1

Revision to ALLEGHENY COUNTY’S portion of the

PENNSYLVANIA STATE IMPLEMENTATION PLAN

For the

Attainment and Maintenance of the National 

Ambient Air Quality Standards

Revision Tracking No. 74

Allegheny County Health Department

Rules and Regulations

Article XXI, Air Pollution Control 

Changes to Article XXI Sections in the SIP:

§2101.20 Definitions, 

§2105.10 Surface Coating Processes, 

§2105.83 Control of VOC Emissions from Miscellaneous Metal and/or Plastic 

Parts Surface Coating Processes, 

§2105.84 Control of VOC Emissions from Automobile and Light-Duty Truck 

Assembly Coatings,

§2105.85 Control of VOC Emissions from Miscellaneous Industrial Adhesives, and

§2105.86 Control of VOC Emissions from Fiberglass Boat Manufacturing 

Materials
2

Table of Contents

1. Changes to Article XXI Rules and Regulations: 

§2101.20, Definitions (SIP Change); 

§2105.10, Surface Coating Processes (SIP Change);

§2105.83, Control of VOC Emissions from Miscellaneous Metal and/or 

Plastic Parts Surface Coating Processes (SIP Change);

§2105.84, Control of VOC Emissions from Automobile and Light-Duty Truck 

Assembly Coatings (SIP Change);

§2105.85, Control of VOC Emissions from Miscellaneous Industrial 

Adhesives (SIP Change)

§2105.86, Control of VOC Emissions from Fiberglass Boat Manufacturing 

Materials (SIP Change)

2. Technical Support Document

3. Documentation of Public Hearing and Certifications

Public hearing notice

Transmittals of hearing notice to EPA & PA DEP

Proof of publication of notice of hearing

Certification of hearing

Summary of Comments and responses

Certifications of approval and adoption
3

1. Article XXI Changes

§ 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. {effective January 1, 2014}

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

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

is not considered a component. {effective January 1, 2014}

“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. {effective January 1, 2014}

ALL NEW TEXT
4

§ 2105.10 SURFACE COATING PROCESSES

a. Applicability. This section applies to a surface coating process category, regardless of 

the size of the facility, which emits or has emitted VOCs into the outdoor atmosphere in 

quantities greater than 3 pounds (1.4 kilograms) per hour, 15 pounds (7 kilograms) per 

day or 2.7 tons (2,455 kilograms) per year during any calendar year since January 1, 

1987. 

1. The limits from § 2105.10 and Table § 2105.10, number 7 for Metal furniture 

coating and number 9 for Large appliance coating, no longer apply to the large 

appliance and metal furniture surface coating process as of January 1, 2011.

2. The limits from § 2105.10 and Table § 2105.10, number 5 for Paper coating, no 

longer apply to the paper, film, and foil surface coating process as of January 1, 

2011.

3. The limits from § 2105.10 and Table § 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.

4. The limits from § 2105.10 and Table § 2105.10, number 6 for Automobile 

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

truck assembly coatings as of January 1, 2014. 

. . .

Additions are shown bolded and underlined.
5

§ 2105.83 CONTROL OF VOC EMISSIONS FROM MISCELLANEOUS METAL 

AND/OR PLASTIC PARTS SURFACE COATING PROCESSES 

a. Applicability. Beginning January 1, 2014, this section applies to the owner or operator 

of a miscellaneous metal parts and/or plastic parts surface coating processes, 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 tons (2,455 kilograms) per twelve 

month rolling period, before controls.

The provisions of this rule shall not apply to the following source categories listed for 

regulation under Section 183(e) of the Clean Air Act:

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

Can coatings, coil coatings or magnet wire coatings which are not listed under Section 

183(e) of the Act, but were addressed by regulation § 2105.10.

b. Limitations. A person may not cause or permit the emission into the outdoor 

atmosphere of VOCs from a miscellaneous metal parts and/or plastic parts surface 

coating processes, unless one of the following limitations is met:

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

specified in Table 2105.83.1.

