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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

1650 Arch Street

Philadelphia, Pennsylvania 19103

DATE: June 4, 2012

SUBJECT: Technical Support Document for Delaware’s Adoption of Control Technique 

Guidelines (CTG) for Plastic Parts, Metal Furniture, Large Appliances, and 

Miscellaneous Metal Parts.

FROM: Gregory Becoat /s/

Office of Air Program Planning

TO: File

THRU: Donna Mastro, Acting Associate Director /s/

Office of Air Program Planning

A. BACKGROUND 

Section 172(c)(1) of the Clean Air Act (CAA) provides that State Implementation Plans (SIP) for 

nonattainment areas must include reasonably available control measures (RACM), including 

reasonably available control technology (RACT), for sources of emissions. Section 182(b)(2)(A) 

provides that for certain nonattainment areas, states must revise their SIP to include RACT for 

sources of volatile organic compound (VOC) emissions covered by a control technique guideline 

(CTG) document issued after November 15, 1990 and prior to the Area’s date of attainment. The 

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 documents issued by EPA intended to provide state and local air pollution control 

authorities information that should assist them in determining RACT for VOC from various 

sources. EPA may issue a CTG in lieu of a national regulation as RACT for a product category 

where EPA determines that the CTG will be substantially as effective as regulations in reducing 

emissions of VOC in ozone nonattainment areas. The recommendations in the CTG are based 

upon available data and information and may not apply to a particular situation based upon the 

circumstances. States can follow the CTG and adopt state regulations to implement the 

recommendations contained therein, or they can adopt alternative approaches. In either case, 

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 

approval process, whether the submitted rules meet the RACT requirements of the CAA and 
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EPA’s regulations. 

Surface Coating of Miscellaneous Metal and Plastic Parts CTG (EPA 453/R-08-003, 

September 2008)

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

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

source performance standards (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 surface coating of automotive/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 Technique Guidelines for Miscellaneous Metal and Plastic Parts Coatings” (EPA 

453/R-08-003, September 2008).

Miscellaneous metal products and plastic parts surface coatings include, but are not limited to, 

the coatings that are applied to the surfaces of a varied range of metal and plastic parts and 

products. These parts or products are constructed either entirely or partially from metal or 

plastic. They include, but are not limited to, metal and plastic components of the following types 

of products as well as the products themselves: fabricated metal products, molded plastic parts, 

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 vehicles1, 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 and plastic 

parts”). The CTG applies to manufacturers of miscellaneous metal and plastic parts that surfacecoat the parts they produce. Miscellaneous metal products and plastic parts coatings do not 

include coatings that are a part of other product categories listed under section 183(e) of the 

CAA for which CTGs have been published and/or coatings addressed by other CTGs. These 

other categories that are not part of the miscellaneous metal products and plastic parts 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 products and plastic parts 

 

1Heavier vehicles includes all 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.
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coatings categories addressed by this CTG.

Applicability

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 and miscellaneous plastic parts surface coating unit at a facility where the total actual 

VOC emissions from all miscellaneous metal product and plastic parts surface coating 

operations, including related cleaning activities, at that facility, are equal to or exceed 6.8 

kilograms a day (kg/day), 15 pounds a day (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. As mentioned previously, states can 

adopt the above recommended 6.8 kg/day (15 lb/day) actual VOC emissions, or an equivalent 

applicability threshold, or they can develop other applicability criteria that they determine are 

appropriate considering the facts and circumstances of the sources in their particular 

nonattainment areas. EPA will review the state RACT rules in the context of the SIP revision 

process. For facilities that coat bodies and/or body parts for new heavier vehicles, EPA 

recommends that these facilities have the option of meeting either the state RACT requirements 

for miscellaneous metals and plastic parts coatings or the state RACT requirements for auto and 

light-duty truck coatings.

Sources of VOC Emissions

Primarily, VOC emissions from miscellaneous metal products and plastic parts surface coating 

operations result from the evaporation of volatile components from the coatings and cleaning 

materials. The majority of VOC emissions from these materials occur during coating 

application/flash-off and drying/curing of the coatings. The remaining emissions are primarily 

from mixing and/or thinning. In most cases, VOC emissions from surface preparation, storage, 

handling, and waste/wastewater operations are relatively small.

Coating Application 

Surface coating of miscellaneous metal products and plastic parts surfaces is applied by applying 

a coating to the metal or plastic part followed by curing or drying the coating. The coating itself 

may be in the form of a liquid or powder. Several different types of application technologies are 

used to apply liquid coatings, and the selection of the application technology can have a 

significant effect on the amount of coating used and the resulting VOC emissions from the 

operation. The most common types of liquid coating applicators include: air atomized spray 

coating, electrostatic spray coating, high volume/low pressure (HVLP) spray coating, dip 

coating, flow coating, roll coating, electrocoating, and autophoretic coating. Powder coatings 

can be applied through electrostatic spraying or dipping. An alternative to the coating techniques 

outlined in EPA’s CTG for this source category would need to be approved by the State and 

EPA.
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CTG Recommended Control Options

As stated previously, there are two main sources of VOC emissions from miscellaneous metal 

and plastic parts coating operations: (1) evaporation of the VOC components of the coatings; 

and (2) evaporation of VOC from the cleaning materials. To control VOC emissions from 

miscellaneous metal and plastic parts surface coatings, the CTG recommends these 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 VOC 

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 of 90 percent 

for facilities that choose to add-on controls instead of low-VOC content coatings and specified 

application methods. The low-VOC coatings recommendation (Option 1) consists of VOC 

content limits in terms of mass of VOC per volume of coating, as applied, excluding water and 

exempt compounds, and the use of specified application methods. The equivalent emission rate 

limit recommendation (Option 2) consists of emission rate limits in terms of mass of VOC 

emitted per volume of coating solids, as applied, and the use of specific application methods. 

This option is intended only for facilities using a combination of low-VOC coatings, specific 

application methods, and add-on control equipment on a coating unit to meet the recommended 

limits for mass of VOC emitted per volume of coating solids. 

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

used in conjunction with the use of low-VOC content coatings in Options 1 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. Under an addon control option, (Option 3), a facility would use an emission capture system and add-on control 

device to achieve an overall emission capture and control efficiency of at least 90 percent. The 

facility would not have to limit the VOC content of the coating materials and would not need to 

use any particular coating application method. 

The first two options are expected to achieve equivalent VOC emission reductions. The third 

option provides facilities the flexibility to use a high efficiency add-on control in lieu of lowVOC coatings and specified application methods, especially when the use of high VOC coatings 

is necessary or desirable. The third option is expected to achieve an emission reduction at least 

as great as the first two options.

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

minimize emissions from cleaning materials used in the surface coating process are 

recommended.

Consistent with the State rules which are the basis for the recommended VOC limits, the CTG 

recommends VOC limits and application methods not apply to certain types of coatings and 

coating operations. For all coating operations, it is recommended that the VOC limits and 

application methods not apply to aerosol coatings products or powder coatings. Aerosol coatings 

are a separate category under Section 183(e) of the CAA, and powder coatings are an inherently 

low-VOC alternative to many liquid coatings.
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The CTG recommends that for all metal parts coatings, only the recommended work practices, 

but not the recommended VOC limits and application methods, apply to the following types of 

coatings and coating operations: stencil coatings, safety indicating coatings, solid-film 

lubricants, electric-insulating and thermal-conducting coatings, magnetic data storage disk 

coatings, and plastic extruded onto metal parts to form a coating. In addition, for all metal parts 

coatings, it is recommended that the recommended application methods not apply to touch-up 

coatings, repair coatings, and textured finishes, but that the recommended VOC limits and work 

practices apply.

For plastic parts coatings, the CTG recommends the application methods and work practices, but 

not the recommended VOC limits, apply to the following types of coatings and coating 

operations: touch-up and repair coatings, stencil coatings applied on clear or transparent 

substrates, clear or translucent coatings, coatings applied at a paint manufacturing facility while 

conducting performance tests on the coatings, any individual coating category used in volumes 

of 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, reflective coatings applied to highway cones, mask coatings that are less than 0.5 

millimeter thick (dried) and the area coated is less than 25 square inches, EMI/RFI shielding 

coatings, and 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. 

Additionally, for plastic parts coatings, the CTG recommends that the application methods not 

apply to airbrush operations using 5 gallons or less per year of coating. However, the 

recommended VOC limits and work practices apply to these operations.

