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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

1650 Arch Street

Philadelphia, Pennsylvania 19103

DATE: November 23, 2010

SUBJECT: Technical Support Document for Allegheny County’s Adoption of Control 

Techniques Guidelines for Large Appliance and Metal Furniture; Flat 

Wood Paneling; Paper, Film, and Foil Surface Coating Processes; and 

Revisions to Definitions and an Existing Regulation

/s/

FROM: Irene Shandruk, Physical Scientist 

Office of Air Program Planning 

TO: File

/s/

THRU: Brian Rehn, Acting Associate Director 

Office of Air Program Planning

A. BACKGROUND 

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

(SIPs) for nonattainment areas must include reasonably available control measures

(RACM), including reasonably available control technology (RACT), for sources of 

emissions. Section 182(b)(2)(A) provides that for certain nonattainment areas, States 

must revise their SIPs to include RACT for sources of volatile organic compound (VOC)

emissions covered by a control techniques guidelines (CTG) document issued after 

November 15, 1990 and prior to the area’s date of attainment. 

The United States Environmental Protection Agency (EPA) defines RACT as “the lowest 

emission limitation that a particular source is capable of meeting by the application of 

control technology that is reasonably available considering technological and economic

feasibility.” (44 FR 53761, Sept. 17, 1979). In subsequent Federal Register notices, EPA 

has addressed how states can meet the RACT requirements of the CAA. 

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

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

large appliance coatings, metal furniture coatings, flat wood paneling coatings, and paper, 

film, and foil 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, metal furniture coatings, flat wood paneling coatings, and paper, film, 
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and foil coatings.

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

034), surface coating of metal furniture (EPA-450/2-77-032), and surface coating of 

paper (EPA-450/2-77-008). In June 1978, EPA published a CTG for flat wood paneling 

coatings (EPA-450/2-78-034). 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 these industries:

 Large appliances in 1982 (40 CFR part 60, subpart SS)

 Surface coating of pressure sensitive tape and labels, which is a subset of 

the paper, film, and foil surface coating industry in 1983 (40 CFR part 60, 

subpart RR)

 Surface coating of metal furniture in 1982 (40 CFR part 60, subpart EE)

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

for these industries: 

 Surface coating of large appliances in 2002 (40 CFR part 63, subpart 

NNNN)

 Surface coating of paper in 2002 (40 CFR part 63, subpart JJJJ)

 Surface coating of metal furniture in 2003 (40 CFR part 63, subpart 

RRRR)

 Surface coating of wood building products, including flat wood paneling 

in 2003 (40 CFR part 63, subpart QQQQ)

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); surface coating of paper, entitled 

Control Techniques Guidelines for Paper, Film, and Foil Coatings (Publication No. EPA 

453/R-07-003; September 2007); surface coating of metal furniture, entitled Control 

Techniques Guidelines for Metal Furniture Coatings (Publication No. EPA 453/R-07-

005; September 2007); and surface coating of flat wood paneling, entitled Control 

Techniques Guidelines for Flat Wood Paneling Coatings (Publication No. EPA 453/R06-004).

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 
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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 below are the recommended emission limits expressed in 

terms of mass of VOC per volume of coating (kilograms per liter or pounds per 

gallon), excluding water and exempt compounds:
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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: 

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 
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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.
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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 
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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.
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Description of Flat Wood Paneling Coatings

Flat wood paneling coatings means wood paneling products that are any interior, exterior 

or tileboard (class I hardboard) panel to which a protective, decorative, or functional 

material or layer has been applied.

Flat wood paneling, like most wood products, are vulnerable to light, moisture and 

insects. Coatings are used for three 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 climaterelated hazards 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 VOCs occur during the coating process as 

the coatings are mixed or thinned, as they are applied to the substrate, and as they dry and 

the VOCs within the coating evaporate into the air.

Emissions of VOCs from flat wood coating facilities occur primarily at the coating line, 

although some emissions also occur at paint mixing and storage areas. To assist facilities 

and regulatory agencies in estimating emissions, VOC emission factors for conventional 

solvent based coatings applied to interior printed panels are as follows (expressed as 

kilograms of VOCs per 100 square meters (m

2

) coated): 3.0 for filler, 0.5 for sealer, 2.4 

for basecoat, 0.3 for inks, and 1.8 for topcoats.

