Control Techniques Guidelines for
Miscellaneous Metal and Plastic Parts
Coatings
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EPA-453/R-08-003
September 2008
Control Techniques Guidelines
for Miscellaneous Metal and
Plastic Parts Coatings
U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Sector Policies and Programs Division
Research Triangle Park, NC
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TABLE OF CONTENTS
I. Introduction 1
II. Background and Overview 2
III. Applicability 3
IV. Process Description and Sources of VOC Emissions 5
A. Process Description 7
1. Surface Preparation 8
2. Coating Application 9
3. Cleaning activities 11
B. Sources of VOC Emissions 11
1. Coatings 12
2. Cleaning Materials 13
V. Available Controls and Regulatory Approaches 14
A. Available Controls for VOC Emissions from Coatings 14
1. Pollution Prevention Measures 14
2. Emission Capture and Add-on Control Systems 15
B. Available Controls for VOC Emissions from Cleaning Materials 18
1. Product Substitution/Reformulation 18
2. Work Practice Procedures 18
C. Existing Federal, State, and Local Recommendations or Regulations 19
1. The 1978 CTG for Surface Coating of Miscellaneous Metal Parts and
Products 19
2. The 1988 NSPS for Surface Coating of Plastic Parts for Business
Machines (40 CFR 60 subpart TTT) 20
3. The 1994 ACT for Surface Coating of Automotive/Transportation and
Business Machine Plastic Parts 20
4. The 2004 NESHAP for Miscellaneous Metal Parts and Products....22
5. The 2004 NESHAP for Plastic Parts and Products 23
6. Existing State and Local VOC Requirements 24
VI. Recommended Control Options 27
A. Recommended Option 1 for Reducing Coating Emissions: VOC
Content Limits Based on Low-VOC Coatings 33
B. Recommended Option 2 for Reducing VOC Emissions: Emission
Rate Limits Based on Low-VOC Coatings and Add-on Controls -
VOC per Volume Solids 35
C. Recommended Option 3 for Reducing VOC Emissions: Emission
Add-on Controls In Lieu of Low-VOC Coatings and Specified
Application Methods 38
D. Work Practices for Coating-Related Activities 38
E. Work Practices for Cleaning Materials 39
VII. Cost Effectiveness of Recommended Control Options 39
VIII. References 41
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LIST OF APPENDICES
Appendix A: Cover Page of 1978 CTG for Surface Coating of Miscellaneous Metal Parts and
Products
Appendix B: Cover Page of 1994 ACT for Surface Coating of Automotive/ Transportation and
Business Machine Plastic Parts
Appendix C: Summary of State and Local Rules for VOC Emissions from Metal Parts Coating
Appendix D: Summary of State and Local Rules for VOC Emissions from Plastic Parts Coating
Appendix E: Summary of California Air District Requirements for VOC Emissions from
Pleasure Craft Surface Coating
Appendix F: Summary of State and Local Requirements for Coating Application Equipment
Appendix G: Summary of State and Local Requirements for VOC Emissions from Cleaning
Operations
Appendix H: Recommended Coating Category Definitions
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Final Control Techniques Guidelines for
Miscellaneous Metal and Plastic Parts Coatings
I. Introduction
Clean Air Act (CAA) section 172(c)( 1) 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 each category of volatile organic compound (VOC) sources covered by a
control techniques guidelines (CTG) document issued between November 15, 1990 and the 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 (September 17, 1979). In subsequent Federal Register notices, EPA has addressed
how States can meet the RACT requirements of the CAA.
Clean Air Act section 183(e) directs EPA to list for regulation those categories of
products that account for at least 80 percent of the VOC emissions, on a reactivity-adjusted basis,
from consumer and commercial products in areas that violate the NAAQS for ozone (i.e., ozone
nonattainment areas). EPA issued the list on March 23, 1995, and has revised the list
periodically. See 60 FR 15264 (March 23, 1995); see also 71 FR 28320 (May 16, 2006), 70 FR
69759 (Nov. 17, 2005); 64 FR 13422 (March 18, 1999). Miscellaneous Metal Products
Coatings and Plastic Parts Coatings are included on the current section 183(e) list. For purposes
of this CTG, these two categories are being addressed under a single CTG for "miscellaneous
metal and plastic parts coatings."
This CTG is intended to provide State and local air pollution control authorities
information that should assist them in determining RACT for VOCs from miscellaneous metal
product and plastic parts surface coating operations. In developing this CTG, EPA, among other
things, evaluated the sources of VOC emissions from the miscellaneous metal product and
plastic parts surface coating industries 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 miscellaneous metal product and plastic parts
surface coating.
States can use the recommendations in this CTG to inform their own determination as to
what constitutes RACT for VOCs for miscellaneous metal product and plastic parts surface
coating operations in their particular nonattainment areas. The information contained in this
document is provided only as guidance. This guidance does not change, or substitute for,
requirements specified in applicable sections of the CAA or EPA's regulations; nor is it a
regulation itself. This document does not impose any legally binding requirements on any entity.
It provides only recommendations for State and local air pollution control agencies to consider in
determining RACT. State and local pollution control agencies are free to implement other
technically-sound approaches that are consistent with the CAA and EPA's implementing
regulations.
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The recommendations contained in this CTG are based on data and information currently
available to EPA. These general recommendations may not apply to a particular situation based
upon the circumstances of a specific source. Regardless of whether a State chooses to implement
the recommendations contained herein through State rules, or to issue State rules that adopt
different approaches for RACT for VOCs from miscellaneous metal product and plastic part
coatings, States must submit their RACT rules to EPA for review and approval as part of the SIP
process.
EPA will evaluate the rules and determine, through notice and comment rulemaking in
the SIP approval process, whether the submitted rules meet the RACT requirements of the CAA
and EPA's regulations. To the extent a State adopts any of the recommendations in this
guidance into its State RACT rules, interested parties can raise questions and objections about
the substance of this guidance and the appropriateness of the application of this guidance to a
particular situation during the development of the State rules and EPA's SIP approval process.
Clean Air Act section 182(b)(2) requires that a CTG issued between November 15, 1990,
and the date of attainment include the date by which States subject to section 182(b) must submit
SIP revisions in response to the CTG. Accordingly, EPA is providing in this CTG a one-year
period for the required submittal. Pursuant to section 182(b)(2), States required to submit rules
consistent with section 182(b) must submit their SIP revisions within one year of the date of
issuance of the final CTG for miscellaneous metal product and plastic part coatings.
II. Background and Overview
There have been five Federal actions that affect miscellaneous metal product and plastic
parts surface coating operations. In June 1978, EPA issued a CTG document (1978 CTG) for
controlling VOC emissions from surface coating of Miscellaneous Metal Parts and Products.11
In January 1988, EPA promulgated the new source performance standards (1988 NSPS) for
Surface Coating of Plastic Parts for Business Machines.b In February 1994, EPA issued an
Alternative Control Techniques (ACT) document (1994 ACT) for controlling VOC emissions
from surface coating of automotive/transportation and business machine plastic parts.0 (The
1978 CTG and the 1994 ACT can be downloaded from EPA's website at:
http://www.epa.gov/ttn/naaqs/ozone/ctg act.) The cover pages from the CTG and ACT have
been included as Appendices A and B to this CTG for reference.
In January 2004, EPA promulgated the National Emission Standards for Hazardous Air
Pollutants for Miscellaneous Metal Parts and Products Surface Coating (40 CFR 63, subpart
MMMM). In April 2004, EPA promulgated the National Emission Standards for Hazardous Air
Pollutants for Plastic Parts and Products Surface Coating (40 CFR 63, subpart PPPP).
a Guideline Series. Control of Volatile Organic Emissions from Existing Stationary Sources - Volume
VI: Surface Coating of Miscellaneous Metal Parts and Products. Publication No. EPA-450/2 -78-015.
U.S. Environmental Protection Agency, Research Triangle Park, NC. June 1978.
b 40 CFR 60 Subpart TTT - Standards of Performance for Industrial Surface Coating: Surface Coating of
Plastic Parts for Business Machines. Applicable to affected facilities for which construction,
modification, or reconstruction begins after January 8, 1986.
0 Alternative Control Techniques Document: Surface Coating of Automotive/Transportation and Business
Machine Plastic Parts. Publication No. EPA-453/R-94-017. U.S. Environmental Protection Agency,
Research Triangle Park, NC. February 1994.
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The 1978 CTG, the 1988 NSPS, the 1994 ACT, and the background information for
subparts MMMM and PPPP provide a thorough discussion of the miscellaneous metal product
and plastic parts surface coating industries, the nature of VOC and volatile organic HAP
emissions from these industries, available control technologies for addressing such emissions,
the costs of available control options, and other items. The 1978 CTG, 1988 NSPS, and 1994
ACT address VOC emissions based on VOC content of low-VOC coatings, whereas subparts
MMMM and PPPP establish volatile organic HAP emissions limits based on HAP content of low
HAP coating materials.
At least 37 States and several local jurisdictions have specific regulations that control
VOC emissions from miscellaneous metal product and plastic parts surface coating. A
discussion of the applicability and control options found in the Federal actions and State and
local rules is presented in Section V of this document.
EPA developed the recommended approaches contained in this document after reviewing
the 1978 CTG, the 1988 NSPS, the 1994 ACT, subparts MMMM and PPPP, and existing State
and local VOC emission reduction approaches.