A. The VOC content, minus exempt compounds, of the applied coating, 

expressed in units of weight of VOC per volume of total nonexempt 

material, shall be calculated as follows:

ALL NEW TEXT
6

 Ws - Ww - Wex

VOC = -----------------------

 Vm - Vw - Vex

Where:

 VOC = VOC content, minus exempt compounds, in lb (g) VOC / 

 gal (l) of materials, minus exempt compounds

 Ws = Weight of all volatile material in pounds (g), including VOC, 

 water, non-precursor organic compounds and dissolved vapors 

 Ww = Weight of water in pounds (g)

 Wex = Weight of exempt solvent(s) in pounds (g)

 Vm = Volume of total material, as applied in gallons (l)

 Vw = Volume of water in gallons (l)

 Vex = Volume of exempt solvent(s) in gallons (l)

B. The VOC content limits of subparagraph A may be met by averaging the 

VOC content of materials used on a single application unit for each day 

(i.e., daily within-application unit averaging).

C. Sampling and testing shall be done in accordance with the procedures and 

test methods specified in Part G (Methods).

2. The VOC content limitations based on low-VOC coatings as specified in Table 

2105.83.2 of this rule, 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.

A. The VOC content, minus exempt compounds, of the applied coating, 

expressed in units of weight of VOC per volume of total material, shall be 

calculated as follows:

 Ws - Ww - Wex

VOC = -----------------------

 Vm

Where:

 VOC = VOC content, minus exempt compounds, in lb (g) VOC / 

 gal (l) of materials 

 Ws = Weight of all volatile material in pounds (g), including VOC, 

 water, non-precursor organic compounds and dissolved vapors 

 Ww = Weight of water in pounds (g)

 Wex = Weight of exempt solvent(s) in pounds (g)

 Vm = Volume of total material, as applied in gallons (l)

 
7

B. The VOC content limits of subparagraph A may be met by averaging the 

VOC content of materials used on a single application unit for each day 

(i.e., daily within-application unit averaging).

C. Sampling and testing shall be done in accordance with the procedures and 

test methods specified in Part G (Methods).

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

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

is acceptable under § 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 90%.

c. Records. A facility, regardless of the facility’s annual emission rate, which contains 

miscellaneous metal parts and/or plastic parts surface coating processes, shall maintain 

records sufficient to demonstrate compliance with this section. At a minimum, a facility 

shall maintain daily records of: 

1. The following parameters for each coating and other component as supplied:

A. The coating, thinner or component name and identification number;

B. The volume used;

C. The mix ratio;

D. The density or specific gravity;

E. The weight percent of total volatiles, water, and exempt solvents; 

F. The volume percent of total materials, water, and exempt solvents for 

either Table 2105.83.1 or Table 2105.83.2 for miscellaneous metal parts 

and/or plastic parts surface coating processes.

The records shall be maintained for 2 years and shall be submitted to the Department on a 

schedule reasonably prescribed by the Department. 

d. Exempt Solvents. The solvents methyl chloroform (1,1,1-trichloroethane) and 

methylene chloride are exempt from control under this Section. No miscellaneous metal 

parts and/or plastic parts surface coating processes which seeks to comply with this 

Section through the use of an exempt solvent may be included in any alternative standard 

approved pursuant to this Article.

e. Application Techniques. A person may not cause or permit the emission into the 

outdoor atmosphere of VOCs from the application of miscellaneous metal parts and/or 

plastic parts surface coatings unless the coatings are applied using one or more of the 

following application methods:

1. Airless spraying;

2. Air-assisted airless spraying;

3. Electrostatic spraying;
8

4. High volume-low pressure (HVLP) spraying;

5. Dip coating, including electrodeposition;

6. Flow coating;

7. Roll coating;

8. Autophoretic coating;

9. Zinc-arc spraying;

10. Other coating application method that the person demonstrates and the 

Department determines achieves emission reductions equivalent to HVLP 

spraying.

f. Exempt Other.