EPA’s Recommended Control Options for Flat Wood Paneling Coatings

EPA issued a CTG for Flat Wood Paneling Coatings in September 2006 (Publication No. 

EPA 453/R-06-004). Recommendations for controlling VOC emissions from flat wood 

paneling coatings are outlined in the CTG and are as follows:

The recommended emission limits for inks, coatings, 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. These limits are expressed in different units but are equivalent. 

A. Emissions Limits on Low-VOC Coatings for Inks, Coatings and Adhesives: The low 

VOC materials recommendation for inks, coatings and adhesives include an emissions 

limit of 250 grams (g) VOC/l (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 g of VOC per liter solids (2.9 lb of VOC per gal of solids). 

The default VOC density used for making this conversion was 0.88 kg/l (7.36 lb/gal).

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 above, a facility could choose to use add-on control equipment to meet an 

overall control efficiency of 90 percent. Add-on devices include oxidizers and solvent 
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recovery systems, which 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 low VOC material option noted above, applies to surface 

coatings, inks, and adhesives applied to all types of flat wood paneling. 

C. Work Practices: Recommended work practices 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, minimizing 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 specifically in use, and minimizing emissions 

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

Table 5: Recommended Emission Limits for Flat Wood Paneling Operations

Surface Coatings, Inks, or 

Adhesives Applied to the 

Following Flat Wood 

Paneling Categories

Should Meet One of These Emission Limits

lb VOC/ gal 

material (g 

VOC/ liter 

material) 

[excluding water 

and exempt 

compounds]

lb VOC/ gal 

solids (g VOC/ 

liter solids)

Overall Control 

Efficiency Using 

an Add-On 

Control Device

Printed interior panels made 

of hardwood, plywood, or 

thin particleboard

2.1 (250) 2.9 (350) 90%

Natural finish hardwood 

plywood panels

2.1 (250) 2.9 (350) 90%

Class II finishes on hardboard 

panels

2.1 (250) 2.9 (350) 90%

Tileboards 2.1 (250) 2.9 (350) 90%

Exterior siding 2.1 (250) 2.9 (350) 90%

Description of Paper, Film, and Foil Coatings

The paper, film, and foil product category listed under section 183(e) of the CAA 

includes coatings that are applied to paper, film, or foil surfaces in the manufacturing of 

several major product types for the following industry sectors: pressure sensitive tape 

and labels; photographic film; industrial and decorative laminates; abrasive products; and 

flexible packaging. The category also includes coatings applied during miscellaneous 

coating operations for several products including: corrugated and solid fiber boxes; diecut paper paperboard and cardboard; converted paper and paperboard not elsewhere 

classified; folding paperboard boxes, including sanitary boxes; manifold business forms 

and related products; plastic asceptic packaging; and carbon paper and inked ribbons.
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Coating performed on or in-line with any offset lithographic, screen, letterpress, 

flexographic, rotogravure, or digital printing press is not part of the paper, film, and foil 

coating category. In addition, size presses and on-machine coaters that function as part of 

an in-line papermaking system are not part of the paper, film, and foil coating category. 

The paper, film, and foil surface coating process can be described as a web coating 

process, which is a process that applies a continuous layer of coating material across 

essentially the entire width or any portion of the width of a web substrate to: (1) provide 

a covering, finish, functional or protective layer to a substrate; (2) saturate a substrate for 

lamination; or (3) provide adhesion between two substrates for lamination. The web 

coating operations and emission control techniques do not vary significantly among the 

sectors of the paper, film, and foil surface coating industry.

VOC emissions from paper, film, and foil surface coating operations primarily result 

from the evaporation of volatile components of the coatings and cleaning materials. The 

majority of VOC emissions from these materials occur during coating application/flashoff, coating curing/drying, and cleaning. The remaining VOC emissions are from 

cleaning operations.

