Department of the Environment 

# T E C H N I C A L 

# S U P P O R T 

# D O C U M E N T

COMAR 26.11.19.33 Control of VOC Emissions from Flat Wood Paneling Operations

Purpose of Amendments

The purpose of this action is to adopt the requirements of the Environmental Protection Agency (EPA) Control Techniques Guidelines (CTG) fo r flat wood paneling coatings. EPA develops CTGs as guidance on control requirements for sour ce categories. States can follow the CTGs or adopt more restrictive standards. MDE proposes to adopt the CTG standards for flat wood paneling coatings.

Background

In June 1978, EPA published a final CTG for flat wood paneling coatings, entitled “Control of Volatile Organic Emissions from Existing Statio nary Sources, Volume VII, Factory Surface Coating of Flat Wood Paneling”. In 1979, EPA published guidance to provide assistance to State and local air pollution control agencies in pr eparing RACT regulations for a variety of categories, including flat wood paneling. In 2003, EPA promulgate d national emission standards for hazardous air pollutants (NESHAP) coveri ng surface coating of wood building products (including flat wood paneling).

A flat wood coating facility applies stains and varnishes to natural plywood panels used for wall coverings. These facilities also print wood grain patterns on particle board pane ls that were first undercoated with an opaque coating to mask the or iginal surface. Coatings applied to flat wood paneling include fillers, sealers, “groove” coats, primers, stains , basecoats, inks and topcoats. Generally, coatings are applied by direct roll co ating. Filler is applied by reverse roll coating. The offset rotogravure process is used wher e the coating and prin ting operation requires precision printing. Other coating methods used include spray techniques, brush coating and curtain coating. A flat wood paneling coating lin e includes a succession of coating operations. Each individual operation consists of the applicat ion of coatings and a heated oven to cure the coatings.

The CTG applies to facilities that apply flat wood paneling coatings that emit 15 pounds or more per day (6.8 kg/day) of VOC before considera tion of controls. Flat wood paneling coatings means paneling products that are any interior, exte rior or tileboard (cla ss I hardboard) panel to which a protective, decorative, or functiona l material or layer has been applied.

Work practice standards that have proven particul arly effective include: (1) frequent visual inspections for all equipment used to transfer or apply coatings, adhesives, or organic solvents; (2) cleaning and wash off solvent accounting sy stem; (3) collecting a nd containing all VOCs when cleaning coating lines and spray guns; a nd (4) using low-VOC or low-vapor pressure cleaning materials.

1The proposed regulation develops standards for flat wood paneling coating operations . Facilities that apply stains and varnishes to natural plyw ood panels used for wall coverings are affected by this regulation.

Sources Affected and Location

The proposed regulation develops standards for flat wood paneling coating operations. Facilities that apply stains and varnishe s to natural plywood panels used for wall coverings are affected by this regulation.

Requirements

COMAR 26.11.19.33 sets a VOC standard of 2.1 pounds of VOC per gallon (250 grams VOC per liter) upon surface coatings , inks or adhesives applied to flat wood paneling.

Affected sources can comply with the coat ing standards or control emissions by 90%. The work practice standards apply to the usage of all VOC containing materials.

Basis for Emission Standards

CTG standards are based on low-VOC coatings for inks, coatings and adhesives. The CTG standard for inks, coatings and adhesives is 250 g VOC/l (2.1 lb VOC/gal) of material (minus water and exempt compounds). The CTG allows the use add-on control equipment to meet an overall control efficiency of 90 percent. This control option is available for surface coatings, inks, and adhesives applied to flat wood paneling.

The CTG also has requirements for work practices at flat wood paneling coating facilities meeting the applicability threshold.

Expected Emissions Reductions

EPA’s CTG for flat wood paneling coating opera tions will result in minimal VOC emission reductions in Maryland. VOC emissions are ex pected to be reduced by 16-27 percent on a

national level.

Health Effects and Ground-Level Ozone

The maximum benefit from these amendments will be provided during the ozone season when VOCs readily combine with NOx to form the pollutant ground level ozone.

Economic Impact

Cost impact on affected sources is approxi mately $2,800/ton of VOC controlled. The economic impact of implementing CTG requirements has been estimated by EPA on a national level. Impact on affected sources is going to be less as cost increase is offset by lower evaporation rates. The impact on the Department is going to be minimal as affected sources are already

DRAFT 12/15/2009 1:11 PM 2DRAFT 12/15/2009 1:11 PM 3 regulated. The Department will need to review additional records and en sure new standards are being met.

Revision to Maryland's SIP

This action will be submitted to the U.S. EP A for approval as part of Maryland's State Implementation Plan.

Other State or Federal Requirements

There are no other state or fede ral 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 Standards

There is a corresponding federal standard to this proposed acti on, but the proposed action is not more restrictive or stringent.

References

Control Techniques Guidelines for Flat Wood Paneling Coatings (EPA 453/R-06-004 September

2006)