1. The following shall be exempt from this regulation:

A. Aerosol coatings;

B. Architectural coatings;

C. Automobile refinish coatings;

D. The coating of bodies and/or body parts for new heavier vehicles where 

the owner or operator elects to comply with the requirements of regulation 

§ 2105.84 CONTROL OF VOC EMISSIONS FROM AUTOMOBILE 

AND LIGHT-DUTY TRUCK ASSEMBLY COATINGS.

2. The following metal parts coatings and coating operations shall be exempt from 

the limitations set by Subsection b, and Subsection e, Application Techniques but 

shall still comply with Subsection h, Housekeeping:

A. Stencil coatings;

B. Safety-indicating coatings;

C. Solid-film lubricants;

D. Electric-insulating and thermal-conducting coatings;

E. Magnetic data storage disk coatings;

F. Plastic extruded onto metal parts to form a coating.

3. The following plastic parts coatings and coating operations shall be exempt from 

the limitations set by Subsection b, but shall still comply with Subsection e, 

Application Techniques and Subsection h, Housekeeping:

A. Touch-up and repair coatings;

B. Stencil coatings applied on clear or transparent substrates;

C. Clear or translucent coatings;

D. Coatings applied at a paint manufacturing facility while conducting 

performance tests on the coating;

E. Any individual coating category used in volumes less than 50 gallons in 

any one year, if substitute compliant coatings are not available, provided 

that the total usage of all such coatings does not exceed 200 gallons per 

year, per facility;
9

F. Reflective coating applied to highway cones;

G. Mask coatings that are less than 0.5 millimeter thick (dried) and the area 

coated is less than 25 square inches;

H. Electromagnetic interference/radio frequency interference (EMI/RFI) 

shielding coatings;

I. Heparin-benzalkonium chloride (HBAC)-containing coatings applied to 

medical devices, provided that the total usage of all such coatings does not 

exceed 100 gallons per year, per facility.

4. The following automotive/transportation and business machine plastic part 

coatings and coating operations shall be exempt from the limitations set by 

Subsection b, but shall still comply with Subsection e, Application Techniques 

and Subsection h, Housekeeping:

A. Texture coatings;

B. Vacuum metalizing coatings;

C. Gloss reducers;

D. Texture topcoats;

E. Adhesive primers;

F. Electrostatic preparation coatings;

G. Resist coatings;

H. Stencil coatings.

5. The application techniques in Subsection e of this rule do not apply to the 

following: 

A. For metal parts coatings; touch-up coatings, repair coatings, and textured 

finishes.

B. For plastic parts coatings; airbrush operations using five gallons or less of 

coating per year.

C. For pleasure craft surface coating operations; extreme high gloss coatings.

g. Emission Limitations. For those who elect to adopt the limitation from Subparagraph 

b.1, if more than one emission limitation in Table 2105.83.1 for miscellaneous metal 

parts and/or plastic parts applies to a specific coating, the least stringent emission 

limitation applies. For those who elect to adopt the limitation from Subparagraph b.2, if 

more than one emission limitation in Table 2105.83.2 for miscellaneous metal parts 

and/or plastic parts applies to a specific coating, the least stringent emission limitation 

applies. 

h. Housekeeping. The following work practices for cleaning materials apply to the owner 

or operator of a miscellaneous metal parts and/or plastic parts surface coating processes:

1. Store all VOC-containing coatings, thinners, coating–related waste materials, 

cleaning materials and used shop towels in closed containers.
10

2. Ensure that mixing and storage containers used for VOC-containing coatings, 

thinners, coating-related waste materials and cleaning materials are kept closed at 

all times except when depositing or removing these materials.

3. Minimize spills of VOC-containing coatings, thinners, coating–related waste 

materials and cleaning materials, cleaning up spills immediately.