EPA’s Recommended Control Option for Paper, Film, and Foil Coatings

EPA issued a CTG for Paper, Film, and Foil Coatings in September 2007 (Publication 

No. EPA 453/R-07-003). The following summarizes recommendations for controlling 

VOC emissions from paper, film, and foil coatings:

A. Coatings: To control VOC emissions from coatings used in paper, film, and foil 

surface coating, an overall VOC control efficiency of 90% for each coating line is 

recommended. Alternatively, emission limits that are equivalent to 90 percent overall 

control is recommended. Applying the control recommendations only to individual 

surface coating lines with the potential to emit, prior to controls, at least 25 tpy of VOC 

from coatings is recommended. The coating line is defined as a series of coating 

applicators, flash-off areas, and any associated curing/drying equipment between one or 

more unwind/feed stations and one or more rewind/cutting stations. It’s also 

recommended that paper, film, and foil surface coating facilities be provided with the 

option of using an enforceable limitation on potential emissions to keep an individual 

paper, film, and foil surface coating line below the 25 tons per year (tpy) potential to emit 

threshold.

An overall VOC control efficiency of 90 percent is recommended as RACT for each 

paper, film, and foil surface coating line. However, as an alternative to an overall 90 

percent control efficiency, VOC content-based emission limits that are equivalent to 90 

percent overall control are recommended, which can be met by use of low VOC content 

materials or combinations of materials and controls. To determine these equivalent 

content-based emission limits for this product category (except for pressure sensitive tape 

and label surface coating lines), 20 weight percent solids and 80 weight percent solvent 
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was used. Using this baseline coating content, the VOC content-based emission limits 

equivalent to 90 percent emission reduction are 0.40 kg VOC/kg (0.40 lb VOC/lb) solids 

applied and 0.08 kg VOC/kg (0.08 lb VOC/lb) coating applied. 

As an alternative to 90 percent emission reduction, a limit of 0.20 kg VOC/kg (0.20 lb 

VOC/lb) solids applied is recommended, and an additional equivalent limit of 0.067 kg 

VOC/kg (0.067 lb VOC/lb) of coating is RACT for pressure sensitive tape and label 

surface coating lines. 

Table 6: Recommended Emission Limits for Paper, Film, and Foil Coatings

Units

RACT Limits

Pressure Sensitive Tape 

and Label Surface 

Coating

Paper, Film, and Foil 

Surface Coating (Not 

including Pressure 

Sensitive Tape and Label)

Emission Reduction (%) 90 90

kg VOC/kg solids

(lb VOC/lb solids)

0.20 0.40

kg VOC/kg coating

(lb VOC/lb coating)

0.067 0.08

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

single surface coating line each day (i.e. daily within-line averaging). 

B. Cleaning Materials: To control VOC emissions from cleaning materials used in 

paper, film, and foil surface coating, it is recommended that facilities implement work 

practices to ensure that VOC emissions are minimized from mixing, storage, and 

handling of cleaning materials, and cleaning-related waste materials. Specifically, the 

following is recommended: (1) store all VOC-containing cleaning materials in closed 

containers; (2) ensure that mixing and storage containers used for VOC-containing 

materials are kept closed at all times except when depositing or removing these materials; 

(3) minimize spills of VOC-containing cleaning materials; (4) convey VOC-containing 

cleaning materials from one location to another in closed containers or pipes; and (6) 

minimize VOC emissions from cleaning of storage, mixing, and conveying equipment.

Additional Revisions

In addition to adopting the CTGs discussed above, definitions arising from these CTG 

regulations were added to Article XXI (section 2101.20) and therefore being added to the 

Allegheny County portion of the Pennsylvania SIP. Also, changes were also made to an 

existing regulation (section 2105.10), making any limits pertaining to these CTG 

regulations void after January 1, 2011.
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B. STATE SUBMITTAL

On July 23, 2010, Pennsylvania Department of Environmental Protection (PADEP) 

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

appliance and metal furniture, flat wood paneling, and paper, film, and foil surface 

coating processes in Allegheny County. EPA develops CTGs as guidance on control 

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

standards. Allegheny County is adopting EPA’s CTG standards for large appliance and 

metal furniture, flat wood paneling, and paper, film, and foil surface coating processes. 

These regulations are contained in the Allegheny County Health Department (ACHD) 

Rules and Regulations, Article XXI, Air Pollution Control Sections 2105.77, 2105.78, 

and 2105.79, respectively, and County Ordinance 16782. This SIP revision also includes 

revisions to existing regulations for surface coating processes in Section 2105.10 and 

related definitions in Section 2101.20.

