOC emissions from all 

miscellaneous industrial adhesives, including related cleaning activities, at that facility are equal 

to or greater than 15 pounds (6.8 kilograms) per day or 2.7 tons (2,455 kilograms) per twelve 

month rolling period, before controls. 

This section establishes emission limits, recordkeeping and housekeeping requirements, as well 

as exemptions. Emission limits of VOCs from miscellaneous industrial adhesives are as follows:
14

1. The VOC content of each as applied ahesive is equal to or less than the standard 

specified in Table 12. 

2. The overall weight of VOCs emitted to the atmosphere is reduced through the use of 

an oxidizer, adsorber, absorber, or another add-on control which is acceptable under 

section 2105. 01 (Equivalent Compliance Techniques). The overall control system, as 

determined by the test methods and procedures specified in Part G, shall be no less than 

85%.

3. A combination of the methods listed in paragraphs 1 and 2. 

Table 12. Emission Limits of VOCs for Miscellaneous Industrial Adhesives

Limits as Applied VOC Content Minus 

Exempt Compounds

General Adhesive Application Process lb/gal g/l

Reinforced Plastic Composite 1.7 200

Flexible Vinyl 2.1 250

Metal 0.3 30

Porous Material (Except Wood) 1.0 120

Rubber 2.1 250

Wood 0.3 30

Other Substrates 2.1 250

Specialty Adhesive Application Processes

Ceramic Tile Installation 1.1 130

Contact Adhesive 2.1 250

Cove Base Installation 1.3 150

Floor Covering Installation (Indoor) 1.3 150

Floor Covering Installation (Outdoor) 2.1 250

Floor Covering Installation (Perimeter Bonded Sheet Vinyl) 5.5 660

Metal to Urethan/Rubber Molding or Casting 7.1 850

Motor Vehicle Adhesive 2.1 250

Motor Vehicle Weather-strip Adhesive 6.3 750

Multipurpose Construction 1.7 200

Plastic Solvent Welding (ABS) 3.3 400

Plastic Solvent Welding (Except ABS) 4.2 500

Sheet Rubber Lining Installation 7.1 850

Single-Ply Roof Membrane Installation/Repair (Except EPDM) 2.1 250

Structural Glazing 0.8 100

Thin Metal Laminating 6.5 780

Tire Repair 0.8 100

Waterproof Resorcinol Glue 1.4 170

Adhesive Primer Application Processes

Motor Vehicle Glass Bonding Primer 7.5 900

Plastic Solvent Welding Adhesive Primer 5.4 650
15

Single-Ply Roof Membrane Adhesive Primer 2.1 250

Other Adhesive Primer 2.1 250

IV. Fiberglass Boat Manufacturing Materials

Beginning January 1, 2014, this section applies to the owner or operator of a fiberglass boat 

manufacturing facility, where the total actual VOC emissions from fiberglass boat manufacturing 

materials including related cleaning activities, at that facility are equal to or greater than 15 

pounds (6.8 kilograms) per day or 2.7 tons (2,455 kilograms) per twelve month rolling period, 

before controls. This regulation applies to facilities that manufacture hulls or decks of boats 

from fiberglass, or build molds to make fiberglass boat hulls or decks. This regulation does not 

apply to facilities that manufacture solely fiberglass parts of boats such as hatches, seats, lockers, 

or boat trailers.

This regulation does not extend to surface coatings applied to fiberglass boats, and industrials 

adhesives used in the assembly of fiberglass boats. Surface coating for fiberglass and metal 

recreational boats, also called pleasure crafts, are addressed in regulation 2105.83, Control of 

VOC Emissions from Miscellaneous Metal and/or Plastic Parts Surface Coating Processes. 

Industrial adhesives used in fiberglass boat assembly are addressed in regulation 2105.85, 

Control of VOC Emissions from Miscellaneous Industrial Adhesives. 

This section establishes emission limits, recordkeeping and housekeeping requirements, work 

practice standards, as well as exemptions. Emission limits of VOCs from miscellaneous metal 

and/or plastic surface coating processes are as follows: Fiberglass boat manufacturing facilities 

shall use resins and/or gel coats that are equal to or less than the applicable weighted average 

monomer VOC content limit specified in Table 2105.861and the non-monomer VOC limit shall 

not exceed 5 percent, by weight, of resin and/or gel coat.

V. Additional Revisions

In addition to adopting the CTGs discussed above, definitions arising from these CTG 

regulations were added to Article XXI (section 2101.20) and are being added to the Allegheny 

County portion of the Pennsylvania SIP. They are as follows:

Section 2101.20: Definitions:

“General Multi-Component Coating” means a coating requiring the addition of a separate 

reactive resin, commonly known as a catalyst or hardener, before application to form an 

acceptable dry film.

“General One Component Coating” means a coating that is ready for application as it comes out 

 

1 This table was erroneously omitted from the regulation, but ACHD has committed to amend Article XXI and 

submit this missing portion to EPA within 12 months of the Federal Register publication of final notice of 

conditional approval of ACHD’s November 15, 2013 CTG SIP submittal.
16

of its container to form an acceptable dry film. A thinner, necessary to reduce the viscosity, is 

not considered a component.

“Solids turnover ratio (RT)” means the ratio of the total volume of coating solids that is added to 

the electrodeposited primer system in a calendar month divided by the total volume design 

capacity of the electrodeposited primer system.

Changes were also made to an existing regulation, Section 2105.10, Surface Coating Processes. 

The specific language added is as follows:

1. The limits from section 2105.10 and Table section 2105.10, number 10 for miscellaneous 

metal parts and products, no longer apply to miscellaneous metal and/or plastic parts 

surface coating processes as of January 1, 2014. 

2. The limits from section 2105.10 and Table section 2105.10, number 6 for automobile and 

light-duty truck coating, no longer apply to automobile and light-duty truck assembly 

coatings of January 1, 2014.

C. EPA EVALUATION AND RECOMMENDED AGENCY ACTION

Allegheny County has adopted the standards and requirements of the CTGs for miscellaneous 

metal and/or plastic parts surface coating processes, automobile and light-duty truck assembly 

coatings, miscellaneous industrial adhesives, and fiberglass boat manufacturing materials, and is 

amending the Pennsylvania SIP to reflect these amendments. The maximum benefit from these 

amendments will be provided during the ozone season when VOCs readily combine with NOx to 

form ground-level ozone. Therefore, this revision will help Pennsylvania attain and maintain the 

NAAQS for ozone. Given that ACHD has erroneously omitted the table of average monomer 

VOC content limits (Table 2105.86) from section 2105.86 – Control of VOC Emissions from 

Fiberglass Boat Manufacturing Materials – EPA recommends conditional approval of the SIP 

revision under CAA section 110(k)(4) until ACHD amends the regulation and submits to EPA 

the missing content. Upon EPA’s approval of the SIP revision satisfying the rulemaking 

commitments, EPA’s conditional approval to the Allegheny portion of the Pennsylvania SIP will 

become a full approval.