For automotive/transportation and business machine plastic parts coatings, the CTG recommends

that the application methods and work practices, but not the VOC limits, apply to the following 

types of coatings and operations: texture coatings, vacuum metalizing coatings, gloss reducers, 

texture topcoats, adhesion primers, electrostatic preparation coatings, resist coatings, and stencil 

coatings.

For pleasure craft surface coating operations, the CTG recommends that the application methods 

not apply to extreme high gloss coatings, but that the recommended VOC limits and work 

practices apply.

For cleaning materials, the CTG recommends that work practices be used with all three of the 

control options to reduce VOC emissions. The application of add-on controls in conjunction 

with these work practices is not recommended. In addition, the use of a VOC content or VOC 

composite vapor pressure limit for cleaning materials is not recommended.

Under Option 1 described above, 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. Separate emission limits for baked and air-dried coatings is 

recommended. Provided in the following five tables are the recommended emission limits 

expressed in terms of mass of VOC per volume of coating (excluding water and exempt 
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compounds, as applied).

Recommended Option 1 for Reducing Coating Emissions: VOC Content Limits Based on 

Low-VOC Coatings

Table 1. Metal Parts and Products VOC Content Limits

Air Dried Baked

Coating Category kg/VOC/l 

coating

lb VOC/gal 

coating

kg VOC/l 

coating

lb VOC/gal 

coating

General One 

Component 0.34 2.8 0.28 2.3

General MultiComponent0.34 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 MultiComponent

0.42 3.5 0.28 2.3

Prefabricated 

Architectural OneComponent

0.42 3.5 0.28 2.3

Pretreatment 

Coatings

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, 0.42 3.5 0.42 3.5
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Reconditioned, 

Exterior

Drum Coating, 

Reconditioned, 

Interior

0.50 4.2 0.50 4.2

Table 2. Plastic Parts and Products VOC Content Limits

Coating Category kg/VOC/l coating lb VOC/gal coating

General One Component 0.28 2.3

General Multi-Component 042 3.5

Electric Dissipating Coatings 

and Shock-Free Coatings 0.80 6.7

Extreme Performance 0.42

(2-pack coatings)

3.5

(2-pack coatings)

Metallic 0.42 3.5

Military Specification 0.34 (1 pack)

0.42 (2 pack)

2.8 (1 pack)

3.5 (2 pack)

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 3. Automotive/Transportation and Business Machine Plastic Parts VOC Content 

Limits

Coating Category kg/VOC/l coating lb VOC/gal coating

Automotive Transportation Coatings2

I. High Bake Coatings – Interior and Exterior Parts

Flexible Primer 0.54 4.5

Non-flexible Primer 0.42 3.5

Base Coats 0.52 4.3

Clear Coat 0.48 4.0

Non-basecoat/clear coat 0.52 4.3

II. Low Bake/Air Dried Coatings – Exterior Parts 

Primers 0.58 4.8

Basecoat 0.60 5.0

Clearcoats 0.54 4.5

Non-basecoat/clearcoat 0.60 5.0

III. Low Bake/AirDried 

Coatings –Interior Parts 0.60 5.0

IV. Touchup and Repair 

Coatings 0.62 5.2

 

2 For red, yellow and black automotive coatings, except touch up and repair coatings, the 

recommended limit is determined by multiplying the appropriate limit in this table by 1.15.
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Business Machine Coatings

I. Primers 0.35 2.9

II. Topcoats 0.35 2.9

III. Texture Coat 0.35 2.9

IV. Fog Coat 0.26 2.2

V. Touchup and repair 0.35 2.9

Table 4. Pleasure Craft Surface Coating VOC Content Limits

Coating Category kg/VOC/l/coating lb VOC/gal 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 Antifoulant 

Coating 0.56 4.7

Other Substrate Antifoulant 

Coating 0.33 2.8

All other pleasure craft surface 

coatings for metal or plastic 0.42 3.5

Table 5. Motor Vehicle Materials VOC Content Limits

Coating Category kg VOC/l 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 gasket/gasket sealing 

material

0.20 1.7

Motor vehicle underbody coating 0.65 5.4

Motor vehicle trunk interior coating 0.65 5.4

Motor vehicle bedliner 0.20 1.7

Motor vehicle lubricating 

wax/compound 0.70 5.8

Recommend Option 2 for Reducing Coating VOC Emissions: Emission Rate Limits Based 

on Low-VOC Coatings and Add-on Controls—VOC per Volume Solids

The recommended emission limits can also be expressed in terms of mass of VOC per volume of 

coating solids, as applied. This recommendation is intended for facilities that use a combination 

of low-VOC coatings and add-on control equipment on a coating unit. Using an assumed VOC 

density of 7.36 pounds per gallon, the equivalent limits in terms of mass VOC per volume of 

solids, as applied, are provided in the following three tables. As noted earlier, for the motor 

vehicle materials listed in Table 5 under Option 1 above, alternative emission rate limits (VOC 

per volume solids) is not recommended.
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Table 6. Metal Parts and Products VOC Emission Rate Limits (VOC per Volume Solids)

Air Dried Baked

Coating Category

kg VOC/l 

solids

lb VOC/gal 

solids

kg VOC/l 

solids

lb VOC/gal 

solids

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 MultiComponent

0.80 6.67 0.40 3.35

Prefabricated 

Architectural OneComponent

0.80 6.67 0.40 3.35

Pretreatment 

Coatings

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
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Table 7. Plastic Parts and Products VOC Emission Rate Limits (VOC per Volume Solids)

Coating Category kg VOC/l solids lb VOC/gal solids

General One Component 0.40 3.35

General Multi-Component 0.80 6.67

Electric Dissipating 

Coatings and Shock-Free 

Coatings

8.96 74.7

Extreme Performance 0.80

(2-pack coatings)

6.67

(2-pack coatings)

Metallic 0.80 6.67

Military Specification 0.54 (1 pack)

0.80 (2 pack)

4.52 (1 pack)

6.67 (2 pack)

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

Table 8. Automotive/Transportation and Business Machine Plastic Parts VOC 

Emission Rate Limits (VOC per Volume Solids)

Coating Category kg VOC/l solids lb VOC/gal solids

Automotive/Transportation Coatings3

I. High Bake Coatings – Interior and Exterior Parts

Flexible Primer 1.39 11.58

Non-flexible Primer 0.80 6.67

Base Coats 1.24 10.34

Clear Coat 1.05 8.76

Non-basecoat/clear coat 1.24 10.34

II. Low Bake/Air Dried Coatings – Exterior Parts

Primers 1.66 13.80

Basecoat 1.87 15.59

Clearcoats 1.39 11.58

Non-basecoat/clearcoat 1.87 15.59

III. Low Bake/Air Dried Coatings –

Interior Parts

1.87 15.59

IV. Touchup and Repair Coatings 2.13 17.72

Business Machine Coatings

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. Touchup and repair 0.57 4.80

 

3 For red, yellow, and black automotive coatings, except touch up and repair coatings, the 

recommended limit is determined by multiplying the appropriate limit in this table by 1.15.
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Table 9. Pleasure Craft Surface Coating VOC Emission Rate Limits (VOC per Volume 

Solids)

Coating Category kg VOC/l solids lb VOC/gal solids

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 

Coating

1.53 12.8

Other Substrate Antifoulant 

Coating

0.53 4.4

All other pleasure craft surface 

coatings for metal or plastic

0.80 6.7

Recommend 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 of 90 percent in lieu of using 

low-VOC coatings and specified application methods. This option, like the two options 

summarized above, applies to all coatings and thinners applied to miscellaneous metal and 

plastic part components or products, except as described above for motor vehicles.

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 percent.

Work Practices for Coating Operations and Cleaning Materials

In addition to the control options mentioned above, this CTG recommends work practices to 

further reduce VOC emissions from miscellaneous metal and plastic parts surface coating-related 

activities. Specifically, at a minimum, the following work practices are recommended: (1) store 

all VOC-containing coatings, thinners, and coating-related waste materials 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 VOCcontaining cleaning materials; (4) convey VOC-containing cleaning materials from one location 

to another in closed containers or pipes; and (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.
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Surface Coating of Metal Furniture CTG (EPA 453/R-07-005, September 2007)

In December 1977, EPA issued a CTG document for controlling VOC emissions from the 

surface coating of metal furniture. In October 1982, EPA promulgated the NSPS for the Surface 

Coating of Metal Furniture, and in May 2003, EPA promulgated the NESHAP for the Surface 

Coating of Metal Furniture. After reviewing the 1977 CTG, the 1982 NSPS, and the 2003 

NESHAP, and existing state and local VOC emission reduction approaches, EPA developed a 

CTG entitled, “Control Technique Guidelines for Metal Furniture Coatings” (EPA 453/R-07-

005).