I. Large Appliance and Metal Furniture Surface Coating Processes

Allegheny County combined the CTGs for large appliance surface coatings and metal 

furniture surface coatings into a single rule in Article XXI, Air Pollution Control Section 

2105.77. The new regulation is summarized below:

Section 2105.77: Control of VOC Emissions from Large Appliance and Metal 

Furniture Surface Coating Processes

a. Applicability: Beginning January 1, 2011, this section applies to the owner or 

operator of a large appliance or metal furniture surface coating process, where the total 

actual VOC emissions from all large appliance or metal furniture surface coating 

operations, including related cleaning activities, at that facility are equal to or greater than 

15 pounds (6.8 kilograms) per day or 2.7 (2,455 kilograms) per twelve month rolling 

period. The limits from section 2105.10 and Table section 2105.10 no longer apply to the 

large appliance and metal furniture surface coating process as of January 1, 2011.

b. Limitations: 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 one of the following limitations is met:

1. The VOC content of each applied coating is equal to or less than the standard 

specified in Table 2105.77.

2. The overall weight of VOCs emitted to the atmosphere is reduced through the 

use of vapor recovery or incineration or another method which is acceptable under 

section 2105.01 (Equivalent Compliance Techniques). The overall efficiency of a 

control system, as determined by the test methods and procedures specified in 

Part G, shall be no less than 90%.
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3. A combination of the methods listed in paragraphs 1 and 2.

c. Records: A facility, regardless of the facility’s annual emission rate, which contains 

large appliance or metal furniture surface coating processes, shall maintain records 

sufficient to demonstrate compliance with this section. The records shall be maintained 

for 2 years and shall be submitted to the Department on a schedule reasonably prescribed 

by the Department.

d. Exempt Solvents: The solvents methyl chloroform (1,1,1-tricholoethane) and 

methylene chloride are exempt from control under this Section. No large appliance or 

metal furniture surface coating process which seeks to comply with this Section through 

the use of an exempt solvent may be included in any alternative standard approved 

pursuant to this Article. 

e. Application Techniques: A person may not cause or permit the emission into the 

outdoor atmosphere of VOCs from the application of large appliance or metal furniture 

surface coatings unless the coatings are applied using one or more of the following 

coating application methods:

1. Electrostatic spraying;

2. Roller coating;

3. Flow coating;

4. Dip coating, including electrodeposition;

5. High volume-low pressure (HVLP) spraying;

6. Brush coating;

7. Other coating application method that the person demonstrates and the 

Department determines achieves emission reductions equivalent to HVLP or 

electrostatic spray application methods.

f. Emission Limitations: If more than one emission limitation in Table 2105.77 for large 

appliances or metal furniture applies to a specific coating, the least stringent emission 

limitation applies.

g. Exempt Other: The VOC coating content standards in Table 2105.77 for large 

appliances or metal furniture do not apply to a coating used exclusively for stencil 

coatings, safety-indicating coatings, solid-film lubricants, electric-insulating coatings, 

thermal-conducting coatings, touch-up and repair coatings, coating applications using 

hand-held aerosol cans, coatings used exclusively for determining product quality and 

commercial acceptance, and other small quantity coatings if the coating meets the 

following criteria:

1. The quantity of coating used does not exceed 50 gallons per year for a single 

coating and a total of 200 gallons per year for all coatings combined for the 

facility.
14

2. The owner or operator of the facility requests, in writing, and the Department 

approves, in writing, the exemption prior to use of the coating.

h. Housekeeping: The following work practices for coating-related activities and 

cleaning materials apply to the owner or operator of a large appliance or metal furniture 

surface coating process:

 Store all VOC-containing coatings, thinners, coating-related waste materials, 

cleaning materials and used shop towels in closed containers.

 Ensure that mixing and storage containers used for VOC-containing coatings, 

thinners, coating-related waste materials and cleaning materials are kept 

closed at all times except when depositing or removing these materials.

 Minimize spills of VOC-containing coatings, thinners, coating-related waste 

materials and cleaning materials, cleaning up spills immediately.

 Convey VOC-containing coatings, thinners, coating-related waste materials 

and cleaning materials from one location to another in closed containers or 

pipes.