The remainder of this document is divided into six sections. Section III describes the
scope of sources to which the control recommendations in this CTG could apply. Section IV
describes the miscellaneous metal product and plastic parts surface coating industries, including
the types of metal and plastic parts and products, the coating materials and the coating processes,
and identifies the sources of VOC emissions from those processes. Section V describes the
available control approaches for addressing VOC emissions from these product categories and
summarizes Federal, State and local approaches for addressing such emissions. Section VI
provides our recommendations for RACT for miscellaneous metal product and plastic part
coating. Section VII discusses the cost-effectiveness of the recommended control approaches.
Section VIII contains a list of references.
III. Applicability
This CTG provides control recommendations for reducing VOC emissions from the use
of coatings in miscellaneous metal products and miscellaneous plastic parts surface coating
operations. Please see section IV of this CTG for a description of the miscellaneous metal
products coatings category and the miscellaneous plastic parts coatings category under section
183(e) of the CAA In terms of applicability, we recommend that the control approaches
discussed in section VI of this CTG apply to each miscellaneous metal product and plastic parts
surface coating unit at a facility where the total actual VOC emissions from all miscellaneous
metal product and plastic parts surface coating operations, including related cleaning activities, at
that facility are equal to or exceed 6.8 kg/day (15 Ib/day), or an equivalent level of 2.7 tons per
12-month rolling period, before consideration of controls. We do not recommend these control
approaches for facilities that emit below this level because of the very small VOC emission
reductions that can be achieved.
d A coating unit consists of a series of one or more coating applicators and any associated drying area
and/or oven wherein a coating is applied, dried, and/or cured. A coating unit ends at the point where
the coating is dried or cured, or prior to any subsequent application of a different coating. It is not
necessary for a coating unit to have an oven or flash-off area.
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The recommended threshold level is equivalent to the evaporation of approximately two
gallons of solvent per day. Such a level is considered to be an incidental level of solvent usage
that could be expected even in facilities that use very low-solvent coatings, such as powder or
UV cure coatings (these coatings will be discussed in more detail in section IV.B.l of this
document). Furthermore, based on the 2002 NEI data and the 2004 ozone nonattainment
designations, facilities emitting below the recommended threshold level collectively emit less
than 4 percent of the total reported VOC emissions from miscellaneous metal product and plastic
parts surface coating facilities in ozone nonattainment areas. For these reasons, we did not
extend our recommendations in this CTG to these low-emitting facilities. For purposes of
determining whether a facility meets our recommended applicability threshold, aggregate
emissions, before consideration of control, from all miscellaneous metal product and plastic part
coating operations (including related cleaning activities) at a given facility are included.
In developing their RACT rules, State and local agencies should consider carefully the
facts and circumstances of the affected sources in their States. As noted above, States can adopt
the above recommended 6.8 kg/day (15 Ib/day) actual VOC emissions or an equivalent
applicability threshold, or they can develop other applicability criteria that they determine are
appropriate considering the facts and circumstances of the sources in their particular
nonattainment areas. EPA will review the State RACT rules in the context of the SIP revision
process.
In addition, we recommend that states consider structuring their RACT rules to provide
facilities that coat bodies and/or body parts for new heavier vehicles6 with the option of meeting
either the state RACT requirements for the automobile and light-duty truck coating category or
the state RACT requirements for the miscellaneous metal products or plastic parts coatings
categories. Heavier vehicle coatings are included in the Miscellaneous Metal Products and
Plastic Parts Coatings categories under section 183(e) and are therefore covered in the CTG for
Miscellaneous Metal and Plastic Parts Coatings. We note, however, that some automobile and
light-duty truck assembly coating facilities also coat new heavier vehicle bodies or body parts for
new heavier vehicles. The new heavier vehicle bodies or body parts for new heavier vehicles
may be coated using the same equipment and materials that are used to coat new automobile and
light-duty truck bodies or body parts for new automobiles and light-duty trucks. The permit
requirements for the heavier vehicle portion of these combined use paint shops are often
structured in the same way as permit requirements for automobile and light-duty truck paint
shops. Also, some facilities that coat only new heavier vehicle bodies or body parts for new
heavier vehicles have paint shops that are designed and operated in the same manner as paint
shops that are used to coat new automobile and light-duty truck bodies and body parts for new
automobiles and light-duty trucks. The permit requirements for these heavier vehicle paint shops
are often structured in the same way as permit requirements for automobile and light-duty truck
paint shops.
In light of the above, providing facilities that coat bodies and/or body parts for new
heavier vehicles with the option of meeting the state RACT requirements for the automobile and
light-duty truck coating category in lieu of the requirements for Miscellaneous Metal Products or
Plastic Parts categories will provide for the most consistency with existing permit requirements
and simplify compliance demonstration requirements for these facilities. Furthermore, in light of
e Heavier vehicles includes all vehicles that meet the definition of the term "other motor vehicles", as defined at 40
CFR § 63.3176 (the NESHAP for Surface Coating of Automobiles and Light-Duty Trucks).
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the stringency of our recommended control measures in the automobile and light-duty truck
assembly coatings CTG, we believe that facilities that choose this alternative will achieve at least
equivalent, if not greater, control of VOC emissions. For the reasons stated above, we
recommend that state RACT rules provide facilities that coat bodies and/or body parts for new
heavier vehicles the option of meeting either the state RACT requirements for miscellaneous
metals and plastic parts coatings or the state RACT requirements for auto and light-duty truck
coatings.
The 2002 National Emission Inventory (NET) was used as the source of emissions data
for the miscellaneous metal product and plastic part surface coating facilities as a whole.
In developing this CTG, the 2002 NEI database was queried for facilities likely
performing miscellaneous metal product and plastic parts surface coating based on Standard
Industrial Classification (SIC) code and Source Classification Code (SCC). The resulting list of
facilities was further reviewed to remove all SIC codes or SCC covered by other CTG finalized
or in development. This activity resulted in 3,925 miscellaneous metal product and plastic part
surface coating facilities in the 2002 NEI, and VOC emissions totaled an estimated 32,700 Mg/yr
(36,000 tpy) from surface coating operations. Of the 3,925 facilities identified in the 2002 NEI,
2,539 facilities were located in ozone nonattainment areas and 1,296 of the facilities located in
ozone nonattainment areas emit more than the 6.8 kg/day (15 Ib/day) VOC applicability
threshold described above. These 1,296 facilities emitted an estimated 20,098 Mg (22,108 tons)
of VOC in 2002.
IV. Process Description and Sources of VOC Emissions
The miscellaneous metal product and plastic parts surface coatings categories under
section 183(e) of the CAA includes the coatings that are applied to the surfaces of a varied range
of metal and plastic parts and products. Such parts or products are constructed either entirely or
partially from metal or plastic. These miscellaneous metal products and plastic parts include, but
are not limited to, metal and plastic components of the following types of products as well as the
products themselves: fabricated metal products, molded plastic parts, small and large farm
machinery, commercial and industrial machinery and equipment, automotive or transportation
equipment, interior or exterior automotive parts, construction equipment, motor vehicle
accessories, bicycles and sporting goods, toys, recreational vehicles, pleasure craft (recreational
boats), extruded aluminum structural components, railroad cars, heavier vehicles, lawn and
garden equipment, business machines, laboratory and medical equipment, electronic equipment,
steel drums, metal pipes, and numerous other industrial and household products (hereinafter
collectively referred to as "miscellaneous metal and plastic parts"). The CTG applies to
manufacturers of miscellaneous metal and plastic parts that surface-coat the parts they produce.
The final CTG also applies to facilities that perform surface coating of miscellaneous metal and
plastic parts on a contract basis. However, coatings that are applied to test panels and coupons
as part of research and development, quality control, or performance testing activities at paint
research or manufacturing facilities are not included in the miscellaneous metal products and
plastic parts coatings categories under section 183(e) and are therefore not addressed in this
CTG.
f Heavier vehicles includes all vehicles that meet the definition of the term "other motor vehicles", as
defined in the National Emission Standards for Surface Coating of Automobile and Light-Duty Trucks
at 40 CFR 63.3176.
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Miscellaneous metal products and plastic parts coatings do not include coatings that are a
part of other product categories listed under Section 183(e) of the Act for which CTGs have been
published and/or addressed by other CTGs. These other categories that are not part of the
miscellaneous metal product and plastic parts coatings categories include shipbuilding and repair
coatings; aerospace coatings; wood furniture coatings; metal furniture coatings; large appliance
coatings; automobile and light-duty truck assembly coatings; flatwood paneling coatings;
miscellaneous industrial adhesives; fiberglass boat manufacturing materials; and paper, film, and
foil coatings. Can coatings, coil coatings, and magnet wire coatings were not listed under
Section 183(e) of the Act, but were addressed by earlier CTGs, and are also not included in the
miscellaneous metal product and plastic parts coatings categories addressed by this CTG.
