1 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

1650 Arch Street Philadelphia, Pennsylvania 19103

DATE: June 23, 2015

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

Guidelines (CTG) for M etal Furniture and M iscellaneous Metal Parts Coatings

FROM: Ellen Schmitt

Office of Air Program Planning

TO: File

THRU: Cristina Fernandez , Associate Director /s/

Office of Air Program Planning

A. BACKGROUND

S ection 172(c)(1) of the Clean Air Act (CAA) provi des that S tate I mplementation P lans (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 f

or certain nonattainment areas, s tates must revise their SIP to include RACT for

sources of volatile organic compound ( VOC ) emissions covered by a control technique s guideline (CTG) document issued after November 15, 1990 and prior to the A rea’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 feasibili ty ” (44 FR 53761, Sept. 17, 1979 )

. In subsequent Federal Register notices, EPA has addressed how states can mee t the RACT requirements of the CAA

.

CTG s are documents issued by EPA that provide state and local air pollution control authorities

informatio n that should assist t hem 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 s tate regulations t o implement the recommendations

contained therein

, or they can adopt alternative approaches

. In either case, s tates must submit their RACT rules to EPA for review and approval as part of the SIP process.

EPA will evaluate the rules and determine, throu gh notice and comment rulemaking in the SIP approval process, whether the submitted rules meet the RACT requirements of the CAA and EPA’s regulations.2

Metal Furniture Coating CTG (EPA 453/R

- 07

- 005, September 2007)

In December 1977, EPA issued a CTG docu ment for controlling VOC emissions from the coating of metal furniture. In October 1982, EPA promulgated the new source performance standards ( NSPS ) for the Surface Coating of Metal Furniture, and in May 2003, EPA promulgated the National Emission Standar ds for Hazardous Air Pollutants ( 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 T echnique Guidelines for Metal Furniture Coatings” (EPA

453/R

- 07

- 005).

Coatings used in metal furniture coating operations include paints, sealants, caulks, ink, adhesives, and maskants. 1 It is recommended that the control approaches discussed herein appl y to each metal furniture coating unit 2 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. 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 i ncludes the coatings that are applied to 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: H ousehold, 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, sh elving, 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 extensivel y in the metal furniture coating indust ry. 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 red ucing VOC emissions from the use of coatings applied t o each metal furniture 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

1 Decorative, 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.

2 A coating unit consists of a se ries 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 differe nt coating. It is not necessary for a coating unit to have an

oven or flash

- off area.3

VOC emissions or an equiva lent 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, emiss ions 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 relati vely 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 thinni ng 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 typ ical 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 c ured 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 m ay be used to apply coatings. The most common types of coating applicators include: A ir atomized spray coating, electrostatic spray coating, high volume/low pressure (HVLP) spray coating, dip coating, flow coating, roll coating, electrocoating, and autop horetic coating.

CTG Recommended Control Options

As stated previously, there are two main sources of VOC emissions from metal furniture 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 CTG4

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

coatin gs 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, excludi ng 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 s pecific 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 coating operations are summarized below

.

Emissions Limits Base d on Low

- VOC C oatings

- Option

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 o f these coating types, separate emission limits are recommended for baked and air

dried coatings. Table 1 provides the recommended emission limits expressed in terms of mass of VOC per volume of coating (excluding water and exempt compounds, as applied) f or option 1,

content limits based on low

- VOC coatings

. 3

Table 1 . Metal Furniture Coating VOC Content Limits

– VOC Content Limits are Expressed as Mass (Kilogram (kg) or Pound (lb)) Per Volume (Liter (l) for Gallon (gal) ) of Coating Less Water and Exempt Compounds, as Applied Coatings Type Baked Air Dried

k g VOC /l coating l b VOC /gal

coating k g VOC /l

coating l b 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 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

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

content limi ts: S tencil coatings, safety

- indicating coatings, solid

- film lubricants, electric

insulating and thermal conducting coatings, touch

- up and repair coatings, and coating applications utilizing hand

- held aerosol cans.

