UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

1650 Arch Street

Philadelphia, Pennsylvania 19103

DATE:

SUBJECT: Technical Support Document for Pennsylvania’s Adoption of Control 

Techniques Guidelines (CTG) for Large Appliance and Metal Furniture 

Surface Coating

FROM: Gregory Becoat, Environmental Scientist /s/

Office of Air Program Planning 

TO: File

THRU: Cristina Fernandez, Associate Director /s/

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 

large appliance coatings and metal furniture coatings. 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 large appliance coatings and metal furniture coatings.
In December 1977, EPA published CTGs for large appliance coatings (EPA-450/2-77-

034) and surface coating of metal furniture (EPA-450/2-77-032). These CTGs discuss 

the nature of VOC emissions from these industries, available control technologies for 

addressing such emissions, the costs of available control options, and other items. EPA 

promulgated national standards of performance for new stationary sources (NSPS) for 

large appliance coatings in 1982 (40 CFR part 60, subpart SS) and surface coating of 

metal furniture in 1982 (40 CFR part 60, subpart EE). The NSPS requires VOC 

emissions limits based on VOC content of low VOC coating materials. EPA also 

published a national emission standard for hazardous air pollutants (NESHAP) for large 

appliance coatings in 2002 (40 CFR part 63, subpart NNNN) and surface coating of metal 

furniture in 2003 (40 CFR part 63, subpart RRRR). The NESHAP establishes national 

emission standards for hazardous air pollutants and emissions limits based on the organic 

HAP content of low organic HAP coating materials.

In 2006 and 2007, after conducting a review of currently existing state and local VOC 

emission reduction approaches for these industries, reviewing the 1977/1978 CTGs and 

the NESHAPs for these industries, and taking into account the information that has 

become available since then, EPA developed new CTGs for: surface coating of large 

appliances, entitled “Control Techniques Guidelines for Large Appliance Coatings,”

(Publication No. EPA 453/R-07-004; September 2007); and surface coating of metal 

furniture, entitled “Control Techniques Guidelines for Metal Furniture Coatings”

(Publication No. EPA 453/R-07-005; September 2007).

Description of Large Appliance Coatings 

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 

appliance parts or products. A large appliance part is defined as any organic surfacecoated metal lid, door, casing, panel, or other interior or exterior 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, refrigerator, freezer, washer, 

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

commercial, or recreational use.

Coatings are a critical constituent of 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 aesthetic appeal. 

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

industries, and include air atomized spraying, dip coating, electrodeposition, and flow 

coating.
VOC emissions from large appliance coating processes result from the evaporation of the 

components of the coatings and cleaning materials. 

EPA’s Recommended Control Options for Large Appliance Coatings

EPA issued a CTG for Large Appliance Coatings in September 2007 (Publication No. 

EPA 453/R-07-004). Recommendations for controlling VOC emissions from large 

appliance coatings are outlined in the CTG. Three alternatives are recommended: (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 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. Additionally, for cleaning materials, work practices are recommended to 

reduce VOC emissions.

Specific recommendations for coating operations and cleaning materials used in large 

appliance surface coating operations are summarized below:

A. Emissions Limits Based on Low-VOC Coatings: Emission limits for one-component 

and multi-component general purpose coatings are recommended. In addition, 

specific emission limits for certain specialty coatings are recommended. For each of 

these coating types, separate emission limits are recommended for baked and airdried coatings. Provided in Table 1 are the recommended emission limits expressed 

in terms of mass of VOC per volume of coating (kilograms per liter (kg/l) or pounds 

per gallon (lb/gal), excluding water and exempt compounds.

Table 1. Recommended Emission Limits (mass of VOC per volume of coating) for 

Large Appliance Coatings

Coating Type Baked Air Dried

kg/l lb/gal kg/l lb/gal

General, One Component 0.275 2.3 0.275 2.3

General, MultiComponent0.275 2.3 0.340 2.8

Extreme High Gloss 0.360 3.0 0.340 2.8

Extreme Performance 0.360 3.0 0.420 3.5

Heat Resistant 0.360 3.0 0.420 3.5

Metallic 0.420 3.5 0.420 3.5

Pretreatment Coatings 0.420 3.5 0.420 3.5

Solar Absorbent 0.360 3.0 0.420 3.5

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

volume of coating solids as shown in Table 2. 
Table 2. Recommended Emission Limits (mass of VOC per volume of coating

solids) for Large Appliance Coatings

Coating Type Baked Air Dried

kg/l lb/gal kg/l lb/gal

General, One Component 0.40 3.3 0.40 3.3

General, MultiComponent0.40 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

The following types of coatings and coating operations are recommended to be exempt 

from the recommended VOC content limits: stencil coatings, safety-indicating coatings, 

solid-film lubricants, electric-insulating and thermal-conducting coatings, touch-up and 

repair coatings, and coating application utilizing hand-held aerosol cans.

