Control Techniques Guidelines for 

Large Appliance Coatings 
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EPA 453/R-07-004 

September 2007 

Control Techniques Guidelines for 

Large Appliance Coatings 

U.S. Environmental Protection Agency 

Office of Air Quality Planning and Standards 

Sector Policies and Programs Division 

Research Triangle Park, NC 
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TABLE OF CONTENTS 

I. Introduction..............................................................................................Page 1 

II. Background and Overview ......................................................................Page 2 

III. Applicability ............................................................................................Page 3 

IV. Process Description and Sources of VOC Emissions..............................Page 4 

 A. Process Description 

 B. Source of VOC Emissions 

 1. Coatings 

 2. Cleaning Materials 

V. Available Controls and Existing Federal, State, and Local 

Recommendations/Regulations..........................................................Page 8 

A. Available Controls for VOC Emissions from Coatings 

 1. Pollution Prevention Measures 

 a. Product Substitution/Reformulation 

 b. Work Practices 

 2. Emission Capture and Add-On Control Systems 

B. Available Controls for VOC Emissions from Cleaning Materials 

 1. Pollution Prevention Measures 

 2. Emission Capture and Add-On Control Systems 

C. Existing Federal, State, and Local Recommendations/Regulations 

 1. The 1977 CTG 

 2. The 1982 NSPS 

 3. The 2002 NESHAP 

 4. Existing State and Local VOC Requirements 

VI. Recommended Control Options...............................................................Page 18 

A. Emissions Limit based on Low-VOC Coatings 

 B. Optional Add-On Controls for Coating Operations 

C. Work Practices for Coating Operations and Cleaning Materials 

VII. Cost Effectiveness of Recommended Control Options ...........................Page 21 

VIII. References ................................................................................................Page 22 

Appendix A 

 1977 Large Appliance Coating CTG Document 

Appendix B 

 Summary of State-Specific Large Appliance Coating Regulations 
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I. Introduction

 Clean Air Act (CAA) section 172(c)(1) 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 each category of volatile organic compound (VOC) 

sources covered by a control techniques guidelines (CTG) document issued between 

November 15, 1990 and the 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 (September 17, 1979). In subsequent Federal Register notices, 

EPA has addressed how States can meet the RACT requirements of the Act. 

 CAA section 183(e) directs EPA to list for regulation those categories of products 

that account for at least 80 percent of the VOC emissions, on a reactivity-adjusted basis, 

from consumer and commercial products in areas that violate the NAAQS for ozone (i.e., 

ozone nonattainment areas). EPA issued the list on March 23, 1995, and has revised the list 

periodically. See 60 FR 15264 (March 23, 1995); see also 71 FR 28320 (May 16, 2006), 70 

FR 69759 (Nov. 17, 2005); 64 FR 13422 (March 18, 1999). Large appliance coatings are 

included on the current section 183(e) list. 

 This CTG is intended to provide State and local air pollution control authorities 

information that should assist them in determining RACT for VOC from large appliance 

coatings. In developing this CTG, EPA evaluated the sources of VOC emissions from the 

large appliance coating 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 large appliance coating. 

 States can use the recommendations in this CTG to inform their own determination 

as to what constitutes RACT for VOC for large appliance coatings in their particular 

nonattainment areas. The information contained in this document is provided only as 

guidance. This guidance does not change, or substitute for, requirements specified in 

applicable sections of the CAA or EPA’s regulations; nor is it a regulation itself. This 

document does not impose any legally binding requirements on any entity. It provides only 

recommendations for State and local air pollution control agencies to consider in 

determining RACT. State and local pollution control agencies are free to implement other 

technically-sound approaches that are consistent with the CAA and EPA’s implementing 

regulations. 

 The recommendations contained in this CTG are based on data and information 

currently available to EPA. These general recommendations may not apply to a particular 

situation based upon the circumstances of a specific source. Regardless of whether a State 

chooses to implement the recommendations contained herein through State rules, or to issue 

State rules that adopt different approaches for RACT for VOC from large appliance 
2

coatings, States must submit their RACT rules to EPA for review and approval as part of the 

SIP process. EPA will evaluate the rules and determine, through notice and comment 

rulemaking in the SIP approval process, whether the submitted rules to meet the RACT 

requirements of the CAA and EPA’s regulations. To the extent a State adopts any of the 

recommendations in this guidance into its State RACT rules, interested parties can raise 

questions and objections about the substance of this guidance and the appropriateness of the 

application of this guidance to a particular situation during the development of the State 

rules and EPA’s SIP approval process. 

 CAA section 182(b)(2) requires that a CTG issued after November 15, 1990 and the 

date of attainment include the date by which States subject to section 182(b) must submit 

SIP revisions in response to the CTG. Accordingly, EPA is providing in this CTG a oneyear period for the required submittal. Pursuant to section 182(b)(2), States required to 

submit rules consistent with section 182(b) must submit their SIP revisions within one year 

of the date of issuance of the final CTG for large appliance coatings. States subject only to 

the RACT requirement in CAA section 172(c)(1) may take action in response to this CTG, 

as necessary to attain. 

II. Background and Overview

 In December 1977, EPA published a CTG for large appliance coating, entitled 

“Control of Volatile Organic Emissions from Existing Stationary Sources, Volume V: 

Surface Coating of Large Appliances,” EPA-450/2-77-034 (1977 CTG). The 1977 CTG can 

be downloaded from EPA’s website at www.epa.gov/ttn/naaqs/ozone/ctg_act. The cover 

page of the 1977 CTG is included as Appendix A to this CTG for additional reference. In 

October 1982, EPA promulgated the National Standards of Performance for New Stationary 

Sources (NSPS): Standards of Performance for Industrial Surface Coating: Large 

Appliances, 40 CFR part 60, subpart SS (1982 NSPS). In 2002, EPA promulgated the 

National Emission Standards for Hazardous Air Pollutants: Surface Coating of Large 

Appliances, 40 CFR part 63, subpart NNNN (2002 NESHAP). The 1977 CTG recommends 

and the 1982 NSPS requires VOC emissions limits based on VOC content of low VOC 

coating materials. The 2002 NESHAP establishes organic hazardous air pollutants (HAP) 

emissions limits based on the organic HAP content of low organic HAP coating materials. 

 At least 24 State and local jurisdictions have specific regulations that control VOC 

emissions from large appliance coating operations. A discussion of the applicability and 

control options found in the Federal actions and State and local rules is presented in Section 

V of this document. 

EPA developed the recommended approaches contained in this document after 

reviewing the 1977 CTG, the 1982 NSPS, the 2002 NESHAP, and existing State and local 

VOC emission reduction approaches and considering information obtained since issuance of 

the 2002 NESHAP. 

 The remainder of this document is divided into six sections. Section III describes the 

scope of sources to which the control recommendations in this CTG could apply. Section 

IV describes the large appliance coating processes and identifies the sources of VOC 

emissions from those processes. Section V describes the available control approaches for 

addressing VOC emissions from this product category and summarizes Federal, State and 
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local approaches for addressing such emissions. Section VI provides our recommendations 

for RACT for large appliance coatings. Section VII discusses the cost-effectiveness of the 

recommended control approaches. Section VIII contains a list of references. 

III. Applicability

 This CTG provides control recommendations for reducing VOC emissions stemming 

from the use of coatings in large appliance coating operations. Coatings include paints, 

sealants, caulks, inks, adhesives, and maskants.1

 This section addresses EPA's 

recommendations as to the scope of entities to which the RACT recommendations in this 

CTG should apply. As explained above, this document is a guidance document and 

provides information for States to consider in determining RACT. When State and local 

pollution control agencies develop RACT rules, they may elect to adopt control approaches 

that differ from those described in this document and/or promulgate applicability criteria 

that differ from those recommended here. 

 In terms of applicability, we recommend that the control approaches discussed in 

Section VI of this CTG apply to each large appliance coating unit2

 at a facility where the 

total actual VOC emissions from all large appliance 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. 

We do not recommend these control approaches for facilities that emit below this level 

because of the very small VOC emission reductions that can be achieved. The 

recommended threshold level is equivalent to the evaporation of about two gallons of 

solvent per day. Such a level is considered to be an incidental level of solvent usage that 

could be expected even in facilities using exclusively powder or ultra-violet and electron 

beam (UV/EB) coatings. Furthermore, based on the 2002 National Emission Inventory 

(NEI) and the 2004 ozone nonattainment designations, we estimated that all of the large 

appliance surface coating facilities located in ozone nonattainment areas (68 facilities) emit 

at or above this level and would therefore be addressed by our recommendations in the 

CTG. For purposes of determining whether a facility meets our recommended applicability 

threshold, aggregate emissions, before consideration of control, from all large appliance 

coating operations (including related cleaning activities) at a given facility are included. 