3 Maryland used option 1, limits based on low

- VOC coatings, from the control options listed in the Metal Furniture Coatings CTG (EPA 453/R

- 07

- 005, September 2007) and on ly the emission limits for option 1 are listed in this TSD. Further details of the other control options and the accompanying emission limits per coating type can be found in the CTG for metal furniture coatings.5

The CTG recommends that all VOC

- containing materials used by each metal furniture coating unit be included when determining the coating unit’s emission rate. Additionally, the following applica tion methods are recommended: E lectrostatic application, HVLP sp ray, flow coat, roller coat, dip coat including electrodeposition, or brush coat.

Work Practices for Coating Operations and Cleaning Materials

Work practices to further reduce emissions from the coatings as well as minimize emissions from cleaning materi als 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, mix ing, and conveying of equipment.

Miscellaneous Metal and Plastic Parts Coatings CTG ( EPA 453/R

- 08

- 003, September 2008 )

In June 1978, EPA issued a CTG document for controlling VOC emissions from the coating of miscellaneous metal parts and products. In Janu ary 1988, EPA promulgated the NSPS for the Surface Coating of Plastic Parts for Business Machines. In February 1994, EPA issued an Alternative Control Techniques (ACT) document for controlling VOC emissions from the coating of automotive/transportatio n and business machine plastic parts. In January 2004, EPA promulgated the 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 1 978 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 s Gui delines for Miscellaneous Metal and Plastic Parts Coatings” (EPA 453/R

- 08

- 003, September 2008). 4

Miscellaneous metal product s part s coatings include, but are not limited to, the coatings that are applied to the surfaces of a varied range of metal parts

. These parts or products are constructed either entirely or partially from metal. They include, but are not limited to, metal components of the following types of products as wel l as the products themselves: F abricated metal products, small and large farm machinery, commercial and industrial machinery and equipment, automotive or transportation equipment, interior or exterior automotive parts, construction equipment, motor vehicle accessories, bicycles and sporting goods, toys, recreational vehicles, pleas ure craft (recreational boats) 5 , extruded aluminum structural components, railroad cars,

heavier vehicles 6 , lawn and garden equipment, business machines, laboratory and medical

4 Maryland previously submitted, and EPA approved, a SIP revision to meet the requirements to adopt RACT for plastic part coatings covered by the CTG for Miscellaneous Metal and Plastic Parts Coatings. See 76 FR 64020 (October 17, 2011)

. 5 Maryland previously submitted, and EPA approved, a SIP re vision to meet the requirements to adopt RACT for pleasure craft coatings covered by the CTG for Miscellaneous Metal and Plastic Parts Coatings. See 78 FR 59240 (September 26, 2013)

. 6 Heavier vehicles includes all vehicles that meet the definition of th e term “other motor vehicles,” as defined in the6

equipment, electronic equipment, steel drums, metal pipes, and numerous other i ndustrial and household products (hereinafter collectively referred to as “miscellaneous metal parts”)

. The CTG applies to manufacturers of miscellaneous metal parts that surface

- coat the parts they produce . Miscellaneous metal parts coatings do not incl ude coatings that are a part of other product categories listed under s ection 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 product s coatin gs 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 i n the miscellaneous metal parts coatings categories addressed by this CTG.

Applicability

The September 2008 CTG for Miscellaneous Metal and Plastic Parts Coating s provides recommendations for reducing VOC emissions from the use of coatings in a misc ellan eous metal products coating unit at a facility where the total actual VOC emissions from all miscellaneous

metal parts coating operations, including related cleaning activities

, at that facility

, are equal to or exceed 6.8 kg/day

, 15 lb/day , or an equivale nt level of 2.7 t ons per 12

- month rolling period

, before con sideration 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 coati ng 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 app licability 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 p arts coatings or the stat e RACT requirements for auto and light

- duty truck coatings. 7

Sources of VOC Emissions

Primarily, VOC emissions from miscellaneous metal product s parts coating operations result from the evaporation of volatile components from the coatings and cleaning ma terials. The majority of VOC emiss ions 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 prepara tion, storage, handling, and waste/wastewater operations are relatively small.

National Emission Standards for Surface Coating of Automobile and Light

- Duty Trucks at 40 CFR 63.3176.

7 Maryland ’s SIP submission to meet requirements as recommended by the CTG for Miscellaneous Metal and

P lastic Parts Coatings includes heavier vehicle coatings as a type of miscellaneous metal coating

.7

Coating Application

Surface coating of miscellaneous metal product s parts surfaces is applied by applying a coating to the metal 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 u sed and the resulting VOC emissions from the operation. The most common types of liquid coating applicators include: A ir atomized spray coating, electrostatic spray

coa ting, 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.