It is recommended that all VOC-containing materials used by each large appliance 

surface coating unit be included when determining the coating unit’s emission rate. 

Additionally, the following application methods are recommended: electrostatic 

application, high volume/low pressure (HVLP) spray, flow coat, roller coat, dip coat 

including electrodeposition, or brush coat. 

B. Optional Add-On Controls for Coating Operations: Should product performance 

requirements or other needs dictate the use of higher VOC materials than those that 

would meet the recommended emission limits, a facility could choose to use add-on 

control equipment to meet an overall efficiency of 90 percent. 

C. Work Practices for Coating Operations and Cleaning Materials: Work practices to 

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

materials used for large appliance coating operations are recommended, and they are: 

store all VOC-containing coatings, thinners, and cleaning materials in closed containers; 

minimize spills of VOC-containing coatings, thinners, and cleaning materials; clean up 

spills immediately; convey any coatings, thinners, and cleaning materials in closed 

containers or pipes; close mixing vessels that contain VOC coatings and other materials 

except when in use; and minimize usage of solvents during cleaning of storage, mixing, 

and conveying of equipment.

Description of Metal Furniture Coatings

The metal furniture coatings product category under section 183(e) of the CAA includes 

the coatings that are applied to the surfaces of metal furniture. A metal furniture 

substrate is the furniture or component of furniture constructed either entirely or partially 

from metal. Metal furniture includes, but is not limited to, the following types of 
products: household, office, institutional, laboratory, hospital, public building, restaurant, 

barber and beauty shop, and dental furniture, as well as components of these products. 

Metal furniture also includes office and store fixtures, partitions, shelving, lockers, lamps 

and lighting fixtures, and wastebaskets. Metal furniture coatings include paints and 

adhesives and are typically applied without a primer. Higher solids and powder coatings 

are used extensively in the metal furniture surface coating industry. Metal furniture 

coatings are used extensively in the metal furniture surface coating industry. 

Metal furniture coatings serve decorative, protective, and functional purposes. Coatings 

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

the outdoor elements. Coatings for each type of metal furniture have special 

requirements and contain unique properties because each type will be exposed to 

somewhat different corrosive elements. The coating must also be durable and have 

excellent adhesion properties to avoid peeling or chipping. Finally, the coatings for many 

products provide decorative appeal.

The metal furniture manufacturing process can be divided into four main unit operations: 

(1) raw material preparation, (2) surface preparation, (3) coating and adhesive application 

operations, and (4) assembly. In addition, cleaning activities are performed in support of 

the surface coating operation. The majority of the raw material preparation operations 

and assembly operations are mechanical in nature and involve no VOC emissions. 

Surface preparation, coating application operations, and cleaning activities utilize VOCcontaining compounds (i.e. coatings, thinners, and/or cleaning materials).

VOC emissions from metal furniture surface coating processes result from the 

evaporation of the volatile components of the coatings and cleaning materials. In most 

cases, VOC emissions from surface preparation, storage, handling, and waste/wastewater 

operations are relatively small.

EPA’s Recommended Control Options for Metal Furniture Coatings

EPA issued a CTG for Metal Furniture Coatings in September 2007 (Publication No. 

EPA 453/R-07-005). Recommendations for controlling VOC emissions from metal 

furniture coatings are outlined in the CTG. Three alternatives are recommended: (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 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. Additionally, for cleaning materials, work practices are recommended to 

reduce VOC emissions.
Specific recommendations for coating operations and cleaning materials used in metal 

furniture surface coating operations are summarized below:

A. Emissions Limits Based on Low-VOC Coatings: Emission limits for one-component 

and multi-component general purpose coatings are recommended. In addition, 

specific emission limits for certain specialty coatings are recommended. For each of 

these coating types, separate emission limits are recommended for baked and airdried coatings. Provided below are the recommended emission limits expressed in 

terms of mass of VOC per volume of coating, excluding water and exempt 

compounds:

Table 3. Recommended Emission Limits (mass of VOC per volume of coating) for 

Metal Furniture Coatings

Coating Type Baked Air Dried

kg/l lb/gal kg/l lb/gal

General, One Component 0.275 2.3 0.275 2.3

General, MultiComponent0.275 2.3 0.340 2.8

Extreme High Gloss 0.360 3.0 0.340 2.8

Extreme Performance 0.360 3.0 0.420 3.5

Heat Resistant 0.360 3.0 0.420 3.5

Metallic 0.420 3.5 0.420 3.5

Pretreatment Coatings 0.420 3.5 0.420 3.5

Solar Absorbent 0.360 3.0 0.420 3.5

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

volume of coating solids, 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 limits. Using an assumed VOC 

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

volume of solids, as applied, are as follows: 

Table 4. Recommended Emission Limits (mass of VOC per volume of coating) for 

Metal Furniture Coating Solids

Coating Type Baked Air Dried

kg/l lb/gal kg/l lb/gal

General, One Component 0.40 3.3 0.40 3.3

General, MultiComponent0.40 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
The following types of coatings and coating operations are recommended to be exempt 

from the recommended VOC content limits: stencil coatings, safety-indicating coatings, 

solid-film lubricants, electric-insulating and thermal-conducting coatings, touch-up and 

repair coatings, and coating application utilizing hand-held aerosol cans.

It is recommended that all VOC-containing materials used by each metal furniture 

surface coating unit be included when determining the coating unit’s emission rate. 

Additionally, the following application methods are recommended: electrostatic 

application, HVLP spray, flow coat, roller coat, dip coat including electrodeposition, or 

brush coat. 

B. Optional Add-On Controls for Coating Operations: Should product performance 

requirements or other needs dictate the use of higher VOC materials than those that 

would meet the recommended emission limits, a facility could choose to use add-on 

control equipment to meet an overall 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 solid limits.

C. Work Practices for Coating Operations and Cleaning Materials: Work practices to 

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

materials used for large appliance coating operations are recommended, and they are: 

store all VOC-containing coatings, thinners, and cleaning materials in closed containers; 

minimize spills of VOC-containing coatings, thinners, and cleaning materials; clean up 

spills immediately; convey any coatings, thinners, and cleaning materials in closed 

containers or pipes; close mixing vessels that contain VOC coatings and other materials 

except when in use; and minimize usage of solvents during cleaning of storage, mixing, 

and conveying of equipment.

B. STATE SUBMITTAL

On October 1, 2010, Pennsylvania Department of the Environmental Protection (PADEP) 

submitted to EPA a SIP revision concerning the adoption of the EPA CTGs for large 

appliance and metal furniture coatings. EPA develops CTGs as guidance on control 

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

standards. PADEP is amending existing regulations at 25 Pa. Code sections 129.51 and 

129.52 (relating to general; and surface coating processes) and adding section 129.52a 

(relating to control of VOC emissions from large appliance and metal furniture surface 

coating processes) in order to control VOC emissions from large appliance and metal 

furniture surface coating processes.

The revision amends section 129.51.(a), entitled “Equivalency,” in order to include large 

appliance and metal furniture surface coating processes. This revision provides an 

alternative method for owners and operators of facilities to achieve compliance with air 

emission limits.
The revision amends section 129.52, entitled “Surface coating processes,” by adding 

subsection (i) in order to establish that the requirements and limits for metal furniture 

coatings and large appliance coatings already specified in section 129.52 are superseded 

by the requirements and limits in section 129.52a (relating to control of VOC emissions 

from large appliance and metal furniture surface coating processes). One emission limit 

in section 129.52 is established for large appliance coatings and one emission limit is 

established for metal furniture coatings, whereas in the CTGs established by the EPA 

separate emission limits are expressed for eight different coating types within large 

appliance coatings and metal furniture coatings. 

The revision adds section 129.52a., entitled “Control of VOC emissions from large 

appliance and metal furniture surface coating processes,” in order to regulate VOC 

emissions from large appliance and metal furniture surface coating processes. 

The revision adds section 129.52a.(a), entitled “Applicability,” in order to establish

applicability to the owner and operator of a large appliance or metal furniture surface 

coating process if the total actual VOC emissions from large appliance or metal furniture 

surface coating operations, including related cleaning activities are equal to or greater 

than 15 pounds per day or 2.7 tons per 12-month rolling period before consideration of 

controls. 