In developing their RACT rules, State and local agencies should consider carefully 

the facts and circumstances of the affected sources in their States. As noted above, States 

can adopt the above recommended 15 lb/day actual VOC emissions or an equivalent 

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. EPA will review the State RACT rules in the context of the SIP 

revision process.

 

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 series 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 different coating. It is not necessary for a coating 

unit to have an oven or a flash-off area. 
4

The 2002 NEI and a questionnaire sent to industry by EPA during the 2002 

NESHAP development (data requested by EPA in 1997 and 1998) were used as the source 

of emissions data and statistical information concerning the large appliance coating industry 

as a whole. There were several discrepancies in the number of facilities reporting in the 

2002 NEI versus the 1997 and 1998 NESHAP questionnaires. During the evaluation of the 

2002 NEI data, it was noted that 14 States had at least one facility that reported emissions 

from this source category in 1997 but not in 2002. There were also States that showed a 

number of facility closures based on the comparison of 2002 NEI data to the data collected 

during the 2002 NESHAP development. 

Results from the NESHAP questionnaires indicated that there were 222 facilities that 

perform large appliance coating operations. These operations were distributed across 38 

States and Puerto Rico. The States with the largest number of large appliance coating 

operations were Ohio (19), Tennessee (16), Illinois (15), Texas (14), Wisconsin (13), and 

Georgia (10). Although information regarding HAP emissions was the main focus of the 

NESHAP questionnaires, information regarding VOC was submitted from 153 of the total 

222 facilities surveyed. These facilities reported actual VOC emissions totaling 

approximately 5,000 tpy for 1997. This total only accounts for the VOC emissions 

generated by these facilities from coatings. In addition, facilities that were excluded from 

the final rule (coating of chillers) were also included in the total 222 facilities surveyed. 

In developing this CTG, the 2002 NEI database was queried for VOC emissions 

generated by facilities that were listed under the SIC codes 3631, 3632, 3633, 3639, 3582, 

3585, and 3589 (those SIC used for the 2002 NESHAP). This query resulted in only 128 

facilities compared to the 222 facilities identified during the 1997 and 1998 NESHAP 

questionnaires. The 128 large appliance coating facilities in the 2002 NEI reported total 

VOC emissions of 6,225 tpy. This total accounts for all of the VOC emissions generated by 

these facilities and does not specify the amount generated just by large appliance coating 

operations. Of the 128 facilities that reported, 44 were located in nonattainment areas. 

Based on the industry information submitted during the 2002 NESHAP 

development, it was anticipated that closer to 200 facilities (excluding the number of 

facilities that reported when chillers were part of the rule development) should have reported 

during 2002. Based on the fact that only 128 facilities reported and the discrepancies noted, 

it can be concluded that the 2002 NEI is not as complete as the data collected during the 

2002 NESHAP development. Based on the information evaluated for this CTG 

development, there are an estimated 200 facilities. Approximately 68 of these facilities are 

believed to be in nonattainment areas. This is based on the fact that 44 facilities out of the 

128 large appliance coating facilities (34 percent) that reported emissions in the 2002 NEI 

were in nonattainment areas (34 percent of the 200 facilities from the 2002 NESHAP 

development would be 68 facilities estimated to be in nonattainment areas). Baseline VOC 

emissions from these 68 facilities are estimated to be 3,300 tpy. 

IV. Process Description and Sources of VOC Emissions

A. Process Description

Large appliance coatings include, but are not limited to, materials referred to as 

paint, topcoats, basecoats, primers, enamels, and adhesives used in the manufacture of large 
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appliance parts or products. A large appliance part is defined as any organic surface-coated 

metal lid, door, casing, panel, or other interior or exterior metal part or accessory that is 

assembled to form a large appliance product. A large appliance product is also defined as 

any organic surface-coated metal range, oven, microwave oven, refrigerator, freezer, 

washer, dryer, dishwasher, water heater, or trash compactor manufactured for household, 

commercial, or recreational use. 

Coatings are a critical constituent to the large appliance industry. Coatings protect 

the metal from corrosion by providing resistance to moisture, heat, detergent, and sometimes 

the outdoor elements. Coatings for each type of large appliance have special requirements 

and contain unique properties because each type will be exposed to somewhat different 

corrosive elements. The coatings must also be durable and have excellent adhesion 

properties to avoid peeling or chipping. Finally, the coatings that are applied on home 

appliances must have esthetic appeal. 

The coating application methods used are typical of surface coating operations in 

many industries. Air atomized spraying and airless spraying of coatings involve the 

atomization of a liquid coating in order to apply it to a substrate. Air atomized spraying 

achieves atomization by the use of compressed air and can provide transfer efficiencies of 

up to 40 percent. Airless spraying uses an airless pump system to force the coating through 

a nozzle designed to atomize the coating and typically has a transfer efficiency of 50 to 60 

percent. The high-volume low-pressure (HVLP) system is a newer technology which 

further reduces overspray because it propels the atomized coating at a lower velocity than 

the air or airless system. 

Most spray applied large appliance coatings are applied electrostatically. An 

electrostatic spray can be generated using an air or an airless gun system. In such systems, 

the transfer efficiency is improved because electrostatic principles are used to attract the 

coating to the substrate (up to about 85 percent transfer efficiency). Other electrostatic 

application methods include electrostatic bell and disk spray gun systems. The electrostatic 

bell and disk systems are similar in many respects. They use the rapid rotation of either a 

bell or disk shaped applicator to mist the coating. The use of oppositely charged substrate 

and coating allows for higher transfer efficiencies (close to 90 percent) and better coating 

uniformity. 

Other application methods commonly used are dip coating, electrodeposition, and 

flow coating. The dip coating operation involves the immersion of a part into a tank 

containing the coating and typical transfer efficiencies are near 85 percent. 

Electrodeposition is a dip coating method in which an electric field is used to facilitate the 

deposition of the waterborne coating on the substrate. The substrate to be coated acts as an 

electrode that is oppositely charged from the coating (particles) in the dip tank. 

Electrodeposition has a transfer efficiency closer to 95 percent. Flow coating is a method 

that involves the application of the coating directly onto the substrate without atomizing the 

coating and has a typical transfer efficiency of 85 percent. 

In typical liquid spray and dip coating operations the coated parts/products typically 

move from the coating application area through a flash-off area, where solvents in the 

coating begin to evaporate slowly, thus avoiding bubbling of the coating while it is curing in 

the oven. After being coated by any of the typical coating operations, large appliance 
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products are dried and cured using heated dryers or by air drying. This step removes any 

remaining volatiles from the coatings so that the surfaces of the large appliance products 

meet the hardness, durability, and appearance requirements of customers. 

The majority of touch-up operations are performed by using manual air spray guns 

and a lacquer based coating. This is because the lacquer coating has good drying 

characteristics that allow for shorter drying times. In some cases, touch-up might include 

recoating a product entirely, but the majority of touch-up consists of manual coating 

application to a small portion of the product surface. 

B. Sources of VOC Emissions

VOC emissions from large appliance coating processes result from the evaporation 

of the components of the coatings and cleaning materials.3

 Provided below are further 

descriptions of these two emission sources. 

1. Coatings 

The primary VOC emissions from large appliance coatings occur during coating 

application (prime, single or topcoat 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 storage, handling, and waste/wastewater operations related to coating 

operations are relatively small. 

After being coated by any of the typical coating operations (such as spray coating or 

dip coating), the large appliance products are cured using heated dryers or allowed to air dry. 

This step removes any remaining volatiles from the coating so that the surfaces of the large 

appliance product meet the hardness, durability, and appearance requirements of the 

customers. 

Coating mixing may be performed in an agitated drum or it may be performed by 

merging two different coating supply lines into one. Coating mixing is typically performed 

by the coating manufacturer prior to shipment to a large appliance manufacturer’s facility. 

Some facilities add water or solvent to the coating (thinning), which may be performed in a 

small mixing booth or it may be automated. Some facilities combine reclaimed coating 

from various coating operations and mix the different coatings together in a drum. Mixing 

also varies depending on the type of coating and usage requirements. 

 Until the 1970’s, conventional solvent-based coatings, with high VOC content, were 

the majority of coatings used in the large appliance industry. Due to increased regulation at 

the State and federal level, the industry has steadily moved to lower VOC content coatings. 

These alternative coatings include powder coatings, waterborne coatings, higher solids 

coatings and ultraviolet coatings. The following discussion summarizes each of these 

alternative coating formulations. 

