Attainment and Maintenance of the National

Ambient Air Quality Standards

Revision Tracking No. 65

Allegheny County Health Department

Rules and Regulations

Article XXI, Air Pollution Control

Changes to Article XXI Sections in the SIP:

§2101.20 Definitions,

§2105.10 Surface Coating Processes,

§2105.77 Control of VOC Emissions from Large Appliance and Metal Furniture

Surface Coating Processes,

§2105.78 Control of VOC Emissions from Flat Wood Paneling Coating Process,

and

§2105.79 Control of VOC Emissions from Paper, Film, and Foil Surface Coating

Processes
§2101.20, Definitions (SIP Change);

§2105.10, Surface Coating Processes (SIP Change);§2105.77, Control of VOC Emissions from Large Appliance and Metal

Furniture Surface Coating Processes (SIP Change);

§2105.78, Control of VOC Emissions from Flat Wood Paneling Coating

Process (SIP Change);

§2105.79, Control of VOC Emissions from Paper, Film, and Foil SurfaceCoating Processes (SIP Change)

2. Technical Support Document3. Documentation of Public Hearing and Certifications

Public hearing notice

Transmittals of hearing notice to EPA & PA DEP

News ReleaseProof of publication of notice of hearing

Certification of hearing

Summary of Comments and responsesCertifications of approval and adoption

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§ 2101.20 DEFINITIONS

“Exterior panels” means panels made of solid wood, hardboard or waferboard. Paneling made

ofsolid wood or hardboard is typically primed at the manufacturing facility and finished in thefield, although some finishing may be performed during manufacturing. (effective January 1,

201]}

“Interior panels” means interior wall paneling that is usually grooved, frequently embossed andsometimes grain printed to resemble various wood species. Interior panels are typically

manufactured at the same facilities as tileboard, although in much smaller quantities. The

substrate can be hardboard, plywood, medium density fiberboard (MDF) or particleboard.

(effective January 1, 20]]}

“Flat wood panel coating” means protective, decorative or functional materials applied to flat

wood panel products, including interior panels, exterior panels or tileboard (class I hardboard).

(effective January 1, 20]]}

“Tileboard” means a premium interior wall paneling product made of hardboard that is used in

high moisture areas of the home including kitchens and bathrooms. Tileboard meets the

specifications for Class I hardboard approved by the American National Standards Institute.

(effective January 1, 20]]}

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

quantities greater than 3 pounds (1.4 kilograms) per hour, 15 pounds (7 kilograms) perday or 2.7 tons (2,455 kilograms) per year during any calendar year since January 1,

1987.

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

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

large appliance and metal furniture surface coating process as ofJanuary 1,

2011.

2. The limits from 2105.10 and Table 2105.10, number 5 for Paper coating,

no longer apply to the paper, film, and foil surface coating process as of

January 1, 2011.

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§ 2105.77 CONTROL OF VOC EMISSIONS FROM LARGE APPLIANCE AND

METAL FURNITURE SURFACE COATING PROCESSES

a. Applicability. Beginning January 1, 2011, this section applies to the owner or operator

of a large appliance or metal furniture surface coating process, where the total actual

VOC emissions from all large appliance or metal furniture surface coating operations,

including related cleaning activities, at that facility are equal to or greater than 15 pounds(6.8 kilograms) per day or 2.7 tons (2,455 kilograms) per twelve month rolling period.

The limits from § 2105.10 and Table § 2105.10 no longer apply to the large applianceand metal furniture surface coating process as ofJanuary 1, 2011.

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

atmosphere of VOCs from a large appliance or metal furniture surface coating process

unless one of the following limitations is met:

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

specified in Table 2105.77.

