UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION III 

1650 Arch Street 

Philadelphia, Pennsylvania 19103 

SUBJECT: Technical Support Document for Virginia's Adoption of Control 

Techniques Guidelines for Offset Lithographic Printing and Letterpress 

Printing; Industrial Solvent Cleaning Operations; Miscellaneous Industrial 

Adhesives; and Miscellaneous Metal and Plastic Parts Coating for Control 

of Volatile Organic Compound Emissions 

FROM: 

TO: 

THRU: 

Leslie Jones Doherty, Environmental Engineer 

Office of Air Program Planning 

File • 

91fUC ~~ /) JA d . D. r· nsli~a 'Fe"'~';"n ez, SSOC!ate !rector 

Office of Air Program Planning 

A. BACKGROUND 

Section 172(c)(l) 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. The ozone transport region (OTR) is established by section 184 of the CAA. 

Pursuant to section 184(b )( 1 )(B) of the CAA, all areas in the OTR must implement 

RACT with respect to sources of volatile organic compounds (VOCs) in the state covered 

by a control techniques guideline (CTG) issued before or after November 15, 1990. In 

addition, pursuant to CAA section 184(b )(2), stationary sources in states or portions of a 

state within the OTR that emit at least 50 tons per year ofVOCs shall be considered 

major stationary sources subject to requirements applicable to major stationary sources if 

the area were classified as a Moderate nonattainment area including requirements for 

CTGs and RACT. The northern portion of Virginia is part of the Metropolitan Statistical 

Area of the District Columbia which is in the ozone transport region (OTR) established 

under section 184(a) of the CAA and therefore, must comply with section 184(b)(l)(B) 

and (2). 

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 YOCs from various sources, including 

offset lithographic printing and letterpress printing; industrial solvent cleaning 

operations; miscellaneous industrial adhesives; and miscellaneous metal and plastic parts 

coatings. In developing these CTGs, EPA, among other things, evaluated the sources of 

voc emissions from these industries and the available control approaches for addressing 

these emissions, including the costs of such approaches. Based on available information 

and data, EPA provides recommendations for RACT for YOCs from offset lithographic 

printing and letterpress printing; industrial solvent cleaning operations; miscellaneous 

industrial adhesives; and miscellaneous metal and plastic parts coatings. 

The CTG recommendations may not apply to a particular situation based upon the 

circumstances of a specific source. Regardless of whether a State chooses to implement 

the recommendations contained within the CTGs through State rules, or to issue State 

rules that adopt different approaches for RACT for YOCs for offset lithographic printing 

and letterpress printing; industrial solvent cleaning operations; miscellaneous industrial 

adhesives; and miscell aneous metal and plastic parts coatings, states must submit their 

RACT rules to EPA for review and approval as part of the SIP process. EPA will 

evaluate the rules and determine, through notice and comment rulemaking in the SIP 

process, whether they meet the RACT requirements of the CAA and EPA's regulations. 

On February I, 2016, Virginia Department of Environmental Quality (V AD EQ) 

submitted to EPA three SIP revisions concerning the adoption of EPA CTGs for offset 

lithographic printing and letterpress printing; industrial solvent cleaning operations; 

miscell aneous industrial adhesives; and miscellaneous metal and plastic parts coatings 

processes. EPA develops CTGs as guidance on control requirements for source 

categories. States can follow the CTGs or adopt more restrictive standards. The 

Commonwealth of Virginia has adopted EPA's CTG standards for offset lithographic 

printing and letterpress printing; industrial solvent cleaning operations; miscellaneous 

industri al adhesives; and miscellaneous metal and plastic parts coatings processes. These 

regulations are in 9V AC5 Chapter 40 - Existing Stationary Sources. Specifically, these 

revisions amend Article 53 and adds Articles 56 and 56. 1 pertaining to offset lithographic 

printing and letterpress printing operations. These revisions also add Article 57 

pertaining to industrial solvent cleaning processes and Article 58 pertaining to 

miscellaneous industrial adhesive processes. Lastly, these revisions amend Article 34 

and adds Article 59 pertaining to miscellaneous metal and plastic parts coatings 

processes. The revisions are summarized below. 

B. OFFSET LITHOGRAPHIC AND LETTERPRESS PRINTING 

l. Description of EPA's Offset Lithographic and Letterpress Printing CTG (EPA 

453/R-06-002, September 2006) 

In 1993, EPA published a draft CTG for offset lithographic printing (58 FR 59261 ). 

After reviewing comments on the draft CTG and soliciting additional information to help 

clarify those comments, EPA published an alternative control techniques (ACT) 
document in June 1994 that provided supplemental information for States to use in 

developing rules based on RACT for offset lithographic printing. After reviewing the 

1993 CTG and 1994 ACT for this industry, conducting a review of currently existing 

state and local VOC emission reduction approaches for this industry, and taking into 

account any information that has become available since then, EPA developed a new 

CTG entitled Control Techniques Guidelines for Offset Lithographic and Letterpress 

Printing (Publication No. EPA 453/R-06-002; September 2006). 

Offset lithography is a planographic method of printing. The term "planographic" 

denotes that the printing and non-printing areas are in the same plane on the surface of a 

thin metal lithographic plate. To maintain the distinction between the areas on the 

lithographic plate, the image area is rendered oil receptive, and the non-image area is 

rendered water receptive. Offset lithography is an indirect printing method; that is, ink is 

not transferred directly to a substrate. Rather, ink is transferred from the lithographic 

plate to a rubber-covered, intermediate "blanket" cylinder and then transferred from the 

blanket cylinder to the substrate. The offset lithographic process is used for a broad 

range of printing applications, including books, magazines, periodicals, labels and 

wrappers, catalogs and directories, financial and legal documents, business forms, 

advertising brochures, newspapers, newspaper inserts, charts and maps, calendars, tickets 

and coupons, greeting cards, and stamps. There are two types of offset lithography 

characterized by the method in which the substrate is fed to the press. In sheet-fed 

printing, individual sheets of paper or other substrate are fed to the press. In web 

printing, continuous rolls of substrate material are fed to the press and rewound or cut to 

size after printing. VOC emissions from offset lithographic printing result from the 

evaporation of components of the inks, fountain solutions, cleaning materials and other 

miscellaneous materials such as varnishes, coatings and glues. 

Letterpress inks are similar to offset lithographic inks. They are paste inks containing 

petroleum oils or vegetable oils. Both sheet-fed and web presses are used for letterpress 

printing. Sheet-fed letterpress presses use coldset inks. Most web letterpress equipment 

use coldset inks. These letterpress inks are similar in composition and behavior to sheetfed and coldset web lithographic inks. In sheet-fed and coldest web letterpress printing, 

95 percent of the petroleum ink oils and essentially all of the vegetable oils are retained in 

the substrate and dry ink film. The remaining 5 percent of petroleum ink oils is 

volatilized and emitted. Because of the high level of ink oil retention, emissions from 

sheet-fed and coldset web letterpress inks are inherently very low. 