Three Section 183(e) categories (aerosol coatings, architectural coatings, and automobile
refmish coatings) are regulated by national VOC rules. Aerosol coatings are not included in the
miscellaneous metal parts or plastic parts coating categories. Architectural coatings and
automobile refmish coatings are not included in the miscellaneous metal parts or plastic parts
coating categories to the extent they are used for architectural coating or automobile refmish
coating purposes as defined in their respective national VOC rules. A coating recommended by
its manufacturer or importer for field application to stationary structures (e.g., steel bridge) and
their appurtenances, to portable buildings, to pavements, or to curbs would be regulated as an
architectural coating under the national VOC rule for architectural coatings. Such a coating,
when used for architectural coating as defined in the national rule, would not be included in the
miscellaneous metal products coatings category under section 183(e). If, however, such coating
were applied to structural steel in a shop setting, the coating would be included in the
miscellaneous metal products coatings category and covered by the CTG for that category, as
well as being subject to the national VOC rule for architectural coatings. Similarly, a coating
recommended for automobile refmishing by its manufacturer or importer for automobile
refmishing would be regulated as an automobile refmish coating under the national VOC rule for
automobile refmish coatings. Such a coating, when used for automobile refmishing as defined in
the national rule, would not be included in the miscellaneous metal products coatings category.
If, however, such coating were applied to a metal box or plastic box, the coating would be
included in the miscellaneous metal products coatings category and covered by the CTG for that
category, as well as being subject to the national VOC rule for automobile refmish coatings.
As mentioned above, the miscellaneous metal products and plastic parts coatings
categories, as listed under section 183(e), do not include products that are a part of other section
183(e) categories for which CTGs have been published, such as the fiberglass boat
manufacturing materials category or the miscellaneous industrial adhesives category.
Specifically, the miscellaneous metal products and plastic parts categories do not include gel
coats applied to fiber-reinforced plastic (fiberglass composite) products removed from the mold
or used as in-mold coatings in the production of fiberglass parts. The miscellaneous metal
products and plastic parts coatings categories also do not include body fillers and putties used to
repair surface defects in fiberglass composite parts, or putties used to bond fiberglass composite
parts together. These putties are part of the composite structure and are not coatings.
Motor vehicle cavity wax, sealers, deadeners, gasket/gasket sealing material, underbody
coatings, trunk interior coating, bedliner and lubricating wax/compound used at a facility that is
not an automobile or light-duty truck assembly coating facility, are included in the miscellaneous
metal and plastic parts coatings categories and addressed in this final CTG for miscellaneous
metal products and plastic parts coatings. However, similar materials used at automobiles and
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light duty trucks assembly coating facilities are included in the automobile and light-duty truck
assembly coatings category and addressed in the CTG for that category.
Except as provided above, miscellaneous metal product and plastic parts coatings include
paints, sealants, caulks, inks, and maskants.g The paints include several categories of primers,
topcoats, and specialty coatings, typically defined by the coating's function. The types of
coating technologies used by miscellaneous metal product and plastic part surface coating
facilities include higher solids, waterborne, and powder coatings, as well as conventional
solventborne coatings.
A. Process Description
Miscellaneous metal product and plastic parts surface coatings serve decorative,
protective, and functional purposes. Coatings protect metal parts from corrosion by providing
resistance to moisture, heat, and sometimes the outdoor elements. Plastic parts may be coated to
provide color, texture, or protection, thus improving appearance and durability, and can also
function to attenuate electromagnetic interference/radio frequency interference (EMI/RFI)
signals, and to conceal mold lines and flaws in the substrate surface.
The coating selections and requirements for such a miscellaneous sector depend on the
end use specifications, but appearance and protection will most likely be important
considerations. Coatings for each type of metal or plastic part can have special requirements and
contain unique properties because each type is used to serve a particular coating performance.
Metal and plastic surface coatings must also be durable and have excellent adhesion properties to
avoid peeling or chipping. Finally, the coatings for many products provide decorative appeal.
Applying a color coat is probably the most common way of decorating metal or plastic parts for
several aesthetic, commercial, and functional reasons (e.g., reflective properties). Often a primer
is applied prior to a color coat.
Such coating and painting of parts in the miscellaneous metal product and plastic parts
surface coating industries are often "secondary operations". These secondary operations are
carried out not only by fabricators of metal and plastic parts, but also in product assembly
facilities and painting job shops.
The miscellaneous metal product and plastic parts surface coating process may be divided
into three main unit operations: (1) surface preparation, (2) coating application operations, and
(3) cleaning activities. These three types of activities utilize VOC-containing compounds (i.e.,
coatings, thinners, and/or cleaning materials) and are further described below.
8 Decorative, protective, or functional materials that consist only of protective oils for metal, acids,
bases, or any combination of these substances are not considered miscellaneous metal or plastic part
coatings.
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1. Surface Prep arati on
Surface preparation is performed for two main reasons: (1) to correct any flaws in the
part prior to coating and (2) to prepare the part to receive the coating. The amount of surface
preparation a part requires or the types of surface preparation processes employed can greatly
vary between metal and plastic part substrates.
Before a metal product can be coated, its surface must be thoroughly cleaned. The
cleaning operation consists of the following basic processing steps: (1) alkaline or acid cleaning,
(2) water rinse, (3) phosphate treatment (typically iron phosphate), (4) water rinse, and (5)
pretreatment and/or water rinse. The last step can involve drying the parts in an oven. In
general, the cleaning chemicals used in this cleaning operation contain little VOC and therefore
generate negligible emissions.
In the alkaline or acid cleaning step, metal parts or products are sprayed with, or
immersed in, a cleaning solution to dissolve and remove oil, grease, and dirt. This solution,
which can be alkaline or acidic, typically includes one or more other ingredients, such as
surfactants or corrosion inhibitors. Generally, acid-based solutions are preferred for removing
corrosion and scale from metal pieces. However, because alkaline formulations are generally
somewhat milder, they are recommended for certain metal substrates when the corrosiveness of
acid solutions is a concern.
The cleaning step can be followed by a phosphate treatment for metal parts. The purpose
of this treatment is to provide corrosion resistance to the surface of the metal part. The final
pretreatment step, if utilized, may be a rust inhibitor or adhesion promoter. Following each
treatment step, the metal part or product is typically sent through several rinse stages in series.
An alternate cleaning method prior to coating is an enclosed shot-blasting operation. The
operation uses steel shot (fine particles) to abrasively remove dirt and grease, as well as to
smooth rough edges and welds. The operation can also be used to remove cured coatings when
parts require rework. This cleaning operation does not involve any liquid chemicals, and no
wastewater discharge is produced.
Surface preparation for plastic parts or products can vary greatly from the surface
preparation steps described above for metal products. For plastic parts or products, some
sanding may be done to remove burrs or other inconsistencies. Puttying may be necessary to fill
in any gaps or small cracks in the plastic part. For pre-primed plastic parts, spot-primer may be
applied to any areas missing primer or with an inconsistent primer application. Following this
type of pretreatment, any remaining surface residue must be removed, typically by wiping off the
dust with water or alcohol soaked rags. Acetone or a hot water and grit material solution can
also be used to remove any tape adhesive, dirt, or dust.
Varying degrees of cleaning are possible, including multiple stages of washing cycles
with proprietary soaps or solvents, or de-ionized water. Also, depending on the types of coating
to be applied, surface preparation can include treatment of the part so that it can receive the
coating. For example, a conductive coating of some sort is necessary for the plastic part to be
coated by some electrostatic coating application techniques.
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2. Coating Application
Surface coating is accomplished by applying a coating to the metal or plastic part,
followed by curing or drying the coating. The coating itself may be in the form of a liquid or
powder.
Several different types of application technology are used to apply liquid coatings, and
the selection of the application technology can have a significant effect on the amount of coating
used and the resulting VOC emissions from the operation. The most common types of liquid
coating applicators include: air atomized spray coating, electrostatic spray coating, high
volume/low pressure (HVLP) spray coating, dip coating, flow coating, roll coating,
electrocoating, and autophoretic coating. Powder coatings can be applied through electrostatic
spraying or dipping,
Conventional air spray application uses compressed air at high pressure (e.g., 30 to 90
pounds per square inch, psi) to pull the coating from a reservoir and atomize the coating as it is
expelled from the spray gun tip. The mixture of air and atomized coating then deposits the
coating on the surface being coated. Because of the high pressure of air used, most of the
coating does not land on the part being coated and is carried away from the part as overspray and
is wasted. The fraction of coating solids that reaches the part is termed transfer efficiency, and
conventional air spray has a relatively low transfer efficiency compared to other application
methods. Therefore, many coating operations have adopted other types of spray application to
use coatings more efficiently.
Airless Spray. With airless spray, a pump forces the coating through an atomizing nozzle
at high pressure (1,000 to 6,000 psi). Airless spray is ideal for rapid coverage of large areas and
when a heavy film build is required. The size of airless spray paint droplets is larger, the spray
cloud is less turbulent, and the transfer efficiency is typically superior to conventional air spray.
However, airless spray leaves a rougher, more textured surface; therefore, it is generally used on
surfaces where appearance is not critical
Air-Assisted Airless Spray. An air-assisted airless system combines the benefits of
conventional air spray and airless spray. The system consists of an airless spray gun with a
compressed air jet at the gun tip to atomize the coating. It uses lower fluid pressures than airless
spray and lower air pressures than conventional air spray (e.g., 5 to 20 psi versus 30 to 90 psi).
This fluid/air pressure combination delivers a less turbulent spray than conventional air systems
and applies a more uniform finish than airless systems. However, the amount of time needed to
apply coatings is greater because of the lower fluid and air pressure.
Electrostatic Spray. In electrostatic spray application, the coating and part are oppositely
charged. The part or product is grounded and attracts the negatively charged coating particles.
Electrostatic spray systems are reported to have the highest transfer efficiency of any of the spray
application techniques because of minimal overspray, which also results in lower paint loss and
lower VOC emissions. Electrostatic systems can be used to spray apply either liquid or powder
coatings. Powder coatings are applied almost exclusively by means of electrostatic spray in
surface coating operations. If a powder recovery system is used, the oversprayed powder is
recovered and recycled.