A. The VOC content of the as applied coating, expressed in units of weight of

VOC per volume of coating solids, shall be calculated as follows:

VOC =

Where:

VOC = VOC content in lb VOC/gal of coating solids

W0 = Weight percent of VOC (WvWwWex)W = Weight percent oftotal volatiles (100%-weight percent solids)W Weight percent of water

Wex = Weight percent of exempt solvent(s)

D = Density of coating, lb/gal, at 25°CV = Volume percent of solids ofthe as applied coating

B. The VOC content of a dip coating, expressed in units of weight of VOC

per volume of coating solids, shall be calculated on a 30-day rolling

average basis using the following equation:

(W01 x x Q’) + (Wc X DdJ X Qj)

VOCA =

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= Density of each as supplied coating (i) added to the dip coating

process, in pounds per gallon

QI = Quantity of each as supplied coating (i) added to the dip

coating process, in gallons

V1 = Percent solids by volume of each as supplied coating (i) added

to the dip coating process, expressed as a decimal fraction

W0 = Percent VOC by weight of each thinner (J) added to the dip

coating process, expressed as a decimal fraction

DdJ Density of each thinner (J) added to the dip coating process, in

pounds per gallon

Qj = Quantity of each thinner (J) added to the dip coating process, in

gallons

C. The VOC content limits ofsubparagraphs A and B may be met by

averaging the VOC content of materials used on a single surface coating

process line each day (i.e., daily within-coating unit averaging).

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

test methods specified in Part G (Methods).

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

of vapor recovery or incineration or another method which is acceptable under

§ 2105.01 (Equivalent Compliance Techniques). The overall efficiency of a

control system, as determined by the test methods and procedures specified in

Part G, shall be no less than 90% as calculated by the following equation:

90%(1 -E/V)xlOO

Where:

V The VOC content ofthe as applied coating, in lb VOC/gal of coating solidsE = The Table 2105.77 limit for large appliances and metal furniture surface

coatings in lbs VOC per gallon of coating solids

3. A combination ofthe methods listed in paragraphs 1 and 2.

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

large appliance or metal furniture surface coating processes, shall maintain records

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

maintain daily records of:

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E. The weight percent oftotal volatiles, water, solids and exempt solvents;F. The volume percent ofsolids, Table 2105.77 for large appliances or metal

furniture, for each coating used in the surface coating process.

2. The VOC content of each coating, thinner and other component as supplied.

3. The VOC content of each as applied coating.

The records shall be maintained for 2 years and shall be submitted to the Department on aschedule reasonably prescribed by the Department.

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

methylene chloride are exempt from control under this Section. No large appliance ormetal furniture surface coating process which seeks to comply with this Section throughthe use of an exempt solvent may be included in any alternative standard approved

pursuant to this Article.

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

outdoor atmosphere of VOCs from the application of large appliance or metal furniture

surface coatings unless the coatings are applied using one or more of the following

coating application methods:

1. Electrostatic spraying;

2. Roller coating;3. Flow coating;

4. Dip coating, including electrodeposition;

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

6. Brush coating;7. Other coating application method that the person demonstrates and the

Department determines achieves emission reductions equivalent to HVLP orelectrostatic spray application methods.

f. Emission Limitations. If more than one emission limitation in Table 2105.77 for large

appliances or metal furniture applies to a specific coating, the least stringent emissionlimitation applies.

g. Exempt Other. The VOC coating content standards in Table 2105.77 for large

appliances or metal furniture do not apply to a coating used exclusively for stencil

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facility.

2. The owner or operator ofthe facility requests, in writing, and the Department

approves, in writing, the exemption prior to use of the coating.

h. Housekeeping. The following work practices for coating-related activities and cleaning

materials apply to the owner or operator of a large appliance or metal furniture surface

coating process:

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

cleaning materials and used shop towels in closed containers.

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

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

all times except when depositing or removing these materials.

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

materials and cleaning materials, cleaning up spills immediately.

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

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

5. Minimize VOC emissions from cleaning ofstorage, mixing and conveying

equipment.