Coatings used in metal furniture surface coating operations include paints, sealants, caulks, ink, 

adhesives, and maskants.

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 It is recommended that the control approaches discussed herein apply 

to each metal furniture surface coating unit5at a facility where the total actual VOC emissions 

from all metal furniture 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 such as 3 tons per 12-month 

rolling period, before consideration of controls. These control approaches are not recommended 

for facilities that emit below this level. 

The metal furniture coatings product category under section 183(e) of the CAA includes the 

coatings that are applied to the surfaces of metal furniture. A metal furniture substrate is the 

furniture or components of furniture constructed either entirely or partially from metal. Metal 

furniture includes, but is not limited to, the following types of products: household, office, 

institutional, laboratory, hospital, public building, restaurant, barber and beauty shop, and dental 

furniture, as well as components of these products. Metal furniture also includes office and store 

fixtures, partitions, shelving, lockers, lamps and lighting fixtures, and wastebaskets. Metal 

furniture coatings include paints and adhesives and are typically applied without a primer. 

Higher solids and powder coatings are used extensively in the metal furniture surface coating 

industry. Metal furniture coatings provide a covering, finish, or functional or protective layer, 

and can also provide a decorative finish to metal furniture.

Applicability

The September 2007 CTG for Metal Furniture coatings provides recommendations for reducing 

VOC emissions from the use of coatings applied to each metal furniture surface coating unit at a 

facility where the total actual VOC emissions from all metal furniture 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 such as 3 tons per 12-month rolling period, before consideration of 

controls. As mentioned previously, states can adopt the above recommended 6.8 kg/day (15 

lb/day) actual VOC emissions or an equivalent applicability threshold, or they can develop other 

 

4Decorative, protective, or functional materials that consist only of protective oils for metal, 

acids, bases, or any combination of these substances are not considered metal furniture coatings.

5A coating unit consists of a series of one or more coating applicators and any associated drying 

area and/or oven wherein 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. It is not necessary for a coating unit to have an oven or flash-off area.
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applicability criteria that they determine are appropriate considering the facts and circumstances 

of the sources in their particular nonattainment areas. 

Sources of VOC Emissions

Primarily, emissions from metal furniture coating operations result from the evaporation of the 

VOC components of the coatings and cleaning materials. In most cases, VOC emissions from 

the surface preparation, storage, handling, and waste/wastewater operations are relatively small. 

The primary VOC emissions from metal furniture coatings occur during coating 

application/flash-off and drying/curing of the coatings. The remaining emissions are primarily 

from mixing and/or thinning. The VOC emissions from mixing and thinning of coatings occur 

from the displacement of VOC-laden air in containers used to mix coatings containing solvents 

(thinners) prior to coating application. The displacement of VOC-laden air can also occur during 

filling of containers and can be caused by changes in temperature, changes in barometric 

pressure, or agitation during mixing.

Coating Application

Surface coating of metal furniture is applied by applying a coating to the metal furniture 

component or product. After being coated by any of the typical coating methods (e.g., spray 

coating or dip coating), the metal furniture components or products are dried/cured. Prior to 

entering the ovens, solvents in the coatings evaporate slowly in the flash-off area to prevent 

bubble formation during curing. The coating itself may be in the form of a liquid or powder, and 

may be applied by spraying or dipping. The amount of VOC emissions from the flash-off area 

depends on the type of coating used, how quickly the component or product moves through the 

flash-off area, and the distance between the application area and the bake oven. For liquid spray 

applications, it is estimated that 65-80 percent of the volatiles are emitted during the application 

and flash-off operations, and the remaining 20-35 percent from the drying/curing operation.

For powder coatings, the curing/drying step melts the powder and forms a continuous coating on 

the metal furniture component or product. For liquid coatings, this step removes any remaining 

volatiles from the coating. The cured coatings provide the desired decorative and/or protective 

characteristics. The VOC emissions during the curing/drying process result from the evaporation 

of the remaining solvents in the dryer.

There are several different types of applicators that may be used to apply coatings. The most 

common types of coating applicators include: air atomized spray coating, electrostatic spray 

coating, high volume/low pressure (HVLP) spray coating, dip coating, flow coating, roll coating, 

electrocoating, and autophoretic coating.

CTG Recommended Control Options

As stated previously, there are two main sources of VOC emissions from metal furniture surface 

coating operations: (1) evaporation of VOC from the coatings; and (2) evaporation of VOC from 

the cleaning materials. To control VOC emissions from metal furniture coatings, the CTG 

recommends three options: (1) emission limits that can be achieved through the use of low-VOC 
14

coatings; (2) equivalent emission limits that can be achieved through the use of low-VOC 

coatings or a combination of coatings and add-on controls; and (3) an overall control efficiency 

of 90 percent for add-on controls. The low-VOC coatings recommendation (Option 1) consists 

of emission limits in terms of mass of VOC per volume of coating, excluding water and exempt 

compounds, as applied, and the use of specified application methods. The equivalent emission 

limit recommendation (Option 2) consists of emission limits in terms of mass of VOC per 

volume of coating solids, as applied, and the use of specific application methods. Additionally, 

for cleaning materials, work practices are recommended to reduce VOC emissions. 

Specific recommendations for coating operations and cleaning materials used in metal furniture 

surface coating operations are summarized below:

Emissions Limits Based on Low-VOC Coatings-Option 1

The CTG recommends emission limits for one-component and multi-component general purpose 

coatings. In addition, specific emission limits for certain specialty coatings are recommended. 

For each of these coating types, separate emission limits are recommended for baked and airdried coatings. Provided below are the recommended emission limits expressed in terms of mass 

of VOC per volume of coating (excluding water and exempt compounds, as applied).

Table 10. Emission Limits (mass of VOC per volume of coating excluding water and 

exempt compounds, as applied) for Metal Furniture Coatings

Coatings Type Baked Air Dried

kg/l lb/gal kg/l lb/gal

General, One Component 0.275 2.3 0.275 2.3

General, Multi-Component 0.275 2.3 0.340 2.8

Extreme High Gloss 0.360 3.0 0.340 2.8

Extreme Performance 0.360 3.0 0.420 3.5

Heat Resistant 0.360 3.0 0.420 3.5

Metallic 0.420 3.5 0.420 3.5

Pretreatment Coatings 0.420 3.5 0.420 3.5

Solar Absorbent 0.360 3.0 0.420 3.5

Equivalent Emission Limits Achieved Through the Use of Low-VOC Coatings or a 

Combination of Coatings and Add-on Controls-Option 2 

The recommended emission limits can also be expressed in terms of mass of VOC per volume of 

coating solids, as applied. A facility could use low-VOC coatings or a combination of coatings 

and add-on control equipment on a coating unit to meet the recommended mass of VOC per 

volume of coating solids limits. Using an assumed VOC density of 7.36 pounds per gallon, the 

equivalent limits in terms of mass of VOC per volume of solids, as applied, are as follows:
15

Table 11. Emission Limits (mass of VOC per volume of coating solids as applied) for Metal 

Furniture Coatings

Coating Type Baked Air Dried

kg/l lb/gal kg/l lb/gal

General, One Component 0.40 3.3 0.40 3.3

General, Multi-Component 0.40 3.3 0.55 4.5

Extreme High Gloss 0.61 5.1 0.55 4.5

Extreme Performance 0.61 5.1 0.80 6.7

Heat Resistant 0.61 5.1 0.80 6.7

Metallic 0.80 6.7 0.80 6.7

Pretreatment Coatings 0.80 6.7 0.80 6.7

Solar Absorbent 0.61 5.1 0.80 6.7

The following types of coatings and coating operations are exempt from the recommended VOC 

content limits: stencil coatings, safety-indicating coatings, solid-film lubricants, electricinsulating and thermal conducting coatings, touch-up and repair coatings, and coating 

applications utilizing hand-held aerosol cans.

The CTG recommends that all VOC-containing materials used by each metal furniture surface 

coating unit be included when determining the coating unit’s emission rate. Additionally, the 

following application methods are recommended: electrostatic application, HVLP spray, flow 

coat, roller coat, dip coat including electrodeposition, or brush coat.

Optional Add-On Controls-Option 3 

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 addon control equipment to meet an overall efficiency of 90 percent. Alternatively, a facility could 

use a combination of coatings and add-on control equipment on a coating unit to meet the 

recommended mass of VOC per volume of coating solid limits.