CTG Recommended Cont rol Options

As stated previously, there are two main sources of VOC emissions from miscellaneous metal parts coating operations: (1) evaporation of the VOC components of the coatings; and (2) evaporation of VOC from the cleaning materials. To control VO C emissions from miscellaneous metal part s 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 efficienc y; (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 V OC control efficiency of 90 percent for facilities that choose to add

on controls inste ad of low

- VOC content coatings and specified application methods. The low

VOC coatings recomm e ndation (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 opti on 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: E lectrostatic application, HVLP spray, flow coat, roller coat, dip coat (including electrodep osition), 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 add

on control option, (Option 3), a facility would use an emissio n c apture system and add

- on control

device to achieve an overall emission capture and control ef ficiency of at least 90 percent. The facility would not have to limit the VOC c ontent of the coating materials and would not need to

use any part ic ular coating application method.8

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 low

VOC 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 emi ssions from coatings as well as to

minimize emissions from cleani ng materials used in the coating process are recommended.

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

recommends VOC limits and application me thods not apply to certain types of coatings and coating operations. For all coating operations, it is recommende d that the VOC limits and application methods not apply to aerosol coatings products or powder coatings. Aerosol coatings

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

low

- VOC alternative to many liquid coatings.

The CTG recommend s that for all metal parts coatings, only the recommended work practices, but not the recommended VOC limits and appl ication methods, apply to the following types of

coa tings and coating operations: S tencil coatings, safety indicating coatings, solid

- film lubricants, electric

- insulating and thermal

- conducting coatings, magnetic data storage disk coatings, and plastic ex truded 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 an d work practices apply

.

F or 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 o ption 1 , VOC content limits based on low

- VOC coatings, s eparate sets of emission limits for metal parts coatings, plastic parts coatings, automotive/transportation and business machine plastic parts, and pleasure craft coatings are recommended. 8 Separate emission limits for baked

and air

- dried coatings is recommended. Table 2 provides the recommended emission limits expressed in terms of mass of VOC per volume of coating (excluding water and exempt compounds, as applied) for option 1

.

8 Maryland used option 1 from the control options listed in the Miscellaneous Metal and Plastic Parts Coatings CTG (EPA 453/R

- 08

- 003, September 2008) . O nly the emission limits for option 1 , and for metal parts coatings, are listed in this TSD. Further details of the other control options and the accompanying emission limits per coating type for miscellaneous metal parts can be found in the CTG.9

Table 2 . Metal Parts and Products VOC Content Limits

– VOC Content Limits are Expressed as Mass (Kilogram (kg) or Pound (lb)) Per Volume (Lit er (l) or Gallon (gal) ) of Coating Less Water and Exempt Compounds, as Applied

Air Dried Baked Coating Category kg VOC/l coating lb VOC/gal

coating kg VOC/l

c oating lb VOC/gal

coating

General One Component 0.34 2.8 0.28 2.3

General

Multi

- Componen t 0.34 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 Performa nce 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

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 0.42 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

Work Practices for Coating Operations and Cleaning Materials

In addition to the control options mentioned above, the CTG recommends work practices to further reduce VOC emissions from miscellaneous metal part s coating

- related activities. Specifical ly, 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

- co ntaining cleaning materials are ke pt closed at all times except when depositing or removing these materials; (3) minimize spills of VOC

- containing cleaning materials; (4) convey VOC

- containing cleaning materials from one location to another10

in closed containers or pipes; and (5) minimize V OC 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.

B. STATE SUBMITTAL

On July 28, 2014

, Maryland Department of the Environment (MDE) submitted a SIP revision to EPA adoptin g the requirements of EPA ’s CTGs for metal furniture, and miscella n eous metal

parts. EPA develops CTGs as guidance on control requirements for source categ ories. States

can follow the recommendations of a CTG and adopt state regulations to implement the recommendations contained therein, or they can adopt alternative approaches. With one exception, MDE is adopting EPA’s CTG standards for the coating of mis cellaneous metal , and

metal furniture , and incorporating them into their Regulation .08 under COMAR 26.11.19.

