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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

1650 Arch Street

Philadelphia, Pennsylvania 19103

DATE: July 19, 2011

SUBJECT: Technical Support Document for Maryland’s Adoption of Drum and Pail Coating 

Standards

/s/

FROM: Irene Shandruk, Physical Scientist 

Office of Air Program Planning 

TO: File

/s/

THRU: Cristina Fernandez, Associate Director 

Office of Air Program Planning

A. BACKGROUND 

Section 172(c)(1) of the Clean Air Act (CAA) provides that state implementation plans (SIPs) 

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 for certain nonattainment areas, States must revise their SIPs to include RACT for 

sources of volatile organic compound (VOC) emissions covered by a control techniques 

guidelines (CTG) document issued after November 15, 1990 and prior to the area’s date of 

attainment. 

The United States 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 feasibility.” (44 

FR 53761, Sept. 17, 1979). In subsequent Federal Register notices, EPA has addressed how 

states can meet the RACT requirements of the CAA. 

CTGs are intended to provide state and local air pollution control authorities information that 

should assist them in determining RACT for VOCs from various sources, including drum and 

pail surface coating operations. In developing these CTGs, EPA, among other things, evaluated 

the sources of VOC emissions from this industry and the available control approaches for 

addressing these emissions, including the costs of such approaches. Based on available 

information and data, EPA provides recommendations for RACT for VOCs from miscellaneous 

metal product and plastic parts surface coating.

In June 1978, EPA published a CTG for controlling VOC emissions from surface coating of 

miscellaneous metal and plastic products (EPA-450/2-78-015). This CTG discusses the nature 
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of VOC emissions from this industry, available control technologies for addressing such 

emissions, the costs of available control options, and other items. EPA also published a national 

emission standard for hazardous air pollutants (NESHAP) for surface coating of miscellaneous 

metal parts and products surface coating (40 CFR part 63, subpart MMMM).

In 2008, after conducting a review of currently existing state and local VOC emission reduction 

approaches for this industry, reviewing the 1978 CTG and the NESHAP for this industry, and 

taking into account the information that has become available since then, EPA developed a new 

CTG for surface coating of miscellaneous metal and plastic parts products, entitled Control 

Techniques Guidelines for Miscellaneous Metal and Plastic Parts Coatings (Publication No. 

EPA 453/R-08-003).

Description of Miscellaneous Metal and Plastic Parts Coatings

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

183(e) of the CAA includes 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. The CTG applied to manufacturers of miscellaneous metal and 

plastic parts that surface-coat the parts they produce. The CTG also applies to facilities that 

perform surface coating of miscellaneous metal and plastic parts on a contract basis. 

Miscellaneous metal product and plastic parts surface coatings serve decorative, protective, and 

functional purposes. Coatings protect metal parts from corrosion by providing resistance to 

moisture, heat, and sometimes the outdoor elements. Plastic parts may be coated to provide 

color, texture, or protection, thus improving appearance and durability, and can also function to 

attenuate electromagnetic interference/radio frequency interference signals, and to conceal mold 

lines and flaws in substrate surface.

The miscellaneous metal product and plastic parts surface coating process may be divided into 

three main unit operations: (1) surface preparation, (2) coating application operations, and (3) 

cleaning activities. These three types of activities utilize VOC-containing compounds (i.e., 

coatings, thinners, and/or cleaning materials). The CTG provides control recommendations for 

reducing VOC emissions from the use of these activities. 

The VOC emissions from miscellaneous metal product and plastic parts surface coating 

processes result from the evaporation of the volatile components of the coatings and cleaning 

materials used in these operations. In most cases, VOC emissions from surface preparation, 

storage, handling, and waste/wastewater operations are relatively small. 

EPA’s Recommended Control Options for Miscellaneous Metal and Plastic Parts Coatings

EPA issued a CTG for miscellaneous metal and plastic parts coatings in September 2008

(Publication No. EPA 453/R-08-003). EPA recommends that the control approaches outlined 

below apply to each miscellaneous metal product and plastic parts surface coating unit at a 

facility where the total actual VOC emissions from all miscellaneous metal product and plastic 

parts surface coating operations, including related cleaning activities, at that facility are equal to 
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or exceed 6.8 kilograms (kg)/day (15 pounds (lbs)/day), or an equivalent level of 2.7 tons per 12-

month rolling period, before consideration of controls. 

The Control Techniques Guidelines for Miscellaneous Metal and Plastic Parts Coatings

document recommends emission limits for various metal and plastic coatings and those emission 

limits that apply to this particular SIP revision are shown in Table 1.

