UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III

1650 Arch Street

Philadelphia, Pennsylvania 19103

DATE: April 15, 2013

SUBJECT: Technical Support Document for Maryland’s Adoption of Control Techniques 

Guidelines (CTG) for Miscellaneous Metal and Plastic Parts which Includes 

Pleasure Craft Coating Operations

FROM: Gregory Becoat, Environmental Scientist /s/

Office of Air Program Planning

TO: File

THRU: Cristina Fernandez, Associate Director /s/

Office of Air Program Planning

A. BACKGROUND: 

On January 10, 2013, the Maryland Department of the Environment (MDE) submitted a revision 

to the State of Maryland State Implementation Plan (SIP). The SIP revision includes a new 

Regulation .27-1 under the Code of Maryland Regulations (COMAR) 26.11.19 – Volatile 

Organic Compounds from Specific Processes in order to adopt the recommended level of control 

requirements of EPA’s Control Technique Guideline (CTG) for miscellaneous metal and plastic 

parts which include controls for pleasure craft coating operations.

Section 172(c)(1) of the Clean Air Act (CAA) provides that SIPs for nonattainment areas must 

include reasonably available control measures (RACM), including 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 CTG document issued after November 15, 1990 and prior to the Area’s date of attainment. 

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, September 17, 1979). 

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. Section 183(e)(3)(c) provides that 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 
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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’s Miscellaneous Metal and Plastic Parts Coatings CTG

EPA developed the CTG for Miscellaneous Metal and Plastic Parts Coatings (MMPPC) after 

reviewing the 1978 CTG, the 1988 new source performance standards (NSPS) for Surface 

Coating of Plastic Parts for Business machines, the 1994 Alternative Control Techniques (ACT) 

document (1994 ACT) for controlling VOC emissions from surface coating of 

automotive/transportation and business machine plastic parts, the National Emission Standards 

for Hazardous Air Pollutants for Miscellaneous Metal Parts and Products Surface Coating, and 

existing State and local VOC emission reduction approaches.

The miscellaneous metal product and plastic parts surface coatings categories under section 

183(e) of the CAA include the coatings that are applied to the surfaces of a varied range of metal 

and plastic parts and products. Such parts or products are constructed either entirely or partially 

from metal or plastic. These miscellaneous metal products and plastic parts 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 vehicles, lawn and 

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

steel drums, metal pipes, and numerous other industrial and household products. 

The pleasure craft coating category does 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 or 

included in other CTGs. As a result, members of the pleasure craft coatings industry contacted 

EPA requesting reconsideration of the pleasure craft VOC limits contained in EPA's 2008 

MMPPC CTG. In response, EPA issued a memorandum on June 1, 2010, titled “Control 

Technique Guidelines for Miscellaneous Metal and Plastic Part Coatings - Industry Request for

Reconsideration,” recommending that the pleasure craft industry work with state agencies during 

their RACT rule development process to assess what is reasonable for the specific sources 

regulated. EPA stated that states can use the recommendations from the MMPPC CTG to form 

their own determinations as to what constitutes RACT for pleasure craft coating operations in 

their particular ozone nonattainment area. CTG imposes no legally binding requirements on any 

entity, including pleasure craft coating facilities. As stated in the memorandum, EPA will 

evaluate state-developed RACT rules and determine whether the submitted rules meet the RACT 

requirements of the CAA.
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B. STATE SUBMITTAL:

MDE’s SIP revision for the control of VOCs from pleasure craft coating operations adopts some 

of the recommended requirements of EPA’s MMPPC CTG, as well as alternative standards

based on the recommendations of the pleasure craft industry for the following coatings: Finish 

Primer/Surfacer; Antifouling Sealer/Tiecoat; Other Substrate Antifoulant; and Extreme High 

Gloss. 