Work Practices for Coating Operations and Cleaning Materials

Work practices to further reduce emissions from the coatings as well as minimize emissions from 

cleaning materials used for large appliance coating operations are recommended, and they are: 

store all VOC-containing coatings, thinners, and cleaning materials in closed containers; 

minimize spills of VOC-containing coatings, thinners, and cleaning materials; clean up spills 

immediately; convey any coatings, thinners, and cleaning materials in closed containers or pipes;

close mixing vessels that contain VOC coatings and other materials, except when in use; and 

minimize usage of solvents during cleaning of storage, mixing, and conveying of equipment.

Surface Coating of Large Appliances CTG (EPA 453/R-07-004, September 2007)

In December 1977, EPA published CTGs for large appliance coatings (EPA-450/2-77-034), and 

surface coatings of metal furniture (EPA-450/2-77-032). In October 1982, EPA promulgated the 

NSPS for industrial surface coating of large appliances, and in 2002, EPA promulgated the 
16

NESHAP for large appliances. After reviewing the 1977 CTG, the 1982 NSPS, the 2002 

NESHAP, and existing state and local VOC emission reduction approaches, and considering 

information obtained since issuance of the 2002 NESHAP, EPA developed a new CTG for the 

surface coating of large appliances, entitled, “Control Technique Guidelines for Large Appliance 

Coatings” (EPA 453/R-07-004, September 2007).

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

basecoats, primers, enamels, and adhesives used in the manufacture of large appliance parts or 

products. A large appliance part is defined as any organic surface-coated metal lid, door, casing, 

panel, or other interior or exterior part or accessory that is assembled to form a large appliance 

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

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

compactor manufactured for household, commercial, or recreational use.

The coating application methods used are typical of surface coating operations in many 

industries, and include air atomized spraying, dip coating, electrodeposition, and flow coating. 

VOC emissions from large appliance coating processes result from the evaporation of the 

components of the coatings and cleaning materials.

Applicability

The September 2007 CTG provides control recommendations for reducing VOC emissions 

stemming from the use of coatings in large appliance coating operations. Coatings include 

paints, sealants, caulks, inks, adhesives, and maskants. The CTG provides recommendations for 

reducing VOC emissions from the use of coatings applied to each large appliance coating unit at 

a facility where the total actual VOC emissions from all large appliance 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 such as three (3) tons per 12-month rolling period, before consideration of 

controls. States can adopt the above recommended 15 lb/day actual VOC emissions or an 

equivalent applicability threshold, or they can develop other applicability criteria that they 

determine are appropriate considering the facts and circumstances of the sources in their 

particular nonattainment areas.

Sources of VOC Emissions

Primarily, VOC emissions from large appliance coating operations result from the evaporation of 

the components of the coatings and cleaning materials. The primary VOC emissions from large 

appliance coatings occur during coating application (prime, single or topcoat application), flashoff and drying/curing of the coatings. The remaining emissions are primarily from mixing 

and/or thinning. In most cases, VOC emissions from storage, handling, and waste/wastewater 

operations related to coating operations are relatively small.

Coating Application

Surface coating of large appliances is applied by applying a coating to the large appliance. After 

being coated by any of the typical coating methods (spray coating or dip coating), the large 
17

appliance products are cured using heated dryers or allowed to air dry. This step removes any 

remaining volatiles from the coating so that the surfaces of the large appliance product meet the 

hardness, durability, and appearance requirements of the customers. Coating mixing may be 

performed in an agitated drum or it may be performed by merging two different coating supply 

lines into one. Coating mixing is typically performed by the coating manufacturer prior to 

shipment to a large appliance manufacturer’s facility. Some facilities add water or solvent to the 

coating (thinning), which may be performed in a small mixing booth or it may be automated. 

Some facilities combine reclaimed coating from various coating operations and mix the different 

coatings together in a drum. Mixing also varies depending upon the type of coating and usage 

requirements.

CTG Recommended Control Options

As stated previously, there are two main sources of VOC emissions from large furniture surface 

coating operations: (1) evaporation of VOC from the coatings; and (2) evaporation of VOC from 

the cleaning materials. To control VOC emissions from large appliance coatings, the CTG 

recommends three options: (1) emission limits that can be achieved through the use of low-VOC 

coatings; (2) equivalent emission limits that can be achieved through the use of low-VOC 

coatings or a combination of coatings and add-on controls; and (3) an overall control efficiency 

of 90 percent for add-on controls. The low VOC coatings recommendation consists of emission 

limits in terms of mass of VOC per volume of coating, excluding water and exempt compounds, 

as applied, and the use of specified application methods. The equivalent emission limit 

recommendation consists of emission limits in terms of mass of VOC per volume of coating 

solids, as applied, and the use of specific application methods. Additionally, for cleaning 

materials, work practices are recommended to reduce VOC emissions.

Specific recommendations for coating operations and cleaning materials used in large furniture 

surface coating operations are summarized below:

Emission Limits Based on Low-VOC Coatings - Option 1

Emission limits for one-component and multi-component general purpose coatings are 

recommended. In addition, specific emission limits for certain specialty coatings are 

recommended. For each of these coating types, separate emission limits are recommended for 

baked and air-dried coatings. Provided below are the CTG-recommended emission limits 

expressed in terms of mass of VOC per volume of coating, excluding water and exempt 

compounds, as applied.

Table 12: Recommended Emission Limits (mass of VOC per volume of coating) Excluding 

Water and Exempt Compounds, as Applied

Coating Type Baked Air Dried

kg/l lb/gal kg/l lb/gal

General, One Component 0.275 2.3 0.275 2.3

General, Multi-Component 0.275 2.3 0.340 2.8

Extreme High Gloss 0.360 3.0 0.340 2.8

Heat Resistant 0.360 3.0 0.420 3.5
18

Metallic 0.420 3.5 0.420 3.5

Pretreatment Coatings 0.420 3.5 0.420 3.5

Solar Absorbent 0.360 3.0 0.420 3.5

Emission Limits in Mass of VOC Per Volume of Coatings Solids, as Applied - Option 2

The recommended emission limits can also be expressed in terms of mass of VOC per volume of 

coating solids, as applied. A facility could use low-VOC coatings or a combination of coatings 

and add-on control equipment on a coating unit to meet the recommended mass of VOC per 

volume of coating solids, as applied, limits. Using an assumed VOC density of 7.36 pounds per 

gallon, equivalent limits in terms of mass of VOC per volume of solids, as applied, are as 

follows:

Table 13: Recommended Emission Limits (mass of VOC per volume of coating solids) for 

Large Appliance Coatings

Coating Type Baked Air Dried

kg/l lb/gal kg/l lb/gal

General, One Component 0.40 3.3 0.40 3.3

General, Multi-Component 0.40 3.3 0.55 4.5

Extreme High Gloss 0.61 5.1 0.55 4.5

Extreme Performance 0.61 5.1 0.80 6.7

Heat Resistant 0.61 5.1 0.80 6.7

Metallic 0.80 6.7 0.80 6.7

Pretreatment Coatings 0.80 6.7 0.80 6.7

Solar Absorbent 0.61 5.1 0.80 6.7

The CTG recommends that the following types of coatings be exempt from the recommended 

VOC content limits: stencil coatings, safety-indicating coatings, solid-film lubricants, electricinsulating and thermal-conducting coatings, touch-up and repair coatings, and coating 

application utilizing hand-held aerosol cans.

The CTG also recommends that all VOC-containing materials used by each large appliance 

surface coating unit be included when determining the coating unit’s emission rate. 

Additionally, the following application methods are recommended: electrostatic application, 

high volume/low pressure (HVLP) spray, flow coat, roller coat, dip coat including 

electrodeposition, or brush coat.

Optional Add-On Controls for Coating Operations - Option 3

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 addon control equipment to meet an overall efficiency of 90 percent. Alternatively, a facility could 

use a combination of coatings and add-on control equipment on a coating unit to meet the 

recommended mass of VOC per volume of coating solids on a coating unit to meet the 

recommended mass of VOC per volume of coating solids limits. Add-on devices include 

oxidizers and solvent recovery systems that, coupled with their attendant systems to capture the 
19

VOC being released at the affected facilities, can achieve an overall control efficiency of 90 

percent. This control option, like the options noted above, applies to all coatings and thinners 

applied to large appliances.