HVLP systems use lower air pressures (generally not more than 10 psi at the spray cap)
and greater volumes than conventional air atomized spray systems. Specialized nozzles provide
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better air and fluid flow at the lower air pressure, and shape the air/spray pattern and guide the
atomized coating particles to the part or product being coated. The lower air pressures result in
greater transfer efficiency compared to conventional air atomized spray systems.
Dip coating is another available method for applying liquid coating. It is typically used
on parts that do not require a high-quality appearance, and is often used for large complicated
parts such building joists, that would be difficult to paint using other methods. The metal or
plastic parts to be coated are manually or automatically dipped into a tank containing the coating.
The parts are then withdrawn from the tank and any excess coating is allowed to drain, thus
achieving very high coating transfer efficiencies. Typical systems have some means of
recirculation of the tank contents, filters to remove paint sediment and solid contaminants, and
means for controlling the viscosity of the fluid. Because the tank opening exposes a large
surface area of liquid coating, solvent losses occur from the tank. To maintain the desired
coating viscosity in the tank, these losses are compensated for by adding thinner (water or
solvent, depending on the coating used).
Powder coatings may also be applied using a dip application operation. The part to be
coated is first heated to a temperature above the powder's melting point. The hot part is then
immersed in a fluidized bed of the powder, melting the powder in contact with it and forming a
continuous coating on the part.
Flow coating is similar to dip coating and involves conveying the metal or plastic part or
product over an enclosed sink, where the coating is applied at low pressure as the item passes
under a series of nozzles. Excess coating drains back into the sink, is filtered, and pumped back
into a coating holding tank. A typical flow coater tank is enclosed and is smaller than the
equivalent dip coating tank. As a result, less coating is used and less solvent is evaporated than
in dip tank operations. This application method results in an increase in production rate.
Roll coating application is used for high viscosity coatings, particularly adhesives, and
for small surface areas.
Electrocoating (electrodeposition) is a specialized form of dip coating where opposite
electric charges are applied to the waterborne coating and the part. The coating is deposited on
the part by means of electrical attraction, which produces a more uniform coating on the part
than traditional dip application.
Autophoretic coating consists of a series of dip tanks in which the parts to be coated are
immersed and cleaned. After cleaning, the coating solids are deposited on the surface of the
parts via chemical reaction. The coating solids are then heat cured.
Zinc-Arc Spray. Metallic zinc may be applied to metal or plastic parts. When applied to
plastic, it is usually done to provide a conductive surface or shielding. When applied to metal
parts, it is usually to provide a corrosion resistant surface. This two-step process first roughens a
metal or plastic surface by grit-blasting or sanding, and then spray-coats with molten zinc, either
manually or with robotics. The zinc-arc spray gun operates by mechanically feeding two zinc
wires into the tip of the spray gun where they are melted by an electric arc. A high-pressure air
nozzle blows the molten zinc particles onto the surface of the metal or plastic part.
As described above, there are various spray application technologies that can be used to
apply coatings to miscellaneous metal and plastic parts. Spray coating operations are typically
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performed in a spray booth by manual or automated (e.g., robotic) means to capture paint
overspray, remove solvent vapors from the workplace during liquid coating spray operations, and
to keep the coating operation from being contaminated by dirt from other operations. In some
instances, productivity is maximized by using automated application followed by manual
touchup. Typically, overspray is collected within the booth on either dry filter media or a
waterwash booth. Air flow in a booth equipped with dry filter media generally passes from the
spray applicator, over the metal or plastic part or product, and through a dry filter bank.
Waterwash booths are less commonly used than dry filter booths in the miscellaneous metal
product and plastic parts surface coating industries. In a waterwash booth, air is drawn through a
continuous curtain of moving water and overspray is removed by contact with the water. In
booths equipped with dry filters and in waterwash booths, the overspray can be collected on a
series of baffles in front of the dry filters or waterwash, and, in some cases, the collected
overspray can be reused. This recycling method substantially reduces both air emissions and
waste (including spent dry filters) generated by the coating application operation.
After each of the liquid and powder coating applications described above, the applied
coating is heat dried or cured or air dried or cured after application. For liquid spray and dip
coating operations, the coated parts are typically first slowly moved through a flash-off area after
the coating application operation to allow solvents in the coating to evaporate slowly and thus
avoid bubbling of the coating while it is curing in the oven. After application of powder
coatings, the coated metal or plastic parts are conveyed directly to an oven (there is no flash-off
area for powder coatings) and heated to cure the powder. This curing process melts the powder,
forming a continuous coating. Following the curing step, the final unit is assembled (if
necessary) and packaged for shipment.
3. Cleaning activities
Cleaning activities other than surface preparation also occur at miscellaneous metal
product and plastic parts surface coating facilities. Cleaning materials are used during these
activities to remove coating residue or other unwanted materials from equipment related to
coating operations, as well as the cleaning of spray guns, transfer lines (e.g., tubing or piping),
tanks, and the interior of spray booths. These cleaning materials are typically mixtures of VOC-
containing solvents.
B. Sources of VOC Emissions
The VOC emissions from miscellaneous metal product and plastic part surface coating
processes result from the evaporation of the volatile components of the coatings and cleaning
materials used in these operations. In most cases, VOC emissions from surface preparation,
storage, handling, and waste/wastewater operations are relatively small. The following
discussion describes these primary emission sources (coatings and cleaning materials).
h In a Federal Register notice, EPA stated that the cleaning operations associated with certain specified
section 183(e) consumer and commercial product categories, including the miscellaneous metal product
coating category and the plastic part coating category, would not be covered by EPA's 2006 CTG for
industrial cleaning solvents (71 FR 44522 and 44540, August 4, 2006). In the notice, EPA expressed its
intention to address cleaning operations associated with these categories in the CTGs for these specified
categories if the Agency determines that a CTG is appropriate for the respective categories. Accordingly,
this CTG addresses VOC emissions from cleaning operations associated the miscellaneous metal product
coating category and the plastic part coating category.
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1. Coatings
The majority of VOC emissions from miscellaneous metal product and plastic part
surface coatings occur from evaporation of solvents in the coatings during coating
applicati on/flash-off and drying/curing of the coatings. In spray coating operations, the majority
of VOC emissions occur in the spray booth during coating application. For liquid spray
applications, it is estimated that 65 to 80 percent of the volatiles from spray coating are emitted
during the application and flash-off operations, and that 20 to 35 percent are emitted from the
drying/curing operation.
The remaining emissions are primarily from mixing and/or thinning. The VOC
emissions from mixing and thinning of coatings occur from displacement of VOC-laden air in
containers used to mix coatings containing solvents (thinners) prior to coating application. The
displacement of VOC-laden air can also occur during filling of containers and can be caused by
changes in temperature, changes in barometric pressure, or agitation during mixing.
The VOC emissions from coating application occur when solvent evaporates from the
coating as it is being applied to the part or product. The transfer efficiency (the percent of
coating solids deposited on the metal and plastic parts) of a coating application method affects
the amount of VOC emitted during coating application. The more efficient a coating application
method is in transferring coatings to the metal or plastic parts, the lower the volume of coatings
(and therefore solvents) needed per given amount of production; thus resulting in lower VOC
emissions.
Conventional air atomized spray equipment utilizes high atomizing air pressure with
typical transfer efficiencies of 25 to 40 percent. The transfer efficiency of a dip coater is very
high (approximately 90 percent); however, some VOC is emitted from the liquid coating bath
due to its large exposed surface area. For liquid coatings, electrostatic spray coating is more
efficient than conventional air atomized spray, with transfer efficiency typically ranging from 60
to 90 percent. Electrostatic spray coating is also an efficient method for applying powder
coating.
After being coated by any of the typical coating methods (e.g., spray coating or dip
coating), the metal or plastic parts are dried/cured. Prior to entering the ovens, solvents in the
coatings evaporate slowly in the flash-off area to prevent bubble formation during curing. The
amount of VOC emissions from the flash-off area depends on the type of coating used, how
quickly the component or product moves through the flash-off area, and the distance between the
application area and the bake oven.
For powder coatings, the curing/drying step melts the powder and forms a continuous
coating on metal products. For liquid coatings, this step removes any remaining volatiles from
the coating. The cured coatings provide the desired decorative and/or protective characteristics.
The VOC emissions during the curing/drying process result from the evaporation of the
remaining solvents in the dryer.
Until the 1970's, conventional solvent-based coatings, with high VOC content, were the
majority of coatings used in the miscellaneous metal product and plastic parts surface coating
industries. Due to increased regulation at the State and Federal level, these industries have
steadily moved to lower VOC content coatings. These alternative coatings include powder
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coatings, waterborne coatings, higher solids coatings, and ultraviolet coatings. The following
discussion summarizes each of these alternative coating formulations.
Powder Coatings. The use of powder coating systems in the metal products and plastic
part manufacturing industries has increased. Many miscellaneous metal products surface coating
facilities have replaced existing liquid coating operations with powder coating operations.
