Purpose of Amendments

These amendments adopt the requirements of the EPA’s Control Techniques Guidelines (CTG)

for large appliance coating. EPA develops CTGs as guidance on control requirements for source

categories. States can follow the CTGs or adopt more restrictive standards. MDE proposes toadopt a new standard for large appliance coating. Application method and work practice

requirements will also be adopted. These amendments affect coaters of large appliances.Background

EPA published a CTG for large appliance coating, entitled “Control of Volatile OrganicEmissions from Existing Stationary Sources, Volume V: Surface Coating of Large Appliances,”EPA-450/2-77-034 (1977 CTG). In October 1982, EPA promulgated the National Standards of

Perfonriance for New Stationary Sources (NSPS): Standards of Performance for Industrial

Surface Coating: Large Appliances, 40 CFR part 60, subpart SS (1982 NSPS). In 2002, EPA

promulgated the National Emission Standards for Hazardous Air Pollutants: Surface Coating of

Large Appliances, 40 CFR part 63, subpart NNNN (2002 NESHAP). The 1977 CTG

recommends and the 1982 NSPS requires VOC emissions limits based on VOC content of lowVOC coating materials. The 2002 NESHAP establishes organic hazardous air pollutants (HAP)

emissions limits based on the organic HAP content of low organic HAP coating materials.

Large appliance coatings include, but are not limited to, materials referred to as paint, topcoats,

basecoats, primers, enamels, and adhesives used in the manufacture of large appliance parts orproducts. A large appliance part is defined as any organic surface-coated metal lid, door, casing,panel, or other interior or exterior metal part or accessory that is assembled to form a large

appliance product. A large appliance product is also defined as any organic surface-coated metal

range, oven, microwave oven, refrigerator, freezer, washer, dryer, dishwasher, water heater, or

trash compactor manufactured for household, commercial, or recreational use.

Several different types of application technologies are used to apply liquid coatings, and the

selection ofthe application technology can have a significant effect on the amount of coating

used and the resulting VOC emissions from the operation. The CTG requires that coatings canonly be applied by coating applicators such as: air atomized spray coating, electrostatic spray

coating, high volume/low pressure (HVLP) spray coating, dip coating, flow coating, roll coating,electrocoating, and autophoretic coating. Powder coatings can be applied through electrostaticspraying or dipping.

Cleaning activities other than surface preparation also occur at large appliance coating facilities.Cleaning materials are used during these activities to remove coating residue or other unwanted

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The amendments affect sources that coat doors, cases, lids, panels, and interior support parts, or

other interior or exterior part or accessory of residential and commercial washers, dryers, ranges,

refrigerators, freezers, water heaters, dishwashers, trash compactors, air conditioners, ovens,microwave ovens and other similar products.Regulation Amendment

COMAR 26.11.19.06 is amended to set the VOC coating standard of 2.3 pounds per gallon of

coating applied (minus water) / 0.275 kilogramlliter of coating applied (minus water).

Application of coatings on large appliances can be conducted using one of the followingmethods: 1. Electrostatic application; 2. HVLP spray; 3. Flow coat; 4. Roller coat; 5. Dip coat

including electrodeposition; 6. Brush coat; or 7.Other coating application method capable ofachieving a transfer efficiency equivalent or better than that achieved by HVLP spraying.

The requirements of the regulation can be met by complying with the standard for VOC content

of coating or achieving an overall capture and control of VOC emissions from the largeappliance coating installation at the affected premises by 90%.

The work practice standards apply to the usage of all VOC containing materials.

Control Technology and Standards

The CTG recommends three options for control of VOC emissions: (1) Emission limits based on

the use of low-VOC coatings; (2) Equivalent emission limits that can be achieved through theuse of low-VOC coatings or a combination of coatings and add-on controls; and (3) Overall

control efficiency of 90 percent for add-on controls.The low-VOC coatings standards consist of emission limits in terms of mass of VOC per volume

of coating and the use of specified application methods.

For cleaning materials, the CTG establishes work practice standards to reduce VOC

emissions. Due to lack of information available regarding current VOC content, there is nospecific limit for cleaning materials used in large appliance surface coating operations.

Expected Emissions ReductionsEPA’s CTG for large appliance coating operations will result in minimal VOC emission

reductions in Maryland. However, emissions of VOCs from large appliance coating

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Economic Impact

The economic impact of these amendments has been estimated by EPA on a national level. Cost

effectiveness is approximately $500/ton of VOC controlled.

Revision to Maryland’s SIPThis action will be submitted to the U.S. EPA for approval as a revision to Maryland’s StateImplementation Plan.

Other State or Federal Requirements

There are no other state or federal reasonably available control technology standards for this

category. Multiple facilities are covered under this CTG and each may be subject to additional

federal requirements.

Comparison to Federal StandardsThere is a corresponding federal standard to this proposed action, but the proposed action is not

more restrictive or stringent.References

Control Techniques Guidelines: Large Appliance Coatings EPA 453/R-07-004 September 2007

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