There are three main sources ofVOC emissions from offset lithographic printing: (1) 

evaporation ofVOCs (petroleum ink oils) from the inks; (2) evaporation ofVOCs from 

the fountain solution; and (3) evaporation ofVOCs from the cleaning materials. There are 

two main sources ofVOC emissions from letterpress printing: (1) evaporation ofVOCs 

(petroleum ink oils) from the inks, and (2) evaporation ofVOCs from the cleaning 

materials. 
EPA's Recommended Control Options for Offset Lithographic and Letterpress 

Printing 

In terms of applicability, the CTG recommends that the controls discussed should apply 

to: (I) A heatset web offset lithographic printing press or heatset web letterpress printing 

press that has potential emissions from the dryer of25 tons per year (tpy) of VOCs before 

consideration of add-on controls; and (2) all letterpress printing and offset lithographic 

printing and related cleaning activities if the total actual VOC emissions are equal to or 

greater than 450 lbs per month or 3 tons per rolling 12-month period. 

The CTG provides control options based on the three main sources ofVOC emissions (1) 

evaporation of VOCs (petroleum ink oils) from the inks; (2) evaporation of VOCs from 

the fountain solution (offset lithographic printing only); and (3) evaporation ofVOCs 

from the cleaning materials. The recommended level of control for VOC emissions from 

inks used in heatset dryers prior to the effective date of the State RACT rule is 90% 

control efficiency for a control device. The recommended level of control for VOC 

emissions from inks used in heatset dryers after the effective date of the State RACT mle 

is 95% control efficiency for a control device. Where the inlet VOC concentration is so 

low that a 90% or 95% efficiency is not achievable, EPA recommends to reduce the 

control device outlet concentration to 20 ppmv as hex ~ on a dry basis. 

In regards to fountain solutions used in offset lithographic printing operations, the 

recommended level of control for heatset web processes is 1.6% alcohol (by weight). 

This may be achieved by reducing the on-press alcohol content to 1.6% alcohol, by using 

3% alcohol or less on-press if the fountain solution is refrigerated to below 60°F and, 

lastly, using a 5% alcohol substitute on-press and no alcohol in the fountain solution. For 

sheet-fed offset lithographic printing processes, the recommended level of control for 

VOC emissions from on-press fountain solution is equivalent to 5% alcohol (by weight). 

This may be achieved by reducing the on-press alcohol content to 5.0% alcohol, by using 

8.5% alcohol or less on-press if the fountain solution is refrigerated to below 60°F and, 

lastly, using a 5% alcohol substitute on-press and no alcohol in the fountain solution. For 

coldset web offset printing the recommended level of control for VOC emissions is 5% 

alcohol substitute or less (by weight) on-press and no alcohol in the fountain solution. 

The CTG recommends using cleaning material with a VOC composite vapor pressure 

less than l 0 mm Hg at 20°C or cleaning materials. containing less than 70 weight% VOC. 

It is also recommended to add the work practice of keeping cleaning materials and used 

shop towels in closed containers to reduce VOC emissions. 

II. State Submittal for Offset Lithographic Printing and Letterpress Printing 

9V AC5 Chapter 40, Article 56, Emission Standards for Letterpress Printing Operations in 

the Northern Virginia Volatile Organic Compound Emissions Control Area, 8-hour 
Ozone Standard 1

• establishes applicability, definitions, emission standards, compliance, 

test methods, monitoring, and notifications, records and reporting for letterpress printing 

operations. These provisions apply to any letterpress printing operation at a stationary 

source where the actual emissions of VOCs fi·om all aspects ofletterpress printing 

operations, including related cleaning acti vities, before the consideration of controls, are 

equal to or exceed 3.0 tons per 12-month rolling period. The provisions apply only to 

affected facilities in the Northern Virginia VOC Emissions Control Area designated in 

subdivision la of9VAC5-20-206. 

ln 9V AC5-40-8640, the following emission standards, exemptions and work practices for 

letterpress printi ng operations are established: 

l. For heatset web letterpress printing, provisions apply to each dryer on each 

heatset web letterpress printing process except those (1) with a theoretical 

potential to emit less than 25 tons per year ofVOC (petroleum ink oil) from the 

dryer, prior to controls; (2) any heatset web letterpress printing process used 

exclusively for book printing; or (3) any heatset web letterpress printing process 

with a maximum web width of22 inches or less. These provisions also do not 

apply to non-heatset web letterpress printing processes or to sheet-fed letterpress 

printing processes. VOC emissions from the heatset web letterpress printing 

process dryer shall be controlled by: 

a. The dryer shall be operated at lower air pressure than the pressroom air 

pressure. 

b. Exhaust air from the dryer shall be collected and sent to a control device. 

c. For a control device installed prior to February I, 2016, the control device 

shall reduce VOC emissions in the dryer air exhaust by at least 90%. 

d. For a control device installed after February l, 2016, the control device 

shall reduce VOC emissions in the dryer air exhaust by at least 95%. 

2. Where the inlet VOC concentration for a heatset web letterpress printing process 

control device is so low that a 90% or 95% efficiency is not achievable, the 

control device shall reduce the outlet VOC concentration to 20 ppmv as hexane 

on a dry basis. 

3. Cleaning materials used at a letterpress printing operation shall meet one of the 

following limits: (a) VOC content of70% by weight; or (b) a composite vapor 

pressure of I 0 mm Hg at 20°C. 

4. The following work practices are to implemented: 

a. Cleaning materials, inks, and coatings containing VOCs shall be kept in 

closed containers at all times unless fi lling, draining, or performing 

cleaning operations. 

b. Shop towels, sponges, and other manual cleaning aids (i) that have been 

used for picking up excess ink and other coatings containing VOCs or (ii) 

that have been used with cleaning materials containing VOCs shall be kept 

in closed containers. 

I The northern portion of Virginia is defined as the Northern Virginia Volatile Organic Compound 

Emissions Control Area in 9V AC5-20-206 (General Provisions). This northern portion of Virginia is also 

part of the Metropolitan Statistical Area of the District Columbia which is in the ozone transport region 

(OTR) established under section 184(a) of the CAA. 
c. Spills of cleaning materials, fountain solution, inks, varnishes, and other 

coatings containing VOCs shall be minimized and shall be cleaned up 

promptly. 