 

3

 In a previous Federal Register notice, EPA identified specific categories, including large appliances coating, 

the cleaning operations of which would not be covered by EPA’s 2006 CTG for industrial cleaning solvents. 

71 Fed Reg. 44522, 44540 (2006). In that notice, EPA expressed its intention to address cleaning operations 

associated with these categories in the CTGs for these specified categories if the Agency determines that a 

CTG is appropriate for the respective categories. 
7

Powder Coatings. The use of powder coating systems in the large appliance industry 

has increased. Many large appliance coating facilities have replaced existing liquid coating 

operations with powder coating operations. Compared to conventional liquid coating 

systems, powder coating produces minimal amounts of VOC emissions because powder 

coatings are applied as dried particles, no VOC are released during the application operation, 

and volatile emissions from the curing operation, if any, are generally much less than the 

volatile emissions from liquid coating systems. Powder coating is applied via powder 

delivery systems, which in most cases is an electrostatic spray. Particulate emissions 

resulting from the application of powder coatings can be minimized through the 

implementation of a recovery and recycling process (reuse of overspray). Depending on the 

powder formulation, some volatile emissions may occur when the powder is heated during 

the curing step. Powder coating applications are best suited for long production runs of 

consistently sized parts without color changes. In the case of some products with special 

performance needs (such as dishwasher racks), a two-step powder coating process may be 

used. In these cases, the powder coating is preceded by a low-solids adhesion enhancer. 

Waterborne Coatings. Waterborne coatings produce minimal VOC emissions 

primarily because a large portion of the solvent carrier is replaced with water. The water 

component can constitute as much as 80 percent of the coating, with the remaining 20 

percent being the coating solids. 

Higher Solids Coatings. These coatings contain at least 60 percent by volume of 

coating solids. VOC emissions are reduced through the use of these coatings because they 

contain less solvent per unit volume of solids than conventional solvent-based coatings. 

Thus, a lesser amount of VOC emissions are released during coating preparation, 

application, and curing to deliver a given amount of coating solids. 

Ultraviolet Coatings. Ultraviolet (UV) curable liquid and UV curable powder 

coatings are used for heat sensitive substrates as they allow for low curing temperatures. 

UV liquid coatings have been used for several decades on parts made of wood, composite, 

and metal, but are not commonly used in the large appliance industry. Because the entire 

coating must be exposed to the UV light source to achieve complete curing of the UV 

coating, UV curable coating applications present problems in the large appliance industry. 

Pigmentation used in the majority of large appliance coatings blocks the UV light. The 

shape of the large appliance also presents curing problems. Many large appliance products 

have bends or are box-shaped, creating areas which would be shaded from the UV light 

source. 

2. Cleaning Materials 

Another main source of VOC emissions from large appliance coating is the cleaning 

materials. Proper cleaning removes all organic and inorganic soils from the substrate prior 

to coating, which is critical for achieving maximum performance from the coating, 

especially with powder coating. Cleaning and pretreatment can consist of numerous stages 

that include several types of chemical washes, such as solvent cleaning, an acid wash, a 

phosphate wash, and a deionized water wash. Facilities use various combinations of these 

stages. Except for solvent cleaning and wetting oil treatment, most stages do not emit any 

VOC emissions. Pretreatment and cleaning requirements vary depending on the type of 

coating application and curing, as well as the type of metal to be coated. 
8

Cleaning materials are also used to clean coating equipment and to touch up the final 

products. These materials are typically VOC solvents such as methyl ethyl ketone (MEK) 

and toluene. However, there has been an increase in the use of alcohol and water-based 

cleaners. 

V. Available Controls and Existing Federal, State, and Local 

Recommendations/Regulations

As previously mentioned, there are two main sources of VOC emissions from large 

appliance coating operations: (1) evaporation of VOC from the coatings; and (2) 

evaporation of VOC from the cleaning materials. This section summarizes the available 

control options for reducing these VOC emissions and existing State and local VOC 

requirements. 

A. Available Controls for VOC Emissions from Coatings

There are two general types of emission control techniques for reducing VOC 

emissions from large appliance coatings: pollution prevention measures and emission 

capture and add-on control systems. Pollution prevention is the most prevalent control 

technique being used by the large appliance surface coating industry. Add-on control 

systems are available to the industry, but few facilities utilize this control technique. 

Provided below is a summary of each of these types of control techniques. 

1. Pollution Prevention Measures

Pollution prevention measures applicable to the large appliance industry, including 

product substitution/reformulation and work practice procedures, may be used to decrease 

VOC emissions from large appliance coatings. Coatings with low VOC content, such as 

waterborne coatings, higher solids solvent-borne coatings and powder coatings, may be used 

to reduce VOC emissions from coatings by reducing or eliminating the organic solvent 

present in the coatings. Work practice procedures may also reduce VOC emissions from 

coatings during paint mixing, paint storage, and paint transfer operations. 

a. Product Substitution/Reformulation

The use of waterborne, higher solids, and powder coatings has increased since 1977. 

Paint manufacturers have developed and are continuing to develop waterborne, higher 

solids, and powder coating formulations that replace conventional solvent-borne coatings. 

These coatings are generally available and often are not produced and marketed specifically 

for the large appliance coating industry. Conversion to these coatings can lower VOC 

emissions greatly, and most coatings operations, including most large appliance coating, are 

capable of converting to these coatings. 

b. Work Practices

 Work practice procedures are physical actions intended to affect emission reductions. 

Because work practice procedures are specifically tailored to an industry, they may vary 

from a few manual operations to a complex program. 

 For the large appliance industry, work practice procedures may be appropriate for the 

following activities: 

• Coating Storage and Handling: 
9

Storage demands vary based on the type of coating and usage requirements. 

Container size and type vary depending on coating manufacturer and end user needs. 

Most coatings are stored in 208 liter (55 gallon) drums. Powder coatings can also be 

stored in drums, as long as the temperature and the humidity are controlled. Most 

facilities store powder coatings in 23 kilogram (50 pound) cardboard boxes that are 

lined with plastic to prevent moisture absorption, but the size of the container can 

vary from 1.4 to 136 kilograms (3 to 300 pounds). These containers should be well 

maintained to prevent leakage and excessive spillage or material loss during transfer 

to other containers or coating equipment. They should also remain sealed except 

when it is necessary to remove material from the containers, after which they should 

be promptly closed again. 

• Fluid Handling Equipment: 

All fluid handling equipment such as coating supply lines, holding tanks, coating 

storage containers, or any fluid handling equipment that contains a VOC-containing 

coating should be well maintained to prevent spills, leaks, or other problems that 

would release some of the contents of the fluid handling system. 

• Mixing Operations: 

Coating mixing may be performed in an agitated 208 liter drum, or it may be 

performed by merging two different coating supply lines into one. Mixing vessels 

should have a top that prevents VOC emissions during the agitation process. Store 

mixed coatings and solvents in closed containers when not being combined to reduce 

VOC emissions. 

Some large appliance coating facilities, either pursuant to Federal, State and/or local 

regulations or on their own initiatives, develop and implement work practice plans to control 

VOC emissions. These plans set forth the steps to be taken to ensure that work practices are 

implemented properly to minimize VOC emissions during coating processes. Such a plan is 

a compliance option under the 2002 NESHAP. The use of a work practice plan is a 

traditional approach for reducing emissions during cleaning operations in various industries, 

including the large appliance coating industry. As shown by these industries, work practice 

plans can be easily adopted and managed. 

2. Emission Capture and Add-On Control Systems 

In addition to pollution prevention measures, VOC emissions from large appliance 

surface coating operations can be reduced by the use of capture systems, in conjunction with 

add-on control systems that either destroy or recover the VOC in the exhaust streams. As 

stated previously, although capture systems and add-on control devices are available to the 

large appliance surface coating industry, EPA is aware of only a few cases where this 

control technology is utilized by the industry. The majority of VOC emissions from large 

appliance coating operations occur in the spray booth. Spray booths typically exhaust a high 

volume of air with a low concentration of VOC which can result in a high cost of control. 

The prevalent method of destruction of organic solvent emissions from coatings is 

thermal oxidation. The organic solvent-containing exhaust air is heated to a very high 

temperature, which converts it to carbon dioxide and water through the process of 

combustion. There are several options for VOC control by oxidation. They include: 

(1) direct, gas-fired, thermal recuperative oxidation; (2) direct, gas-fired, thermal 
10

regenerative oxidation; (3) direct, electrically heated, thermal regenerative oxidation; (4) 

direct, electrically heated, catalytic oxidation; and (5) direct, gas-fired, catalytic oxidation. 