Work Practices for Coating Operations and Cleaning Materials

Work practices to further reduce emissions from the coatings as well as minimize emissions from 

cleaning materials used for large appliance coating operations are recommended, and they are: 

store all VOC-containing coatings, thinners, and cleaning materials in closed containers; 

minimize spills of VOC-containing coatings, thinners, and cleaning materials; clean up spills 

immediately; convey any coatings, thinners, and cleaning materials in closed containers or pipes; 

close mixing vessels that contain VOC coatings and other materials except when in use; and 

minimize use of solvents during cleaning of storage, mixing, and conveying of equipment.

B. STATE SUBMITTAL

On April 1, 2010, Delaware Department of Natural Resources and Environmental Control 

(DNREC) submitted SIP revisions to EPA adopting the requirements of EPA’s CTGs for plastic 

parts, metal furniture, large appliances, and miscellaneous metal parts. On March 9, 2012, 

Delaware submitted a revision to its April 1, 2010 submittal to correct non-substantive 

administrative errors, and to include EPA approval, as well as the Department’s for any 

alternative coating application method that is not one of the of the application methods explicitly 

specified in the regulations. EPA develops CTGs as guidance on control requirements for source 

categories. States can follow the CTGs or adopt more restrictive standards. DNREC is adopting 

EPA’s CTG standards for the coating of miscellaneous metal and plastic parts, metal furniture, 

and large appliances, and incorporating them into their Regulation 1124, Control of Volatile 

Organic Compounds - sections 12.0, 19.0, 20.0, and 22.0. Listed below is a summary of 

Delaware’s SIP revisions to Regulation 1124.

I. Revisions to section 2.0, Definitions

The revisions to section 2.0, “Definitions,” add the following definitions used in the substantive 

provisions of this regulation and in multiple sections of other Delaware air quality regulations.

Adhesion primer- means a coating that is applied to thermoplastic olefin (TPO) parts to promote 

adhesion of subsequent coatings. An adhesion primer is clearly identified as an adhesion primer 

or adhesion promoter on its accompanying material safety data sheet.

Aerosol coating product- means a pressurized coating product containing pigments of resins that 

dispense product ingredients by means of a propellant and is packaged in a disposable can for 

hand-held application, or for use in specialized equipment for ground traffic marking 

applications.

Air-dried coating- means a coating that is cured at a temperature below 90o C (194o F). 

Baked coating- means a coating that is cured at a temperature at or above 90o C (194o F). 
20

Dip coating- means the application method of a coating material to a substrate by dipping the 

part into a tank of coating material.

Electric-insulating and thermal-conducting coating- means a coating that displays an electrical 

insulation of at least 1000 volts DC per mil on a flat test plate and an average thermal 

conductivity of at least 0.27 BTU per hour-foot-degree Fahrenheit.

Electrostatic spray-means a method of applying a spray coating in which opposite electric 

charges are applied to the substrate and the coating. The coating is attracted to the substrate by 

the electrostatic potential between them.

Extreme high-gloss coating- means a coating which, when tested by ASTM International Method 

D-523, adopted in 1980, shows a reflectance of 75 or more on a 60o meter.

Extreme performance coating- means a coating used on a metal surface where the coated surface 

is, in its intended use, subject to the following: (a) chronic exposure to corrosive, caustic or 

acidic agents, chemicals, chemical fumes, chemical mixtures or solutions; or (b) repeated 

exposure to temperatures in excess of 250oF or (c) repeated heavy abrasion, including 

mechanical wear, and repeated scrubbing with industrial grade solvents, cleansers or scouring 

agents.

Flow coating- means the application of a coating material to a substrate by pouring the coating 

over the suspended part.

Hand application- means a method of applying coatings by non-mechanical hand-held equipment 

including, but not limited to, paint brushes, hand rollers, caulking guns, trowels, spatulas, syringe 

daubers, rags and sponges.

Heat resistant coating- means a coating that must withstand a temperature of at least 400oF 

during normal use.

High-volume, low-pressure (HVLP) spray equipment- means spray equipment that is used to 

apply coatings using a spray gun that operates less than or equal to 10 psig of atomized air 

pressure at the air cap.

Metallic coating- means a coating which contains more than 5 grams of metal particles per liter 

of coating, as applied. Metal particles are pieces of a pure elemental metal or a combination of 

elemental metals.

Mold-seal coating- means the initial coating applied to a new mold or a repaired mold to provide 

a smooth surface which, when coated with a mold release coating, prevents products from 

sticking to the mold.

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.
21

Pretreatment coating- means a coating which contains no more than 12% solids by weight, and at 

least 0.5% acid by weight, is used to provide surface etching, and is applied directly to metal 

surfaces to provide corrosion resistance, adhesion, and ease of stripping.

Repair coating- means a coating used to re-coat portions of a previously coated product which 

has sustained mechanical damage to the coating following normal coating operations.

Safety-indicating coatings- means a coating which changes physical characteristics, such as 

color, to indicate unsafe conditions.

Solar-absorbent coating- means a coating which has as its prime purpose the absorption of solar 

radiation.

Solid-film lubricant- means a very thin coating consisting of a binder system containing as its 

chief pigment material one or more of molybdenum disulfide, graphite, polytetraflouroethylene 

(PTFE) or other solids that act as a dry lubricant between faying surfaces.

Stencil coating- means a coating which is rolled or brushed onto a template or stamp in order to 

add identifying letters, symbols or numbers.

Touch-up coating- means a coating used to cover minor coating imperfections appearing after 

the main coating operation.

Two-component paint- means a coating that is manufactured in two components that are mixed 

shortly before use. When mixed, the two liquids rapidly crosslink to form a solid composition.

Vacuum-metalizing coating-means the undercoat applied to the substrate on which the metal is 

deposited or the overcoat applied directly to the metal film. Vacuum 

metalizing/physical/physical vapor deposition (PVD) is the process whereby metal is vaporized 

and deposited on a substrate in a vacuum chamber.

II. Revisions to Section 12.0, Surface Coating of Plastic Parts

DNREC has individual regulations for the CTG recommendations contained in the EPA 

combined CTG entitled, “Control Technique Guidelines for Miscellaneous Metal and Plastic 

Parts Coatings,” dated September 2008. Section 12.0 of Delaware’s Regulation 1124 pertains to 

the control of VOC from the surface coating of plastic parts, and section 22.0 pertains to the 

control of VOC from the surface coatings of miscellaneous metal parts. A summary of 

Delaware’s revised regulations can be found below.

Applicability

The provisions of this section apply to any plastic parts or products coating unit. Every owner or 

operator of any plastic parts or products coating unit shall comply with this section on and after 

April 11, 2010. A transition period exists for sources that have been previously permitted. 

Every owner or operator of any plastic parts or products coating unit that has a permit issued 
22

pursuant to 7 DE Admin Code 1102 or 1130 containing all applicable conditions of section 12.0 

of this regulation as that regulation existed on November 29, 1994, needs to comply with those 

permit conditions until December 31, 2010. On and after January 1, 2011, every such owner or 

operator of any plastic parts or products coating unit shall comply with the provisions of 12.0 of 

this regulation. The provisions of this section do not apply to plastic parts or products coating 

facilities whose actual emissions, without control devices, from all plastic parts or products 

coating units, including emissions from related cleaning activities, are less than 6.8 kg, 15 lbs of 

VOC per day. An owner or operator of a facility whose emissions are below this applicability 

threshold shall comply with the certification, recordkeeping and reporting requirements of this 

section. The provisions of section 12.0 do not apply to parts covered by other sections of this 

regulation, exterior parts of completely assembled marine vessels, and internal electrical parts of 

business and commercial machines, including, but not limited to, medical and entertainment 

equipment. If a metal component that is permanently attached to a plastic part is coated in a 

spray booth or on a process line where plastic parts or products are being coated, the 

requirements of this section apply to the coating of both the plastic part and the attached metal 

component.

Definitions

The revisions to section 12.0 add the following definitions:

Black coating- means a coating which meets a maximum lightness of 23 units, and has a 

saturation of less than 2.8, where saturation equals the square root of A2 + B2. These criteria are 

based on Cielab color space, 0/45 geometry. For spherical geometry, specular included, the 

maximum lightness is 33 units.

Business machine- means a device that uses electronic or mechanical methods to process 

information, perform calculations, print or copy information or convert sound into electrical 

impulses for transmission, including devices listed in standard industrial classification numbers 

3572, 3573, 3574, 3579, and 3661 and photocopy machines, a subcategory of standard industrial 

classification number 3861.