Maryland’s SIP submission included one alternative approach for meeting VOC RACT, by adding robotic application of heavy

- duty engine coatings a s an appropriate method for coating application s as long as the transfer efficiency is equivalent or better than the efficiency achieved by HVLP spraying.

The following changes are being made to COMAR 26.11.19.08 in the Maryland SIP :

The title of s ecti on 26.11.19.08 is being changed from “Metal Furniture Coating” to “Metal Parts and Products Coating”

Definitions for the following are added in s ection 26.11.19.08(A): Adhesion promoter, air

- dried coating, baked coating, camouflage coating, electric

- insu lating and thermal

- conducting coating,

electric

- insulating varnish, etching filler, extreme high gloss coating, extreme performance coating, heat

- resistant coating, high performance architectural coating, high temperature coating, magnetic data storage dis k coating, metal parts and products coating, metallic coating, military specification coating, mold

- seal coating, multi

- component coating, one

- component coating, pan

backing coating, prefabricated architectural component coating, pretreatment coating, repa ir coating, robotic application of heavy

- duty engine coatings, safety

- indicating coating, silicone release coating, stencil coating, touch

- up coa ting, and vacuum

- metalizing coating.

The existing section 26.11.19.08(B), Emission S tandards

, is being re move d

.

Section 26.11.19.08(B), Incorporation by Reference, is added, incorporating the following documents for incorporation by reference: AAMA 2604

- 05 Voluntary Specification, Performance Requirements and Test Procedures for High Performance Organic Coatin gs on Aluminum Extrusions and Panels; and AAMA 2605

- 05 Voluntary Specification, Performance Requirements and Test Procedures for Superior Performing Organic Coatings on Aluminum

Extrusions and Panels.

Section 26.11.19.08(C), Applicability and Exemptions

, is added. Section 26.11.19.08(C) defines

to whom the regulation applies and in what instances it does not. In line with the11

recommendations found in the Metal Furniture and Miscellaneous Metal and Plastic Parts CTGs, Maryland’s regulation applies to tho se who own or operate a metal furniture coating installation, and to a metal parts and products coating operation at a premise where the total VOC emissions from all metal parts and products surface coating operations, including emissions from related

clea ning activities, exceeds 15 lb/day ( 6.8 k g/day)

. This section clarifies that regulation .08 does not apply to those coatings for product categories which are already covered by previously in place state regulations . The product category coatings which ar e listed as not applying under regulation .08, and the applicable state regulation which covers each product category type, include the following : Automotive and light duty truck coating (COMAR 26.11.19.03), can coating (COMAR 26.11.19.04), coil coating ( COMAR 26.11.19.05), large appliance coating (COMAR 26.11.19.06), paper, fabric, film, and foil coating (COMAR 26.11.19.07), plastic parts and business machine coatings (COMAR 26.11.19.07

- 2), cold and vapor degreasing (COMAR 26.11.19.09), industrial solvent cleaning operations other than cold and vapor degreasing (COMAR 26.11.19.09

- 1), drum and pail coating (COMAR 26.11.19.13), aerospace coating (COMAR 26.11.19.13

- 1), brake shoe coating (COMAR 26.11.19.13

- 2), structural steel coating (COMAR 26.11.19.13

- 3), r efinishing of motor vehicles (COMAR 26.11.19.23), marine vessel coating (COMAR 26.11.19.27), and pleasure craft coating (COMAR 26.11.19.27

- 1).

Section 26.11.19.08(D), Emission Standards, is added and includes emission standards for the following metal fu rniture coatings: Extreme high gloss, extreme performance, one

- component
and multi

- component general, metallic, pre treatment, and solar absorbent. Table 3 shows Maryland’s maximum applicable VOC emission standards (expressed in terms of mass VOC per

volu me coating excluding water and exempt compounds) allowed when applying one of the listed coating types to metal furniture

.