Direct, gas-fired, thermal recuperative oxidizers usually operate at temperatures of 

760 EC (1400 EF) and use a natural gas burner. The residence time for organic solvent rich 

air is about 0.5 seconds. This type of unit is usually constructed solely of steel and utilizes 

heat exchangers to recover heat. These oxidizers can achieve a high VOC destruction (98 

percent efficient or better), especially when the VOC concentration in the inlet stream is 

high. These devices are not the most efficient for heat recovery, but it is possible to use 

waste heat to produce steam or heated air. Their all steel construction becomes a problem 

when hydrochloric acid is produced as a product of the combustion of chlorinated organic 

solvents. 

Direct, gas-fired, thermal regenerative oxidizers utilize ceramic towers in a 3-, 5- or 

7-chamber configuration to achieve heat recovery efficiencies in the 80-95 percent range. 

For this reason, the unit produces less NOX emissions and uses very little natural gas. 

Regenerative oxidizers can be effective for airstreams with flow rates of 280 to 4,250 cubic 

meters per minute (10,000 to 150,000 cubic feet per minute). Regenerative oxidizers are 

capable of achieving high destruction efficiencies similar to those of recuperative oxidizers. 

Direct, electrically heated, thermal regenerative oxidizers are based on the principle 

that if enough organic solvent emissions enter the unit at high concentrations then the 

combustion process will maintain itself using only the heat of the organic solvent 

combustion. Electric coils within the unit are used to bring the unit up to its operating 

temperature (760 EC) as well as to help maintain operating temperature when the organic 

solvent concentrations in the effluent stream drop below critical levels. The unit itself 

creates no NOX, CO, or CO2 emissions because it operates on electricity instead of the 

combustion of natural gas or other fuels. Some problems with these types of units include a 

long startup time and costly operation due to the electricity required to operate them 

properly. Another problem with this type of oxidizer is that hydrochloric acid from the 

oxidation of chlorinated organic solvents can destroy the electric coils in the unit. 

Direct, electrically heated, catalytic oxidizers use precious metal catalysts as an 

integral part of the combustion chamber which allows for lower combustion temperatures in 

the range of 320 to 430 EC (versus 760 EC for non-catalytic oxidizers). These units use 

electric coils for startup and temperature maintenance. These units are typically constructed 

completely of steel with integrated catalyst units. They do not produce NOX or CO, nor do 

they require large amounts of electricity because they run at relatively low temperatures and 

they use heat exchangers to pre-heat incoming air. The catalyst must be cleaned 

periodically. Also, the catalyst effectiveness may be masked by halogens, metals, nonorganic solvent resins, and other materials. If appropriate materials are used in the 

combustion chamber and the electric coils, halogenated solvents can be oxidized. 

Direct, gas-fired, catalytic oxidizers are similar to the electric catalytic oxidizers 

except that they use gas fired burners, instead of electric coils, for makeup heat. They also 

use precious metal catalysts. These oxidizers utilize heat exchangers to pre-heat exhaust air, 

which reduces fuel requirements to relatively small amounts. If their catalysts are 

contaminated by halogen resins or high boiling organic solvents, the units may produce 

some NOX or CO emissions. 
11

Carbon adsorption as a technique for organic-solvent recovery has been used 

commercially for several decades. Spray applied coatings contain a mixture of several 

organic solvents in order to maximize gloss, transfer efficiency, and other desirable coating 

properties. Organic solvent recovery is usually most effective economically and technically 

when used with air streams containing a few, expensive organic solvents. In a carbon 

adsorption system with steam desorption, carbon beds adsorb organic solvents from the air 

stream passing through them. In most cases, one bed is in the adsorption phase while the 

second bed is in the steam desorption phase. In the desorption phase, steam is passed 

through the carbon to release the collected organic solvent. Once the steam has been passed 

through the carbon, it is then condensed and the organic solvent is removed through the 

process of settling or distillation. The carbon desorption phase can be performed on site or 

the spent carbon can be shipped off-site for regeneration. The efficiency of this type of 

system can be very high when there are low organic solvent concentrations in the air 

exhausted from the application booths. Advantages of the carbon adsorption/steam 

desorption system are that they are relatively inexpensive and have been proven effective 

over the years. They can handle a relatively high volume of air (about 30 to 1,400 cubic 

meters per minute) efficiently. Also, because the organic solvent is reclaimed there are no 

carbon monoxide (CO), carbon dioxide (CO2), or nitrogen oxide (NOX) emissions that are 

usually associated with the destruction of used organic solvent in air streams by combustion. 

Also, if the recovered organic solvents can be re-used it reduces the demand for production 

of additional organic solvent. The disadvantages of these systems result from the difficulty 

of separating organic solvents from each other for re-use. Also, if water soluble organic 

solvents (i.e., alcohols, etc.) are used, it may be difficult to separate the organic solvents 

from water. In addition, carbon does not adsorb all organic solvents. Therefore, the blend 

of organic solvents in use must be determined and considered before choosing this type of 

system. Another problem with systems of this type is that organic solvent quality can be 

degraded while the organic solvent is held on the carbon. 

B. Available Controls for VOC Emissions from Cleaning Materials

Pollution prevention measures and emission capture and add-on control systems are 

also employed to reduce VOC emissions from cleaning materials used in large appliance 

coating facilities. 

1. Pollution Prevention Measures

Product substitution/reformulation and work practice procedures are pollution 

prevention measures that may be used to decrease VOC emissions from cleaning materials. 

Alternative cleaners, such as alcohols and citrus-based cleaners, may be used to reduce VOC 

emissions from cleaning operations. 

Work practice procedures may also reduce VOC emissions from materials during 

cleaning operations. An example of a cleaning specific work practice involves spraying 

operations and cleaning. Nozzle maintenance, although often overlooked, is a critical 

component of any metal pretreatment system. In order to keep the system running at 

maximum efficiency to produce the highest-quality finished product, nozzle maintenance 

must become a regular part of system operation. Improperly maintained nozzles decrease 

spray impact and distort spray patterns, reducing cleaning efficiency. As a result, more time 

will be spent and more chemicals will be used to accomplish cleaning tasks. Learning to 
12

identify, solve, and prevent spray nozzle performance problems in a parts washer can cut 

spray liquid and energy waste, assure better washer performance, and reduce chances of 

equipment damage. The same holds true for coating spray nozzles. Typical cleaning 

activities involve organic solvent wipes, dips, and spraying of pure organic solvent which 

can contribute to the emissions from a facility. The amount of organic solvent emissions 

released from these activities can be minimized by taking actions such as storing cleaning 

materials in covered containers, using only the smallest amount of cleaning materials 

necessary, and collecting and placing solvent-laden cleaning materials in closed containers 

immediately after they are used. 

2. Emission Capture and Add-On Control Systems 

Carbon adsorption units or oxidizers can be used to control VOC emissions from 

cleaning operations as well as coating operations. Large appliance coaters can employ addon controls, such as carbon adsorption units or oxidizers, to reduce their VOC emissions 

from cleaning operations. 

C. Existing Federal, State, and Local Recommendations/Regulations

Provided below is a summary of EPA actions, as well as State and local regulations, 

that address VOC emissions from large appliance coating processes. In addition, Table 1 

outlines these Federal, State and local provisions and the bases for these provisions. 

1. The 1977 CTG 

The 1977 CTG recommended limiting VOC emissions from each large appliance 

coating unit. A coating unit consists of a series 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 different coating. (Two-step powder coating systems in which the powder 

coating is preceded by an adhesion enhancer may be considered as a single coating unit.) It 

is not necessary for a coating unit to have an oven or a flash-off area. 

For each coating unit, the 1977 CTG recommended a daily volume-weighted average 

limit of 0.34 kg/l (2.8 lb/gal) of coating, excluding water and exempt compounds, as applied. 

The emission limit was based on the use of low VOC content coatings and can be achieved 

with coatings which contain at least 62 volume percent solids or any waterborne equivalent. 

It was anticipated that this emission limit would result in approximately an 80 percent 

reduction in VOC emissions over conventional solvent-borne coatings that contain about 25 

volume percent solids. An equivalent reduction could be achieved by use of add-on control 

devices such as thermal oxidation or carbon adsorbers. Even greater reductions, 90 percent 

and more, could be achieved by conversion to electrodeposited waterborne coatings or 

powder coatings. There was no single control technique that was considered best for the 

entire industry since the large appliance industry included a wide variety of products. At the 

time, it was believed that most facilities would seek to meet future regulations through the 

use of low VOC content coatings rather than using to add-on control technologies. 
13

2. The 1982 NSPS

The 1982 NSPS applies to coating of large appliance products and parts at facilities 

that commence construction, modification, or reconstruction after December 24, 1980. The 

NSPS defines a large appliance part as any organic surface-coated metal lid, door, casing, 

panel, or other interior or exterior metal part or accessory that is assembled to form a large 

appliance product. Parts subject to in-use temperatures in excess of 250◦

F are not included 

in this definition. Large appliance product is defined as any organic surface-coated metal 

range, oven, microwave oven, refrigerator, freezer, washer, dryer, dishwasher, water heater, 

or trash compactor manufactured for household, commercial, or recreational use. The NSPS 

establishes a monthly volume-weighted average VOC limit of 0.90 kg/l (7.5 lb/gal) coating 

solids deposited for each surface coating operation on a large appliance surface coating line. 