I. New Regulation COMAR 26.11.19.27-1 – Control of Volatile Organic Compounds from 

Pleasure Craft Coating Operations

The SIP revision added Regulation .27-1 in order to establish applicability for pleasure craft and 

fiberglass boat coating operations at facilities with actual VOC emissions of 15 pounds or more 

per day (15 lb/day) from coating operations as determined on a monthly average on or after

January 1, 2013. The SIP revision also establishes exemptions for the following: (1) coatings 

applied using a hand-held, pressurized, nonrefillable container which expels coatings from the 

container in finely divided spray when a valve on the container is depressed; (2) coatings applied 

to recoat portions of a product which as sustained mechanical damage to the coating following 

normal painting operations; (3) coatings applied to cover minor coating imperfections appearing 

after the main coating operation; and (4) coatings or resins applied during the manufacturing 

process.

The SIP revision adds the following definitions to Regulation .27-1: “Antifouling sealer/tiecoat,” 

“Extreme high gloss coating,” “Fiberglass boat,” “Finish primer/surface,” “High build 

primer/surface,” “Pleasure craft,” “Pleasure craft coating,” and “Pretreatment wash primer.” The 

SIP revision also incorporates by reference testing methods and specifies VOC limit 

requirements for pleasure craft coating operations in Table 1 below. MDE added an additional 

specialty category of “Anitfouling Sealer/Tie Coat” with a VOC limit of 420 grams/liter (g/L); 

amended the VOC emission limits in the category, “Other Substrate Anitfoulant Coating” from 

330 g/L to 400 g/L; amended the CTG “Finish Primer/Surfacer” VOC limit from 420 g/L to 600 

g/L; and amended the “Extreme High Gloss” VOC limit form 420 g/L to 600 g/L. For these four 

categories, Maryland reviewed industry data and determined that for the purpose of functionality, 

cost, and VOC emissions, the alternative limits adopted for these four coating categories 

constitute RACT.

Table 1. Pleasure Craft Coating Standards (Expressed in Terms of Mass of VOC per 

Volume of Coating Excluding Water and Exempt Compounds, as Applied)

Coating Types lbs VOC/gallon kg VOC/liter

Extreme high gloss topcoat 5.0 0.60

High gloss topcoat 3.5 0.42

Pretreatment wash primers 6.5 0.78

Finish primer/surface

 Applicable through March 31, 2014 5.0 0.60
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Coating Types lbs VOC/gallon kg VOC/liter

 Applicable through March 31, 2014 3.5 0.42

High build primer/surface 2.8 0.34

Aluminum substrate antifoulant coating 4.7 0.56

Antifouling sealer/tiecoat 3.5 0.42

Other substrate antifoulant coating 3.3 0.40

All other pleasure craft surface coatings 3.5 0.42

The SIP revision establishes that the least stringent emission limitation is applicable if more than 

one emission limitation in Table 1 applies to a specific coating. The SIP revision also establishes 

the following application methods, except for the application of Extreme high gloss coating: (1) 

Electrostatic application, (2) High Volume Low Pressure (HVLP) spray, (3) Flow coat, (4) Roller 

coat, (5) Dip coat including electrodeposition, (6) Brush coat, (7) Airless spray, and (8) Other 

coating application method that has a transfer efficiency equivalent to or better than that achieved 

by HVLP spraying.

C. CONCLUSIONS AND RECOMMENDED AGENCY ACTION:

This SIP revision satisfies all requirements for an acceptable SIP. The addition of new 

Regulation .27-1 under COMAR 26.11.19 Volatile Organic Compounds from Specific Processes

meet the applicable requirements of the CAA, and the applicable EPA regulations, guidance, and 

policy and strengthen the SIP. The State of Maryland generally implemented the requirements as 

recommended by the MMPPC CTG by including applicability, standards, exemptions, 

definitions, requirements for testing, and application methods for pleasure craft coatings with the

exception of adopting the pleasure craft industry recommendations for the following four coating 

categories: Finish Primer/Surfacer; Antifouling Sealer/Tiecoat; Other Substrate Antifoulant; and 

Extreme High Gloss. EPA believes that Maryland’s approach is consistent with the guidance 

memorandum entitled, “Control Technique Guidelines for Miscellaneous Metal and Plastic Part 

Coatings - Industry Request for Reconsideration,” and therefore, believes that these regulations 

reflect RACT. This SIP revision satisfies all requirements for an acceptable SIP and for 

RACM/RACT. EPA is proposing approval of the SIP revision.