Commercial machine- means a device that is used in commercial activities, including, but not 

limited to, medical, laboratory and entertainment equipment.

Electric dissipating coating- means a coating that rapidly dissipates a high-volume electric 

charge.

Electrostatic preparation coating- means a coating that is applied to a plastic part solely to 

provide conductivity for the subsequent application of a prime, a topcoat, or other coating 

through the use of electrostatic application methods. An electrostatic prep coat is clearly 

identified as an electrostatic prep coat on its accompanying material safety data sheet.

Fog coat- means a coating that is applied to a plastic part for the purpose of color matching 

without masking a molded-in texture. A fog coat shall not be applied at a thickness of more than 

0.5 mils of coating solids.
23

Gloss reducer- means a coating that is applied to a plastic part solely to reduce the shine of the 

part. A gloss reducer shall not be applied at a thickness of more than 0.5 mils of coating solids.

Mask coating –means a thin film coating applied through a template to coat a small portion of a 

substrate.

Military specification coating- means a coating which has a formulation approved by a United 

States military agency for use on military equipment.

Optical coating- means a coating applied to an optical lens.

Red coating- means a coating which meets all of the following criteria: yellow limit, the hue of 

hostaperm scarlet; blue limit, the hue of monastral red-violet, lightness limit for metallics; 35% 

aluminum flake; lightness limit for solids, 50% titanium dioxide white; solid reds, hue angle of -

11 to 38 degrees and maximum lightness of 23 to 45 units; metallic reds, hue angle of -16 to 35 

degrees and maximum lightness of 28 to 45 units. These criteria are based on Cielab color 

space, 0/45 geometry. For spherical geometry, specula included, the upper limit is 49 units. The 

maximum lightness varies as the hue moves from violet to orange. This is a natural consequence 

of the strength of the colorants, and real colors show this effect.

Texture coat- means a coating that is applied to a plastic part which, in its finished form, consists 

of discrete raised spots of the coating.

Translucent coating- means a coating which contains binders and pigment, and is formulated to 

form a colored, but not opaque, film.

The revisions to section 12.0 revise the following definitions:

Basecoat/clearcoat –means a two-step topcoat system in which a highly pigmented, often 

metallic, basecoat is followed by a clearcoat, resulting in a finish with high-gloss characteristics.

EMI/RFI (electromagnetic interference/radio frequency interference shielding coating-means a 

coating that is used in a plastic business or commercial machine housing to attenuate 

electromagnetic and radio frequency interference signals that would otherwise pass through the 

plastic housing.

Flexible primer-means any coating that is required to comply with engineering specifications for 

impact resistance, mandrel bend, or elongation as defined by the original equipment 

manufacturer.

Nonflexible primer-means a paint that cannot withstand dimensional changes.

Plastic part or product-means a piece made from a substance that has been formed from resin 

through the application of pressure or heat. Plastic parts or products include automotive or other 

transportation equipment including, but not limited to, parts or products for automobiles, trucks 

(light, medium, and heavy-duty), large and small farm machinery, motorcycles, recreational 

vehicles, construction equipment, vans, buses, lawnmowers and other motorized mobile 
24

equipment; business and commercial machines, including, but not limited to, computers, copy 

machines, typewriters, medical equipment, laboratory equipment and entertainment equipment; 

and commercial and industrial machinery, sporting goods, toys, lawn and garden equipment and 

other industrial and household products.

Specialty coating-means a coating that is used for unusual job performance requirements, usually 

in small amounts. These products include but are not limited to adhesion primers, resist 

coatings, soft coatings, reflective coatings, electrostatic prep coatings, headlamp lens coatings, 

ink pad printing coatings, stencil coatings, texture coatings (automotive), vacuum metalizing 

coatings, and gloss flatteners. 

As a result of comments received at a public hearing held on January 5, 2010, a new definition 

for “specialty coating” was added and the term,”hand-held aerosol cans” was changed to 

“aerosol coating product.” A definition for the term “aerosol coating product” has been added to 

section 12.0, “Definitions,” since other Regulation 1124 sections and other existing Delaware 

regulations also use this term.

The revisions to section 12.0 delete the following definitions: add-on controls, adhesion 

promoter (primer), affected facility, aftermarket automobile, overspray, two-component paint, 

and waterborne coating.

Standards

Except as noted in the exemptions listed below, no owner or operator of a plastic parts or 

products coating unit subject to section 12.0 of this regulation may cause or allow the application 

of any coating to plastic parts or products unless:

1. The VC content of the coating is less than or equal to the limits listed in Table 14 below, or

2. For a plastic parts or products coating unit that applies multiple coatings, which are subject to 

the same numerical emission limits in Table 14, the daily-weighted average VOC content is less 

than or equal to the limit in Table 14 corresponding to the category of coating used, or

3. Control equipment is installed and operated that achieves an emission reduction efficiency in 

accordance with this regulation. The application requirements below do not apply to any plastic 

parts or products coating unit that achieves an emission reduction efficiency of 95% or greater.

4. Except as provided in number 3 above and in the specific exemptions listed below, no owner 

or operator of a plastic parts or products coating unit subject to section 12.0 of this regulation 

shall apply a coating to plastic parts or products unless the coating is applied with equipment 

properly operated and maintained according to the manufacturer’s suggested guidelines and 

using one or more of the following coating application methods.

a) Electrostatic spray

b) Flow coating

c) Dip coating, including electrodeposition

d) Roll coating
25

e) High-volume, low pressure (HVLP) spray

f) Hand application

g) An alternative method demonstrated to be capable of achieving a transfer efficiency equal 

to or better than HVLP spray and approved by the Department and EPA.

Table 14: Plastic Parts Coating Voc Content Limits - VOC content limits are expressed as 

mass kg or lb per volume l or gal of coating less water and exempt compounds, as applied.

Coating Category kg VOC/l coating lb VOC/gal coating

General*

One component coating 0.28 2.3

Multi-component coating 0.42 3.5

Electric dissipating coatings and 

shock-free coatings 0.36 3.0

Extreme performance 0.42 (2 pack) 3.5 (2 pack)

Metallic 0.42 3.5

Military specification 0.34 (1 pack)

0.42 (2 pack)

2.8 (1 pack)

3.5 (2 pack)

Mold-seal 0.76 6.3

Multicolored coatings 0.68 5.7

Optical coatings 0.80 6.7

Vacuum-metalizing 0.80 6.7

Business Machine Parts

Primers 0.14 1.2

Topcoat 0.28 2.3

Texture coat 0.28 2.3

Fog coat 0.26 2.2

Touchup and repair 0.28 2.3

Clearcoats 0.28 2.3

EMI/RFI coatings 0.48 4.0

Soft coatings 0.52 4.3

Plating resist coatings 0.71 5.9

Plating sensitizer coatings 0.85 7.1

Automotive/Transportation Parts

High bake coatings

Flexible primer 0.46 3.8

Non-flexible primer 0.42 3.5

Base coats 0.52 4.3

Clear coat 0.48 4.0

Non-basecoat/clear coat 0.52 4.3

Interior colorcoat 0.49 4.1

Exterior colorcoat 0.55 4.6

Low bake/air dried coatings-exterior

Primers 0.58 4.8

Basecoat 0.60 5.0

Clearcoats 0.54 4.5
26

Non-basecoat/clearcoat 0.60 5.0

Red and black colorcoats 0.67 5.6

All other colorcoats 0.61 5.1

Low bake/air dried coatings

Interior primers 0.42 3.5

Colorcoats 0.38 3.2

Touchup and repair coatings 0.62 5.2

Auto specialty

Vacuum metalizing basecoats 0.66 5.5

Texture coatings 0.66 5.5

Reflective argent coatings 0.71 5.9

Soft specialty coatings 0.71 5.9

Air bag cover coatings 0.71 5.9

Gloss flatteners 0.77 6.4

Vacuum metalizing topcoats 0.77 6.4

Texture topcoats 0.77 6.4

Stencil coatings 0.81 6.8

Adhesion primers 0.81 6.8

Ink pad printing coatings 0.81 6.8

Electrostatic prep coats 0.81 6.8

Resist coatings 0.81 6.8

Headlamp lens coatings 0.89 7.4

*General refers to those parts or products which are not Business Machine Parts or 

Automotive/Transportation Parts.

Based on comments received on its proposed regulation, DNREC made the following changes 

from its proposed regulation to its final regulation.