Compared to conventional liquid coating systems, powder coating produces minimal amounts of
VOC emissions because powder coatings are applied as dried particles, no VOC are released
during the application operation, and volatile emissions from the curing operation, if any, are
generally much less than the volatile emissions from liquid coating systems. Powder coating is
applied via powder delivery systems, which in most cases is an electrostatic spray. Particulate
emissions resulting from the application of powder coatings can be minimized through the
implementation of a recovery and recycling process (reuse of overspray). Depending on the
powder formulation, some volatile emissions may occur when the powder is heated during the
curing step. Powder coating applications are best suited for long production runs of consistently
sized parts without color changes.
Waterborne Coatings. Waterborne coatings produce minimal VOC emissions primarily
because a large portion of the solvent carrier is replaced with water. The water component can
constitute as much as 80 percent of the coating, with the remaining 20 percent being the coating
solids. Waterborne coatings are used widely, most often when there is a primer applied to the
substrate prior to the waterborne coating.
Higher Solids Coatings. These coatings contain at least 60 percent by volume of coating
solids. VOC emissions are reduced through the use of these coatings because they contain less
solvent per unit volume of solids than conventional solvent-based coatings. Thus, a lesser
amount of VOC emissions are released during coating preparation, application, and curing to
deliver a given amount of coating solids.
Ultraviolet Curable Coatings. Ultraviolet (UV) curable liquid and UV curable powder
coatings are used for heat sensitive substrates as they allow for low curing temperatures. UV
liquid coatings have been used for several decades on parts made of plastic and metal. Because
the entire coating must be exposed to the UV light source to achieve complete curing of the UV
coating, UV curable coating applications may not be feasible for some miscellaneous metal and
plastic parts. Pigmentation used in the majority of metal and plastic part coatings would block
the UV light. The shape of the metal or plastic part may also present curing problems. Metal
and plastic parts with complex shapes or enclosed spaces would have areas that could be shaded
from the UV light source.
2. Cleaning Materials
Cleaning materials are another source of VOC emitted by miscellaneous metal product
and plastic parts surface coating operations. The VOC are emitted when solvents evaporate from
the cleaning materials during use.
Cleaning materials with low-VOC composite vapor pressure and/or low-VOC content
generate less VOC emissions than materials with higher VOC vapor pressure and/or content.
The VOC composite vapor pressure of a cleaning material is a weighted average of the vapor
pressures of the VOC components of that cleaning material. The vapor pressure of each VOC
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component is weighted by the mole fraction of that VOC component in the whole cleaning
material, including non-VOC components such as water or exempt compounds.1
Water and exempt compounds thereby reduce the VOC composite vapor pressure of
cleaning materials in which they are present. Although use of lower vapor pressure cleaning
materials may reduce VOC emissions, these materials may not be feasible with the broad range
of coatings used in the miscellaneous metal product and plastic parts surface coating facilities.
Similarly, cleaning materials with low VOC content would generate less VOC emissions than
materials with high VOC content, but may not be feasible with the broad range of coatings used
in the miscellaneous metal product and plastic parts surface coating facilities.
V. Available Controls and Regulatory Approaches
As previously mentioned, there are two main sources of VOC emissions from
miscellaneous metal product and plastic parts surface coating operations: (1) evaporation of
VOC from the coatings; and (2) evaporation of VOC from the cleaning materials. This section
summarizes the available control options for reducing these VOC emissions and existing federal,
State, and local VOC recommendations or requirements that address these emissions.
A. Available Controls for VOC Emissions from Coatings
There are two general emission control techniques for reducing VOC emissions from
miscellaneous metal product and plastic parts coatings: pollution prevention measures, and
emission capture and add-on control systems. Pollution prevention is the most prevalent control
technique being used by the miscellaneous metal product and plastic parts surface coating
facilities. Add-on control systems are available to these facilities, but few facilities utilize this
control technique. Provided below is a summary of these control techniques.
1. Pollution Prevention Measures
Pollution prevention measures applicable to the miscellaneous metal product and plastic
parts surface coating operations, including product substitution/reformulation, work practice
procedures, and equipment substitution, may be used to decrease VOC emissions from coating
application operations. Lower VOC content coatings, such as powder coatings, higher solids
coatings and waterborne coatings, may be used to reduce VOC emissions by reducing or
eliminating the organic solvent present in the coating. Work practice procedures may also result
in VOC emission reductions during the coating process by reducing coating waste. The use of
efficient coating application equipment can reduce VOC emission by increasing the coating
transfer efficiency (i.e., the percentage of coating solids used that is deposited onto the substrate)
and reducing the amount of coating used and wasted as overspray.
Product substitution/Reformulation
One pollution prevention measure is to substitute higher-solvent coatings with coatings
containing little or no solvents. As previously discussed, these coatings include powder coatings,
waterborne coatings, higher solids coatings, UV coatings, electrocoatings, and autophoretic
coatings. The use of higher solids, powder and waterborne coatings has increased since 1978.
1 Exempt compounds are those classified by EPA as having negligible photochemical reactivity as listed
in 40 CFR 51.100(s). Exempt compounds are not considered to be VOC.
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Manufacturers have developed and are continuing to develop waterborne and powder coating
formulations that replace conventional organic solvent-borne coatings. These coatings are
generally available. Conversion to powder coatings (for example) can lower VOC emissions
greatly, and many miscellaneous metal product and plastic parts coating operations are capable
of converting to these coatings. However, the currently available low-VOC coatings or coatings
with no solvents do not meet the performance requirements of some metal or plastic coating
applications and therefore are not viable options for these operations.
Work Practices
Work practice procedures are physical actions intended to affect emission reductions.
Because work practice procedures are specifically tailored to an industry, they may vary from a
few manual operations to a complex program.
Coating waste is generated during coating material preparation, coating application, and
equipment cleaning. If coating waste is reduced, overall VOC emissions from coating operations
will be reduced because less VOC coating material will be needed for production. Coating waste
may be reduced by effectively controlling material preparation and using proper equipment
maintenance procedures. Other work practices include storing VOC-containing coatings,
thinners, and coating-related waste materials in closed containers; ensuring that mixing and
storage containers used for VOC-containing materials are kept closed as much as possible;
minimizing spills of VOC-containing materials; and conveying VOC-containing materials in
closed containers or pipes.
Equipment Substitution
The use of the more effective application equipment also reduces VOC emissions.
Conventional air atomized spray application systems utilize high atomizing air pressure with
typical transfer efficiencies of 25 to 40 percent.
More modern technologies, such electrostatic and HVLP spray equipment, can achieve
much higher transfer efficiencies. The increase in transfer efficiency translates to a decrease in
usage of materials containing VOC.
In electrostatic spraying, the coating is charged and the part is grounded, thereby
attracting the atomized coating to the part. Transfer efficiencies of up to 90 percent may be
achieved depending on the product shape, size, and substrate.
HVLP systems use reduced air pressure to atomize coatings and the reduced air reduces
turbulence at the part surface and increases transfer efficiency. HVLP spray systems can
achieve transfer efficiencies of up to 65 percent under optimal conditions of part size and shape,
and with good operator technique.
2. Emission Capture and Add-on Control Systems
In addition to pollution prevention measures, VOC emissions from miscellaneous metal
product and plastic parts surface coating operations can be reduced by the use of capture
systems, in conjunction with add-on control systems that either destroy or recover the VOC in
the exhaust streams. As stated previously, although capture systems and add-on control devices
are available to the miscellaneous metal product and plastic parts surface coating facilities, they
are generally not used. That is the case when low VOC coatings and alternative application
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methods can be used to reduce VOC emissions. The majority of VOC emissions from
miscellaneous metal product and plastic parts coating operations occur in the spray booth. Spray
booths typically exhaust a high volume of air to dilute the concentration of VOC for safety
reasons to reduce potential worker exposure to solvent vapors and to reduce the flammability of
the air-vapor mixture. Although VOC emissions in spray booth exhaust can be controlled with
add-on controls, it is generally not cost effective to do so because of the large volume of air that
must be treated and the low concentration of VOC.
Capture Systems
Capture systems, such as hoods and enclosures, collect solvent-laden air from process
vents (e.g., spray booth or bake oven vents) and/or fugitive emissions (e.g., flash-off area) and
direct the captured air to a control device. The majority of VOC emissions from miscellaneous
metal product and plastic parts surface coating occur in the spray booth. These emissions can be
ducted from the spray booth directly to the control device. Similarly, bake oven exhaust can be
ducted directly to the control device. Spray booths and bake ovens are the principal elements of
the capture system. In addition, hoods, floor air sweeps or enclosures can be used to collect
fugitive emissions from solvents that evaporate in flash-off areas and route them to a control
device.
The design of the capture system can greatly contribute to the overall VOC control
efficiency. An efficient capture system maximizes the capture of emissions and minimizes the
capture of dilution air. Spray booth and bake oven design and air management can reduce the
volume of exhaust air and maximize the VOC concentration of the exhaust air which can reduce
the cost of control. Facilities may combine several captured VOC-laden streams and duct them
to a single control device.
Add-on Control Systems
Add-on controls reduce the amount of VOC emissions by either destruction or recovery
with or without recycling of VOC emission in the exhaust streams. Two categories of add-on
control devices can be used by the miscellaneous metal product and plastic parts and products
surface coating facilities: combustion (thermal or catalytic oxidation) and recovery (adsorption
and absorption). While many control devices can be used to reduce VOC emissions, the
following summary covers those control devices known to be used with surface coating
operations: oxidation, adsorption, and absorption. In addition, there are other control measures
known to reduce VOC emissions, but are not currently being widely used in the miscellaneous
metal product and plastic parts surface coating facilities. These alternative control technologies
are also discussed below.