4. Convey VOC-containing coatings, thinners, coating–related waste materials and 

cleaning materials from one location to another in closed containers or pipes.

i. Measurements. Measurements of the volatile fraction of coatings, other than reactive 

coatings, used at facilities operating miscellaneous metal parts and/or plastic parts surface 

coating processes shall be performed according to the applicable procedures established 

in § 2107.04 of this Article.
11

Table 2105.83.1

Emission Limits of VOCs for Miscellaneous Metal and/or Plastic Surface Coatings

Limits as Applied Mass of VOC per volume of coating (minus exempt compounds)

Metal Parts and Products VOC Content Limits Air Dried Baked

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

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

Plastic Parts and Products VOC Content Limits Coating Category kg/l lb/gal

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
12

Automotive Transportation and Business Machine Plastic Parts VOC Content Limits Coating Category kg/l lb/gal

--Automotive Transportation Coatings*--

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

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

Low Bake/Air Dried – Interior Parts 0.60 5.0

Touch-Up and Repair 0.62 5.2

--Business Machine Coatings--

Primers 0.35 2.9

Topcoat 0.35 2.9

Texture Coat 0.35 2.9

Fog Coat 0.26 2.2

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

Pleasure Craft Surface Coating VOC Content Limits Coating Category kg/l lb/gal

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 0.42 3.5

for Metal or Plastic

Motor Vehicle Materials VOC Content Limits Coating Category kg/l lb/gal

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 Material 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
13

Table 2105.83.2

Emission Limits of VOCs for Miscellaneous Metal and/or Plastic Surface Coatings

with Applicable Add-on Controls

Limits as Applied Mass of VOC per volume solids

Metal Parts and Products VOC Content Limits Air Dried Baked

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

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

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 0.40 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

Plastic Parts and Products VOC Content Limits Coating Category kg/l lb/gal

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
14

Automotive Transportation and Business Machine Plastic Parts VOC Content Limits Coating Category kg/l lb/gal

--Automotive Transportation Coatings*--

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

Non-Basecoat/Clearcoat 1.24 10.34

Low Bake/Air Dried – Exterior Parts

Primer 1.66 13.80

Basecoat 1.87 15.59

Clearcoat 1.39 11.58

Non-Basecoat/Clearcoat 1.87 15.59

Low Bake/Air Dried – Interior Parts 1.87 15.59

Touch-Up and Repair 2.13 17.72

--Business Machine Coatings--

Primers 0.57 4.80

Topcoat 0.57 4.80

Texture Coat 0.57 4.80

Fog Coat 0.38 3.14

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

Pleasure Craft Surface Coating VOC Content Limits Coating Category kg/l lb/gal

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 0.80 6.7

for Metal or Plastic
15

§ 2105.84 CONTROL OF VOC EMISSIONS FROM AUTOMOBILE AND 

LIGHT-DUTY TRUCK ASSEMBLY COATINGS 

a. Applicability. 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 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. 

b. Limitations. A person may not cause or permit the emission into the outdoor 

atmosphere of VOCs from an automobile and/or light-duty truck assembly coating 

operation, unless one of the following limitations is met:

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

is equal to or less than the standard specified in Table 2105.84.

A. The VOC content, minus exempt compounds, of the applied coating, 

expressed in units of weight of VOC per volume of total nonexempt 

material, shall be calculated as follows:

 Ws - Ww - Wes

VOC = -----------------------

 Vm - Vw - Ves

Where:

 VOC = VOC content, minus exempt compounds, in lb (g) VOC / 

 gal (l) of materials, minus exempt compounds

 Ws = Weight of all volatile material in pounds (g), including VOC, 

 water, non-precursor organic compounds and dissolved vapors 

 Ww = Weight of water in pounds (g)

 Wes = Weight of all non-precursor compounds in pounds (g)

 Vm = Volume of total material, as applied in gallons (l)

 Vw = Volume of water in gallons (l)

 Ves = Volume of all non-precursor compounds in gallons (l)

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

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

ALL NEW TEXT
16

§ 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%.

c. Records. A facility, regardless of the facility’s annual emission rate, which contains an 

automobile and/or light-duty truck assembly coating operation, shall maintain records 

sufficient to demonstrate compliance with this section. At a minimum, a facility shall 

maintain daily records of: 

1. The following parameters for each coating, thinner and other component as 

supplied:

A. The coating, thinner or component name and identification number;

B. The volume used;

C. The mix ratio;

D. The density or specific gravity;

E. The weight percent of total volatiles, water, and exempt solvents; 

F. The volume percent of total solids, water, and exempt solvents for Table 

2105.84 automobile and/or light-duty truck assembly coating operation.