3. The 2002 NESHAP 

EPA promulgated the large appliance surface coating NESHAP on July 23, 2002. 

Since the rule development was conducted within the past five (5) years, it was determined 

that the information collected during the rule’s development would be consistent with 

current large appliance coating facilities. 

Per the 2002 NESHAP, large appliance surface coating facilities are likely to be 

included under SIC codes 3631, 3632, 3633, 3639, 3582, 3585, and 3589 (excluding special 

industry machinery, industrial and commercial machinery and equipment, and electrical 

machinery equipment and supplies not elsewhere classified). Typical NAICS codes for this 

industry include 335221, 335222, 335224, 335228, 333312, 333415, and 333319 (also 

excluding special industry machinery, industrial and commercial machinery and equipment, 

and electrical machinery equipment and supplies not elsewhere classified). The large 

appliance source category includes facilities that apply coatings to large appliance parts or 

products. In the NESHAP, large appliances includes “white goods” such as ovens, 

refrigerators, freezers, dishwashers, laundry equipment, trash compactors, water heaters, 

comfort furnaces, and electric heat pumps. The source category also includes most heating, 

ventilating, and air conditioning (HVAC) equipment intended for any application. 

However, the NESHAP did not include in the source category motor vehicle airconditioning units, heat transfer coils, and large commercial and industrial chillers. 
14

Table 1. Summary of Existing Requirements 

Existing Regulation Emission Limit Basis for Emission Limit 

Large Appliance Coating CTG 

(December 1977) 

Recommended VOC emission limit 

of 2.8 pounds of VOC per gallon of 

coating, excluding water and 

exempt compounds, as applied 

(daily volume-weighted average) 

(narrow definition of coating unit) 

Calculated based on the use of higher 

solids coatings (62 percent solids) with 

an assumed VOC density of 7.36 

lb/gal. Associated with a baseline 

transfer efficiency of 60 percent. 

Large Appliances NSPS 

(October 27, 1982) 

VOC emission limit of 7.5 pounds 

of VOC per gallon of coating solids 

deposited from any surface coating 

operation on a large appliance 

surface coating line (monthly 

volume-weighted average) (narrow 

definition of coating operation) 

Based on the use of higher solids 

coatings (62 percent by volume solids) 

with an assumed VOC density of 7.36 

lb/gal and a baseline transfer efficiency 

of 60 percent. 

Large Appliances NESHAP 

(July 23, 2002) 

Existing sources: HAP emission 

limit of 1.1 pounds of organic HAP 

per gallon of coating solids used 

New sources: HAP emission limit 

of 0.18 pounds of organic HAP per 

gallon of coating solids used 

MACT level of control based on 2000 

survey of coating materials used in the 

industry 

California – South Coast Rule 

1107 (Originally adopted 

June 1, 1979 with last 

amendment January 6, 2006) 

VOC emissions limits for the 

coating of metal parts and products 

(which includes large appliance 

coating) of: (1) 2.3 pounds of VOC 

per gallon (0.275 kilograms per 

liter) of coating, excluding water 

and exempt compounds, as applied 

for general one component coatings 

(air-dried and baked) and general 

multi-component baked coatings; 

and (2) 2.8 pounds of VOC per 

gallon (0.34 kilograms per liter) of 

coating, excluding water and 

exempt compounds, as applied for 

general multi-component air-dried 

coating. Includes specific limits for 

specialty coatings such as extreme 

high gloss, high temperature, and 

metallic coatings. Electrostatic 

application, flow coat, dip coat, roll 

coat, HVLP spray, hand application 

methods, or other coating 

application method capable of 

achieving a transfer efficiency 

equivalent or better than that 

achieved by HVLP spraying 

required. 

Similar to the 1977 CTG but using a 

coating with 69 percent volume solids 

for general one-component (air-dried 

and baked) coatings and for general 

multi-component baked coatings, 62 

percent volume solids for general 

multi-component air-dried coatings 

and a transfer efficiency of 65 percent 
15

Table 1. Summary of Existing Requirements (Continued) 

Existing Regulation Emission Limit Basis for Emission Limit 

California – South Coast Rule 

1107 Continued 

Exempts coatings and operations 

such as stencil coatings, safetyindicating coatings, touch-up 

coatings and application with 

hand-held aerosol cans. 

Alternative to the emissions limit 

and operating equipment 

requirement allows the use of 

capture and control equipment to 

collect at least 90 percent by 

weight of the VOC emissions 

generated by the sources of VOC 

emissions (capture efficiency) 

and reduce VOC emissions from 

an emission collection system by 

at least 95 percent by weight 

(control efficiency). 

California - Bay Area Regulation 

8, Rule 14 

(Originally adopted 

March 7, 1979 with last 

amendment October 16, 2002) 

Method of coating application 

must have a transfer efficiency of 

65% or greater. VOC emission 

limit for baked coatings of 2.3 

pounds per gallon (0.275 

kilograms per liter) of coating, 

excluding water and exempt 

compounds, as applied and for 

air-dried coatings of 2.8 pounds 

per gallon (0.34 kilograms per 

liter) of coating, excluding water 

and exempt compounds, as 

applied. Includes specific limits 

for specialty coatings such as 

extreme high gloss, high 

temperature, and metallic 

coatings. 

Similar to the 1977 CTG but 

using a coating with 69 percent 

volume solids for baked coatings 

and 62 percent volume solids for 

air-dried coatings and a transfer 

efficiency of 65 percent 

State Regulations: 

22 State rules specifically for 

large appliance coating 

operations were identified 

VOC emission limit of 

2.8 pounds of VOC per gallon of 

coating, excluding water and 

exempt compounds, as applied, or 

an overall emission reduction of 

90 percent by utilization of an 

add-on control device 

1977 CTG 
16

The NESHAP’s affected source includes all of the activities that involve coatings, 

thinners, and cleaning materials used in large appliance coating operations. These activities 

include: 

1) Surface preparation of the large appliance parts or products; 

2) Preparation of coatings for application; 

3) Applying the coatings; 

4) Flash-off, drying, or curing f the coatings; 

5) Cleaning of coating equipment; 

6) Storage of coatings, thinners, and cleaning materials; 

7) Conveying of these materials; and 

8) Handling and conveying of waste materials generated by the coating operation. 

For the 2002 NESHAP, EPA selected the pollutants to regulate based on some 

assumptions generated during the rule development. Emission data collected during the 

development of the rule showed that the primary organic HAP emitted from the surface 

coating of large appliances included xylene, glycol ethers, toluene, methylene diphenyl 

diisocyanate, and MEK. These compounds accounted for approximately 82 percent of this 

category’s nationwide organic HAP emissions. However, many other organic HAP are 

used, or can be used, in large appliance coatings, thinners, and cleaning materials. 

Therefore, the rule regulated emissions of all organic HAP. Although most of the coatings 

used in this source category do not contain inorganic HAP, some special purpose coatings 

used by this source category were found to contain inorganic HAP such as chromium, 

cobalt, lead, and manganese. Emissions of these materials to the atmosphere are minimal 

because the facilities in this source category employ either water curtains or dry filters that 

remove overspray particles from the spray booth exhaust. At the time, it did not appear that 

emissions of inorganic HAP from this source category warranted Federal regulation. 

The final rule established different emission limits for existing and new sources. For 

an existing source, the organic HAP emissions limits is no more than 0.13 kilograms per 

liter (1.1 pounds per gallon) of coating solids used during each compliance (monthly) 

period. For a new or reconstructed source, the organic HAP emissions limit is no more than 

0.022 kilograms per liter (0.18 pounds per gallon) of coating solids. The limits apply to the 

total of all coatings, thinners, and cleaning materials used in coating operations at the 

affected source. Existing sources had to be in compliance no later than July 25, 2005. New 

or reconstructed sources have to be in compliance by this same date or upon startup, 

whichever is later. These HAP emission limits take into account products that contain MEK 

even though in December 2005, EPA amended the list of HAP contained in section 112 of 

the CAA by removing MEK. It is unclear at this point how MEK being delisted as a HAP 

has affected the large appliance coatings formulation. The NESHAP established three 

compliance options for meeting the emissions limits. 