Table 3. Maryland’s Adopted Standards for Metal Furniture Coatings

Coating Air

- Dried Baked

kg VOC/l coating lb VOC/l

coating kg VOC/l

coating lb VOC/l

coating Extreme high gloss 0.340 2.8 0.360 3.0 Extreme performance 0.420 3.5 0.360 3.0 General, multi

- component 0.340 2.8 0.275 2.3 General, one

- component 0.275 2.3 0.275 2.3

Metallic 0.420 3.5 0.420 3.5

Pretreatment 0.420 3.5 0.420 3.5

Solar absorbent 0.420 3.5 0.360 3.0

Maryland’s adopted maximum VOC emission standards for metal furniture coating types are all equal to or more stringent than the applicable recommended maximum coating standards found

in the Metal Furniture Coatings CTG and in Table 1 of this document

.

S ection 26.11.19.08(D), Emission Standards, also includes the emission standards for the following miscellaneous metal parts coatings: Adhesion promoter, camouflage, electric insulating varnish, etching fill er, extreme high

- gloss, extreme performance, one

- component general, multi

- component general, heat

- resistant, high performance architectural, high temperature, military specification, metallic, mold

- seal, pan backing, prefabricated architectural12

multi

- compo nent, prefabricated architectural one

- component, pretreatment, repair coating, silicone release, solar absorbent, touch up coating, and vacuum

- metalizing. Table 4 shows Maryland’s maximum applicable VOC emission standards (expressed in terms of mass VOC p er volume coating excluding water and exempt compounds) allowed when applying one of the listed coating types to miscellaneous metal parts.

Table 4. Maryland’s Adopted Standards for Miscellaneous Metal Parts Coatings

Coating Air

- Dried Baked

kg VOC/l

coa ting lb VOC/l

coating kg VOC/l

coating lb VOC/l

coating Adhesion promoter 0.479 4.0 0.479 4.0 Camouflage 0.340 2.8 0.420 3.5 Electric insulating

varnish 0.340 2.8 0.420 3.5

Etching filler 0.340 2.8 0.420 3.5 Extreme high

- gloss 0.420 3.5 0.360 3.0

Ext reme performance 0.420 3.5 0.360 3.0 General, multi

component 0.340 2.8 0.275 2.3

General, one

- component 0.340 2.8 0.275 2.3

Heat

- resistant 0.420 3.5 0.360 3.0 High performance

architectural 0.420 3.5 0.360 3.0

High temperature 0.340 2.8 0.420 3.5

Mi litary specification 0.340 2.8 0.280 2.3

Metallic 0.340 2.8 0.420 3.5

Mold

- seal 0.340 2.8 0.420 3.5 Pan backing 0.340 2.8 0.420 3.5

Prefabricated

architectural

multi

- component 0.420 3.5 0.280 2.3

Prefabricated

architectural one

component 0.420 3.5 0.2 80 2.3

Pretreatment 0.340 2.8 0.420 3.5 Repair coating 0.420 3.5 0.360 3.0

Silicone release 0.340 2.8 0.420 3.5

Solar absorbent 0.420 3.5 0.360 3.0 Touch up coating 0.420 3.5 0.360 3.0

Vacuum

- metalizing 0.340 2.8 0.420 3.5

Maryland’s adopted maximu m VOC emission standards for miscellaneous metal parts coating types are all equal to or more stringent than the applicable recommended maximum coating standards found in the Miscellaneous Metal and Plastic Parts Coatings CTG and in Table 2 of

this documen t

.13

Section 26.11.19.08(E), App lication Methods, is added and includes the following application methods as appropriate when applying a coating: Electrostatic application, H VLP , flow coat, roller coat, dip coat including electrodeposition, brush coat, or a coating application method capable of achieving a transfer efficiency equivalent to or better than the efficiency a chieved by HLVP spraying. These application methods to do apply to repair coatings, touch

- up coatings, coatings applied to create a textu red finish, or robotic application of heavy

- duty engine coatings.

C . CONCLUSIONS AND RECOMMENDED AGENCY ACTION:

This SIP revision satisfies all requirements for an acceptable SIP. EPA ’s evaluat ion shows t hat Regulation .08 under COMAR 26.11 contains the required elements for a federally enforceable

rule: E mission limitations, compliance procedures and test methods, compliance dates and record keeping provisions

. Maryland ’s SIP revision contains special provisions that establishes definitions, specif

ies applicability, establishes standards, specifies exemptions, specifies control devices, and specifies general testing, compliance, recordkeeping, and reporting require ments

. The amendments to Regulation .08 meet the applicable requirements of the CAA, and the applic able 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 coatin g 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.