The records shall be maintained for 2 years and shall be submitted to the Department on a 

schedule reasonably prescribed by the Department. 

d. Exempt Solvents. The solvents methyl chloroform (1,1,1-trichloroethane) and 

methylene chloride are exempt from control under this Section. No automobile and/or 

light-duty truck assembly coating operation which seeks to comply with this Section 

through the use of an exempt solvent may be included in any alternative standard 

approved pursuant to this Article.

e. Housekeeping. The following work practices for cleaning materials apply to the owner 

or operator of an automobile and/or light-duty truck assembly coating operation:

1. Store all VOC-containing coatings, thinners, coating-related waste materials,

cleaning materials and used shop towels in closed containers.

2. Ensure that mixing and storage containers used for VOC-containing coatings, 

thinners, coating-related waste materials, and cleaning materials are kept closed at 

all times except when depositing or removing those materials.

3. Minimize spills of VOC-containing coatings, thinners, coating-related waste 

materials, and cleaning materials, cleaning up spills immediately.

4. Convey VOC-containing coatings, thinners, coating-related waste materials, and 

cleaning materials from one location to another in closed containers or pipes.
17

5. Minimize VOC emissions 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.

6. Develop and implement a work practice plan to minimize VOC emissions from 

cleaning and from purging of equipment associated with all coating operations for 

which emission limits are specified in this regulation. The plan shall specify 

practices and procedures to ensure that VOC emissions from the following 

operations are minimized:

A. Vehicle body wiping;

B. Coating line purging;

C. Flushing of coating systems;

D. Cleaning of spray booth grates;

E. Cleaning of spray booth walls;

F. Cleaning of spray booth equipment;

G. Cleaning of external spray booth areas; and

H. Other housekeeping measures.

f. Measurements. Measurements of the volatile fraction of coatings, other than reactive 

coatings, used at automobile and/or light-duty truck assembly coating facilities shall be 

performed according to the applicable procedures established in § 2107.04 of this 

Article.
18

Table 2105.84

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

(pounds VOC per gallon or grams VOC per liter coating solids applied)

Assembly Coating Process VOC Emission Limit

lb/gal g/l

Electodeposition primer operation when solids turnover ratio (RT) ≥ 0.16 0.7 84

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

Electodeposition primer operation when 0.040 ≤ (RT) < 0.16 0.7*3500.160- R

T 84*3500.160- RT

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

Electodeposition primer operation when (RT) < 0.040 No VOC emission limit

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

Primer-surfacer operations 12.0 1,440

(including application area, flash-off area, and oven)

Topcoat operations 12.0 1,440

(including application area, flash-off area, and oven)

Final repair operations 4.8 580

Combined primer-surfacer and topcoat operations 12.0 1,440

VOC Emission Limits for Miscellaneous Materials Used at Automobile and/or Light-duty 

Truck Assembly Coating Facilities 

(pounds VOC per gallon or grams VOC per of liter coating excluding water and exempt compounds, as applied)

Material VOC Emission Limit

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
19

§ 2105.85 CONTROL OF VOC EMISSIONS FROM MISCELLANEOUS INDUSTRIAL 

ADHESIVES 

a. Applicability. 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. 

b. Limitations. A person may not cause or permit the emission into the outdoor 

atmosphere of VOCs from a miscellaneous industrial adhesive process, unless one of the 

following limitations is met:

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

specified in Table 2105.85.