1) Compliant Material Option – Each coating used in the operation must meet the 

limit, and each thinner and cleaning material must contain no organic HAP. 

2) Emission Rate Without Add-on Controls Option – The facility may average all of 

the coatings, thinners, and cleaning materials together and demonstrate that the 

overall emission rate is in compliance with the applicable limit. 
17

3) Emission Rate With Add-on Controls Option – This option applies to coating 

operations for which add-on controls are used to meet the limit. The facility 

must meet certain operating limits for the capture systems and control devices 

and follow a work practice plan for material storage, mixing, conveying, and 

spills. 

4. Existing State and Local VOC Requirements 

Every State has incorporated the large appliance coating Federal regulations 

described above (1982 NSPS and 2002 NESHAP). In addition, 22 States have specific large 

appliance coating regulations. 21 states have adopted the 1977 CTG recommended VOC 

emissions limit of 0.34 kilogram per liter (2.8 pounds per gallon) of coating, excluding water 

and exempt compounds, as applied. Five (5) States also have equivalent pound of VOC per 

gallon of coating solids used emissions limits. Appendix B provides a table which 

summarizes the large appliance coating regulations that are specific to a State and/or local 

agency within that State. 

The California South Coast Air Quality Management District (South Coast) has 

adopted limits for large appliance coating that are, in part, more stringent than the 1977 CTG 

recommendation. The VOC emissions limits established by the South Coast for the coating 

of metal parts and products (which includes large appliance coating) are: (1) 275 grams 

VOC per liter (g VOC/l) (2.3 lb VOC/gal) of coating, excluding water and exempt 

compounds, as applied for general one-component coatings (air-dried and baked) and 

general multi-component baked coatings; and (2) 340 g VOC/l (2.8 lb VOC/gal) of coating, 

excluding water and exempt compounds, as applied for general multi-component air-dried 

coatings. The South Coast regulation also includes specific limits for specialty coatings such 

as extreme high gloss, high temperature, and metallic coatings. The South Coast regulation 

specifies the following application methods: electrostatic application, flow coat, dip coat, 

roll coat, HVLP spray, hand application methods, or other coating application method 

capable of achieving a transfer efficiency equivalent or better than that achieved by HVLP 

spraying. Coatings and operations such as stencil coatings, safety-indicating coatings, 

touch-up coatings and application with hand-held aerosol cans are exempt from the South 

Coast’s regulation. As an alternative to the emissions limit and operating equipment 

requirement, the South Coast regulation allows the use of capture and control equipment to 

collect at least 90 percent by weight of the VOC emissions generated by the sources of VOC 

emissions (capture efficiency) and reduce VOC emissions from an emission collection 

system by at least 95 percent by weight (control efficiency). 

The California Bay Area Air Quality Management District (Bay Area) has also 

adopted limits for large appliance coating that are, in part, more stringent than the 1977 CTG 

recommendation: (1) 275 grams of VOC per liter (2.3 pounds of VOC per gallon) of 

coating, excluding water and exempt compounds, as applied for baked coating; and (2) 340 

grams of VOC per liter (2.8 pounds of VOC per gallon) of coating, excluding water and 

exempt compounds, as applied for air-dried coating. Like the South Coast regulations, the 

Bay Area regulations include specific limits for specialty coatings and exemptions for some 

coatings and coating operations. In addition, the Bay Area rule requires the use of coating 

application equipment that can meet a 65 percent or greater transfer efficiency. Per the Bay 

Area regulation, compliance with the standard’s 65 percent or great transfer efficiency can 
18

be achieved by properly operated electrostatic application or HVLP spray, flow coat, roller 

coat, dip coat including electrodeposition, and brush coat.

VI. Recommended Control Options

Based on a review of the 1977 CTG, the 1982 NSPS, the 2003 NESHAP, and the 

current State and local requirements discussed above, we are recommending emission limits 

for controlling the VOC emissions from the coatings used by large appliance manufacturing 

facilities and work practices to further reduce VOC emissions from coatings as well as to 

minimize emissions from cleaning materials used in metal furniture surface coating 

processes. 

To control VOC emissions from large appliance coatings, we are recommending 

three alternatives: (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 

coatings 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 

consists of emission limits in terms of mass of VOC per volume of coating, excluding water 

and exempt compounds, as applied and the use of specified application methods. The 

equivalent emission limit recommendation consists of emission limits in terms of mass of 

VOC per volume of coating solids, as applied, and the use of specific application methods. 

We estimate that these recommendations will reduce VOC emissions from large 

appliance coatings by about 30 percent (a reduction of 1,000 tons of VOC from the 

nonattainment area facilities). In our analysis of the impacts of the recommended level of 

control, we have assumed that all facilities will choose to utilize the low-VOC coating 

materials alternative. We made this assumption for two reasons. First, we believe that 

complying low-VOC coating materials are already widely available at a cost that is not 

significantly greater than the cost of coating materials with higher VOC contents. Secondly, 

the use of add-on controls to reduce emissions from typical spray coating operations would 

be a more costly alternative. 

For cleaning materials, we are recommending work practices to reduce VOC 

emissions. We do not have information available regarding current VOC content to 

determine a RACT limit for cleaning materials used in large appliance surface coating 

operations. Therefore, we are not recommending the use of a VOC content limit for 

cleaning materials. We are also not recommending the application of add-on controls solely 

as a means of reducing VOC emissions from cleaning materials. This would be a very 

costly alternative because the area to be controlled is quite large and a large volume of air 

would need to be captured and directed to a control device. However, any cleaning 

activities that occur within a capture device used to control VOC emissions from coating 

operations would be controlled by the associated control device. 

The following paragraphs summarize our specific recommendations for coating 

operations and cleaning materials used in large appliance surface coating operations. 
19

A. Emissions Limits based on Low-VOC Coatings

We are recommending emission limits for one-component and multi-component 

general purpose coatings. In addition, we are recommending specific emission limits for 

certain specialty coatings. For each of these coating types, we are recommending separate 

emission limits for baked and air-dried coatings. Provided below are our recommended 

emission limits expressed in terms of mass of VOC per volume of coating, excluding water 

and exempt compounds, as applied: 

 

 The recommended emission limits can also be expressed in terms of mass of VOC 

per volume of coating solids, as applied. A facility could use low-VOC coatings or a 

combination of coatings and add-on control equipment on a coating unit to meet the 

recommended mass of VOC per volume of coating solids, as applied, limits. Using an 

assumed VOC density of 7.36 pounds per gallon, equivalent limits in terms of mass of VOC 

per volume of solids, as applied, are as follows: 

We are also recommending that the following types of coatings and coating 

operations be exempt from our recommended VOC content limits: 

• Stencil coatings 

• Safety-indicating coatings 

• Solid-film lubricants 

• Electric-insulating and thermal-conducting coatings 

Baked Air Dried Coating Type kg/l lb/gal kg/l lb/gal

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 

Baked Air Dried Coating Type kg/l lb/gal kg/l lb/gal 

General, One Component 0.40 3.3 0.40 3.3 

General, Multi-Component 0.40 3.3 0.55 4.5 

Extreme High Gloss 0.61 5.1 0.55 4.5 

Extreme Performance 0.61 5.1 0.80 6.7 

Heat Resistant 0.61 5.1 0.80 6.7 

Metallic 0.80 6.7 0.80 6.7 

Pretreatment Coatings 0.80 6.7 0.80 6.7 

Solar Absorbent 0.61 5.1 0.80 6.7 
20

• Touch-up and repair coatings 

• Coating application utilizing hand-held aerosol cans 

We are recommending that all VOC-containing materials (i.e., coatings and thinners) 

used by each large appliance surface coating unit are included when determining the coating 

unit’s emission rate. In addition, we are recommending the use of the following application 

methods: electrostatic application, HVLP spray, flow coat, roller coat, dip coat including 

electrodeposition, brush coat, or other coating application method capable of achieving a 

transfer efficiency equivalent or better than that achieved by HVLP spraying. The 

recommendations described above are based on the South Coast’s metal parts and products 

coating regulation, which includes large appliances. 

The VOC content limits can be met by averaging the VOC content of materials used 

on a single surface coating unit each day (i.e., daily within-coating unit averaging). We do 

not recommend the use of cross-coating unit averaging (i.e., averaging across multiple 

coating units) to meet the VOC content limits. However, we have previously provided 

guidance on cross-line averaging4

. The guidance is directed to State and local agencies that 

elect to adopt a discretionary economic incentive programs (EIP) and includes guidance on 

the use of cross-line averaging.

