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 Fur niture

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

S ection 172(c)(1) of the Clean Air A ct (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 t hat 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 dat e 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 tech nological and economic feasibility.” (44 FR 53761, Sept. 17, 1979 )

. In subsequent Federal Register notices, EPA

has addressed how states can mee t the RACT requirements of the CAA

.

CTG s are intended to provide state and local air pollution control author ities 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 th is 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 furnit ure 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 technol ogies 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

ap pliance 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 organi c 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

- 0 7

- 004; Septe mber 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 a re 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 surface

coated 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, dishwas her, 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, d etergent, 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

- 0 7

- 004). Recommendations for controlling VOC emissions from large appliance coatings are outlined in the CTG. Three alternati ves 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 method s. 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 recommende d 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 B ased 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 air

dried coatings. P rovided 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) , exclu ding 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, Multi

Component 0.275 2.3 0.340 2.8

Extreme High Gloss 0.360 3.0 0.340 2.8

Extreme Perfor mance 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 V OC 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, 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

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, touc h

- 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.

Addit ionally, 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 Operatio ns : 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 perc ent.

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 t hey 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 mater ials 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 Coatin gs

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 ofproducts: household, office, institutional, laboratory, hospital, public building, restaurant,

barber and beauty shop, and dental furniture, as well as comp onents 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 pri mer. 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, prot ective, 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 be cause 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 sup port 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 uti lize VOC

containing 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 li mits 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

fu rniture surface coating operations are summarized below:

A. Emissions Limits B ased on Low

- VOC Coatings : Emission limits for one

- component
and multi

- component general purpose coatings are recommended. In addition, specific emission limits for certain specia lty coatings are recommended. For each of these coating types, separate emission limits are recommended for baked and air

dried coatings. Provided below are the recommended emission limits expressed in terms of mass of VOC per volume of coating, excludin g 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, Multi

Compone nt 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

The recommended emission limits can also be expressed in terms of mass of V OC 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, 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 6.7The following types of coatings and coating operations are recommended to be exempt

from the recomme nded 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 t hat 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 reco mmended 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 ap pliance 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 CT Gs 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 s ections 129.51 and 129.52 (relating to general; and surface coating proce sses) and adding s ection 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 s ection 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

emiss ion limits.The revision amends s ection 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 s ection 12 9.52 are supersede d 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 coatin gs 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 r evision adds s ection 129. 52 a., entitled “Control of VOC emissions from large appliance and metal furniture surface coating p rocesses
, ” in order to regulate V OC emissions from large appliance and metal furni ture surface coating processes.

The revision ad ds s ection 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

surfac e 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 s ection 129.52a.(b) , entitled “Existing RACT permit,” i n 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, exce pt to the extent the RACT permit contains more stringent requirements.

The revision adds s ection 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 V OC 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 s ection 129.52a.(d) , entitled “ Compliance monitoring procedures,” i n order to identi fy 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 complian ce with section 129.52a.

The revision adds s ection 129.52a.(e) , entitled “Recordkeeping and reporting requirements,” in order to establish the new recordkeeping and reporting requirements.

The revision adds se ction 129.52a.(f) , entitled “Coating applicat ion methods,” in order to establish that an owner or operator subject to section 129.52a may not cause or permit theemission into the outdoor atmosphere of VOCs from the application of large appliance or

metal furniture surface coating, unless the coating s are applied using electrostatic coating, roller coating, flow coating, dip coating, high volume

- low pressure spray (HVLP), or brush coating.

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

in order to exempt s tencil 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 s ection 129.52a.(h) , entitled “Work practice requirements for coating

related 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 o perators 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 we ight 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 Co mponent ” 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, Multi

Component” and “Extreme H igh 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 i n 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, Multi

Component 0.40 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 0.5 5 4.62 0.55 4.62Table 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 emissio n 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 remain ing 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 Coat ing 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, Multi

Component 0.40 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 emissi on 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 methodo logies 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

CTG s 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

P ennsylvania 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. Theemission 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 ra tionale 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 res ult 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