Oxidation destroys VOC emissions in an exhaust stream by exposing the stream to an
oxidizing atmosphere at high temperatures. Oxidizers may be of thermal or catalytic design and
combust VOC-containing exhaust streams. Catalytic oxidizers are similar to thermal oxidizers
but employ a catalyst to aid in the oxidation reaction. As a result, catalytic oxidizers operate at
lower combustion temperatures relative to that required in thermal oxidizers. Both types of
oxidizers generally utilize either regenerative or recuperative techniques to preheat inlet gas in
order to decrease energy costs associated with high oxidation temperatures. They may also use
primary or secondary heat recovery to reduce energy consumption. In general, oxidizers may
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achieve destruction efficiencies of greater than 95 percent as applied to coating application
operations with high and constant concentrations of VOC.
Adsorption occurs when the unbalanced molecular forces on the surface of solids (the
adsorbant) attract and retain gases and particulate matter that come in contact with the solid.
Several materials are widely used as the adsorbent, such as activated carbon, organic resin
polymer, and inorganic materials. Each has substantial surface area per unit volume. Carbon
adsorbers are most commonly used in the miscellaneous metal product and plastic parts surface
coating facilities.
In a carbon adsorber, activated carbon is used as the adsorbent in a regenerable fixed bed.
In a typical carbon adsorber, VOC-laden air is passed through a fixed bed of granular activated
carbon. Adsorber beds are typically operated in parallel to avoid interruption of VOC control.
In this arrangement, when the adsorption capacity of one bed is exhausted, it can be removed
from service and a second adsorber bed can be put into service, ensuring that a control device is
operating at all times. The spent carbon bed in the first adsorber bed is then regenerated and can
be put into service again.
Carbon adsorption systems can achieve control device efficiencies greater than 95
percent. In contrast to combustion, carbon adsorption does not destroy the VOC it removes from
the air stream. Carbon adsorbers used in miscellaneous metal and plastic parts surface coating
are thermally regenerated, usually by passing steam through the carbon beds. The VOC are
removed from the carbon (desorbed) and transferred to the steam. The VOC-containing steam is
then condensed, and the VOC solvent is separated from the water. The recovered solvent can
then be decanted for sale or reuse. Regeneration can also be achieved with hot air. Hot-air
regeneration can be quite attractive when dealing with water soluble solvents. Carbon adsorption
is most amenable to coatings that use a single solvent; if solvent mixtures are collected by
adsorbers, they usually are distilled for reuse.
There are two options for disposing of recovered solvents which cannot be reused. The
first is to sell the material back to the solvent supplier or an independent firm that specializes in
reclaiming contaminated solvents. The other option is to use the recovered solvent as a fuel in
coating ovens or in boilers. However, many coating ovens and boilers are gas-fired and would
require burner modifications to burn solvent. Carbon adsorption is generally economically
attractive only if the recovered solvent can be reused directly.
Carbon adsorbers are most suitable for solvents that are immiscible with water, such as
toluene and xylene, but are not recommended for water-soluble VOC, such as methyl ethyl
ketone and methyl isobutyl ketone. In the case where a water-soluble VOC is present, the water
vapor will be adsorbed and desorbed along with the VOC vapor, and the VOC may require
subsequent purification if it is to be reused.
The presence of solid particles or polymerizable substances in the inlet air stream to a
carbon adsorber may require pretreatment of the inlet air. In addition, adsorption is usually used
for coating application exhaust streams at ambient temperature up to approximately 38°C
(100°F). Therefore, cooling and dehumidification may also be required as pretreatment in some
cases. Adding equipment, such as a dehumidification system, increases the costs associated with
the use of a carbon adsorption system.
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Absorption is the process by which a gas stream is contacted with a liquid so that one or
more of the components of the gas stream will dissolve in the liquid. Water is the most common
absorbent, but organic solvents may also be used. Removal efficiency can be enhanced by the
addition of reactive chemical additives to the absorbent to increase solubility of the absorbed
pollutant or change the equilibrium.
Alternative control technologies, such as condensation, biodegradation, and UV oxidation
are applicable for control of VOC emissions from coatings. However, EPA is not aware of any
miscellaneous metal product and plastic parts surface coating facilities currently using these
types of control technologies.
B. Available Controls for VOC Emissions from Cleaning Materials
Pollution prevention is the most common emission control technique for reducing VOC
emissions from cleaning materials. The pollution prevention measures applicable to the
miscellaneous metal product and plastic parts surface coating operations include product
substitution or reformulation, and work practice procedures. Cleaning materials with low or no
VOC content or low-VOC composite vapor pressure may be used to reduce or eliminate VOC
emissions from using these materials. Work practice procedures may also reduce VOC emission
during cleaning operations by reducing the amount of VOC that can evaporate due to exposure to
air.
No add-on control technologies are being used specifically for reducing VOC emissions
from cleaning operations associated with miscellaneous metal and plastic parts surface coating.
However, if cleaning operations are performed within a capture system that is ducted to an add-
on control system, such as a hood routed to a thermal oxidizer, the VOC emissions from the
cleaning operations would be reduced by destruction in the thermal oxidizer.
1. Product Sub stituti on/Reformul ati on
Reducing the composite VOC vapor pressure or VOC content of the cleaning material
used, either by substitution or reformulation, is one pollution prevention measure that is used to
reduce VOC emissions from cleaning operations. However, little information is available
regarding the types of low-VOC or VOC-free cleaning materials that could be used in the
miscellaneous metal product and plastic parts surface coating operations and whether they are
feasible for the broad types of coatings used.
2. Work Practice Procedures
Work practice procedures are commonly used at the miscellaneous metal product and
plastic parts surface coating facilities to reduce VOC emissions from cleaning operations. Such
work practices include the following:
• Cover mixing and storage vessels for VOC-containing cleaning materials, and
cleaning waste materials except when adding, removing, or mixing contents;
• Use closed containers or pipes to store and convey VOC-containing cleaning and
cleaning waste materials;
• Minimize spills of VOC-containing cleaning and cleaning waste materials; and
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• Minimize VOC emissions during cleaning operations.
C. Existing Federal State, and Local Recommendations or Regulations
The following discussion is a summary of five EPA actions, as well as State and local
regulations that address VOC emissions from miscellaneous metal product and plastic parts
coating processes. In addition, Appendices C through F summarize the State and local
provisions for surface coating VOC content limits for metal parts and plastic parts, application
equipment requirements, and cleaning operations.
1. The 1978 CTG for Surface Coating of Miscellaneous Metal Parts and Products
The 1978 CTG recommended limiting VOC emissions for each of the major types of
coatings used by the numerous and varying types of sources performing miscellaneous metal
parts and products surface coating. It was found in developing the CTG that hundreds of small
industrial categories perform surface coating of miscellaneous metal parts and that writing
individual guidelines for each would be unreasonable. Therefore, the CTG attempted to address
the different types of surface coating products that are used at miscellaneous metal part and
products surface coating facilities.
For each major type of coating, the 1978 CTG recommended a daily volume-weighted
average VOC content limit, excluding water and exempt compounds, as applied. The CTG
recommended emission limits, in terms of mass of VOC per volume of coating less water, for the
following coating operation types:
1. Air-dried or forced air-dried coated items: 0.42 kg/1 (3.5 Ibs/gal), based on the use
of a 52 percent solids organic solvent-borne coating;
2. Clear coatings: 0.52 kg/1 (4.3 Ibs/gal), based on the use of a 41 percent solids
organic solvent-borne coating;
3. Parts or products coating involving frequent color changes or large numbers of
colors applied, or the first coat applied to an untreated non-ferrous substrate: 0.36
kg/1 (3.0 Ibs/gal), based on the use of a 59 percent solids organic solvent-borne
coating or an equivalent water-borne coating, or electrodeposited water-borne
coating;
4. Outdoor, harsh environment, or extreme performance coatings: 0.42 kg/1 (3.5
Ibs/gal), based on the use of a 52 percent solids organic solvent-borne coating;
5. Powder coatings: 0.05 kg/1 (0.4 Ibs/gal) based on a coating thickness of 2 mils; and
6. All other coatings not falling under one of the preceding categories: 0.36 kg/1 (3.0
Ibs/gal), based on the use of a 59 percent solids organic solvent-borne coating or an
equivalent water-borne coating, or powder or electrodeposited water-borne coating.
The 1978 CTG assumed that sources could meet the emission limits with the addition of
add-on controls or through the use of coatings that are low in organic solvents. The CTG
assumed either of these approaches to meeting the emission limits would be RACT. The CTG
also recognized that current technology did not provide coatings low in organic solvent as
reasonable replacements for all sources and that some situations existed in which low-polluting
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coatings or add-on controls may never be technologically or economically feasible. The 1978
CTG did not address VOC emissions from cleaning materials.
2. The 1988 NSPS for Surface Coating of Plastic Parts for Business Machines (40 CFR 60
subpart TTT)
The NSPS limits the amount of VOC in coatings that are applied to office equipment,
laboratory machines, and computers. The NSPS applies to coating booths that began
construction, reconstruction, or modification after January 8, 1986. The standard defines the
business machine sector as typewriters (SIC Code 3572), electronic computing devices (SIC
Code 3573), calculating and accounting machines (SIC Code 3574), telephone and telegraph
equipment (SIC Code 3661), office machines (SIC Code 3579), and photocopy machines (SIC
Code 3861).