Table 1. VOC Content Limits

Air Dried Baked

Coating Category kg VOC/liter 

coating

lbs VOC/gallon 

coating

kg VOC/liter 

coating

lbs VOC/gallon 

coating

Drum Coating, New, 

Exterior

0.34 2.8 0.34 2.8

Drum Coating, New, 

Interior

0.42 3.5 0.42 3.5

Drum Coating, 

Reconditioned, Exterior

0.42 3.5 0.42 3.5

Drum Coating, 

Reconditioned, Interior

0.50 4.2 0.50 4.2

B. STATE SUBMITTAL

On June 22, 2011, Maryland Department of the Environment (MDE) submitted to EPA a SIP 

revision concerning the adoption of the emission limits for drum and pail coatings, part of the 

EPA miscellaneous metal and plastic parts coatings CTG. EPA develops CTGs as guidance on 

control requirements for source categories. States can follow the CTGs or adopt more restrictive 

standards. The State of Maryland has adopted EPA’s CTG standards for drum and pail coating 

processes and this regulation is found in COMAR 26.11.19, Volatile Organic Compounds from 

Specific Processes. This revision amends the existing regulation by making it specific to drum 

and pail coating processes only. Specifically, this revision amends the existing regulation at

section 26.11.19.13 by removing several definitions and adding several new definitions, 

amending the applicability and exemptions, amending the emission standards, and adding 

application methods. Work practice procedures for coating can be found in COMAR 

26.11.19.02. Specifically, requirements for cleaning activities can be found in COMAR 

26.11.19.02(I) and these have previously been approved into Maryland’s SIP.

The following changes are being made to COMAR 26.11.19.13, Volatile Organic Compounds 

from Specific Processes:

The title of Section 26.11.19.13 is being changed from “Miscellaneous Metal Coating” to “Drum 

and Pail Coating.” The following terms are being removed from Section 26.11.19.13(A), 

Definitions: clear coating, high performance coating, and standard coating. Definitions for the 

following terms are added to Section 26.11.19.13(A): drum, pail, and reconditioned drums or 

pails. 

Section 26.11.19.13(B), Applicability and Exemptions, is being amended to apply to any drum or 

pail coating operations at a premises where the total VOC emissions exceed 15 pounds (6.8 
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kilograms) per day. It does not apply to coatings applied using a hand-held, pressurized, nonrefillable container which expels coatings from the container in a finely divided spray when a 

valve on the container is depressed (a) To recoat portions of a previously coated product which 

has sustained mechanical damage to the coating following normal painting operation, or (b) To 

cover minor coating imperfections appearing after the main coating operation.

Section 26.11.19.13(C), Emission Standards, is amended to explain that any person subject to 

Regulation 26.11.19.13 may not exceed the applicable VOC emission standards in Table 2.

Table 2. Drum and Pail Coating Standards

Coating Types lbs VOC/gallon coating

(minus water)

kg VOC/liter coating

(minus water)

New, Exterior 2.8 0.34

New, Interior 3.5 0.42

Reconditioned, Exterior 3.5 0.42

Reconditioned, Interior 4.2 0.50

Section 26.11.19.13(D), Application Methods, is added to the regulation. This section lists the 

application methods subject to this regulation. They are: electrostatic application, high volume 

low pressure (HVLP) spray, 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 achieved by HVLP spraying. The above application requirements do 

not apply to the following drum or pail coating operations: (a) Coating applied in order to recoat 

portions of a previously coated product which has sustained mechanical damage to the coating 

following normal painting operation, or (b) Coatings applied in order to cover minor coating 

imperfections appearing after the main coating operation.

C. EPA EVALUATION

MDE has adopted the standards and requirements of the CTG for drum and pail coating 

applications and is amending the Maryland SIP to reflect these amendments. The maximum 

benefit from these amendments will be provided during the ozone season when VOCs readily

combine with nitrogen oxides (NOx) to form ground-level ozone. Specifically, emissions of 

VOCs from drum and pail coatings are expected to be reduced by 35 percent nationally from 

facilities above the recommended 6.8 kg/day threshold, which include those in Maryland, as a 

result of this rulemaking. Therefore, this revision will help Maryland attain and maintain the 

National Ambient Air Quality Standards (NAAQS) for ozone. 

D. CONCLUSIONS AND RECOMMENDED AGENCY ACTION

The adoption of the EPA CTG requirements for drum and pail coating standards by the State of 

Maryland will result in the reduction of VOC emissions from drum and pail coatings. EPA’s

approval of the SIP revision is recommended.