1 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 Applianc e 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, Phy sical Scientist

Office of Air Program Planning TO: File

/s/ THRU: B rian Rehn , Acting Associate Director

Office of Air Program Planning
A. BACKGROUND S ection 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 ) e missions covered b y 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 p articular source is capable of meeting b y the application of control technology

that is reasonabl y available considering technological and economic feasibility .” (44 FR 53761, Sept. 17, 1979 )
. Insubsequent 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 authorities information that should assist them in determining RACT for VOCs from various sources, including large appliance coatings, me tal 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,2

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 (4 0 CFR part 63, subpart QQQQ) In 2006 and 2007, after conducting a review of currentl y 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 acco unt 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; September 2007); surface coati ng 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 W ood Paneling Coatings (Publication No. EPA 453/R
06
- 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 surface
coated metal lid, door, casing, panel, or other interior or exterior part or accessory that is3

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 mo isture, heat, detergent, and sometimes the outdoor elements. Coatings for each ty pe of large appliance have special requirements and contain unique properties because each ty pe will be exposed to somewhat different corrosive elements. The coatings must also be durable and have excellent adhesion properties to avoid peeling or chipping. Finall y, 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 Recom mended 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 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 app lication 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 L imits B ased on L ow - 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
dri ed 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:4

Table 1: Recommended Emission Limits (mass of VOC p er 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 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 volum e 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, 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 typ es 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 a pplication 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 perf ormance 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
- on5

control equipment to meet an overall efficiency of 90 percent. C. Work Practic es 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 container s 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 partiall y 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 ty pe of metal furniture have special requirements and contain unique properties because each ty pe will be exposed to somewhat different corrosive elements. The coating must also be durable and have excellent adhesion properties to avoid peeling or chipping. Finall y, the coatings for man y 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 coat ing operation. The majority of the raw material preparation operations and assembl y operations are mechanical in nature and involve no VOC emissions. Surface preparation, coating application operations, and cleaning activities utilize VOC
containing comp ounds (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 surf ace preparation, storage, handling, and waste/wastewater operations are relatively

small.6

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 appli ed, 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 L imits B ased on L ow - 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. Provided below are the recommended emission limits expressed in terms of mass of VOC per volume of coating, excluding water and exempt compo unds: 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
Component 0.275 2.3 0.340 2.8 Extreme High Gloss 0.360 3.0 0.340 2.8 Extreme Performance 0.360 3.0 0.420 3.5 Heat Resistant 0.360 3.0 0.420 3.5 Metallic 0.420 3.5 0.420 3.5 Pretreatment Coatings 0.420 3.5 0.420 3.5 Solar Absorbent 0.360 3.0 0.420 3.5 The recommended emission lim its 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 co ating solids limits. Using an assumed VOC7

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 M etal 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 Re sistant 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 typ es 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 m aterials 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 lim its, 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 operatio ns 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, thi nners, 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.8

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 element s such as moisture and temperature extremes and other climate
related hazards and from insect infestation. Coatings are also applied to enhance surfaces to make other coatings more effective. Finall y, 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 primaril y 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 applie d 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
- 0 6
- 004). Recommendations for controlling VOC emissions from flat wood paneling coatings are outlined in the CTG and are as follows: The recommended e mission limits for inks, coatings, and adhesives can be achieved either b y using materials with VOC contents low enough to achieve the limits during application, or b y reducing the amount of VOC emitted through the use of add
- on controls. There are two al ternative limits recommended for the use of low VOC inks, coatings and adhesives. These limits are expressed in different units but are equivalent. A. Emissions L imits on Low
- VOC Coatings for Inks, Coatings and Adhesives : The low VOC materials recomm endation 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 3 50 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 o r 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 solvent9

recovery s ys tems, which co upled with their attendant sy stems 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 ty pes 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 co atings, 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 s pills immediately , conveying an y 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 cleanin g 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 l b VOC / gal ma terial ( g VOC/ liter ma terial) [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, pl ywood, 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% Tileboards 2.1 (250) 2.9 (350) 90% Exterior siding 2.1 (250) 2.9 (350) 90% Description of Paper, Fil m, 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 secto rs: 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; die
cut 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.10

