TECHNICAL SUPPORT DOCUMENT

Department of the Environment 

Amendments to — COMAR 26.11.19.13 Drum and 

Pail Coating

Purpose of Regulation 

The purpose of these amendments is to adopt the requirements of the EPA’s Control 

Techniques Guidelines (CTG) for metal parts and products. EPA develops CTGs as 

guidance on control requirements for source categories. States can follow the CTGs or 

adopt more restrictive standards. MDE proposes to adopt new standards that will be set 

for drum and pail coating. Application method and work practice requirements will also 

be adopted. These amendments affect coaters of drums and pails. 

Background 

EPA developed the CTG after reviewing the 1978 CTG, the 1988 NSPS for Surface 

Coating of Plastic Parts for Business Machines (40 CFR 60 Subpart TTT), the 1994 ACT 

for Surface Coating of Automotive/Transportation and Business Machine Plastic Parts, 

National Emission Standards for Hazardous Air Pollutants for Miscellaneous Metal Parts 

and Products 40 CFR 63 Subpart MMMM, and existing State and local VOC emission 

reduction approaches. The metal parts and products category includes fabricated metal 

products, small and large farm machinery, commercial and industrial machinery and 

equipment, automotive or transportation equipment, interior or exterior automotive parts, 

construction equipment, motor vehicle accessories, bicycles and sporting goods, toys, 

recreational vehicles, pleasure craft (recreational boats), extruded aluminum structural 

components, railroad cars, heavier vehicles, lawn and garden equipment, business 

machines, laboratory and medical equipment, electronic equipment, metal pipes, and 

other industrial and household products. Drums and pails are included in this category. 

The metal parts and products coating category does not include coatings that are a part of 

other product categories listed under Section 183(e) of the Act for which CTGs have been 

published or included in other CTGs. 

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 CTG requires that 

coatings can only be applied by coating applicators such as: 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. 
Cleaning activities other than surface preparation also occur at miscellaneous metal 

product surface coating facilities. Additional requirements for cleaning materials and 

activities are covered under COMAR 26.11.19.02I. Cleaning materials are used during 

these activities to remove coating residue or other unwanted materials from equipment 

related to coating operations, as well as the cleaning of spray guns, transfer lines (e.g., 

tubing or piping), tanks, and the interior of spray booths. These cleaning materials are 

typically mixtures of VOC containing solvents. Emission control requirements for 

cleaning materials are in the CTG. 

Regulation Amendments

COMAR 26.11.19.13 is amended to set VOC coating standards for exterior and interior 

coatings for new and reconditioned drums and pails in the range of 2.8 to 4.2 lbs/gal. 

Application methods for coatings are limited to: 1. Electrostatic application; 2. HVLP 

spray; 3. Flow coat; 4. Roller coat; 5. Dip coat including electrodeposition; 6. Brush coat; 

or 7.Other coating application method capable of achieving a transfer efficiency 

equivalent or better than that achieved by HVLP spraying. 

Sources Affected 

These proposed amendments affect coaters of drums and pails. 

Technology and Standards 

The CTG for miscellaneous metal and plastic parts include technical analysis for drum 

and pail coating operations. Development and application of lower VOC content 

coatings, powder coatings, higher solids coatings and waterborne coatings have reduced 

the organic solvent content of drum and pail coatings. Work practice standards and 

procedures control fugitive VOC emissions. Higher transfer efficiency also reduces VOC 

emissions. 

Availability of powder coatings, waterborne coatings, higher solids coatings, UV 

coatings, electrocoatings, and autophoretic coatings has played a significant role in the 

establishment of standards and requirements. For certain performance requirements, 

conventional coatings or coatings with higher VOC content may be needed. With 

continued research and development new materials are undergoing tests to match the 

performance characteristics of conventional coatings. 

Work practice procedures are inherently specific to the industry, and can vary 

significantly in terms of requirements. COMAR 26.11.19.02 includes elements of work 

practice requirements suitable for drum and pail coatings. 

High atomizing air pressure method of application has transfer efficiency of 25 to 40 

percent. High volume low pressure atomization can achieve transfer efficiency of 65 
percent depending on shape, size and substrate. Electrostatic spraying achieves transfer 

efficiency of 90 percent or more. 

VOC emissions from drum and pail coating operations can be reduced by the use of 

capture and control systems. These systems would be useful in large scale production. 

Most common operations are conducted in the spray booths that significantly dilute air 

for safety standards to reduce the flammability of the mixture. The low VOC 

concentration makes the control systems not cost effective. An effective system captures 

emissions and minimizes the capture of dilution air. 

Large scale drum and pail coating operations could be controlled with combustion, 

catalytic oxidation, adsorption and absorption devices. Combustion and catalytic 

oxidation systems are capable of achieving 95% control efficiency. Catalytic oxidation 

systems are capable of operating at lower temperatures. Energy consumption can be 

reduced by preheating the air with the help of regenerative or recuperative systems and 

primary and secondary heat recovery to reduce energy consumption. 

Commonly used adsorption systems are based on activated carbon with regenerable fixed 

beds. Such systems use imbalances of molecular forces on the surface of solids to adsorb 

VOCs and may use not only activated carbon but also organic resin polymer, and 

inorganic materials. 

Control efficiencies of adsorption systems are greater than 95 percent. Regeneration of 

carbon is done with the help of steam and is particularly effective for immiscible 

solvents. 

Absorption systems use liquid to dissolve and control the VOCs from the effluent. Such 

systems are rarely used for coating operations. 

Expected Emissions Reductions 

The proposed amendments set standards for coatings, application methods and work 

practices. Emissions of VOCs from metal parts and products are expected to be reduced 

by 35 percent nationally. Drum and pail coatings are a part of this category. The 

maximum benefit will be provided during the ozone season when VOCs readily combine 

with NOx to from the pollutant ground level ozone.

Health Effects and Ground-Level Ozone 

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

when VOCs readily combine with NOx to form the pollutant ground level ozone.

Economic Impact

The economic impact of implementing CTG requirements has been estimated by 

EPA on a national level. Cost effectiveness is approximately $1,800 /ton of 
VOC controlled. This action will have minimal to no economic impact on affected 

Maryland sources. The impact on the Department is going to be minimal as affected 

sources are already regulated. The Department will need to review additional records and 

ensure new standards are being met.

Revision to Maryland's SIP 

This action will be submitted to the U.S. EPA for approval as a revision to Maryland's 

State Implementation Plan. 

Other State or Federal Requirements 

There are no other state or federal reasonably available control technology standards for 

this category. Multiple facilities are covered under this CTG and each may be subject to 

additional federal requirements.

Comparison to Federal Standards 

There is a corresponding federal standard to this proposed action, but the proposed action 

is not more restrictive or stringent. 

References

Control Techniques Guidelines: Miscellaneous Metal and Plastic Parts Coatings EPA453/R-08-003 September 2008