9V ACS-40-8386 establishes the standard for visible emissions and 9V ACS-40-8388 

establishes the standard for fugitive dust/emissions. 9V ACS-40-8396 establishes 

compliance requirements for control devices installed on heatset web letterpress printing 

process dryers, VOC retention factors, and capture efficiencies for letterpress printing 

operations. 9V ACS-40-8398 establishes a compliance schedule for letterpress printing 

operations. 9VAC5-40-8400 establishes test methods and procedures and 9VAC5-40-

841 0 establishes monitoring requirements for the temperature for catalytic and thermal 

oxidation control devices. 9VAC5-40-8412 establishes notification, records and 

reporting requirements. 9V AC5-40-8414 and 9V AC5-40-84 15 state registration and 

permit requirements. 

9V AC5 Chapter 40, Article 56.1, Emission Standards for Offset Lithographic Printing 

Operations in the Northern Virginia Volatile Organic Compound Emissions Control 

Area, 8-hour Ozone Standard, establishes applicability, definitions, emission standards, 

compliance, test methods, monitoring, and notifications, records and reporting for offset 

lithographic printing operations. These provisions apply to any offset lithographic 

printing operation at a stationary source where the actual emissions of VOCs from all 

aspects of offset lithographic printing operations, including related cleaning activities, 

before the consideration of controls, are equal to or exceed 3.0 tons per 12-month rolling 

period. The provisions apply only to affected facilities in the Northern Virginia VOC 

Emissions Control Area designated in subdivision I a of9VAC5-20-206. 

In 9V ACS-40-8424, the following emission standards and exemptions for offset 

lithographic printing operations are established: 

1. For heatset offset lithographic printing processes, provisions apply to each 

process at a facility whose potential to emit is greater than or equal to 10 tons per 

year ofVOC. All VOC emissions from printing inks, coatings, cleaning 

solutions, and fountain solutions shall be considered in determining the potential 

to emit for this subsection. 

2. VOC emissions from the heatset offset lithographic printing process dryer shall be 

controlled by: 

a. The dryer shall be operated at lower air pressure than the pressroom air 

pressure. 

b. Exhaust air from the dryer shall be collected and sent to a control device. 

c. The control device shall reduce VOC emissions in the dryer air exhaust by 

at least 90%. 

3. Where the inlet VOC concentration for a heatset web offset lithographic printing 

process control device is so low that a 90% efficiency is not achievable, the 

control device shall reduce the outlet VOC concentration to 50 ppmv or less as 

carbon (minus methane and ethane). 

4. For heatset web offset lithographic printing processes with the theoretical 

potential to emit 25 tpy ofVOC or more from the dryer, 9VAC5-40-8424 
establishes the same VOC emission standards as listed above in 9VAC5-40-8640 

for heatset letterpress printing operations for the dryers (1 a - 1 d and 2), cleaning 

materials (3) and work practices (4). Exemptions include (i) any heatset web 

offset lithographic printing process used exclusively for book printing; or (ii) any 

heatset web offset lithographic printing process with a maximum web width of22 

inches or less. 

5. For the fountain solution in offset lithographic printing processes, requirements 

for heatset, non-heatset and sheet-fed processes are provided. 

a. For heatset web presses, when the fountain solution contains alcohol, ( 1) 

the fountain solution, as applied, shall contain no more than 1.6% VOC by 

weight, (2) the fountain solutions shall be maintained at 60°F and shall 

contain no more than 3% VOC by weight, or (3) if the fountain solution 

contains no alcohol, shall contain no more than 5% VOC by weight. 

b. For non-heatset web presses, the fountain solution shall contain no 

alcohol, shall contain no more than 5% VOC by weight. 

c. For sheet-fed presses, the fountain solution shall contain no more than 5% 

VOC by weight or the fountain solutions shall be maintained at 60°F and 

shall contain no more than 8.5% VOC by weight. 

9V AC5-40-8426 establishes the standard for visible emissions and 9V AC5-40-8428 

establishes the standard for fugitive dust/emissions. 9V AC5-40-8434 establishes 

compliance requirements for control devices installed on heatset web offset lithographic 

printing process dryers, VOC retention factors, and capture efficiencies for offset 

lithographic printing operations. 9V AC5-40-8436 establishes the compliance schedule 

and 9VAC5-40-8438 establishes test methods and procedures. 9VAC5-40-8440 

establishes monitoring requirements for the alcohol concentration of the fountain 

solution, the temperature of a refrigerated fountain solution, and the temperature for 

catalytic and thermal oxidation control devices. 9VAC5-40-8450 establishes notification, 

records, and reporting requirements. 9V ACS-40-8460 and 9V AC5-40-8480 state 

registration and permit requirements. 

III. EPA Evaluation for Offset Lithographic Printing and Letterpress Printing 

Virginia has adopted all of the standards and requirements of EPA's CTG for offset 

lithographic and letterpress printing. EPA's evaluation shows that Articles 56 and 56.1 

contain the required elements for a federally enforceable rule: Emission limitations, 

compliance procedures and test methods, compliance dates and record keeping provisions 

and are consistent with the guidance in EPA's CTG for this source category. The 

maximum benefit from these amendments will be provided during the ozone season when 

VOCs readily combine with NOx to form ground-l evel ozone. 

C. INDUSTRIAL CLEANING SOLVENTS 

I. Description of EPA's Industrial Cleaning Solvents CTG (EPA 453/R-06-001, 

September 2006) 
In 1994, EPA developed an ACT document for industrial cleaning solvents. After 

reviewing the ACT, conducting a review of currently existing state and local VOC 

emission reduction approaches, and taking into account any information that has become 

available since then, EPA developed a new CTG entitled Control Techniques Guidelines 

for Industrial Cleaning Solvents (Publication No. EPA 453/R-06-00 1; September 2006). 

This category of consumer and commercial products includes the industrial cleaning 

solvents used by many industries. It includes a variety of products that are used to 

remove contaminants such as adhesives, inks, paint, dirt, soil, oil, and grease. 

Contaminants are removed from parts, products, tools, machinery, equipment, vessels, 

floors, walls, and other work production related work areas for a variety of reasons 

including safety, operability, and to avoid product contamination. The cleaning solvents 

used in these (unit) operations are, in many cases, generally available bulk solvents that 

are used for a multitude of applications not limited to cleaning. For example, petroleum 

distillates may be used as a cleaning solvent, as a paint thinner, or as an ingredient used 

in the manufacture of a coating, such as paint. Because a portion of all solvents 

evaporate during use, such solvent-based cleaning materials result in large amounts of 

emissions ofVOC. 