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(a) general, one component 0.40 3.3 0.40 3.3(b) general, multi-component 0.40 3.3 0.55 4.5(c) extreme high gloss 0.55 4.62 0.55 4.5

(d) extreme performance 0.55 4.62 0.55 4.62(e) heat resistant 0.55 4.62 0.55 4.62(f) metallic 0.55 4.62 0.55 4.62(g) pretreatment coatings 0.55 4.62 0.55 4.62

(h) solar absorbent 0.55 4.62 0.55 4.62

2. Metal Furniture coating

(a) general, one component 0.40 3.3 0.40 3.3(b) general, multi-component 0.40 3.3 0.55 4.5

(c) extreme high gloss 0.61 5.06 0.55 4.5(d) extreme performance 0.61 5.06 0.61 5.06(e)heatresistant 0.61 5.06 0.61 5.06(f) metallic 0.61 5.06 0.61 5.06

(g) pretreatment coatings 0.61 5.06 0.61 5.06(h)solarabsorbent 0.61 5.06 0.61 5.06

Page 9
a. Applicability. Beginning January 1, 2011, this section applies to the owner or operator

of a flat wood paneling coating process, where the total actual VOC emissions from all

flat wood panel surface coating operations, including related cleaning activities, at thefacility are equal to or greater than 15 pounds (6.8 kilograms) per day or 2.7 tons (2,455

kilograms) per twelve month rolling period.

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

atmosphere of VOCs from a flat wood paneling coating process, unless one ofthefollowing limitations is met:

1. The VOC content of each as applied coating is equal to or less than 2.9 lbs VOC

per gallon of coating solids (0.35 kg VOC per liter of coating solids).A. The VOC content of each as applied coating, expressed in units of weight

of VOC per volume of coating solids, shall be calculated as follows:

VOC = (W0)(D)N

Where:

VOC VOC content in lb VOC/gal of coating solids

W0 Weight percent of VOC (WvWwWex)WV = Weight percent of total volatiles (100%-weight percent solids)

W = Weight percent of waterWex = Weight percent of exempt solvent(s)

D Density of coating, lb/gal, at 25°CV Volume percent ofsolids ofthe as applied coating

B. The VOC content of a dip coating, expressed in units of weight of VOC

per volume of coating solids, shall be calculated on a 30-day rolling

average basis using the following equation:

j (W x D0 x Q’) + j(W0jx DdJ x Qj)

VOCA

j (Vx Q’)

Where:

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Q Quantity of each as supplied coating (i) added to the dip

coating process, in gallons

V1 = Percent solids by volume of each as supplied coating (i) added

to the dip coating process, expressed as a decimal fraction

W0j= Percent VOC by weight of each thinner (J) added to the dip

coating process, expressed as a decimal fraction

DdJ = Density of each thinner (J) added to the dip coating process, in

pounds per gallon

Qj = Quantity of each thinner (J) added to the dip coating process, in

gallons

C. The VOC content limits of subparagraphs A and B may be met by

averaging the VOC content of materials used on a single surface coating

process line each day (i.e., daily within-coating unit averaging).

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

test methods specified in Part G (Methods).

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

of vapor recovery or incineration or another method which is acceptable under

§ 2105.01 (Equivalent Compliance Techniques). The overall efficiency of a

control system, as determined by the test methods and procedures specified inPart G, shall be no less than 90% as calculated by the following equation:

90%=(1-EIV)xlOO

Where:

V = The VOC content ofthe as applied coating, in lb VOC/gal of coating solidsE = Limit of 2.9 lbs VOC per gallon of coating solids (0.35 kg VOC per liter of

coating solids)

3. A combination ofthe methods listed in paragraphs 1 and 2.

c. Records. A facility, regardless ofthe facility’s annual emission rate, which contains flat

wood paneling coating processes, shall maintain records sufficient to demonstratecompliance with this section. At a minimum, a facility shall maintain daily records of:

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F. The volume percent of solids for each coating used in the flat wood

paneling coating process.