B. Optional Add-On Controls for Coating Operations

 Should product performance requirements or other needs dictate the use of higherVOC materials than those that would meet the recommended emission limit, a facility could 

choose to use add-on control equipment to meet an overall control efficiency of 90 percent. 

Alternatively, a facility could use a combination of coatings and add-on control equipment 

on a coating unit to meet the recommended mass of VOC per volume of coating solids 

limits. Add-on devices include oxidizers and solvent recovery systems that, coupled with 

their attendant systems to capture the VOC being released at the affected facilities, can 

achieve an overall control efficiency of 90 percent. This control option, like the options 

noted above, applies to all coatings and thinners applied to large appliances. 

C. Work Practices for Coating Operations and Cleaning Materials

 In addition to the control options above, this CTG recommends work practices to 

further reduce emissions from the coatings as well as to minimize emissions from the 

cleaning materials used for large appliance coating operations. Although VOC reductions 

achieved by implementing the work practice recommendations may not be quantifiable, we 

believe they are beneficial to the overall goal of reducing VOC emissions. We recommend 

implementing work practices for solvent storage, mixing operations, and handling 

operations for coatings, thinners, cleaning materials, and waste materials. Specifically, we 

recommend the following work practices: 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 

 

4 Improving Air Quality with Economic Incentive Programs. U.S. Environmental Protection 

Agency. Research Triangle Park, NC. EPA-452/R-01-001. January 2001.
21

coatings and other materials except when specifically in use; and minimize usage of solvents 

during cleaning of storage, mixing, and conveying of equipment. 

VII. Cost Effectiveness of Recommended Control Options 

As previously mentioned, the recommendations in this CTG are similar to the South 

Coast regulations governing large appliance coating operations. Unfortunately, the costeffectiveness of these regulations was not estimated during those regulations’ development. 

Therefore, cost-effectiveness estimates for the recommended control levels were determined 

based on information collected during the 1977 CTG and the 2002 NESHAP development. 

Although the 2002 NESHAP regulates organic HAP, the 2002 NESHAP cost estimates are 

relevant to this CTG’s recommended levels of control because they are based on the use of 

the similar control measures (i.e., product substitution/reformulation and work practices) for 

large appliance coatings and cleaning materials as those recommended in this CTG. In 

addition, the 2002 NESHAP provides data regarding large appliance coating facilities that 

are more current than the 1977 CTG. 

During the development of the 2002 NESHAP, it was estimated that no facility 

within the industry would install add-on control devices as a result of the standard. The 

capital costs and annual operating costs of add-on control devices usually make them less 

desirable than other compliance options for reducing VOC emissions from spray coating 

operations. 

In the 1977 CTG, the cost effectiveness for a medium-sized facility using waterborne 

prime and higher solids topcoat was estimated to be $141 per megagram ($128 per ton) of 

VOC reduced. This would be approximately $425 per ton in 2006 dollars based on 

historical CPI data from www.inflationdata.com. The 2002 NESHAP presented a control 

cost of $480,000 for 1,191 tons of HAP reduction from 74 facilities expected to be subject to 

the rule ($403 per ton HAP reduced, about $480 per ton in 2006 dollars). For, the 

recommendations in this CTG, we therefore estimate a cost-effectiveness of $500 per ton of 

VOC reduced. We estimate the total annual cost of the estimated 1,000 tpy of emission 

reduction to be $500,000. 
22

VIII. References

1. Control of Volatile Organic Emissions from Existing Sources - Volume V: Surface 

Coating of Large Appliances. Publication No. EPA-450/2-77-034. U. S. 

Environmental Protection Agency, Research Triangle Park, NC. December 1977. 

2. Bay Area (California) Air Quality Management District Regulation 8, Organic 

Compounds, Rule 14, Surface Preparation and Coating of Large Appliances and 

Metal Furniture. Amended October 16, 2002. 

3. South Coast (California) Air Quality Management District Regulation XI, Source 

Specific Standards, Rule 1107, Coating of Metal Parts and Products. Amended 

January 6, 2006. 

4. National Emission Standards for Hazardous Air Pollutants (NESHAP) for Source 

Category: Large Appliances Surface Coating Operations - Background Information 

for Promulgated Standards. EPA-453/R-02-004. U. S. Environmental Protection 

Agency, Research Triangle Park, NC. April 2002. 

5. Industrial Surface Coating: Appliances – Background Information for Proposed 

Standard. EPA-450/3-80-037a. U. S. Environmental Protection Agency, Research 

Triangle Park, NC. November 1980. 

6. Improving Air Quality with Economic Incentive Programs. U.S. Environmental 

Protection Agency. Research Triangle Park, NC. EPA-452/R-01-001. January 

2001. 
Appendix A: 1977 Large Appliance Coating CTG Document 
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Appendix B: Summary of State-Specific Large Appliance 

Coating Regulations 
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State County/Area VOC Limit Applies To VOC Limit Emission Limi

AL Jefferson 

Application area(s), flash-off area(s), and oven(s) of coating lines involved in prime, single, or topcoat coating operations. Does not apply to the use of quick-drying lacquers for repair of scratches and nicks that occur during assembly, provided that the volume of coating does not exceed 757 liter/yr (200 gal/yr). 

0.34 kg/liter (2.8 lb/gal) of coating, excluding water, delivered to the coating applicator from prime, single, or topcoat coating operations. 

AZ Maricopa 

Application of coating, coating preparation/mixing at the facility applying the coating, & the cleanup of coating application equipment. Does not apply to coatings with VOC content, minus exempt compounds, of less than 0.15 lb VOC/gal (18 g/liter) nor to solvents having a VOC content of material less than 0.15 lb VOC/gal. 

2.8 lb/gal or 0.34 kg/liter of coating (minus water) 

For coating containin(240 g/liter) minus ex1. Low-pressure spra2. Electrostatic syste3. Atomizing system including "airless" an4. Non-atomizing or such as dipping, rollin5. Any method approAdministrator and Cotransfer efficiency of 

CA Bay Area 

Does not apply to the use of any coating used in volumes less than 75.7 liters/yr (20 gal/yr) (facility limited to 208.1 liters or 55 gallons total coating/yr). Also does not apply to surface preparation of electrical and electronic components, stripping of cured inks, coatings and adhesives or cleaning of resin, coating, ink and adhesive mixing, molding and application equipment, or surface preparation associated with research and development operations; performance testing to determine coating, adhesive or ink performance; or testing for QA/QC purposes. 

Method of coating application must have a transfer efficiency of 65% or greater and then a VOC emission limit for baked coatings of 2.3 lb/gal (275 g/L) and for air-dried coatings of 2.8 lb/gal (340 g/L) of coating, excluding water. Includes specific limits for specialty coatings such as extreme high gloss, high temperature, and metallic coatings. 
State County/Area VOC Limit Applies To VOC Limit Emission Limi

South Coast 

Applies to all metal coatings operations except those performed on aerospace assembly, magnet wire, marine craft, motor vehicle, metal container, and coil coating operations. This rule does not apply to the coating of architectural components coated at the structure site or at a temporary unimproved location designated exclusively for the coating of structural components. 

2.3 lb/gal (0.275 kg/liter) of coating, excluding water and exempt compounds, as applied for general one component coatings (air-dried and baked) and general multi-component baked coatings; and 2.8 lb/gal (0.34 kg/liter) of coating, excluding water and exempt compounds, as applied for general multi-component airdried coating. Includes specific limits for specialty coatings such as extreme high gloss, high temperature, and metallic coatings. Electrostatic application, flow coat, dip coat, roll coat, HVLP spray, hand application methods, or other coating application method capable of achieving a transfer efficiency equivalent or better than that achieved by HVLP spraying required. 

CO 

Coating line; prime, single or topcoat application area, flash-off area, and oven 

0.34 kg/liter coating or 2.8 lb/gal coating (minus water) 
State County/Area VOC Limit Applies To VOC Limit Emission Limi

DE 

Any large appliance coating unit. Does not apply to a facility whose actual emissions w/out control devices from all large appliance coating units w/in the facility are <6.8 kg VOC/day (15 lb VOC/day) or the use of quick-drying lacquers for repairs of scratches & nicks that occur during assembly, provided that the volume of coating does not exceed 0.95 liter/any 8-hr period (0.25 gal/any 8-hr period). 

0.34 kg/liter (2.8 lb/gal) of coating (minus water & exempt compounds) 

1. Installing and oper2. Installing and oper3. Determining the oefficiency for each dacompliance 4. Demonstration eacemission reduction efday is greater than or emission reduction efday 

FL 

Application areas, flash-off areas, and ovens of coating lines involved in prime, single, or topcoat coating operations. 