EPA's Recommended Control Options for Industrial Cleaning Solvents 

Although the industrial cleaning solvent product category includes a variety of different 

products with differing VOC contents, and although these products are used in different 

ways by a wide range of industries, there are several basic approaches to achieve VOC 

emission reductions. First, the users of the products can control emissions through work 

practices targeted at the activities and sources of emissions specific to the user's industry 

(e.g., keeping solvent containers covered, properly storing and disposing of used shop 

towels and solvent, etc.). Second, users can also reduce overall VOC emissions through 

solvent substitution (e.g., use of low- VOC, no-VOC, or low -vapor pressure solvents). 

They can also reduce VOC emissions by using add-on controls, modifying equipment, or 

upgrading to using a lower emitting cleaning technology. 

The CTG recommends that these approaches apply to industries that have to use organic 

solvent for cleaning unit operations such as mixing vessels (tanks), spray booths, and 

parts cleaners, where a facility emits at least 6.8 kg/day (15 lb/day) ofVOC before 

consideration of controls in an ozone nonattainment area. Recommended work practices 

to reduce VOC emissions from use, handling, storage, and disposal of cleaning solvents 

and shop towels include: 

I. Covering open and containers and used applicators; 

2. Minimizing air circulation around cleaning operations; 

3. Properly disposing of used solvent and shop towels; and 

4. Implementing equipment practices that minimize emissions (e.g., keeping parts 

cleaners covered, maintaining cleaning equipment to repair solvent leaks, etc). 
The CTG recommends a VOC limit of 50 grams VOC per liter (0.42 lb/gal) of cleaning 

material unless emissions are controlled by an emission control system with an overall 

control efficiency of at least 85%. In addition, the CTG recommends a composite vapor 

pressure limit of 8 millimeters of mercury (mmHg) at 20°C. 

II. State Submittal for Industrial Cleaning Solvents 

9VAC5 Chapter 40, Article 57, Emission Standards for Industrial Solvent Cleaning 

Operations in the Northern Virginia Volatile Organic Compound Emissions Control 

Area, 8-hour Ozone Standard, establishes applicability, exemptions, definitions, emission 

standards, compliance, test methods, monitoring, and notifications, records and reporting 

for industrial solvent cleaning operations. The provisions apply to each facility that uses 

organic solvent for cleaning unit operations such as mixing vessels (tanks), spray booths, 

and parts cleaners, where a facility emits at least 6.8 kg/day (15 lb/day) of VOC before 

consideration of controls. Such operations include, but are not limited to, spray gun 

cleaning, spray booth cleaning, large manufactured components cleaning, parts cleaning, 

equipment cleaning, line cleaning, floor cleaning, tank cleaning, and small manufactured 

components cleaning. The provisions apply only to affected facilities in the Northern 

Virginia VOC Emissions Control Area designated in subdivision la of9VAC5-20-206. 

Exempted from the provisions of this article are solvent cleaning operations for (i) 

cleaning of electrical and electronic components; (ii) for cleaning of high precision 

optics and cleaning of cotton swabs to remove cottonseed oil before cleaning of high 

precision optics; (iii) for cleaning of numismatic dies; (iv) for cleaning of resin, coating, 

ink, and adhesive mixing, molding, and application equipment; (v) in research and 

development laboratories; (vi) in manufacturing medical devices or pharmaceutical 

products; (vii) related to performance or quality assurance testing of coatings, inks, or 

adhesives. 

9V AC5-40-8530, subsection A, limits VOC emissions from industrial cleaning solvent 

operations to both (I) VOC content limit of 50 grams/liter (0.42 lb/gal) of industrial 

cleaning solvent unless emissions are controlled by an emission control system with an 

overall control efficiency of at least 85% and (2) a composite vapor pressure limit of 8 

millimeters of mercury (mmHg) at 20°C. 

9V AC5-40-8530 subsection B, establishes the following work practices for the use, 

handling, storage and disposal of cleaning solvents and shop towels: 

I. Open containers and used applicators shall be covered. 

2. Air circulation around cleaning operations shall be minimized. 

3. Used solvent and shop towels shall be disposed of properly. 

4. Equipment practices that minimize emissions (including but not limited to 

keeping arts cleaners covered and maintaining cleaning equipment to repair 

solvent leaks) shall be implemented. 

9V AC5-40-8530, subsection C, establishes VOC limits and work practices for 

manufacturers of coatings, inks, resins, and adhesives. Cleaning solvents for these 
industries shall contain less than 1.67 pounds per gallon of VOC or have a composite 

vapor pressure no more than eight mmHg at 20°C. 

9V ACS-40-8530, subsection D, limits VOC content for use in screen printing to less than 

4.2 pounds per gallon ofYOC or have a composite vapor pressure no more than eight 

mmHg at 20°C. 

9V AC5-40-8540 establishes the standard for visible emissions and 9V ACS-40-8550 

establishes the standard for fugitive dust/emissions. 9VAC5-40-8580 and 9VAC5-40-

8590 establish compliance requirements and a compliance schedule, respectively, for 

industrial cleaning solvent practices. 9VAC5-40-8600 establishes test methods and 

procedures, 9VAC5-40-861 0 establishes monitoring requirements and 9V ACS-40-8620 

establishes notification, records, and reporting requirements. 9V ACS-40-8630 and 

9VAC5-40-8650 state registration and permit requirements. 

HI. EPA Analysis for Industrial Cleaning Solvents 

Virginia has adopted the standards and requirements of EPA's CTGs for industrial 

solvent cleaning operations. An exception for manufacturers of coatings, inks, resins, 

and adhesives pertaining to the VOC limit of cleaning solvent and work practices for 

these industries is consistent with industry practices and standards adopted in other states 

such as South Coast, California. The VOC limit for cleaning solvents for screen printing 

processes has been adopted by other states in the OTR such as Connecticut regulation 

22a-1 74-20(ii). EPA believes the alternatives Virginia has adopted for manufacturers of 

coatings, inks, resins, and adhesives and screen printing processes are acceptable and still 

representative of RACT for these industries. EPA's evaluation shows that Article 57 

contains the required elements for a federally enforceable rule: Emission limitations, 

compliance procedures and test methods, compliance dates and record keeping provisions 

and is consistent with the guidance in EPA's CTG for this source category. The 

maximum benefit from these amendments will be provided during the ozone season when 

VOCs readily combine with NOx to form ground-level ozone. 