1. Changed Table 14 in its final submittal from its proposed regulation by deleting the following 

note applicable to “Automotive/Transportation Parts:” (Note: for red, yellow, and black 

automotive coatings, except touch up and repair coatings, the allowable limit is determined by 

multiplying the appropriate limit in this table by 1.15). Although this language is contained in 

EPA’s CTG for Plastic Parts, including it in Delaware’s VOC limits would make the proposed 

limits less stringent than the current limits for color coats. As a result, in its final regulation, 

Delaware has reverted the language back to its existing regulatory language.

The SIP revision also amends section 12.0 in order to: (1) establish exemptions, (2) establish 

control devices, and (3) establish test methods, compliance certification, recordkeeping, and 

reporting requirements based on EPA CTGs.

III. Revisions to Section 19.0, Coating of Metal Furniture

Applicability

The provisions of this section apply to any metal furniture coating unit. Every owner or operator 

of any metal furniture coating unit shall comply with this section on and after April 11, 2010. A 
27

transition period exists for sources that have been previously permitted. Every owner or operator 

of any plastic parts or products coating unit that has a permit issued pursuant to 7 DE Admin 

Code 1102 or 1130 containing all applicable conditions of section 19.0 of this regulation as that 

regulation existed on January 11, 1993, needs to comply with those permit conditions until 

December 31, 2010. On and after January 1, 2011, every such owner or operator of any metal 

furniture coating unit shall comply with the provisions of 19.0 of this regulation. The provisions 

of this section do not apply to any metal furniture coating unit within a facility whose actual 

emissions without control devices from all metal furniture coatings units within the facility, 

including emissions from related cleaning activities, are less than 6.8 kg 15 lb of VOC per day. 

An owner or operator of a facility whose emissions are below the applicability threshold 

described above shall comply with the certification, recordkeeping and reporting requirements of 

this section. 

Definitions

The revisions to section 19 revise the definition of Metal furniture to include “fixtures, lamps, and 

lighting units.

As a result of comments received at its public hearing, Delaware revised the term “hand-held 

aerosol cans” to “Aerosol coating product.” A definition for the term “Aerosol coating product” 

has been added to Section 2.0, Definitions, since other Regulation 1124 sections and other 

existing Delaware air regulations also use this term.

Standards

No owner or operator of a metal furniture coating unit subject to this section shall allow the 

application of any coating to metal furniture unless:

1. The VOC content of the coating is less than or equal to the limits listed in Table 15 below, or

2. For a metal furniture coating unit that applies multiple coatings, which are subject to the same 

emission limit in Table 15, the daily-weighted average VOC content, is less than or equal to the 

limit in Table 15 corresponding to the category of coating used, or

3. Control equipment is installed and operated that achieves an emission reduction efficiency in 

accordance with the provisions for control devices as specified below. The application 

requirements described below shall not apply to any metal furniture coating unit that achieves an 

emission reduction efficiency of 95 percent or greater.

Table 15: Metal Furniture Coating VOC Content Limits - (VOC content limits are 

expressed as mass (either kg or lb) per volume (either l or gal) of coating less water and 

exempt compounds, as applied

Coating Category

Baked Air Dried

kg VOC/l 

coating

lb VOC/gal 

coating

kg/VOC/l 

coating

lb/VOC/gal 

coating

General, one-component 0.275 2.3 0.275 2.3
28

General, multi-component 0.275 2.3 0.340 2.8

Extreme, high-gloss 0.360 3.0 0.340 2.8

Extreme performance 0.360 3.0 0.420 3.5

Heat-resistant 0.360 3.0 0.420 3.5

Metallic 0.420 3.5 0.420 3.5

Pretreatment 0.420 3.5 0.420 3.5

Solar-absorbent 0.360 3.0 0.420 3.5

No owner or operator of a metal furniture coating unit subject to this section should apply a 

coating to metal furniture unless the coating is applied with equipment properly operating and 

maintained according to the manufacturer’s suggested guidelines and using one or more of the 

following coating application methods:

1. Electrostatic spray

2. Flow coating.

3. Dip coating, including electrodeposition.

4. Roll coating.

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

6. Hand application.

7. An alternative method that is demonstrated to be capable of achieving a transfer efficiency 

equal to or better than HVLP spray and approved by the Department and EPA.

Note: Touch-up and Repair coatings are exempt from the application methods of this section.

The SIP revision also amends section 19.0 in order to: (1) establish exemptions, (2) establish 

control devices, and (3) establish test methods, compliance certification, recordkeeping, and 

reporting requirements based on EPA CTGs.

IV. Revisions to Section 20.0 Coating of Large Appliances

Applicability

The provisions of this section apply to any large appliance coating unit. Every owner or operator 

of any metal furniture coating unit shall comply with this section on and after April 11, 2010. A 

transition period exists for sources that have been previously permitted. Every owner or operator 

of any plastic parts or products coating unit that has a permit issued pursuant to 7 DE Admin 

Code 1102 or 1130 containing all applicable conditions of this section of this regulation as that 

regulation existed on January 11, 1993, needs to comply with those permit conditions until

December 31, 2010. On and after January 1, 2011, every such owner or operator of any metal 

furniture coating unit shall comply with the provisions of 19.0 of this regulation. The provisions 

of this section do not apply to any large appliance coating unit within a facility whose actual 

emissions without control devices from all large appliance coating units within the facility, 

including related cleaning activities, are less than 6.8 kg, 15 lb of VOC per day. An owner or 

operator of a facility whose emissions are below this applicability threshold described above 

shall comply with the certification, recordkeeping and reporting requirements of this section. 
29

Definitions

The definition for “Large appliance” has been revised to read as follows:

Large appliance- means any residential or commercial washer, dryer, range, oven, microwave 

oven, refrigerator, freezer, water heater, dishwasher, trash compactor, air conditioner, or other 

similar products under North American Industry Classification System Code 33522.

As a result of comments received at its public hearing, Delaware revised the term, “hand-held 

aerosol cans” to “Aerosol coating product.” A definition for the term “aerosol coating product” 

has been added to Section 2.0, Definitions, since other Regulation 1124 sections and other 

existing Delaware air regulations also use this term.

Standards

No owner or operator of a large appliance coating unit subject to this section shall allow the 

application of any coating to large appliances unless:

1. The VOC content of the coating is less than or equal to the limits in Table 16 below or

2. For a large appliance coating unit that applies multiple coatings, which are subject to the 

same numerical emission limitation in Table 16, the daily-weighted average VOC content, is less 

than or equal to the limit in Table 16 of this section corresponding to the category of coating 

used, or

3. Control equipment is installed and operated that achieves an emission reduction efficiency in 

accordance with the control devices provision of this regulation as specified below. The 

application requirements described below do not apply to any metal furniture coating unit that 

achieves an emission reduction efficiency of 95 percent or greater.

Table 16: Large Appliance Coating VOC Content Limits - VOC Content Limits are 

expressed as mass (either kg or lb) per volume (either l or gal) of coating less water and 

exempt compounds, as applied

Coating Category

Baked Air Dried

Kg VOC/l 

coating

lb VOC/gal 

coating

kg VOC/l 

coating

lb VOC/gal 

coating

General, one-component 0.275 2.3 0.275 2.3

General, multi-component 0.275 2.3 0.340 2.8

Extreme high-gloss 0.360 3.0 0.340 2.8

Extreme performance 0.360 3.0 0.420 3.5

Heat-resistance 0.360 3.0 0.420 3.5

Metallic 0.420 3.5 0.420 3.5

Pretreatment 0.420 3.5 0.420 3.5

Solar-absorbent 0.360 3.0 0.420 3.5
30

No owner or operator of a metal furniture coating unit subject to this section should apply a 

coating to metal furniture unless the coating is applied with equipment properly operated and 

maintained according to the manufacturer’s suggested guidelines and using one or more of the 

following coating application methods:

1. Electrostatic spray.

2. Flow coating.

3. Dip coating, including electrodeposition.

4. Roll coating.

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

6. Hand application.

7. An alternative method that is demonstrated to be capable of achieving a transfer efficiency 

equal to or better than HVLP spray and approved by the Department and EPA.

The SIP revision also amends section 20.0 in order to: (1) establish exemptions, (2) establish 

control devices, and (3) establish test methods, compliance certification, recordkeeping, and 

reporting requirements based on EPA CTGs.

IV. Revisions to Section 22.0 Coating of Miscellaneous Metal Parts

Applicability

The provisions of this section apply to any miscellaneous metal parts and products coating unit. 

