Department of the Environment 

TECHNICAL SUPPORT DOCUMENT

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) for flat wood paneling coatings. EPA develops 

CTGs as guidance on control requirements for source 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 Stationary 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 preparing RACT regulations for a variety of 

categories, including flat wood paneling. In 2003, EPA promulgated national emission standards 

for hazardous air pollutants (NESHAP) covering 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 panels that were first 

undercoated with an opaque coating to mask the original 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 coating. Filler is applied by reverse roll coating. 

The offset rotogravure process is used where the coating and printing operation requires 

precision printing. Other coating methods used include spray techniques, brush coating and 

curtain coating. A flat wood paneling coating line includes a succession of coating operations. 

Each individual operation consists of the application 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 consideration of controls. Flat wood paneling coatings 

means paneling products that are any interior, exterior or tileboard (class I hardboard) panel to 

which a protective, decorative, or functional material or layer has been applied. 

Work practice standards that have proven particularly 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 system; (3) collecting and containing all VOCs 

when cleaning coating lines and spray guns; and (4) using low-VOC or low-vapor pressure 

cleaning materials. 

1 
The proposed regulation develops standards for flat wood paneling coating operations. Facilities 

that apply stains and varnishes to natural plywood 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 varnishes 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 coating 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 operations will result in minimal VOC emission 

reductions in Maryland. VOC emissions are expected 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 approximately $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 2 12/15/2009 1:11 PM 
DRAFT 3 12/15/2009 1:11 PM 

regulated. The Department will need to review additional records and ensure new standards are 

being met. 

Revision to Maryland's SIP 

This action will be submitted to the U.S. EPA for approval as part of Maryland's State 

Implementation 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 Standards 

There is a corresponding federal standard to this proposed action, 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)