D. MISCELLANEOUS INDUSTRIAL ADHESIVES 

I. Description of EPA's Miscellaneous Industrial Adhesives CTG (EPA 453/R-08-

005, September 2008) 

There are no previous EPA action that affect miscellaneous industrial adhesive 

application operations. After reviewing the 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 a new CTG entitled Control Techniques 

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

September 2008). 
The miscellaneous industrial adhesives product category includes adhesives (including 

adhesive primers used in conj unction with certain types of adhesives) used at industrial 

manufacturing and repair facilities for a wide vari ety of products and equipment that 

operate adhesives application processes. The miscellaneous industrial adhesives product 

category does not include adhesives that are addressed by CTGs a lready 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, fi lm, and foi l 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. In terms of 

applicability, the provisions should apply to each miscellaneous industrial adhesive 

application process at a facility where the total actual VOC emissions from miscellaneous 

industrial adhesive application processes, including related cleaning activities, at that 

faci lity are equal to or exceed 6.8 kg/day (15 lb/day). 

Recommended VOC emission limits are listed below in Table I. Two options are 

recommended for achieving the VOC emission limits: (1) through the use of low-VOC 

content adhesives and specified application methods with good adhesive transfer 

efficiency; or (2) through the use of a combination of low-VOC adhesives, specified 

application methods, and add-on controls. As an alternative to the emission limits, an 

overall control efficiency of 85% is recommended. 

Table 1. Recommended VOC Emission Limits for General and Specialty Adhesive 

A .pp r acatlon P rocesses 

General Adhesive VOC Emission Limit 

Application Processes Grams per liter (g/1) Pounds per gallon (lbs/gal) 

Reinforced Plastic 200 1.7 

Composite 

Flexible Vinyl 250 2. 1 

Metal 30 0.3 

Porous Material (Except 120 1.0 
Wood) 

Rubber 250 2.1 

Wood 30 0.3 

Other Substrates 250 2.1 

Specialty Adhesive VOC Emission Limit 

Application Processes Grams per liter (g/1) Pounds per gallon (lbs/gal) 

Ceramic Tile Installation 130 1.1 

Contact Adhesive 250 2.1 

Cove Base Installation 150 1.3 

Floor Covering Installation 150 1.3 

(Indoor) 

Floor Covering Installation 250 2.1 

(Outdoor) 

Floor Covering Installation 660 5.5 

(Perimeter Bonded Sheet 

Vinyl) 

Metal to Urethane/Rubber 850 7.1 

Molding or Casting 

Motor Vehicle Adhesive 250 2.1 

Motor Vehicle Weather-strip 750 6.3 

Adhesive 

Multipurpose Construction 200 1.7 

Plastic Solvent Welding 400 3.3 

(ABS) 

Plastic Solvent Welding 500 4.2 

(Except ABS) 

Sheet Rubber Lini ng 850 7.1 

Installation 

Single-Ply Roof Membrane 250 2.1 

Installation/Repair (Except 

EPDM) 

Structural Glazing 100 0.8 

Thin Metal Laminating 780 6.5 

Tire Repair 100 0.8 

Waterproof Resorcinol Glue 170 1.4 

Adhesive Primer VOC Emission Limit 

Application Processes Grams per liter (g/1) Pounds per gallon (lbs/gal) 

Motor Vehicle Glass 900 7.5 

Bonding Primer 

Plastic Solvent Welding 650 5.4 

Adhesive Primer 

Single-Ply RoofMembrane 250 2.1 

Adhesive Primer 

Other Adhesive Primer 250 2.1 
In addition to the VOC emission limits, EPA recommends that one of the following 

application methods be used in conjunction with using low-VOC adhesives or adhesive 

primers: 

1. Electrostatic spray. 

2. High-volume, low-pressure (HVLP) spray. 

3. Flow coat. 

4. Roll coat or hand application, including non-spray application methods similar to 

hand or mechanically powered caulking gun, brush, or direct hand application. 

5. Dip coat (including electrodeposition). 

6. Airless spray. 

7. Air-assisted airless spray. 

8. Other adhesive application method capable of achieving a transfer efficiency 

equivalent to or better than that achieved by HVLP spraying. 

Recommended work practices for adhesive related activities are: 

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

materials in closed containers. 

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

adhesive primers, and process-related waste materials are kept closed at all times 

except when depositing or removing these materials. 

3. Minimize spills ofVOC-containing adhesives, adhesive primers, and processrelated waste materials. 

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

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

Recommended work practices for cleaning materials are: 

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 ofVOC-containing cleaning materials. 

4. Convey VOC-containing 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 perfonned without 

atomizing the cleaning solvent and all spent solvent is captured in closed 

containers. 

II. State Submittal for Miscellaneous Industrial Adhesives 

9V AC5 Chapter 40, Article 58, Emission Standards for Miscellaneous Industrial 

Adhesive Application Processes in the Northern Virginia Volatile Organic Compound 

Emissions Control Area, 8-hour Ozone Standard, establishes applicability, exemptions, 

definitions, emission standards, compliance, test methods, monitoring, and notifications, 

records and reporting requirements for industrial adhesive operations. The provisions 

apply to each miscellaneous industrial adhesive application process at a facility where the 
total actual VOC emissions from miscellaneous industrial adhesive application processes, 

including related cleaning activities and related application of adhesive primers, are, 

before consideration of controls, either (1) equal to or exceed 6.8 kg/day or (15 lb/day) or 

(2) 3 tons per 12-month rolling average. The provisions apply only to affected facilities 

in the Northern Virginia VOC Emissions Control Area designated in subdivision la of 

9V ACS-20-206. 

9V ACS-40-8680 establishes VOC emissions limits for industrial adhesive application 

processes listed above in Table 1 (see EPA's Recommended Control Options for 

Industrial Adhesives). ln section 9V ACS-40-8680, subsection A this table is Table 4-

58A. Facilities opting to meet a control efficiency in lieu of meeting the VOC emission 

limits in Table 4-58A, shall meet an overall control efficiency of 85%. 

9V ACS-40-8680, subsection B, establishes application methods as well as work practices 

for application of adhesives, adhesive primers, and process related waste materials and 

work practices for cleaning activities. Facilities using low-VOC adhesives and adhesive 

primers shall use one of the following application methods: 

I. Electrostatic spray. 

2. HVLP spray. 

3. Flow coat. 

4. Roll coat or hand application, including non-spray application methods similar to 

hand or mechanically powered caulking gun, brush, or direct hand application. 

5. Dip coat (including electrodeposition). 

6. Airless spray. 

7. Air-assisted airless spray. 

8. Other adhesive application method capable of achieving a transfer efficiency 

equivalent to or better than that achieved by HVLP spraying. 

Work practices for the application for adhesives, adhesive primers, and process related 

waste materials are the same as the recommended practices described in EPA's 

Recommended Control Options for Industrial Adhesives, above. Work practices for 

cleaning acti vities are also the same as the recommended practices described in EPA's 

Recommended Control Options for Industrial Adhesives, above. 