The NSPS sets VOC content limits for prime coats (1.5 kg/liter coating solids applied),
color coats (1.5 kg/liter coating solids applied), texture coats (2.3 kg/liter coating solids applied),
and touch-up coats (2.3 kg/liter coating solids applied) in any facility in which plastic parts are
coated for use in the manufacturing of business machines. While the standard defines the
affected facility as spray booths, all resulting VOC emissions from the applied coatings (i.e.,
including emissions during flash off and curing) must also be included in calculating a facility's
compliance status.
The standards also take into account the transfer efficiency of the equipment used to
apply the coatings, since they are in units of mass of VOC per volume of coating solids applied
to the actual part.
Add-on control devices can be used as an alternative means of compliance, as determined
on a case-by-case basis by the Administrator. If add-on controls are used, the owner or operator
must demonstrate that volume-weighted average mass of VOC emitted per unit volume of
coating solids applied is within the applicable limit. The NSPS did not address cleaning
operations or materials.
3. The 1994 ACT for Surface Coating of Automotive/Transportation and Business Machine
Plastic Parts
The 1994 ACT provided alternative control technologies available for VOC emissions
from the surface coating of plastic parts in the automotive and other transportation equipment
and business machine industries. The ACT only presented options of alternative control and did
not establish a RACT recommendation.
The ACT stated that the use of lower VOC content coatings (such as waterborne or high-
solids coatings), the use of non-VOC coatings (such as zinc-arc, UV, powder, or vapor cure
coatings), process modifications (such as improvements of spray equipment), or add-on controls
(such as adsorption or incineration) are all available alternative control options. The 1994 ACT
did not address VOC emissions from cleaning materials.
Three control levels were stated in the ACT, two of which (Level 1 and Level 2) were
based on coating reformulation to a lower VOC coating. The third control level (Level 3) was
based on thermal incineration. A fourth control level (Level 4) was identified for red and black
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colors of certain automotive coatings because of the need for higher VOC contents to effectively
disperse the pigments in these colors:1
These technologies were identified in detail in the ACT because of wide availability and
feasibility for the range of coating applications covered by the ACT. Table 1 summarizes control
levels 1 and 2 for coating reformulation. The ACT states that these control levels would achieve
significant VOC emission reductions.
Because the 1988 NSPS limits are expressed in terms of coating solids deposited and the
1994 ACT recommended limits are expressed in terms of VOC per gallon of coating, less water
and exempt solvents, these limits cannot be compared directly for surface coating of business
machine plastic parts without making an assumption for the transfer efficiency of the application
equipment. If we assume a transfer efficiency of 40 percent, then the 1988 NSPS limits for
business machine coating are less stringent than the most stringent control level in the 1994 ACT
for comparable categories of coatings.
Table 1. Reformulation Control Levels for Lower VOC Coatings from 1994 ACT.
(All units are expressed in Ib of VOC per gallon of coating, less water and exempt solvents.)
Category
Control
Level 1
Control
Level 2
Auto Interiors
High-bake Color Coat
High-bake Primer
Low-bake Color Coat
Low-bake Primer
4.3
4.3
5.0
3.5
4.1
3.8
3.2
3.5
Auto Exteriors
Flexible
High-bake Color Coat
High-bake Clear Coat
High-bake Primer
Low-bake Color Coat
Low-bake Clear Coat
Low-bake Primer
Nonflexible
High-bake Color Coat
High-bake Clear Coat
High-bake Primer
Low-bake Color Coat
Low-bake Clear Coat
Low-bake Primer
4.3
3.8
5.0
5.4
4.0
5.5
4.3
3.8
4.0
5.4
4.0
5.5
4.1
3.5
4.5
5.1
3.7
5.5
4.1
3.5
3.0
5.1
3.7
5.5
Automotive/Transportation Specialty Coatings (Control Levels are equal to Baseline VOC)
Group A Coatings (Black and reflective argent coatings, Air bag
cover coatings, Soft coatings, Vacuum metalizing basecoats,
Texture basecoats)
Group B Coatings (Gloss reducers, Vacuum metalizing topcoats,
Texture topcoats)
5.5
6.4
5.5
6.4
See Section 6.0 of the 1994 ACT.
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Table 1. Reformulation Control Levels for Lower VOC Coatings from 1994 ACT.
(All units are expressed in Ib of VOC per gallon of coating, less water and exempt solvents.)
Category
Group C Coatings (Stencil, Adhesion primers, Ink pad, Electrostatic
prep, Resist)
Headlamp Lens Coatings
Control
Level 1
6.8
7.4
Control
Level 2
6.8
7.4
Business Machines
Color Coat
Color Coat/Texture Coat
Primer
EMI/RFI Shielding
3.5
3.5
2.9
4.0
2.3
2.3
1.2
4.0
Business Machine Specialty Coatings (Control Levels are equal to Baseline VOC)
Soft Coatings
Plating Resist
Plating Sensitizers
4.3
5.9
7.1
4.3
5.9
7.1
4.
The 2004 NESHAP for Miscellaneous Metal Parts and Products
The National Emission Standards for Hazardous Air Pollutants for Miscellaneous Metal
Parts and Products (Surface Coating), 40 CFR Part 63, subpart MMMM was promulgated
January 2, 2004. The NESHAP applies to "major" sources of HAP emissions, which are
stationary sources that emit or have the potential to emit 10 tons per year or more of any single
HAP, or 25 tons per year or more of any combination of HAP.
The NESHAP applies to sources performing miscellaneous metal parts coating except
those covered by other major source surface coating NESHAP (e.g., metal parts of wood
furniture, large appliances, metal furniture, metal parts of wood building products, aerospace
vehicles and components, web coating, coil coating, ships and boats, auto and light duty truck
plants). The NESHAP regulates coating application, surface and equipment cleaning, and
depainting at affected sources, but does not apply to individual coatings used in quantity of less
than 50 gallons (189 liters) per year as long as the total quantity of exempt coatings does not
exceed 250 gallons (946 liters) per year.
The emission limits established by the NESHAP are expressed in terms of kilograms of
HAP per liter coating solids (kg/1) and include the following:
• General use coatings: 0.23 kg/1 (1.9 Ib/gal) (new sources) and 0.31kg/l (2.3 Ib/gal)
(existing sources);
• High-performance coatings: 3.3 kg/1 (27.5 Ib/gal) (for both new and existing sources);
• Magnet wire coatings: 0.05 kg/1 (0.44 Ib/gal) (new sources) and 0.12 kg/1 (1.0 Ib/gal)
(existing sources);
• Rubber-to-metal bonding of 0.81kg/l (6.8 Ib/gal) (new sources) and 4.5 kg/1 (37.7
Ib/gal) (existing sources); and
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• Extreme performance fluoropolymer coatings: 1.5 kg/1 (12.4 Ib/gal) (for both new and
existing sources).
In this NESHAP, coatings that do not meet one of the specialty category definitions are
subject to the general use emission limitations.
Compliance with the 2003 NESHAP can be demonstrated by any of three methods: (1) a
compliant coatings option, where all coatings used have organic HAP contents that individually
meet the organic HAP emission limit, and all thinners and cleaning materials contain no organic
HAP; (2) an emission rate without add-on controls option, where the monthly average organic
HAP emission rate is equal to or less than the organic HAP emission limit; or (3) emission rate
with add-on controls option, where the monthly emission rate, taking into account the emission
reduction achieved through the use of one or more control devices, is equal to or less than the
organic HAP emission limit.
Since this NESHAP is based on coating reformulation to lower the HAP content, it is not
known how compliance has affected VOC emissions, if at all, since HAP could be replaced with
non-HAP VOC in many coatings.
5. The 2004 NESHAP for Plastic Parts and Products
The National Emission Standards for Hazardous Air Pollutants for Plastic Parts and
Products (Surface Coating), 40 CFR Part 63, subpart PPP was promulgated April 19, 2004. The
NESHAP also applies to "major" sources of HAP emissions.
The NESHAP applies to sources performing plastic part and product surface coating,
except those covered by other major source surface coating NESHAP (e.g., plastic parts of wood
furniture, large appliances, plastic parts of metal furniture, plastic parts of wood building
products, aerospace vehicles and components, web coating, coil coating, ships and boats, auto
and light duty truck plants). The NESHAP regulates coating, cleaning, and depainting at
affected sources, but does not apply to sources that use less than 100 gallons (378 liters) per year
of HAP-containing coatings.
The emission limits established by the NESHAP are in terms of kilograms of HAP per kg
coating solids (kg/kg) and include the following:
• General use coatings: 0.16 kg/kg (0.16 Ib/lb) (new sources and existing sources);
• Automotive lamp coatings: 0.26 kg/kg (0.26 Ib/lb) (new sources) and 0.45 kg/kg
(0.45 Ib/lb) (existing sources);
• Thermoplastic olefin coatings: 0.22 kg/kg (0.22 Ib/lb) (new sources) and 0.26kg/kg
(0.26 Ib/lb) (existing sources); and
• Assembled on-road vehicle coatings: 1.34 kg/kg (1.34 Ib/lb) (for both new and
existing sources).
In this NESHAP, coatings that do not meet one of the specialty category definitions are
subject to the general use emission limitations.
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Compliance with the 2004 plastic Parts NESHAP can be demonstrated by any of same
three methods as with the 2004 Metal Parts NESHAP: (1) compliant coatings option; (2)
emission rate without add-on controls option; or (3) emission rate with add-on controls option.