2. The VOC content of each coating, thinner and other component as supplied.

3. The VOC content of each as applied coating.

The records shall be maintained for 2 years and shall be submitted to the Department on aschedule reasonably prescribed by the Department.

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

methylene chloride are exempt from control under this Section. No flat wood panelingcoating process which seeks to comply with this Section through the use of an exempt

solvent may be included in any alternative standard approved pursuant to this Article.

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

outdoor atmosphere of VOCs from the flat wood paneling coatings unless the coatingsare applied using one or more ofthe following coating application methods:

1. Electrostatic spraying;

2. Airless coating;3. Curtain coating;

4. Roller coating;

5. Flow coating;6. Dip coating, including electrodeposition;7. High volume-low pressure (HVLP) spraying;8. Hand brush or roller coat;

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

Department determines achieves emission reductions equivalent to HVLP orelectrostatic spray application methods.

f. Exempt Other. The VOC coating content standard of 2.9 lbs VOC per gallon of coating

solids (0.35 kg VOC per liter of coating solids) do not apply to a coating used exclusively

for stencil coatings, touch-up and repair coatings, coating applications using hand-heldaerosol cans, air atomized sprays that apply cosmetic specialty coatings, ifthe volume of

the cosmetic specialty coatings is less than 5% by volume ofthe total coating used at the

source or to apply finial repair coatings, coatings used exclusively for determining

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approves, in writing, the exemption prior to use ofthe coating.

g. Housekeeping. The following work practices for coating-related activities and cleaning

materials apply to the owner or operator of a flat wood paneling coating process:

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

cleaning materials and used shop towels in closed containers.

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

thinners, coating-related waste materials and cleaning materials are kept closed atall times except when depositing or removing these materials.

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

materials and cleaning materials, cleaning up spills immediately.

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

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

5. Minimize VOC emissions during cleaning ofstorage, mixing, and conveying

equipment.

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a. Applicability. Beginning January 1, 2011, this section applies to the owner or operator

of a paper, film, and foil surface coating process, where the total actual VOC emissionsfrom all paper, film, and foil surface coating operations, including related cleaning

activities, at that facility are equal to or greater than 15 pounds (6.8 kilograms) per day or2.7 tons (2,455 kilograms) per twelve month rolling period. The limits from § 2105.10and Table § 2105.10 no longer apply to the paper, film, and foil surface coating processas ofJanuary 1,2011.

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

atmosphere of VOCs from a paper, film, and foil surface coating process unless one of

the following limitations is met:

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

specified in Table 2105.79.

A. The VOC content of the as applied coating, expressed in units of weight of

VOC per weight of coating solids, shall be calculated as follows:

VOCB = (W0)/(W)

Where:

VOCB VOC content in lb VOC/lb of coating solidsW0 = Weight percent of VOC (WvWwWex)

Wi,, Weight percent oftotal volatiles (100%-weight percent solids)

= Weight percent of water

Wex = Weight percent of exempt solventsW = Weight percent ofsolids ofthe as applied coating

B. The VOC content of a dip coating, expressed in units of weight of VOC

per weight of coating solids, shall be calculated on a 30-day rolling

average basis using the following equation:

j (Wcjj x D1 x Q’) + j(W0jx DdJ x Qj)

VOCA =

j (‘Wrn x D1 x Q’)

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process, in pounds per gallon

Q1 = Quantity of each as supplied coating (i) added to the dip

coating process, in gallons

W11 = Percent solids by weight of each as supplied coating (i) added

to the dip coating process, expressed as a decimal fraction

W0j = Percent VOC by weight of each thinner (J) added to the dip

coating process, expressed as a decimal fraction

DdJ = Density of each thinner (J) added to the dip coating process, in

pounds per gallon

Qj = Quantity of each thinner (J) added to the dip coating process, in

gallons

C. The VOC content limits ofsubparagraphs A and B may be met by

averaging the VOC content of materials used on a single surface coating

process line each day (i.e., daily within-coating unit averaging).

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

test methods specified in Part G (Methods).