A. The VOC content, minus exempt compounds, of the applied adhesive, 

expressed in units of weight of VOC per volume of total nonexempt 

material, shall be calculated as follows:

 Ws - Ww - Wes

VOC = -----------------------

 Vm - Vw - Ves

Where:

 VOC = VOC content, minus exempt compounds, in lb (g) VOC / 

 gal (l) of materials, minus exempt compounds

 Ws = Weight of all volatile material in pounds (g), including VOC, 

 water, non-precursor organic compounds and dissolved vapors 

 Ww = Weight of water in pounds (g)

 Wes = Weight of all non-precursor compounds in pounds (g)

 Vm = Volume of total material, as applied in gallons (l)

 Vw = Volume of water in gallons (l)

 Ves = Volume of all non-precursor compounds in gallons (l)

B. The VOC content limits of subparagraph A may be met by averaging the 

VOC content of materials used on a single application unit for each day 

(i.e., daily within-application unit averaging).

ALL NEW TEXT
20

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

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

under § 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.

c. Records. A facility, regardless of the facility’s annual emission rate, which contains 

miscellaneous industrial adhesive application processes, shall maintain records sufficient 

to demonstrate compliance with this section. At a minimum, a facility shall maintain 

daily records of: 

1. The following parameters for each adhesive and other component as supplied:

A. The name and identification number of each adhesive, or component;

B. The volume used;

C. The mix ratio;

D. The density or specific gravity;

E. The weight percent of total volatiles, water, and exempt solvents; 

F. The volume percent of total materials, water, and exempt solvents for 

Table 2105.86 miscellaneous industrial adhesives.

The records shall be maintained for 2 years and shall be submitted to the Department on a 

schedule reasonably prescribed by the Department. 

d. Exempt Solvents. The solvents methyl chloroform (1,1,1-trichloroethane) and 

methylene chloride are exempt from control under this Section. No miscellaneous 

industrial adhesive application process which seeks to comply with this Section through 

the use of an exempt solvent may be included in any alternative standard approved 

pursuant to this Article.

e. Application Techniques. A person may not cause or permit the emission into the 

outdoor atmosphere of VOCs from the application of miscellaneous industrial adhesives 

unless the adhesives are applied using one or more of the following application methods:

1. Electrostatic spraying;

2. High volume-low pressure (HVLP) spraying;

3. Flow coating;

4. Dip coating, including electrodeposition;

5. Airless spraying;

6. Air-assisted airless spraying;

7. Roll coating or hand application, including non-spray application methods similar 

to hand or mechanically powered caulking gun, brush, or direct hand application;
21

8. Other adhesive application method that the person demonstrates and the 

Department determines achieves emission reductions equivalent to HVLP 

spraying.

f. Exempt Other. The following shall be exempt from the limitations set by Subsection b, 

but shall still comply with the Subsection h, Housekeeping:

1. Adhesives or adhesive primers being tested or evaluated in any research and 

development, quality assurance, or analytical laboratory.

2. Adhesives or adhesive primers used in the assembly, repair, or manufacture of 

aerospace or undersea-based weapon systems.

 

3. Adhesives or adhesive primers used in medical equipment manufacturing 

operations.

4. Cyanoacrylate adhesive application processes.

5. Aerosol adhesive and aerosol adhesive primer application processes.

6. Processes using polyester bonding putties to assemble fiberglass parts at 

fiberglass boat manufacturing facilities and at other reinforced plastic composite 

manufacturing facilities.

7. Processes using adhesives and adhesive primers that are supplied to the 

manufacturer in containers with a net volume of 16 ounces or less, or a net weight 

of one pound or less.

g. Emission Limitations. If an adhesive is used to bond dissimilar substrates together, then 

the applicable substrate category with the least stringent emission limitation applies.

h. Housekeeping. The following work practices for cleaning materials apply to the owner 

or operator of a miscellaneous industrial adhesive application processes:

1. Store all VOC-containing adhesives, adhesive primers, process-related waste 

materials, cleaning materials and used shop towels in closed containers.

2. Ensure that mixing and storage containers used for VOC-containing adhesives, 

adhesive primers, process-related waste materials, and cleaning materials are kept 

closed at all times except when depositing or removing those materials.

3. Minimize spills of VOC-containing adhesives, adhesive primers, process-related 

waste materials, and cleaning materials, cleaning up spills immediately.
22

4. Convey VOC-containing adhesives, adhesive primers, process-related waste 

materials, and cleaning materials from one location to another in closed containers 

or pipes.