9V ACS-40-8690 establishes the standard for visible emissions and 9V ACS-40-8700 

establishes the standard for fugitive dust/emissions. 9V ACS-40-8730 and 9V ACS-40-

8740 establish compliance requirements and a compliance schedule for industrial 

adhesive application processes. 9VAC5-40-8750 establishes test methods and 

procedures, 9V ACS-40-8760 establishes monitoring requirements, and 9V ACS-40-8770 

establishes notification, records, and reporting requirements. 9V ACS-40-8780 and 

9V ACS-40-8800 state registration and permit requirements. 

III. EPA Analysis for Miscellaneous Industrial Adhesives 

Virginia has adopted the standards and requirements of EPA's CTGs for miscellaneous 

industrial adhesives. EPA's evaluation shows that Article 58 contains the required 
elements for a federally enforceable rule: Emission limitations, compliance procedures 

and test methods, compliance dates and record keeping provisions and is consistent with 

the guidance in EPA's CTG for this source category. The maximum benefit from these 

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

NOx to form ground-level ozone. 

E. MISCELLANEOUS METAL AND PLASTIC PARTS COATINGS 

I. Description of EPA's Miscellaneous Metal and Plastic Parts Coatings CTG (EPA 

453/R-08-003, September 2008) 

In June 1978, EPA issued a CTG document for controlling VOC emissions from the 

coating of miscellaneous metal parts and products. In January 1988, EPA promulgated 

the new source performance standard (NSPS) for the Surface Coating of Plastic Parts for 

Business Machines. In February 1994, EPA issued an Alternative Control Techniques 

{ACT) document for controlling VOC emissions from the coating of 

automoti ve/transportation and business machine plastic parts. In January 2004, EPA 

promulgated the National Emission Standards for Hazardous Air Pollutants (NESHAP) 

for Miscellaneous Metal Parts and Products Surface Coating. In April 2004, EPA 

promulgated the NESHAP for Plastic Parts and Products Surface Coating. After 

reviewing the 1978 CTG, the 1988 NSPS, the 1994 ACT, and existing state and local 

VOC emission reduction approaches, EPA developed a new CTG combining the 

requirements for miscellaneous metal and plastic parts coatings into a single CTG, 

entitled Control Techniques Guidelines for Miscellaneous Metal and Plastic Parts 

Coatings (Publication No. EPA 453/R-08-003, September 2008). 

Miscellaneous metal products parts coatings include, but are not limited to, the coatings 

that are applied to the surfaces of a varied range of metal parts. These parts or products 

are constructed either entirely or partially from metal. They include, but are not limited 

to, metal components of the following types of products as well as the products 

themselves: Fabricated metal products, 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 vehicles2, lawn and 

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

equipment, steel drums, metal pipes, and numerous other industrial and household 

products (hereinafter collectively referred to as "miscellaneous metal parts"). The CTG 

applies to manufacturers of miscellaneous metal parts that surface-coat the parts they 

produce. Miscellaneous metal parts coatings do not include coatings that are a part of 

other product categories listed under section l83(e) of the CAA for which CTGs have 

been published and/or coatings addressed by other CTGs. These other categories that are 

2 Heavier vehicles includes a ll vehicles that meet the definition of the term "other motor vehicles," as 

defined in the National Emission Standards for Surface Coating of Automobile and Light-Duty Trucks at 

40 CFR 63.3176. 
not part of the miscellaneous metal products coatings categories include shipbuilding and 

repair coatings; aerospace coatings; wood furniture coatings; metal furniture coatings; 

large appliance coatings; automobile and light-duty truck assembly coatings; flatwood 

paneling coatings; miscellaneous industrial adhesives; fiberglass boat manufacturing 

materials; and paper, film, and foil coatings. Can coatings, coil coatings, and magnet 

wire coatings were not listed under section 183 (e) of the Act, but were addressed by 

earlier CTGs, and are also not included in the miscellaneous metal and plastic parts 

coatings categories addressed by this CTG. 

EPA's Recommended Control Options for Miscellaneous Metal and Plastic Parts 

Coatings 

The September 2008 CTG for Miscellaneous Metal and Plastic Parts Coatings provides 

recommendations for reducing VOC emissions from the use of coatings in a 

miscellaneous metal products coating unit at a facility where the total actual VOC 

emissions from all miscellaneous metal parts coating operations, including related 

cleaning activities, at that facility, are equal to or exceed 6.8 kg/day, 15 lb/day, or an 

equivalent level of 2. 7 tons per 12-month rolling period, before consideration of controls. 

A coating unit consists of a series of one or more coating applicators and any associated 

drying area and/or oven where a coating is applied, dried, and/or cured. A coating unit 

ends at the point where the coating is dried or cured, or prior to any subsequent 

application of a different coating. Primarily, VOC emissions from miscellaneous metal 

products parts coating operations result from: (1) evaporation of the VOC components of 

the coatings; and (2) evaporation of YOC from the cleaning materials. The majority of 

VOC emissions from these materials occur during coating application/flash-off and 

drying/curing of the coatings. 

To control VOC emissions from miscellaneous metal parts coatings, the CTG 

recommends three options: (1) VOC content limits for each coating category based on 

the use of low-VOC content coatings and specified application methods to achieve good 

transfer efficiency; (2) equivalent YOC emission rate limits based on the use of a 

combination of low-VOC coatings, specified application methods, and add-on controls; 

or (3) an overall VOC control efficiency of90 percent for facilities that choose to add-on 

controls instead of low-YOC content coatings and specified application methods. 

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

Limits Based on Low-VOC Coatings 

Under Option 1, separate sets of emission limits for metal parts coatings, plastic parts 

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

coatings are recommended. For metal parts coatings, EPA recommended separate 

emission limits for baked and air-dried coatings. Provided in Tables 2 - 6, are the 

recommended emission limits expressed in terms of mass of VOC per volume of coating 

(excluding water and exempt compounds, as applied). 
Table 2. Metal Parts and Products VOC Content Limits 