The revision adds section 129.52a.(b), entitled “Existing RACT permit,” in order to 

establish that section 129.52a supersedes the requirements of a RACT permit for VOC 

emission from a large appliance or metal furniture surface coating operation already 

issued to the owner or operator of a source subject to section 129.52a, except to the extent 

the RACT permit contains more stringent requirements.

The revision adds section 129.52a.(c), entitled “Emission limits,” in order to establish

VOC limits. Beginning January 1, 2011, a person may not cause or permit the emission 

into the outdoor atmosphere of VOCs from a large appliance or metal furniture surface 

coating process, unless the VOC content of each as applied coating is equal to or less 

than the limit specified in Table I or Table II in section 129.52a; or the overall weight of

VOCs emitted to the atmosphere is reduced through the use of vapor recovery, 

incineration or another method that is acceptable under section 129.51(a).

The revision adds section 129.52a.(d), entitled “Compliance monitoring procedures,” in 

order to identify daily records, including records of parameters and VOC content of each 

coating, thinner, component and cleaning solvent, as supplied, and the VOC content of 

each as applied coating or cleaning solvent, that shall be kept in order to demonstrate 

compliance with section 129.52a.

The revision adds section 129.52a.(e), entitled “Recordkeeping and reporting 

requirements,” in order to establish the new recordkeeping and reporting requirements.

The revision adds section 129.52a.(f), entitled “Coating application methods,” in order to 

establish that an owner or operator subject to section 129.52a may not cause or permit the 
emission into the outdoor atmosphere of VOCs from the application of large appliance or 

metal furniture surface coating, unless the coatings are applied using electrostatic coating, 

roller coating, flow coating, dip coating, high volume-low pressure spray (HVLP), or 

brush coating. 

The revision adds section 129.52a.(g), entitled “Exempt coatings and coating operations,” 

in order to exempt stencil coating, safety-indicating coatings, solid-film lubricants, 

electric-insulating coatings, thermal-conducting coatings, touch-up and repair coatings 

and coating applications using hand-held aerosol cans form the VOC coating content 

limits established in section 129.52a, Table I and Table II. 

The revision adds section 129.52a.(h), entitled “Work practice requirements for coatingrelated activities,” in order to establish work practices that owners or operators of a large 

appliance or metal furniture surface coating process subject to section 129.52a shall 

comply with for coating-related activities.

The revision adds section 129.52a.(i), entitled “Work practice requirements for cleaning 

materials” in order to establish work practices that owners or operators of a large 

appliance or metal furniture surface coating process subject to section 129.52a shall 

comply with for cleaning materials.

Table 5 establishes emission limits for VOCs for eight types of large appliance surface 

coatings, expressed in weight of VOC per volume of coating solids (kilograms per liter 

(kg/l) or pounds per gallon (lb/gal)), as applied. The emission limits for Baked (kg/l and 

lb/gal) - “General, One Component” and “General, Multi-Component,” Air Dried (kg/l) –

“General, One Component” and Air Dried (lb/gal) – “General, One Component,” 

“General, Multi-component,” and “Extreme High Gloss” are taken directly from the large 

appliance coatings CTG. The emission limits for Air Dried (kg/l) – “General, MultiComponent” and “Extreme High Gloss” are taken from the large appliance coatings CTG 

and the emission limit for large appliance coatings in section 129.52. All remaining 

emission limits are taken from section 129.52 because the limit is more stringent than the 

recommended limits in the large appliance coatings CTG.

Table 5. Emission Limits of VOCs for Large Appliance Surface Coatings (Weight 

of VOC per Volume of Coating Solids, as Applied)

Coating Type Baked Air Dried

kg/l lb/gal kg/l lb/gal

General, One Component 0.40 3.34 0.40 3.34

General, MultiComponent0.40 3.34 0.55 4.62

Extreme High Gloss 0.55 4.62 0.55 4.62

Extreme Performance 0.55 4.62 0.55 4.62

Heat Resistant 0.55 4.62 0.55 4.62

Metallic 0.55 4.62 0.55 4.62

Pretreatment 0.55 4.62 0.55 4.62

Solar Absorbent 0.55 4.62 0.55 4.62
Table 6 establishes emission limits for VOCs for eight types of metal furniture surface 

coatings, expressed in weight of VOC per volume of coating solids (kilograms per liter 

(kg/l) or pounds per gallon (lb/gal)), as applied. The emission limits for Baked (kg/l and 

lb/gal) - “General, One Component” and “General, Multi-Component” and Air Dried 

(kg/l and lb/gal) – “General, One Component,” “General, Multi-Component,” and 

“Extreme High Gloss” are taken directly from the metal furniture CTG. The emission 

limits for Baked (kg/l) – “Extreme High Gloss,” “Extreme Performance,” “Heat 

Resistant,” and “Solar Absorbent” are taken from the metal furniture coatings CTG and 

the emission limit for metal furniture coatings in section 129.52. All remaining emission 

limits are taken from section 129.52 because the limit is more stringent than the 

recommended limits in the metal furniture coatings CTG.