Every owner or operator of any miscellaneous metal parts and products coating unit shall comply 

with this section on and after April 11, 2010. A transition period exists for sources that have been 

previously permitted. Every owner or operator of any miscellaneous metal parts and products

coating unit that has a permit issued pursuant to 7 DE Admin Code 1102 or 1130 containing all 

applicable conditions of this section of this regulation as that regulation existed on January 11, 

1993, needs to comply with those permit conditions until December 31, 2010. On and after 

January 1, 2011, every such owner or operator of any miscellaneous metal parts and products 

coating unit, shall comply with the provisions of 22.0 of this regulation. The provisions of this 

section do not apply to any miscellaneous metal parts and products coating unit within a facility 

whose actual emissions without control devices from all large appliance coating units within the 

facility, including related cleaning activities, are less than 6.8 kg, 15 lb of VOC per day. An 

owner or operator of a facility whose emissions are below this applicability threshold described 

above shall comply with the certification, recordkeeping and reporting requirements of this 

section.

Definitions

The revisions to section 22.0 delete the following definitions: Air dried coating, baked coating, 

clear coating, extreme environmental conditions, extreme performance coatings, and refinishing.

The revisions add the following definitions:

Camouflage coating- means a coating used principally by the military to conceal equipment from 
31

detection.

Electric-insulating varnish- means a non-convertible-type coating applied to electric motors, 

components of electric motors or power transformers, to provide electrical, mechanical and 

environmental protection or resistance.

Etching filler-means a coating that contains less than 23 % solids by weight and at least 0.5 

percent acid by weight and is used instead of applying a pretreatment coating followed by a 

primer.

High-performance architectural coating- means a coating used to protect architectural subsections 

and which meets the requirements of the Architectural Aluminum Manufacturer Associations 

publication number AAMA 2604-05a (Voluntary Specification, Performance Requirements and 

Test Procedures for High Performance Organic Coatings on Aluminum Extrusions and Panels) or 

2605-05 (Voluntary Specification Performance Requirements and Test Procedures for Superior 

Performing Organic Coatings on aluminum Extrusions and Panels).

High-temperature coating- means a coating that is certified to withstand a temperature of 1000°F 

for 24 hours.

Military specification coating- means a coating which has a formulation approved by a United 

States military agency for use on military equipment.

Pail- means any cylindrical metal shipping container of 1 to 12-gallon capacity and constructed of 

29-gauge and heavier material.

Pan-backing coating- means a coating applied to the surface of pots, pans, or other cooking 

implements that are exposed directly to a flame or other heating elements.

Prefabricated architectural component coating- means a coating applied to a metal part and 

product which is to be used as an architectural structure.

Silicone-releasing coating-means a coating which contains silicone resin and is intended to 

prevent food from sticking to metal surfaces such as baking pans.

The revisions revise the following definitions:

Drum-means any cylindrical metal shipping container larger than 12 gallons capacity, but no 

larger than 110 gallons capacity.

Miscellaneous metal parts and products coating unit-(deleted provision #8 from the definition).

Due to public comments received at its public hearing, Delaware revised the term, “hand-held 

aerosol cans” to “Aerosol coating product.” A definition for the term “aerosol coating product” 

has been added to Section 2.0, Definitions, since other Regulation 1124 sections and other 

existing Delaware air regulations also use this term.
32

Standards

No owner or operator of a miscellaneous metal parts and products coating unit subject to this 

section shall cause or allow the application of any coating to miscellaneous metal parts and 

products unless:

1. The VOC content of the coating is less than or equal to the limits in Table 17 below, or

2. For a miscellaneous metal parts and products coating unit that applies multiple coatings, 

which are subject to the same numerical emission limitation in Table 17 below, the dailyweighted average VOC content, is less than or equal to the limit in Table 17 corresponding to the 

category of coating used, or 

3. Control equipment is installed and operated that achieves an emission reduction efficiency in 

accordance with the stipulations in this section. The application requirements described below 

shall not apply to any metal parts and products coating unit that achieves an emission reduction 

efficiency of 95 percent or greater.

No owner or operator of a miscellaneous metal parts and products coating unit subject to this 

section shall apply a coating to miscellaneous metal parts and products unless the coating is 

applied with equipment properly operated and maintained according to the manufacturer’s 

suggested guidelines and using one or more of the following coating application methods:

1. Electrostatic spray.

2. Flow coating.

3. Dip coating, including electrodeposition.

4. Roll coating.

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

6. Hand application.

7. An alternative method that is demonstrated to be capable of achieving a transfer 

efficiency equal to or better than HVLP spray and approved by the Department and 

EPA.

The following types of coatings are exempt from the application methods of this section:

1. Texture coatings

2. Repair and Touch-up coatings.

Table 17: Metal Parts and Products Coating VOC Content Limits - VOC content limits 

are expressed as mass (either kg or lb) per volume (either l or gal) of coating less water and 

exempt compounds, as applied

Coating Category

Air Dried Baked

kg VOC/l 

coating

lb VOC/gal 

coating

kg VOC/l 

coating

lb VOC/gal 

coating

General One Component 0.34 2.8 0.28 2.3

General Multi Component 0.34 2.8 0.28 2.3
33

Camouflage 0.42 3.5 0.36 3.0

Electric Insulating Varnish 0.42 3.5 0.36 3.0

Electric Insulating and 

Thermal Conducting 

Coatings

0.42 3.5 0.36 3.0

Etching Filler 0.42 3.5 0.36 3.0

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

0.42 3.5 0.36 3.0

High Temperature 0.42 3.5 0.36 3.0

Magnetic Data Storage Disc 

Coatings

0.42 3.5 0.36 3.0

Metallic 0.42 3.5 0.36 3.0

Military Specification 0.34 2.8 0.28 2.3

Mold Seal 0.42 3.5 0.36 3.0

Pan Backing 0.42 3.5 0.36 3.0

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 Coatings 0.42 3.5 0.36 3.0

Repair and Touch Up 0.42 3.5 0.36 3.0

Safety Indicating Coatings 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

Solid-Film Lubricant 0.42 3.5 0.36 3.0

Stencil Coatings 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 0.36 3.0

Drum Coating, 

reconditioned, Interior

0.50 4.2 0.50 4.2

Based on comments received on its proposed regulation, DNREC made the following changes 

from its proposed rule to their final rules that are reflected in its final regulation.

1. Deleted the following exemptions from the VOC content and application method 

requirements: Stencil Coatings, Safety Indicating Coatings, Solid-Film Lubricant, Electric 

Insulating and Thermal Conducting Coatings, and Magnetic Data Storage Disc Coatings. These 

coating category exemptions, which are listed in the CTG, were inadvertently added to the 
34

proposed regulation, despite the fact that the current section 22.0 subjected these coatings to a 

VOC limit of 3.0 lb/gal (i.e., the limit applicable to “All other coatings”). This proposed change 

makes the proposed regulation less stringent than the current version—a condition called 

“backsliding.” The Department proposes to correct this by withdrawing these proposed new 

exemptions, and maintaining the existing allowable VOC content limits (see #2 below).

2. Changed Table 17 to maintain the VOC content limits that currently exist for the following 

coating categories: Stencil Coatings, Safety Indicating Coatings, Solid-Film Lubricant, Electric 

Insulating and Thermal Conducting Coatings, Magnetic Data Storage Disc Coatings.

The SIP revision also amends section 22.0 in order to: (1) establish exemptions, (2) establish 

control devices, and (3) establish test methods, compliance certification, recordkeeping, and 

reporting requirements based on EPA CTGs.

C. CONCLUSIONS AND RECOMMENDED AGENCY ACTION:

This SIP revision satisfies all requirements for an acceptable SIP. EPA evaluates that Regulation 

1124, Control of Volatile Organic Compounds - sections 12.0, 19.0, 20.0, and 22.0 contains the 

required elements for a federally enforceable rule: emission limitations, compliance procedures 

and test methods, compliance dates and record keeping provisions. Delaware’s SIP revision

contains special provisions that establishes definitions, specifies applicability, establishes 

standards, specifies exemptions, specifies control devices, and specifies general testing, 

compliance, recordkeeping, and reporting requirements. The amendments to sections 12.0, 19.0, 

20.0, and 22.0 meet the applicable requirements of the CAA, and the applicable EPA regulations 

and policy and can be approved.

EPA approval of the SIP revision is recommended. The regulations reduce the VOC contents of 

currently regulated coatings, regulate additional coating categories, require the use of coating 

application equipment that provides for high transfer efficiency, and require that clean-up solvent 

emissions be included in regulatory applicability determinations. The reduction of VOC 

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