Air Dried Baked 

Coating Category kgVOC/1 lb VOC/gal kg VOC/1 lb VOC/gal 

coating coating coating coating 

General 

One Component 0.34 2.8 0.28 2.3 

General 0.34 2.8 0.28 2.3 

Multi-Component 

Camouflage 0.42 3.5 0.42 3.5 

Electric-Insulating 0.42 3.5 0.42 3.5 

Varnish 

Etching Filler 0.42 3.5 0.42 3.5 

Extreme High-Gloss 0.42 3.5 0.36 3.0 

Extreme Perfonnance 0.42 3.5 0.36 3.0 

Heat Resistant 0.42 3.5 0.36 3.0 

High Performance 0.74 6.2 0.74 6.2 

Architectural 

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 0.42 3.5 0.28 2.3 

Architectural 

Multi-Component 

Prefabricated 0.42 3.5 0.28 2.3 

Architectural · 

One-Component 

Pretreatment 0.42 3.5 0.42 3.5 

Coatings 

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 

Table 3. Plastic Parts and Products VOC Content Limits 

Coating Category kg VOC/1 Coating lb VOC/ gal Coating 

General One Component 0.28 2.3 

General Multi-Component 0.42 3.5 

Electric Dissipating and 0.80 6.7 

Shock-Free 

Extreme Performance (2- 0.42 3.5 

pack coatings) 

Metallic 0.42 3.5 

Military Specification ( 1- 0.34 2.8 
pack coatings) 

Military Specification (2- 0.42 3.5 

pack coatings) 

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 4. Automotiveffra nsportation and Business Ma chine 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- 0.60 5.0 

Interior Parts 

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. 

T a e bl 5 . PI easure C ra ft S ur f ace C oa f mg VOC C on t en t L. IIDI •t S 

Coating Category kg VOC/1 Coating lb VOC/ ga l 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 0.56 4.7 

Antifoulant 
Other Substrate Antifoulant 0.33 2.8 

All Other Pleasure Craft 0.42 3.5 

Surface Coatings for Metal 

or Plastic 

Table 6. Motor Vehicle Materials VOC Content Limits 

Coating Category kg VOC/1 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 0.20 1.7 

Gasket/Gasket Sealing 

Materials 

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 0.70 5.8 

Wax/Compound 

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 addon control equipment on a coating unit. Using an assumed VOC density of 7.36 pounds 

per gallon, the equivalent limits in terms of mass ofVOC per volume of solids, as 

applied, are provided in Tables 7- I 0. 

Table 7. Metal Parts and Products VOC Content Limits 

Coating Air Dried Baked 

Category kg VOC/1 lb VOC/ gal kg VOC/1 lb VOC/ gal 

Coating Coating Coating Coating 

General One 0.54 4.52 0.40 3.35 

Component 

General Multi- 0.54 4.52 0.40 3.35 

Component 

Camouflage 0.80 6.67 0.80 6.67 

Electric- 0.80 6.67 0.80 6.67 

Insulating 

Varnish 

Etching Filler 0.80 6.67 0.80 6.67 

Extreme High- 0.80 6.67 0.61 5.06 

Gloss 

Extreme 0.80 6.67 0.6 1 5.06 

Performance 
Heat-Resistant 0.80 6.67 0.61 5.06 

High 4.56 38.0 4.56 38.0 

Performance 

Architectural 

High 0.80 6.67 0.80 6.67 

Temperature 

Metallic 0.80 6.67 0.80 6.67 

Military 0.54 4.52 0.70 3.35 

Specification 

Mold-Seal 0.80 6.67 0.80 6.67 

Pan Backing 0.80 6.67 0.80 6.67 

Prefabricated 0.80 6.67 0.40 3.35 

Architectural 

MultiComponent 

Prefabricated 0.80 6.67 0.40 3.35 

Architectural 

One Component 

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- 0.80 6.67 0.80 6.67 

Metalizing 

Drum Coating, 0.54 4.52 0.54 4.52 

New, Exterior 

Drum Coating, 0.80 6.67 0.80 6.67 

New, Interior 

Drum Coating, 0.80 6.67 0.80 6.67 

Reconditioned, 

Exterior 

Drum Coating, 1.17 9.78 1.1 7 9.78 

Reconditioned, 

Interior 

Table 8 . Plastic Parts and Products VOC Content Limits 

Coating Category kg VOC/1 Coating lb VOC/ gal Coating 

General One Component 0.40 3.35 

General Multi-Component 0.80 6.67 

Electric Dissipating and 8.96 74.7 

Shock-Free 

Extreme Performance (2- 0.80 6.67 

pack coatings) 

Metallic 0.80 6.67 

Military Specification ( 1- 0.54 4.52 

pack coatings) 
Military Specification (2- 0.80 6.67 

pack coatings) 

Mold-Seal 5.24 43.7 

Multi-colored Coatings 3.04 25.3 

Optical Coatings 8.96 74.7 

Vacuum-Metal izi ng 8.96 74.7 

Table 9. Automotiveffransportation and Business Machine Plastic Parts VOC 

Content Limits 

Coating Category kg VOC/1 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 

Non-Basecoat/Clearcoat 1.24 10.34 

II. 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 

III. Low Bake/ Air Dried - 1.87 15.59 

Interior Parts 

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 coatmgs, except touch-up and repair coatmgs, 

the limit is determined by multiplying the appropriate limit in this section of the table by 

1.1 5. 

T a e bl 10 . PI easure c rat f s ur f ace c oatmg voce on tent L .. a mats 

Coating Category kg VOC/1 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 1.53 12.8 

Antifoulant 

Other Substrate Antifoulant 0.53 4.4 
All Other Pleasure Craft 0.80 6.7 

Surface Coatings for Metal 

or Plastic 

In addition, it is recommended that one or more of the following coating application 

methods be used in conjunction with the use oflow-VOC content coatings in Options I 

and 2: Electrostatic application, HVLP spray, flow coat, roller coat, dip coat (including 

electrodeposition), airless spray, air-assisted airless spray, or other coating application 

methods capable of achieving a transfer efficiency equivalent to or better than that 

achieved by HVLP spraying. 

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 of90% 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%. 

Additionally, work practices to further reduce VOC emissions from coatings as well as to 

minimize emissions from cleaning materials used in coating processes are recommended. 

For coating related activities, the CTG recommends the following work practices: 

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. 

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

from one location to another in closed containers or pipes. 

The CTG recommends 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. 

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. 

II. State Submittal for Miscellaneous Metal Parts and Products Coating 

Application Systems 

9V AC5 Chapter 40, Article 59, Emission Standards for Miscell aneous Metal Parts and 

Products Coating Application Systems in the Northern Virginia Volatile Organic 

Compound Emissions Control Area, 8-hour Ozone Standard, establishes applicability and 

exemptions, definitions, emission standards, compliance, test methods, monitoring, and 

notifications, records and reporting for miscellaneous metal parts and products coating 

operations. The provisions apply to each miscellaneous metal parts and products 

application process at a facility where the total actual VOC emissions from miscellaneous 

metal products and plastic parts surface coating operations, including related cleaning 

activities, at the faci lity are, equal to or exceed 6.8 kg/day or ( 15 lb/day) or an equivalent 

level of2.7 tons per 12-month rolling average, before consideration of controls. The 

provisions apply only to affected facilities in the Northern Virginia VOC Emissions 

Control Area designated in subdivision I a of 9V ACS-20-206. 