0.34 kg/liter (2.8 lb/gal) of coating (excluding water) 

1. Application of low technology 2. Incineration, proviwhich enter the incincarbon dioxide and w

IL 

Does not apply to use of quick-drying lacquers for repair of scratches & nicks that occur during assembly, provided that the volume of coating does not exceed 0.95 liter/any one 8-hr period (1 qt/any 1 8-hr period) 

0.34 kg/liter (2.8 lb/gal) of coating (minus water & exempted compounds) 

IN 

Coating application (prime, single, or topcoat coating operations). Does not apply to use of quick-drying lacquers for repair of scratches & nicks that occur during assembly (limited to 1 gal in an 8-hr period). 

0.34 kg/liter (2.8 lb/gal) of coating (minus water) 
State County/Area VOC Limit Applies To VOC Limit Emission Limi

KY 

Applies to facilities commenced before 6/29/79 located in a ozone nonattainment county. Does not apply to any affected 

facility: 1) if the VOC content of the coating is <0.34 kg/liter (2.8 lb/gal) (minus water or exempt solvent) 2) repair coating operations 3) total VOC emissions are less than or equal to 3 lb/hr actual, 15 lb/day actual, or 10 ton/yr potential before control 4) low-use coatings if plantwide consumption of these coatings in the aggregate is less than or equal to 55 gals during the previous 12 months 

No facility discharge of VOC into the atmosphere more that 15% by weight of the VOC net input into the facility 

MD 

Does not apply to use of quick-drying lacquers for repair of scratches & nicks that occur during assembly. 

0.34 kg/liter (2.8 lb/gal) of coating (minus water) 

MI 

The primer surface or topcoat coating includes an anti-chip, blackout, or spot primer coating if this coating is applied as part of the primer surface or topcoat coating operation. Does not apply to coatings that are used for the repair of scratches & nicks. Exceptions also include coating lines w/in a stationary source with actual VOC emissions <100 lb/day or 2,0000 lb/month and excludes low-use coatings that total 55 gallons or less per rolling 12-month period. 

2.8 lb VOC/gal of coating (minus water) or 7.5 lb VOC/gal of applied coating solids 
State County/Area VOC Limit Applies To VOC Limit Emission Limi

NJ 

Surface coating operation located at a major VOC facility having the potential to emit 3 lb VOC/hr or more. 

0.34 kg/liter (2.8 lb/gal) of coating (minus water) 

May apply to alternatVOC limit per volumformulation provided formulation is applied greater than 60 percen

NC 

Application area(s), flashoff area(s), and 

oven(s) of coating lines involved in prime, single, or topcoat coating operations. Does not apply to the use of quick-drying lacquers for repair of scratches and nicks that occur during assembly, if the volume of coating does not exceed 1 qt in any 8-hr period. 

4.5 lb VOC/gal of solids delivered to the coating applicator from prime, single, or topcoat coating operations. If controlled by approved air pollution control equipment, the limit is 2.8 lb VOC/gal of coating (excluding water & exempt compounds). 

OH 

Prime coat, single coat or topcoat coating 

line, as follows: (a) in 24 counties [listed in OAC rule 3745-21-09(A)(1)], to existing and new coating lines; (b) in the other 64 counties, to any new coating line and to existing and new coating lines at a facility with potential to emit equal to or greater than 100 tons VOC per year. A new coating line is a coating line for which construction of modification commenced on or after October 19, 1979. The emission limitation does not apply to the use of quick drying lacquers for repair of scratches and nicks that occur during assembly, provided that the maximum usage of such lacquers does not exceed one quart in any eight hour period. 

2.8 lb VOC/gal of coating (excluding water & exempt solvents) or, if control system is employed, 4.5 lb VOC/gal of solids 

(a) complying coating(b) control system thaVOC/gal solids or an with a control device or (c) an alternative emiupon a “tested” transf60%. 
State County/Area VOC Limit Applies To VOC Limit Emission Limi

OR 

Does not apply to sources whose potential to emit from coating of VOC are <10 tpy (or 3 lb VOC/hr or 15 lb VOC/day actual) or research facilities. 

2.8 lb/gal (excluding water & exempt solvents) 

1. Application of low technology 2. Incineration, proviwhich enter the incincarbon dioxide and w3. Equivalent means Meaning it must be apauthority (Dept. of En

RI 

Does not apply to the use of quick drying lacquers for repair of scratches & nicks that occur during assembly, provided that the volume of coating does not exceed 0.25 gals in any one 8-hr period. 

2.8 lb VOC/gal of coating (minus water) or 4.52 lb VOC/gal of solids 

Compliance with emiachieved through: 1. Installation of an asuch that the total emgreater over uncontro2. Coating reformulaemission limitation is 3. Installation of conemissions to the equivlimitations as calculabasis 4. Use of daily-weigh5. An alternative, appof control 

SC 

Applies to the prime, single or topcoat from a coating application system. Does not apply to the use of quick-drying lacquers for repair of scratches & nicks that occur during assembly, provided that the volume of coating does not exceed 1 qt (0.95 liter) in any one 8-hr period. 

2.8 lb/gal (0.34 kg/liter) of coating (excluding water & exempt solvents) 

1. Application of low technology 2. Incineration, provinonmethane VOC whare oxidized to CO2 a3. Carbon bed solven4. Alternative controPart C 
State County/Area VOC Limit Applies To VOC Limit Emission Limi

TN 

Does not apply to the use of quick-drying lacquers for repair of scratches & nicks that occur during assembly, provided that the volume of coating does not exceed 0.95 liter (0.25 gal) in any one 8-hr period and any large appliance coating line w/in a facility: 1) in Davidson, Rutherford, Sumner, Williamson, or Wilson County whose actual emissions w/our control are <6.8kg (15 lb) VOC per day or whose max emissions from all large appliance coating lines are <10 ton VOC/yr 2) in Hamilton or Shelby County whose potential VOC emissions from all large appliance coating lines are <25 ton VOC/yr3) in any other county whose potential VOC emissions from all large appliance coating lines are <100 ton VOC/yr 

0.34 kg/liter (2.8 lb/gal) of coating (excluding water & exempt compounds) 

TX 

Beaumont/Port 

Arthur 

Dallas/Fort Worth 

El Paso 

Houston/Galveston 

Gregg County 

Nueces County 

Victoria County 

VOC emissions from the application, flashoff, and oven areas during the coating of large appliances (prime and topcoat, or single coat). 

2.8 lb/gal (0.34 kg/liter) of coating (minus water & exempt solvent) delivered to the application system 
State County/Area VOC Limit Applies To VOC Limit Emission Limi

UT 

Application areas, flash-off areas, and ovens of coating lines involved in prime, singe or top coating operations. 

0.34 kg/liter (2.8 lb/gal) of coating (excluding water & exempt solvents) or 4.5 lb VOC/gal solids 

1. Application of low technology 2. Incineration, provinonmethane VOC whare oxidized to CO2 a3. Use of water-born4. Use of water-born5. Use of powder 6. Use of higher solid7. Carbon adsorption 

WA 

The operation of a coater and dryer, that may serve one or more process lines, shall comply if the uncontrolled emissions of VOC from the coater, flash-off areas, and dryer would be >18 kg (40 lb) in any given 24-hr period. The emission limits and uncontrolled emission quantity shall include the additional quantity of emissions from the dryer during the 12-hr period after the application of the coating. 

0.34 kg/liter (2.8 lb/gal) of coating (minus water) 

WV 

Does not apply to any coating line w/in a facility whose actual emissions w/out control from all large appliance coating lines w/in the fenceline are <6.8 kg (15 lb) VOC/day or the use of quick-drying lacquers for repair of scratches & nicks that occur during assembly, provided that the volume of coating does not exceed 0.95 liter (0.25 gal) in any one 8-hr period. 

0.34 kg/liter (2.8 lb/gal) of coating (minus water & exempt compounds) as applied 

As an alternative to th1. Installation and opsystem 2. Installation and op3. Determination eacemission reduction efdemonstrate complian4. Demonstration eacemission reduction efday is greater than or emission reduction efday 
State County/Area VOC Limit Applies To VOC Limit Emission Limi

WI 

Application areas, flash-off areas, and ovens of coating lines involved in single, prime or topcoat coating operations. Does not apply to the use of quick-drying lacquers for repair of scratches & nicks that occur during assembly, provided that the volume of coating does not exceed 0.95 liter (1 qt) in any one 8-hr period for any appliance coating line. 

0.34 kg/liter (2.8 lb/gal) of coating (excluding water) delivered 
United States 

Environmental Protection Agency 

Office of Air Quality Planning and Standards 

Sector Policies and Programs Division 

Research Triangle Park, NC 

Publication N