5. Minimize VOC emissions 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.

i. Measurements. Measurements of the volatile fraction of adhesives, other than reactive 

adhesives, used at facilities operating miscellaneous industrial adhesive application 

processes shall be performed according to the applicable procedures established in 

§ 2107.04 of this Article.
23

Table 2105.85

Emission Limits of VOCs for Miscellaneous Industrial Adhesives

Limits as Applied VOC content minus exempt compounds

General Adhesive Application Processes 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 Urethane/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

Single-Ply Roof Membrane Adhesive Primer 2.1 250

Other Adhesive Primer 2.1 250
24

§ 2105.86 CONTROL OF VOC EMISSIONS FROM FIBERGLASS BOAT 

MANUFACTURING MATERIALS

a. Applicability. 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.

b. Exemptions. This regulation does not extend to surface coatings applied to fiberglass 

boats, and industrial 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 PROSSES. Industrial 

adhesives used in fiberglass boat assembly are addressed in regulation § 2105.85 

CONTROL OF VOC EMISSIONS FROM MISCELLANEOUS INDUSTRIAL 

ADHESIVES.

c. Limitations. A person may not cause or permit the emission into the outdoor 

atmosphere of VOCs from fiberglass boat manufacturing materials, unless one of the 

following limitations is met:

1. 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 2105.86 and the non-monomer VOC limit shall not exceed 

5 percent, by weight, of resin and/or gel coat.

A. The weighted average monomer VOC content shall be calculated as 

follows:

 ∑ (Mi * VOCi)

Weighted Average Monomer VOC Content = -----------------------

 ∑ (Mi)

Where:

ALL NEW TEXT
25

Mi = Mass of open molding resin or gel coat i used in the past 12 

months in an operation in pounds (kg)

VOCi = Monomer VOC content, by weight percent, of open molding 

 resin or gel coat i used in the past 12 months in an operation

d. Records. A facility, regardless of the facility’s annual emission rate, which uses 

fiberglass boat manufacturing materials, shall maintain records sufficient to demonstrate 

compliance with this section. At a minimum, a facility shall maintain daily records of: 

1. The following parameters for each material either resin and/or gel as supplied:

A. The name and identification number of each resin and/or gel;

B. The volume used;

C. The mass of materials used;

D. The monomer VOC content, by weight percent, of resin or gel coat used;

E. The non-monomer VOC content, by weight percent, of each resin or gel 

coat; 

The records shall be maintained for 2 years and shall be submitted to the Department on a 

schedule reasonably prescribed by the Department. 

e. Cleaning Material Standards. The VOC content of cleaning solvents employed for 

routine application equipment cleaning shall contain a maximum of 5 percent VOC, by 

weight, or have a composite partial vapor pressure of no more than 0.50 mm Hg at sixtyeight degrees Fahrenheit. Only non-VOC solvents shall be used to remove cured resin 

and gel coat from application equipment. 

f. Work Practice Standards. All resin and gel coat mixing containers with a capacity 

equal to or greater than 208 liters (55 gallons), including those used for onsite mixing of 

putties and polyputties, have a cover with no visible gaps in place at all times. This work 

practice standard does not apply when material is being manually added to or removed 

from a container, or when mixing or pumping equipment is being placed in or removed 

from a container. 

g. Measurements. Measurements of the volatile fraction of resin and gels, used at 

fiberglass boat manufacturing facilities shall be performed according to the applicable 

procedures established in § 2107.04 of this Article.
26

2. Technical Support Document

Summary of Change

The changes to the sections of Article XXI add four Control Techniques Guidelines (CTG) 

categories as four regulations. Definitions arising from these CTG regulations were also added 

to Article XXI. Changes were also made to an existing regulation, making any limits pertaining 

to these CTG regulations void after 1/1/2014. 

