# T E C H N I C A L 

# S U P P O R T 

# D O C U M E N T

Department of the Environment 

## Amendments to — COMA R 26.11.19.13 Drum and Pail Coating

Purpose of Regulation

The purpose of these amendments is to a dopt the requirements of the EPA’s Control Techniques Guidelines (CTG) for metal pa rts and products. EPA develops CTGs as guidance on control requirements for source ca tegories. 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 M achines (40 CFR 60 Subpart TTT), the 1994 ACT for Surface Coating of Automotive/Transportation and Business Machine Plastic Parts,

National Emission Standards for Hazardous Ai r Pollutants for Miscellaneous Metal Parts and Products 40 CFR 63 Subpart MMMM, a nd existing State and local VOC emission reduction approaches. The metal parts and pr oducts category includes fabricated metal products, small and large farm machinery, commercial and industrial machinery and equipment, automotive or transportation equipmen t, interior or exterior automotive parts, construction equipment, motor vehicle acces sories, bicycles and sporting goods, toys, recreational vehicles, pleasure craft (recreational boats), ex truded aluminum structural components, railroad cars, heavier vehicl es, lawn and garden equipment, business machines, laboratory and medical equipment, electronic equipment, metal pipes, and other industrial and household pr oducts. Drums and pails are included in this category.

The metal parts and products coating category do es 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 app lication technologies are used to apply liquid coatings, and the selection of the application technology can have a significant eff ect 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 applic ators such as: air atomized spray coating, electrostatic spray co ating, high volume/low pressure ( HVLP) spray coating, dip coating, flow coating, roll coating, electrocoating, a nd autophoretic coating. Powder coatings can be applied through electros tatic spraying or dipping.Cleaning activities other than surface prepar ation 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 sp ray guns, transfer lines (e.g., tubing or piping), tanks, and the interior of spray booths. These cleaning materials are typically mixtures of VOC containing so lvents. Emission control requirements for cleaning materials are in the CTG.

Regulation Amendments

COMAR 26.11.19.13 is amended to set VOC coati ng 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 electrodepos ition; 6. Brush coat; or 7.Other coating application method capab le 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, hi gher solids coatings and waterb orne coatings have reduced the organic solvent content of drum and pail coatings. Work practice standards and procedures control fugitive VOC emissions. Hi gher transfer efficiency also reduces VOC

emissions.

Availability of powder coatings, water borne coatings, highe r solids coatings, UV coatings, electrocoatings, and autophoretic co atings has played a significant role in the establishment of standards and requirement s. For certain performance requirements, conventional coatings or coatings with higher VOC content may be needed. With continued research and development new ma terials 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 incl udes elements of work practice requirements suitable for drum and pail coatings.

High atomizing air pressure method of appli cation has transfer e fficiency of 25 to 40 percent. High volume low pressure atomiza tion can achieve transfer efficiency of 65percent depending on shape, size and substrate. Electrostatic spraying achieves transfer efficiency of 90 percent or more.

VOC emissions from drum and pail coating op erations 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 sign ificantly 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 operati ons could be controlled with combustion, catalytic oxidation, adsorption and absorp tion devices. Combustion and catalytic oxidation systems are capable of achieving 95 % control efficiency. Catalytic oxidation systems are capable of operating at lowe r temperatures. Energy consumption can be reduced by preheating the air with the help of regenerative or r ecuperative systems and primary and secondary heat recove ry to reduce energy consumption.

Commonly used adsorption systems are based on activated carbon with regenerable fixed beds. Such systems use imbalances of molecu lar 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 ar e 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 a nd 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 part s and products are expe cted to be reduced by 35 percent nationally. Drum and pail coa tings are a part of this category. The maximum benefit will be provided during th e 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 effectiv eness is approximately $1,800 /ton ofVOC controlled. This action will have mi nimal 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 fe deral reasonably available cont rol 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