1 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III 1650 Arch Street Philadelphia, Pennsylvania 19103
DATE: December 7, 2010 SUBJECT: Technical Support Document for Maryland’s Adoption of Control Techniques

Guidelines (CTG) for Flat Wood Paneling Coatings FROM: Gregory

Becoat, Environmental Scientist /s/ Office of Air Program Planning TO: File THRU: Marily

n Powers , Acting Associate Director / s/ Office of Air Program Planning
A. BACKGROUND What is the flat wood paneling coating CTG? Section 172(c)(1) of the Clean Air Act (CAA) provides that state implementation plans (SI Ps) 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 SI Ps to include RACT for sources of volatile organic compound (VOC) emi ssions covered by a 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 mee ting 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 requireme nts of the CAA. The CTG for flat wood paneling coatings is intended to provide state and local air pollution control authorities information that should assist them in determining RACT for VOCs from flat wood paneling coating. In developing this CTG, EPA , among other things, evaluated the sources of VOC emissions from the flat wood paneling 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 flat wood2

paneling coating. InJune 1978, EPA published a final CTG for flat wood paneling coatings, entitled “Control of Volatile Organic Emissions from Existing Stationary Sources, Volume VI I, Factory Surface Co ating of Flat Wood Paneling,” EPA

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- 034 (June 1978). 1 InSeptember 1979, EPA published guidance to provide assistance to State and local air pollution control agencies in preparing RACT regulations for a variety of categories, including flat wood paneli ng. I n 2003, EPA promulgated national emission standards for hazardous air pollutants (NESHAP) covering surface coating of wood building products (including flat wood paneling). See 68 FR 31746 (May 28, 2003). What is flat wood paneling coatings ? Flat wood paneling products are used in construction and can be classified as three main product ty pes: decorative interior panels, exterior siding, and tileboard. Flat wood paneling, like most wood products, are vulnerable to light, moisture and insects. Coatings are used for three principal purposes: protection, appearance, and surface modification. Surface coatings are applied to reduce potential damage from environmental elements such as moisture and temperature extremes and other climate

- related hazar ds and from insect infestation. Coatings are also applied to enhance surfaces to make other coatings more effective. Finally , coatings are applied to improve the appearance of the wood product. Releases of VOC occur during the coating process as the coat ings are mixed or thinned, as they are applied to the substrate, and as they dry and the VOC within the coating evaporate into the air. A ty pical flat wood coating facility applies stains and varnishes to natural ply wood panels used for wall coverings. O ther plants print wood grain patterns on particle board panels that were first undercoated with an opaque coating to mask the original surface. Coatings applied to flat wood paneling include fillers, sealers, “groove” coats, primers, stains, basecoats, inks and topcoats. Most coatings are applied by direct roll coating. Filler is usually applied by

reverse roll coating. The offset rotogravure process is used where the coating and printing operation requires precision printing techniques. Other coating m ethods include spray techniques, brush coating and curtain coating. A ty pical flat wood paneling coating line includes a succession of coating operations. Each individual operation consists of the application of one or more coatings followed by

a heated oven to cure the coatings. A ty pical production line begins with mechanical alterations of the substrate (filling of holes, cutting of grooves, sanding, etc.), followed by the coating operations, and packaging/stacking for shipment. This CTG applies to f

acilities that apply

flat wood paneling coatings that emit at least 6.8 kg/day (15 lb/day

) of VOC before consideration of controls. Flat wood paneling coatings means wood

1 Control of Volatile Organic Emissions from Existing Sources

- Volume VI I: Factory Surface Coating of Flat Wood Paneling. Publication No. EPA

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- 032. U. S. Environmental Protection Agency , Research Triangle Park, NC. June 1978.3

paneling products that are any interior, exterior or tileboard (class I hardboard) p anel to which a protective, decorative, or functional material or lay er has been applied. There are several approaches to reducing VOC emissions from flat wood coating facilities: (1) the use of low

- VOC, waterborne coatings, (2) the use of ultraviolet cur e and electron beam cure coatings, (3) adding/improving add

- on controls, and (4) the implementation of work practice standards. EPA’s Recommended Emissions and Control Options for Flat wood Paneling Coatings EPA issued a CTG for Flat wood Paneling Coat ings on June 1978 (EPA

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- 034). EPA recommended emission limits for the inks, coatings and adhesives used by the flat wood paneling coating facilities and work practices for cleaning materials used. The recommended emission limits for inks, coating s, and adhesives can be achieved either by using materials with VOC contents low enough to achieve the limits during application, or by reducing the amount of VOC emitted through the use of add

- on controls. There are two alternative limits recommended for the use of low VOC inks, coatings and adhesives. Table 1 summarizes the VOC emission limits recommended in this CTG. A. Emissions L imit based on L ow - VOC Coatings for Inks, Coatings and Adhesives The low