 Minimize VOC emissions from cleaning of storage, mixing and conveying 

equipment.

Table 2105.77: Emissions Limits of VOCs for Large Appliance and Metal Surface

Coatings (Weight of VOC per Volume of Coating Solids)

Baked Air Dried

Surface Coating Process 

Category

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

1. Large Appliance coating 0.40 3.3 0.40 3.3

(a) general, one component 0.40 3.3 0.55 4.5

(b) general, multi-component 0.55 4.62 0.55 4.62

(c) extreme high gloss 0.55 4.62 0.55 4.62

(d) extreme performance 0.55 4.62 0.55 4.62

(e) heat resistant 0.55 4.62 0.55 4.62

(f) metallic 0.55 4.62 0.55 4.62

(g) pretreatment coatings 0.55 4.62 0.55 4.62

(h) solar absorbent 0.55 4.62 0.55 4.62

2. Metal Furniture coating 0.40 3.3 0.40 3.3

(a) general, one component 0.40 3.3 0.55 4.5

(b) general, multi-component 0.61 5.06 0.55 4.5

(c) extreme high gloss 0.61 5.06 0.61 5.06

(d) extreme performance 0.61 5.06 0.61 5.06

(e) heat resistant 0.61 5.06 0.61 5.06

(f) metallic 0.61 5.06 0.61 5.06

(g) pretreatment coatings 0.61 5.06 0.61 5.06

(h) solar absorbent 0.61 5.06 0.61 5.06
15

II. Flat Wood Paneling Coating Processes

Section 2105.78 Control of VOC Emissions from Flat Wood Paneling Coating 

Processes

a. Applicability: Beginning January 1, 2011, this section applies to the owner or 

operator of a flat wood paneling coating process, where the total actual VOC emissions 

from all flat wood panel surface coating operations, including related cleaning activities, 

at the facility are equal to or greater than 15 pounds (6.8 kilograms) per day or 2.7 tons 

(2,455 kilograms) per twelve month rolling period.

b. Limitations: A person may not cause or permit the emission into the outdoor 

atmosphere of VOCs from a flat wood paneling coating process, unless one of the 

following limitations is met: 

1. The VOC content of each as applied coating is equal to or less than 2.9 lbs. 

VOC per gallon of coating solids (0.35 kg VOC per liter of coating solids).

2. The overall weight of VOCs emitted to the atmosphere is reduced through the 

use of vapor recovery or incineration or another method which is acceptable under 

section 2105.01 (Equivalent Compliance Techniques). The overall efficiency of a 

control system, as determined by the test methods and procedures specified in 

Part G, shall be no less than 90%.

3. A combination of the methods listed in paragraphs 1 and 2. 

c. Records: A facility, regardless of the facility’s annual emission rate, which contains 

flat wood paneling coating processes, shall maintain records sufficient to demonstrate

compliance with this section. The records shall be maintained for 2 years and shall be 

submitted to the Department on a schedule reasonably prescribed by the Department.

d. Exempt Solvents: The solvents methyl chloroform (1,1,1-tricholoethane) and 

methylene chloride are exempt from control under this Section. No flat wood paneling 

coating process which seeks to comply with this Section through the use of an exempt 

solvent may be included in any alternative standard approved pursuant to this Article. 

e. Application Techniques: A person may not cause or permit the emission into the 

outdoor atmosphere of VOCs from the application of flat wood paneling coatings unless 

the coatings are applied using one or more of the following coating application methods:

1. Electrostatic spraying;

2. Airless coating;

3. Curtain coating;

4. Roller coating;
16

5. Flow coating;

6. Dip coating, including electrodeposition;

7. High volume-low pressure (HVLP) spraying;

8. Hand brush or roller coat;

9. Other coating application method that the person demonstrates and the 

Department determines achieves emission reductions equivalent to HVLP or 

electrostatic spray application methods.

f. Exempt Other: The VOC coating content standard of 2.9 lbs. VOC per gallon of 

coating solids (0.35 kg VOC per liter of coating solids) do not apply to a coating used 

exclusively for stencil coatings, touch-up and repair coatings, coating applications using 

hand-held aerosol cans, air atomized sprays that apply cosmetic specialty coatings, if the 

volume of the cosmetic specialty coatings is less than 5% by volume of the total coating 

used at the source or to apply final repair coatings, coatings used exclusively for 

determining product quality and commercial acceptance and other small quantity coatings 

if the coatings meet the following criteria:

1. The quantity of coating used does not exceed 50 gallons per year for a single 

coating and a total of 200 gallons per year for all coatings combined for the 

facility.