9V ACS-40-8820 establishes definitions which pertain to metal and plastic parts coatings. 

The definition for high performance architectural coating refers to any coating used to 

protect architectural subsections and that meets the requirements of the American 

Architectural Manufacturers Association's (AAMA) Voluntary Specification, 

Performance Requirements and Test Procedures for High Performance Organic Coatings 

on Aluminum Extrusions and Panels, publication number AAMA 2604-05, or Voluntary 

Specification, Performance Requirements and Test Procedures for Superior Performing 

Organic Coatings on Aluminum Extrusions and Panels, publication number AAMA 

2605-05. Virginia is amending 9V ACS-20-2 1, Documents incorporated by reference, in 

order to add these two documents. 

9V ACS-40-8830 establishes VOC content limits and emission limits for coating 

operations stated in EPA's recommended limits described above in EPA's Recommended 

Control Options for Miscellaneous Metal and Plastic Parts Coatings. The VOC content 

limits are the same as those listed in Tables 2 - 6 above for Option I, VOC Content 

Limits Based on low-VOC Coatings. In section 9V ACS-40-8830, subsection A, these 

tables are Table 4-59A through 4-59E. 

In addition, subsection B of9VAC5-40-8830 establishes VOC emission rate limits for 

low-VOC coatings and add-on controls on a VOC per volume solids basis. These 

emission limits are listed in Tables 7 - 10 above in Option 2, VOC Emission Limits 

Based on low-VOC Coatings and Add-on Controls. In section 9V ACS-40-8830, 

subsection B, these tables are Table 4-59F through 4-591. 
Should product performance requirements dictate the use of higher-VOC materials than 

those specified in subsections A and B, 9V AC5-40-8830, subsection C, allows an 

affected facility to use add-on control equipment with an overall control efficiency of 

90% in lieu of using low-VOC coatings. 

In 9V ACS-40-8830, subsection D, work practices for storage, mixing operations, and 

handling operations for coatings, thinners, and coating-related waste materials are 

established and are the same as the recommended practices described above in EPA's 

Recommended Control Options for Miscellaneous Metal and Plastic Parts Coatings. In 

9V AC5-40-8830, subsection E, work practices for cleaning materials used to clean 

surfaces before coating and to clean application equipment between coating jobs are 

established and are the same as the recommended practices described above in EPA's 

Recommended Control Options for Miscellaneous Metal and Plastic Parts Coatings. 

Lastly, 9V AC5-40-8830, subsection F, states that the following application techniques 

sha ll be used to apply any finish material listed in Tables 4-59A through 4-591: 

1. Flow/curtain coating 

2. Dip coating 

3. Roller coating 

4. Brush coating 

5. Electrodeposition coating 

6. HVLP spraying 

7. Electrostatic spray 

8. Airless spray 

9. Air-assisted airless spray or 

I 0. Other coating application methods that achieve emission reductions equivalent to 

or greater than those achieved by HVLP or electrostatic spray application 

methods. 

9V AC5-40-8840 establishes the standard for visible emissions and 9V AC5-40-8850 

establishes the standard for fugitive dust/emissions. 9V AC5-40-8880 and 9V AC5-40-

8890 establish compliance requirements and a compliance schedule for miscellaneous 

metal parts and products coating operations. 9V AC5-40-8900 establishes test methods 

and procedures, 9V AC5-40-891 0 establishes monitoring requirements, and 9V AC5-40-

8920 establishes notification, records, and reporting requirements. 9V AC5-40-8930 and 

9V AC5-40-8950 state registration and permit requirements. 

HI. EPA Analysis for Miscellaneous Metal Parts and Products Coating 

Virginia has adopted the standards and requirements of EPA's CTG for miscellaneous 

metal and plastic parts coatings. EPA's evaluation shows that Article 59 contains the 

required elements for a federally enforceable rule: Emission limitations, compliance 

procedures and test methods, compliance dates and record keeping provisions and is 

consistent with the guidance in EPA's CTG for this source category. EPA has reviewed 

AAMA publications 2604-05 and 2605-05 and finds that the definition of high 

performance architectural coating is reasonable and appropriate. The maximum benefit 
from these amendments will be provided during the ozone season when VOCs readily 

combine with NOx to form ground-level ozone. 

F. ADDITIONAL REVISIONS 

9V AC5 Chapter 40, Article 53, Emission Standards for Lithographic Printing Processes, 

section 9V AC5-40-7800, is amended to exempt offset lithographic printing processes in 

the Northern Virginia VOC Emissions Control Area from its provisions and refers 

applicable facilities to the provisions in Article 56. 1, Emission Standards for Offset 

Lithographic Printing Operations in the Northern Virginia Volatile Organic Compound 

Emissions Control Area, 8-hour Ozone Standard. Article 56.1 adopts EPA's 

recommended control levels in the CTG which are more stringent than the provisions in 

Article 53 and are specific to offset lithographic printing operations. 

9V AC5 Chapter 40, Article 34, Emission Standards for Miscellaneous Metal Parts and 

Products Coating Application Systems, section 9VAC5-40-4760 is amended to exempt 

VOC sources in the Northern Virginia Volatile Organic Compound Emissions Control 

Area from its provisions. On and after February l , 2017, these sources are subject to 

Article 59, Emission Standards for Miscellaneous Metal Parts and Products Coating 

Application Systems in the Northern Virginia Volatile Organic Compound Emissions 

Control Area, 8-hour Ozone Standard. Article 59 is specific to facilities in the OTR and 

adopts EPA's recommended control levels in the CTG which are more stringent than the 

provisions in Article 34. 

G. EPA EVALUATION AND RECOMMENED AGENCY ACTION 

Virginia has adopted the standards and requirements of EPA's CTGs for offset 

lithographic printing and letterpress printing; industrial solvent cleaning operations; 

miscellaneous industri al adhesives; and miscellaneous metal and plastic parts coatings 

and is amending the Virginia SIP to reflect these amendments. These revisions will 

address the RACT requirements for Virginia for offset lithographic printing and 

letterpress printing; industrial solvent cleaning operations; miscellaneous industrial 

adhesives; and miscellaneous metal and plastic parts coatings. The adoption of these 

CTG requirements meet the requirements of section 184 of the CAA and will result in the 

reduction ofVOC emissions from these sources within the OTR. The reduction ofVOC 

emissions will reduce the formation of ozone, and thereby protect public health and 

welfare. EPA's approval ofthe SIP revisions is recommended.