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 pre sses and on
- machine coaters that function as part of an in
- line papermaking sy stem 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 proces s 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, f ilm, 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/flash
off, 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
- 0 7
- 003). T he 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 ea ch 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 statio ns. 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 ye ar (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 em ission 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 c ategory (except for pressure sensitive tape and label surface coating lines), 20 weight percent solids and 80 weight percent solvent11

was used. Using this baseline coating content, the VOC content
- based emission limits equivalent to 90 percent emission red uction 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 i s 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 cont ent limits can be met b y 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 Alleghen y 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, 2011.12

B. STATE SUBMITTAL On July 23, 2010, Pennsylvania Department of Environmental Protection (PADEP) submitted to EPA a SIP revisi on 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 Alleghen y 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. Appli cability : 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 appl y to the large appliance and metal furniture surface coating process as of January 1, 2011. b. Li mitations : 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 Tab l e 2105.77. 2. The overall weight of VOCs emitted to the atmosphere is reduced through the use of vapor reco very

or incineration or another method which is acceptable under section 2105.01 (Equivalent Compliance Techniques). The overall efficiency of a control sy stem, as determined by the test methods and procedures specified in Part G, shall be no less than 90 %
.13 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
- tricholo ethane) 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 appli ed 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. O ther coating application method that the person demonstrates and the Department determines achieves emission reductions equivalent to HVLP or electrostatic spray a

pplication methods. f. Emission L imitations : 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 ex clusively 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 20 0 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 pract ices 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 an d 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 l ocation 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 Coatin g Solids) Baked Air Dried Surface Coating Process Category kg/l lb/gal kg/l lb/gal 1. L arge 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 5.0615

II. Flat Wood Paneling Coating Processes Section 2105.78 Control of VOC Emissions from Flat Wood Paneling Coating Processes
a. Applicability : B eginning 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. Li mitations : 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 sy stem, as determined by the test me thods 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 ye ars and shall be submitted to the Department on a schedule reasonably prescribed b y the Department. d. Exempt Solvents : Th e 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 u sing 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 : T he 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 aeros ol cans, air atomized spray s that apply cosmetic specialty coatings, if the volume of the cosmetic specialty coatings is less than 5% b y volume of the total coating used at the source or to apply final repair coatings, coatings used exclusively for determi ning 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 fo r 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 m aterials and used shop towels i n 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 spil ls 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 Processes17

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 relat ed 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 appl y to the paper, film, and foil surface coating process as of January 1, 2011. b. Li mitations : 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 me thod which acceptable under section 2105. 01 (Equivalent Compliance Techniques). The overall efficiency of a control s ys tem, 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. Th e records shall be maintained for 2 years and shall be submitted to the Department on a schedule reasonabl y prescribed by the Department. d. Exempt Solvents : The solvents methyl chloroform (1,1,1
- tricholoethane) and methylene chloride are exempt from co ntrol 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 pe rson 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 coating18 8. Extrusion coating, including calendaring f. Emission L imitations : 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 accep tance 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 appl y 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, c oating
- 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 o f 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 Coatin g 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 0.0819

IV. Additional Revisions In addition to adopting the CTGs discussed above, definitions ari sing from these CTG regulations were added to Article XXI (section 2101.20) and are being added to the Alleghen y County portion of the Pennsylvania SIP. They are as follows: Section 2101.20: Definitions : “Exterior panels” means panels made of solid woo d, hardboard or waferboard. Paneling made of solid wood or hardboard is typicall y 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 typicall y manufactured at the same facilities as tileboard, although in much smaller quantities. The substrate can be hardboard, ply wood, 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 Ihardboard 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 an y limits pertaini ng 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 t o 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 appl y to the paper, film, and foil surface coating process as of January 1, 2011.
C. EPA EVALUATION20

Alleghen y County has adopted the standards and requirements of the CTG s for large appliance and metal furniture, flat wood paneling, and paper, film, and foil surface coating processes and is amending the Pennsylvania S IP to reflect these amendments. The maximum benefit from these amendments will be provided during the ozone season when VOCs readily

combine with NO x to form ground
- level ozone. Therefore, this revision will help Pennsylvania attain and maintain the NAAQ S 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 res ult 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.