2. The owner or operator of the facility requests, in writing, and the Department 

approves, in writing, the exemption prior to use of the coating.

g. Housekeeping: The following work practices for coating-related activities and 

cleaning materials apply to the owner or operator of a flat wood paneling coating process:

 Store all VOC-containing coatings, thinners, coating-related waste materials, 

cleaning materials and used shop towels in closed containers.

 Ensure that mixing and storage containers used for VOC-containing coatings, 

thinners, coating-related waste materials and cleaning materials are kept 

closed at all times except when depositing or removing these materials.

 Minimize spills of VOC-containing coatings, thinners, coating-related waste 

materials and cleaning materials, cleaning up spills immediately.

 Convey VOC-containing coatings, thinners, coating-related waste materials 

and cleaning materials from one location to another in closed containers or 

pipes.

 Minimize VOC emissions from cleaning of storage, mixing and conveying 

equipment.

III. Paper, Film, and Foil Coating Processes

Section 2105.79: Control of VOC Emissions from Paper, Film, and Foil Surface 

Coating Processes
17

a. Applicability: Beginning January 1, 2011, this section applies to the owner or 

operator of a paper, film, and foil surface coating process, where the total actual VOC 

emissions from all paper, film, and foil surface coating operations, including related 

cleaning activities, at that facility are equal to or greater than 15 pounds (6.8 kilograms) 

per day or 2.7 tons (2,455 kilograms) per twelve month rolling period. The limits from 

section 2105.10 and Table section 2105. 10 no longer apply to the paper, film, and foil 

surface coating process as of January 1, 2011.

b. Limitations: A person may not cause or permit the emission into the outdoor 

atmosphere of VOCs from a paper, film, and foil surface coating process unless one of 

the following limitations is met:

1. The VOC content of each as applied coating is equal to or less than the 

standard specified in Table 2105.79. 

2. The overall weight of VOCs emitted to the atmosphere is reduced through the 

use of vapor recovery or incineration or another method which acceptable under 

section 2105. 01 (Equivalent Compliance Techniques). The overall efficiency of 

a control system, as determined by the test methods and procedures specified in 

Part G, shall be no less than 90%.

3. A combination of the methods listed in paragraphs 1 and 2. 

c. Records: A facility, regardless of the facility’s annual emission rate, which contains 

paper, film, and foil surface coating processes, shall maintain records sufficient to 

demonstrate compliance with this section. The records shall be maintained for 2 years 

and shall be submitted to the Department on a schedule reasonably prescribed by the 

Department.

d. Exempt Solvents: The solvents methyl chloroform (1,1,1-tricholoethane) and 

methylene chloride are exempt from control under this Section. No flat wood paneling 

coating process which seeks to comply with this Section through the use of an exempt 

solvent may be included in any alternative standard approved pursuant to this Article. 

e. Application Techniques: A person may not cause or permit the emission into the 

outdoor atmosphere of VOCs from the application of paper, film, and foil surface 

coatings unless the coatings are applied using one or more of the following coating 

application methods:

1. Rotogravure (web-fed gravure)

2. Reverse roll coating

3. Slot die coating

4. Knife coating

5. Flexographic coating

6. Mayer rod or wire-wound rod coating

7. Dip and squeeze coating
18

8. Extrusion coating, including calendaring

f. Emission Limitations: If more than one emission limitation in Table 2105.79 for 

paper, film, and foil surface coating applies to a specific coating, the least stringent 

emission limitation applies.

g. Exempt Other: The VOC coating content standards in Table 2105.79 for paper, film, 

and foil surface coatings do not apply to a coating used exclusively for stencil coatings, 

touch-up and repair coatings, coating applications using hand-held aerosol cans, coatings 

used exclusively for determining product quality and commercial acceptance and other 

small quantity coatings if the coating meets the following criteria:

1. The quantity of coating used does not exceed 50 gallons per year for a single 

coating and a total of 200 gallons per year for all coatings combined for the 

facility.