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

of vapor recovery or incineration or another method which is acceptable under

§ 2105.01 (Equivalent Compliance Techniques). The overall efficiency of a

control system, as determined by the test methods and procedures specified inPart G, shall be no less than 90% as calculated by the following equation:

90%=(1-E/V)xlOO

Where:

V = The VOC content ofthe as applied coating, in lb VOC/lb of coating solids

E The Table 2105.79 limit for paper, film, and foil surface coating in lbs VOC

per lbs of coating solids

3. A combination of the methods listed in paragraphs 1 and 2.

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

paper, film, and foil surface coating processes, shall maintain records sufficient to

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

records of:

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F. The volume percent of solids, Table 2105.79 for paper, film, and foil, for

each coating used in the surface coating process..

2. The VOC content of each coating, thinner and other component as supplied.

3. The VOC content of each as applied coating.

The records shall be maintained for 2 years and shall be submitted to the Department on aschedule reasonably prescribed by the Department.

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

methylene chloride are exempt from control under this Section. No paper, film, and foil

surface coating process which seeks to comply with this Section through the use of anexempt solvent may be included in any alternative standard approved pursuant to this

Article.

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

outdoor atmosphere of VOCs from the application of paper, film, and foil surface

coatings unless the coatings are applied using one or more ofthe following coatingapplication methods:

1. Rotogravure (web-fed gravure).

2. Reverse roll coating.

3. Slot die coating.

4. Knife coating.

5. Flexographic coating.

6. Mayer rod or wire-wound rod coating.7. Dip and squeeze coating.

8. Extrusion coating, including calendaring

f. Emission Limitations. If more than one emission limitation in Table 2105.79 for paper,

film, and foil surface coating applies to a specific coating, the least stringent emissionlimitation applies.

g. Exempt Other. The VOC coating content standards in Table 2105.79 for paper, film,

and foil surface coatings do not apply to a coating used exclusively stencil coatings,

touch-up and repair coatings, coating applications using hand-held aerosol cans, coatings

Page 16
approves, in writing, the exemption prior to use ofthe coating.

h. Housekeeping. The following work practices for coating-related activities and cleaning

materials apply to the owner or operator of a paper, film, and foil surface coating process:

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

cleaning materials and used shop towels in closed containers.

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

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

all times except when depositing or removing these materials.

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

materials and cleaning materials, cleaning up spills immediately.

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

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

5. Minimize VOC emissions from cleaning ofstorage, mixing and conveying

equipment.

Table 2105.79

Emission Limits of VOCs for Paper, Film, and Foil Surface Coatings

Weight of VOC per Weight of Solids or Coating Applied

Solids Applied Coating Applied

kg VOC/kg solids kg VOC/kg coatings

Surface Coating Process Category (lb VOC/ib solids) (lb VOC/ib coatings)

Pressure Sensitive Tape and Label 0.20 0.067

2. Paper, Film, and Foil 0.40 0.08

(Not including Pressure Sensitive Tape and Label)

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to these CTG regulations void after 1/1/20 11.

§2101.20, Definitions (SIP Change);§2105.10, Surface Coating Processes (SIP Change);§2105.77, Control of VOC Emissions from Large Appliance and Metal Furniture

Surface Coating Processes (SIP Change);§2105.78, Control of VOC Emissions from Flat Wood Paneling Coating Process

(SIP Change);

§2105.79, Control of VOC Emissions from Paper, Film, and Foil Surface Coating

Processes (SIP Change)

The CTG categories for Large Appliances Coatings, Metal Furniture Coatings and Paper, Film,and Foil Coatings were issued by the EPA in 2007; the CTG for Flat Wood Paneling Coatings

was issued by the EPA in 2006. The EPA has mandated that these CTGs become regulations,

written by Local or State Air Pollution Control Agencies.

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

§2105.77, §2105.78 and §2105.79 to Article XXI constitute a change to the Allegheny County

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

respect to those sections.

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