- VOC materials recommendation for inks, coatings and adhesives include an emissions limit of 250 g VOC/l iter (2.1 lb VOC/gal) of material (minus water and exempt compounds). An equivalent limit, expressed as units of weight of VOC per volume of solids in all coatings is 350 grams of VOC per liter solids (2.9 lb of VOC per gal of solids). B. Optional Add

- On Controls for Inks, Coatings and Adhesives Should product performance requirements or other needs dictate the use of higher

- VOC coatings than specified in Table 1, a facility could choose to use ad d

- on control equipment to meet an overall control efficiency of 90 percent. C. Work Practices The recommended work practice plan include steps to ensure that VOC emissions are minimized from mixing operations , storage tanks and other containers, and handling operations for coatings, thinners, cleaning materials, and waste materials. Examples of work practice standards include: storing all VOC coatings, thinners, and cleaning materials in closed containers, min imizing spills of VOC containing coatings, thinners, cleaning up spills immediately , conveying any coatings, thinners, and cleaning materials in closed containers or pipes, closing mixing vessels which contain VOC coatings and other materials except when s pecifically in use, and minimizing emissions of VOC during cleaning of storage, mixing, and conveying equipment.4

Table 1. Recommended Emission Limits for Flat Wood Paneling Coating Operations

B. STATE SUBMITTAL On April 23, 2010, Maryland Department of the Environment (MDE) submitted to EPA a SI P revision concerning the adoption of the EPA CTG for flat wood paneling coatings . EPA develops CTGs to provide States with guidance on control requirements for source categories. States can follow the CTGs or adopt more restrictive standards. MDE is adopting EPA’s CTG standards for flat wood paneling coatings (see EPA
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- 034 , June 1978 ). This SI P revision inclu des new regulation .33 under COMAR 26.11.19, Volatile Organic Compounds from Specific Processes. This action affects facilities that apply stains and varnishes to natural ply wood panels used for wall coverings. This SI P revision also includes amendments to regulation .32 under COMAR 26.11.19; however, on N ovember 12, 2010, MDE submitted a letter to withdraw this portion because Maryland had not previously submitted COMAR 26.11.19.32 to be approved as part of the SI P. COMAR 26.11.19.33

– Control of Volatile Organic Compounds (VOCs) Emissions from Flat Wood Paneling Coatings is being added: Section .33(A) : I ncludes definitions for the following terms pertaining to flat wood paneling coatings: (1) “Class I I finishes on hardboard panels,” “ Exterior siding,” “Flat wood paneling,” Surface Coatings, Inks, or Adhesives Applied to the Following Flat Wood Paneling

Categories Should Meet One of These Emission Limits: lb VOC per gallon material (grams VOC per liter material) [excluding water and exempt compounds ] lb VOC per

gallon solids (grams VOC per liter solids) Overall Control

Efficiency Using an Add - On Control Device:

Printed interior panels made of hardwood, ply

wood, or thin particleboard 2.1 (250) 2.9 (350) 90% Natural finish hardwood ply wood panels 2.1 (250) 2.9 (350) 90% Class II finishes on hardboard panels 2.1 (250) 2.9 (350) 90% Tileboard 2.1 (250) 2.9 (350) 90% Exterior siding 2.1 (250) 2.9 (350) 90%5

“Hardwood ply

wood,” “Natural finish hardwood ply wood panels,” “Printed interior panels,” “Thin particleboard,” and “Tileboard.” Section .33(B) : I ncorporates by reference ANSIA135.5
- 2004, Prefinished Hardwood Pane ling and ANSIA135.4
- 2004, Basic Hardboard. Section .33(C) : Describes the applicability of this regulation. Section .33(D) : I ncludes the requirements for flat wood paneling coating. Any person who applies flat wood paneling coatings, including inks an d adhesives, where total precontrol VOC emissions from all flat wood paneling coating operations at a premises is 15 pounds or more per day (6.8 kg/day

) shall meet the coating standards or overall control efficiency specified in Table 1. C. EPA EVALUATIO N The State of Maryland has adopted the standards and requirements of the CTG for flat wood paneling coating and is revising its SI P to reflect these amendments. The maximum benefit from these amendments will be provided during the ozone season when VOCs readily combine with nitrogen oxide to form ground

- level ozone. Therefore, this revision will help Maryland attain and maintain the national ambient air quality standard for ozone. D. CONCLUSIONS AND RECOMMENDED AGENCY ACTION The adoption of the EPA CTG requirements for flat wood paneling coating by the State of Maryland will result in the reduction of VOC emissions from flat wood coating facilities . EPA approval of the SI P revision is recommended.