2. The owner or operator of the facility requests, in writing, and the Department 

approves, in writing, the exemption prior to use of the coating.

h. Housekeeping: The following work practices for coating-related activities and 

cleaning materials apply to the owner or operator of a flat wood paneling coating process:

 Store all VOC-containing coatings, thinners, coating-related waste materials, 

cleaning materials and used shop towels in closed containers.

 Ensure that mixing and storage containers used for VOC-containing coatings, 

thinners, coating-related waste materials and cleaning materials are kept 

closed at all times except when depositing or removing these materials.

 Minimize spills of VOC-containing coatings, thinners, coating-related waste 

materials and cleaning materials, cleaning up spills immediately.

 Convey VOC-containing coatings, thinners, coating-related waste materials 

and cleaning materials from one location to another in closed containers or 

pipes.

 Minimize VOC emissions from cleaning of storage, mixing and conveying 

equipment.

Table 2105.79: Emissions Limits of VOCs for Paper, Film, and Foil Surface 

Coatings (Weight of VOC per Weight of Solids or Coating Applied)

Surface Coating Process 

Catergory

Solids Applied

kg VOC/kg solids

Coating Applied

kg VOC/kg coatings

Pressure Sensitive Tape and 

Label

0.20 0.067

Paper, Film, and Foil (Not 

including pressure sensitive 

tape and labels)

0.40 0.08
19

IV. Additional Revisions

In addition to adopting the CTGs discussed above, definitions arising from these CTG 

regulations were added to Article XXI (section 2101.20) and are being added to the 

Allegheny County portion of the Pennsylvania SIP. They are as follows:

Section 2101.20: Definitions:

“Exterior panels” means panels made of solid wood, hardboard or waferboard. Paneling 

made of solid wood or hardboard is typically primed at the manufacturing facility and 

finished in the field, although some finishing may be performed during manufacturing. 

(effective January 1, 2011)

“Interior panels” means interior wall paneling that is usually grooved, frequently

embossed and sometimes grain printed to resemble various wood species. Interior panels 

are typically manufactured at the same facilities as tileboard, although in much smaller 

quantities. The substrate can be hardboard, plywood, medium density fiberboard (MDF) 

or particleboard. (effective January 1, 2011)

“Flat wood panel coating” means protective, decorative or functional materials applied to 

flat wood panel products, including interior panels, exterior panels or tileboard (Class I 

hardboard). (effective January 1, 2011)

“Tileboard” means a premium interior wall paneling product made of hardboard that is 

used in high moisture areas of the home including kitchens and bathrooms. Tileboard 

meets the specifications for Class I hardboard approved by the American National 

Standards Institute. (effective January 1, 2011).

Changes were also made to an existing regulation, Section 2105.10, Surface Coating 

Processes, making any limits pertaining to these CTG regulations void after January 1, 

2011. The specific language added is as follows:

1. The limits from section 2105.10 and Table section 2105.10, number 7 for metal 

furniture coating and number 9 for large appliance coating, no longer apply to the 

large appliance and metal furniture surface coating process as of January 1, 2011. 

2. The limits from section 2105.10 and Table section 2105.10, number 5 for Paper 

coating, no longer apply to the paper, film, and foil surface coating process as of 

January 1, 2011.

C. EPA EVALUATION
20

Allegheny County has adopted the standards and requirements of the CTGs for large 

appliance and metal furniture, flat wood paneling, and paper, film, and foil surface 

coating processes and is amending the Pennsylvania SIP to reflect these amendments. 

The maximum benefit from these amendments will be provided during the ozone season 

when VOCs readily combine with NOx to form ground-level ozone. Therefore, this 

revision will help Pennsylvania attain and maintain the NAAQS for ozone. 

D. CONCLUSIONS AND RECOMMENDED AGENCY ACTION

The adoption of the EPA CTG requirements for large appliance and metal furniture, flat 

wood paneling, and paper, film, and foil surface coating processes by the State of 

Pennsylvania will result in the reduction of VOC emissions from large appliance and 

metal furniture, flat wood paneling, and paper, film, and foil surface coating processes. 

EPA approval of the SIP revision is recommended.