Table 6. Emission Limits of VOCs for Metal Furniture Surface Coatings (Weight of 

VOC per Volume of Coating Solids, as Applied)

Coating Type Baked Air Dried

kg/l lb/gal kg/l lb/gal

General, One Component 0.40 3.34 0.40 3.34

General, MultiComponent0.40 3.34 0.55 4.62

Extreme High Gloss 0.61 5.06 0.55 4.62

Extreme Performance 0.61 5.06 0.61 5.06

Heat Resistant 0.61 5.06 0.61 5.06

Metallic 0.61 5.06 0.61 5.06

Pretreatment 0.61 5.06 0.61 5.06

Solar Absorbent 0.61 5.06 0.61 5.06

The emission limits in Tables 5 and 6 were amended to provide consistency in the 

number of significant digits. The emission limit of 3.3 lb/gal was revised to 3.34 lb/gal in 

the Baked – “General, One Component: and “General, Multi-Component,” and in the Air 

Dried – “General, One component” coatings. The 4.62 lb/gal emission limit in the Air 

Dried – “General, Multi-Component” and “Extreme High Gloss” coatings was used to 

provide consistency with the limit in section 129.52. Although the 4.62 lb/gal emission 

limit is greater than the 4.5 lb/gal emission limit recommended in the CTGs, the 

difference is due to different methodologies used for rounding during the conversion 

from metric units to English units. However, the emission reduction that will be achieved 

is equivalent.

C. EPA EVALUATION

The Commonwealth of Pennsylvania has adopted the standards and requirements of the 

CTGs for large appliance and metal furniture coatings and is revising its SIP to reflect 

these amendments. Several of the emission limits in the CTGs are less stringent than the 

existing limits expressed in section 129.52; therefore, the Commonwealth of 

Pennsylvania retained the more restrictive limits for both large appliance and metal 

furniture coatings. As a result, the Commonwealth of Pennsylvania’s adoption of the 

more restrictive emission limits is more protective of Pennsylvania’s air quality. The
emission limit of 4.62 lb/gal for Air Dried – “General, Multi-Component” and “Extreme 

High Gloss” coatings was used in order to provide consistency with the limit in section 

129.52, entitled “Surface coating processes.” Although the 4.62 lb/gal emission limit is 

greater than the 4.5 lb/gal emission limit recommended in the CTGs, EPA believes that 

4.62 lb VOC/gal of solids is equivalent to 0.340 kg VOC per liter of coating or as an 

equivalent 2.8 lbs/gal of coating, which is the CTG recommendation. The rationale is 

that the difference is due to different methodologies used for rounding during the 

conversion from metric units to English units and the emission reduction that will be 

achieved is equivalent. Converting 2.838 lb VOC/gal of coating to kg/liter yields 0.3401 

which rounds to 0.34 kg/l of coating (equal to the CTG recommendation). By using the 

VOC density of 7.36 lbs/gal, the equivalent limits in terms of mass of VOC per volume 

of solids, the CTG is equivalent to 4.5 lbs VOC per gal of solids and 0.55 kg/liter of 

solids for the original limits of 2.8 lbs/gal of coating and 0.340 kg/liter of coating, 

respectively.1,2 Converting 2.838 lb VOC/gal of coating to lb/gal of solids yields 4.6231 

lb/gal of solids which converts to 0.5540 kg/liter of solids. Rounding both to two places 

yields 4.62 and 0.55, respectively.

D. CONCLUSIONS AND RECOMMENDED AGENCY ACTION

The adoption of the EPA CTG requirements for large appliance coating and metal 

furniture coating by the Commonwealth of Pennsylvania will result in the reduction of 

VOC emissions from large appliance and metal furniture coating facilities. EPA 

approval of the SIP revision is recommended.

 

1 Control Techniques Guidelines for Large Appliance Coatings, EPA 453/R-07-004, September 2007

2 Control Techniques Guidelines for Metal Furniture Coatings, EPA 453/R-07-005, September 2007