§2101.20, Definitions (SIP Change); 

§2105.10, Surface Coating Processes (SIP Change);

§2105.83, Control of VOC Emissions from Miscellaneous Metal and/or Plastic Parts 

Surface Coating Processes (SIP Change); 

§2105.84, Control of VOC Emissions from Automobile and Light-Duty Truck 

Assembly Coatings (SIP Change);

§2105.85, Control of VOC Emissions from Miscellaneous Industrial Adhesives

(SIP Change); and

§2105.86, Control of VOC Emissions from Fiberglass Boat Manufacturing 

Materials (SIP Change)

The CTG categories for Miscellaneous Metal and Plastic Parts Coatings, Automobile and LightDuty Truck Assembly Coatings, Miscellaneous Industrial Adhesives, and Fiberglass Boat 

Manufacturing Materials, were issued by the EPA in 2008. The EPA has mandated that these 

CTGs become regulations, written by Local or State Air Pollution Control Agencies.

The regulation changes to sections §2101.20 and §2105.10, and the addition of regulations 

§2105.83, §2105.84, §2105.85 and §2105.86 to Article XXI constitute a change to the Allegheny 

County portion of the Pennsylvania State Implementation Plan (SIP) for the control of ozone 

with respect to those sections.
27

3. Documentation of Public Hearing and Certifications

Notice of Public Hearing

Transmittals of hearing notice to EPA & PA DEP

Proof of publication of notice of hearing

Certification of hearing

Summary of Comments and responses

Certification of approval and adoption
28

NOTICE OF PUBLIC HEARING

FOR PROPOSED AMENDMENTS TO

ALLEGHENY COUNTY HEALTH DEPARTMENT RULES AND REGULATIONS

ARTICLE XXI, AIR POLLUTION CONTROL

The Allegheny County Board of Health will hold a public hearing on Friday, March 9, 2012, at 

10:00 AM, Building #7 First Floor Conference Room, Clack Health Center, 301 39th Street, 

Pittsburgh, PA 15201 to take testimony on the following proposed modifications to Allegheny 

County Health Department Article XXI and County Ordinance 16782:

Revision to the following Article XXI sections as they relate to Control Techniques 

Guidelines:

§2101.20, Definitions; 

§2105.10, Surface Coating Processes;

§2105.83, Control of VOC Emissions from Miscellaneous Metal and/or Plastic Parts 

Surface Coating Processes;

§2105.84, Control of VOC Emissions from Automobile and Light-Duty Truck Assembly 

Coatings;

§2105.85, Control of VOC Emissions from Miscellaneous Industrial Adhesives;

§2105.86, Control of VOC Emissions from Fiberglass Boat Manufacturing Materials.

The proposed changes to §2101.20 and §2105.10 and the additional regulations 

§2105.83, §2105.84, §2105.85, §2105.86 will be incorporated as a revision to 

Allegheny County’s portion of the Pennsylvania State Implementation Plan for the 

control of ozone.

Copies of the proposed amendments may be examined beginning Wednesday, February 8, 2012, 

at the Allegheny County Law Library, Room 921 City-County Building, Grant Street, Pittsburgh, 

PA 15219, from 8:30 AM to 5:00 PM; at the Allegheny County Health Department Library, 

Building 7, Clack Health Center, from 8:30 AM until 3:30 PM Monday thru Friday; on the 

Allegheny County Health Department web site: www.achd.net; or by calling 412-578-8120 to 

request a mailed printed copy.

Oral testimony must be pre-scheduled by calling 412-578-8008 no less than 24 hours in advance 

of the public hearing. Speakers will be limited to five minutes and should bring a written copy 

of their comments. 

The Board will accept written testimony beginning Wednesday, February 8, 2012, and 

concluding Wednesday, March 14, 2012, by mail to: 

Board of Health

3333 Forbes Avenue

Pittsburgh, PA 15213

By email to BOH@achd.net

By Fax to 412-578-8325 
29
30
31
32
33

Comment and Response Document for the Proposed SIP Revision 74

Regulation Changes for Ozone Control Techniques Guidelines

March 9, 2012 Public Hearing

1. Comment: 

Commenter: No comments were received. 

Response: 
34