Since this NESHAP is based on coating reformulation to lower the HAP content, it is not known
how compliance has affected VOC emissions, if at all, since HAP could be replaced with non-
HAP VOC in many coatings.
6. Existing State and Local VOC Requirements
In addition to the EPA actions described above, the EPA has identified many State and
local regulations that control VOC emissions from miscellaneous metal product and plastic part
surface coating operations.
At least 37 States and local jurisdictions have regulations that control VOC emissions
from miscellaneous metal parts surface coating. The vast majority of these States (except
California) have incorporated the categories and corresponding VOC emission limits
recommended by the 1978 CTG for metal parts surface coating. However, 19 States have
included additional categories and limits, usually to specifically address high performance
architectural coatings, steel pail and drum coatings, or heavy duty truck coating. Several States
(at least 11) incorporated an emission limit for the coating of steel pail or drum interiors. Two
States incorporate an emission limit for high performance architectural aluminum coatings, while
two other states incorporate provisions for minimum transfer efficiency of spray applied
coatings. Appendix C summarizes the applicable State and local metal parts surface coating
rules.
To aid regional air districts in developing emission limits to meet or maintain ambient air
quality standards, the California Air Resources Board (ARE) developed its own recommendation
of RACT in 1992. Compared to the 1978 CTG, which recommended separate limits for five
categories, the 1992 ARE guidance has specific limits for more categories of specialty coatings
that cannot meet the more stringent "general use" category limits. However, overall, the
recommended VOC content limits in the 1992 ARB guidance are more stringent than the
recommended limits in the 1978 CTG.
These RACT recommendations were the basis for emission limits established by
individual California Air Quality Management Districts. A total of 15 air pollution control
Districts in California have established rules for metal part surface coating operations, but they
do not all include the same categories and limits as the ARB RACT guidance.
Among these Districts, the South Coast Air Quality Management District (SCAQMD)
has adopted the most stringent VOC content limits for 21 categories of metal parts coatings in
SCAQMD Rule 1107 (South Coast Rule 1107). All of these limits, except the limits for four
categories of air dried coatings (general use one component coatings, extreme high gloss, and
one and two component high performance architectural component coatings), have been in place
since the rule's 1996 amendment or earlier. Since the 1996 amendment, SCAQMD has further
tightened the limits for these four categories of air dried coatings through subsequent
amendments to Rule 1107.
In addition to setting VOC content limits, South Coast Rule 1107 requires that, if add-on
controls are used, the control system must capture at least 90 percent of the VOC emissions.
Rule 1107 further requires that the captured VOC emissions be reduced by at least 95 percent or
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the VOC concentration at the outlet of the air pollution control device be no more than 5 parts
per million (ppm) VOC by volume calculated as carbon with no dilution, and that the control
system achieves at least 90 percent capture. The add-on control requirements described above
have been in place since the rule's 1996 amendment or earlier.
In addition to South Coast Rule 1107, SCAQMD has also issued Rule 1125 to regulate
VOC emissions from steel pail and drum coating operations, whose coatings are included in the
miscellaneous metal products coatings category listed under 183(e). Rule 1125 establishes limits
for interior and exterior coatings used on new and reconditioned drums and pails. At least four
other Districts have specific limits for these surface coating operations in either their metal part
surface coating rules or rules for metal container coating operations.
At least 13 States have emission limits for coating lines that are specifically for plastic
parts and products. Seven of the State rules (Delaware, Illinois, Massachusetts, Michigan, New
Hampshire, Tennessee, and Wisconsin) and the one proposed rule (Ohio) are specifically for
automotive and business machine plastic parts and follow the categories and control levels
included in the 1994 ACT for these categories. The other six states (Arizona, California,
Indiana, Maryland, Missouri, and New York) have not adopted the control levels provided in the
1994 ACT. Instead, they have adopted limits for only one or two categories of plastic parts
coatings. In some cases, these limits apply to all plastic parts coatings and are not limited to only
automotive or business machine plastic parts. These limits are generally not as stringent as the
most stringent control level in the 1994 ACT for comparable coating categories.
Three California Air Quality Management Districts, including the South Coast AQMD,
have rules containing emission limits for coating plastic parts. Appendix D summarizes the
applicable State and local plastic part surface coating rules, both for general plastic parts coating
and for automotive/transportation and business machine plastic parts.
South Coast Rule 1145 (Plastic, Rubber, Leather, And Glass Coatings) has VOC content
limits for 11 categories of coatings that can be applied to plastics. All of these limits, except the
limits for four categories (general use one and two component coatings, electrical dissipating and
shock free coatings, and optical coatings), have been in place since the rule's 1997 amendment
or earlier. Since the 1997 amendment, SCAQMD has further tightened the limits for the four
categories identified above through subsequent amendments to Rule 1145.
In addition to setting VOC content limits, South Coast Rule 1145 requires that, if add-on
controls are used the control system must capture at least 90 percent of the VOC emissions. Rule
1145 further requires that the captured VOC emissions be reduced by at least 95 percent or the
VOC concentration at the outlet of the air pollution control device be no more than 5 parts per
million (ppm) VOC by volume calculated as carbon with no dilution, and that the control system
achieves at least 90 percent capture. The add-on control requirements described above have
been in place since 1997 or earlier.
As mentioned above in section IV, miscellaneous metal products and plastic parts
coatings include coatings that are applied to the metal and plastic components of a wide range of
products, including pleasure craft (recreational boats). Pleasure craft are often made of plastic
(e.g., fiberglass) or metal, usually aluminum. Pleasure craft surface coating is performed either
as part of the manufacturing process or during maintenance and repair. California is the only
State in which specific VOC limits address pleasure craft surface coating. Six California Air
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Pollution Control Districts have surface coating rules that address pleasure craft surface coating.
Three of these Districts (Bay Area, Mojave Desert, and San Diego) have rules for marine surface
coating, which includes pleasure craft surface coating. The Bay Area rule applies to surface
coating of all vessels, but only to coatings sold in containers greater than one gallon, and does
not include specific limits for coatings applied to pleasure craft. The other two Districts (Mojave
Desert and San Diego) have rules with specific limits for coatings applied to pleasure craft.
Three California Districts (Antelope Valley, Ventura County, and South Coast) have
rules that specifically address pleasure craft surface coating as a separate category from
miscellaneous metal parts coating, plastic parts coating, and marine coating. These three rules
have separate definitions and VOC limits for eight categories of pleasure craft coatings used on
either metal or plastic substrates. The three District rules have nearly the same categories and
VOC limits, but the South Coast limits are the most stringent among the three where there are
differences in VOC limits. Appendix E summarizes the California Air District rules for pleasure
craft surface coating and marine coatings.
Several States (Arizona, California, Massachusetts, and New Hampshire) have
requirements to use specific types of high-efficiency coating application methods to further
reduce VOC emissions. In California, ten of the Air Quality Management Districts require the
use of high efficiency application methods as part of either metal part or plastic part surface
coating rules. These high efficiency methods include the following types of application
equipment: electrostatic application; flow coating; dip coating; roll coating; hand application;
high-volume, low-pressure (HVLP) spray; or an alternative method that is demonstrated to be
capable of achieving a transfer efficiency equal to or better than HVLP spray. Three other states
(Arizona, Massachusetts, and New Hampshire) have similar requirements for either metal or
plastic part surface coating operations. Appendix F summarizes the State and local requirements
that specify high-efficiency application methods.
California and at least 11 other States have requirements to reduce VOC emissions from
cleaning materials used in metal and plastic part surface coating operations for either surface
preparation or spray gun cleaning. At least 12 Districts in California regulate the VOC content
of cleaning materials used in metal or plastic part surface coating operations. These regulations
are aimed at reducing VOC emissions from cleaning materials by combining work practice and
equipment standards with limits on the VOC content, boiling point, or composite vapor pressure
of the solvent being used.
Some District rules allow the use of add-on controls as an alternative to the VOC
content/boiling point/vapor pressure limits for cleaning materials. As mentioned above, several
Districts have also established work practice and equipment standards to minimize VOC solvent
emissions. These standards include, for example, using closed containers for storing solvent and
solvent containing wipes and rags, using enclosed and automated spray gun washing equipment,
and prohibiting atomized spraying of solvent during spray gun cleaning. However, the cleaning
material VOC content/boiling point/vapor pressure limits, overall control efficiency
requirements, and work practices vary by District.
At least 12 States have cleaning material work practice requirements that apply to
miscellaneous metal or plastic part surface coating operations for either surface preparation or
spray gun cleaning. Of these, only one (Massachusetts) limits the VOC content of solvents used
for surface preparation, and no State limits the VOC content or vapor pressure of solvents used
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specifically for spray gun cleaning. Instead, the States have established equipment standards and
work practices, such as the use of enclosed spray gun washers and requirements to store solvents
and solvent containing rags and wipes in closed containers. However, for metal part surface
coating operations, seven States require that VOC from equipment cleaning must be considered
in determining compliance with the emission limits, unless the solvent is directed into containers
that prevent evaporation into the atmosphere. Appendix G summarizes the State and local
requirements for cleaning solvents used for surface preparation and spray gun cleaning.
VI. Recommended Control Options
Based on a review of the previous Federal actions and the current State and local
requirements discussed above, we are recommending three options for controlling the VOC
emissions from the coatings used by miscellaneous metal product and plastic part surface coating
facilities. We are also recommending work practices to further reduce VOC emissions from
coatings as well as to minimize emissions from cleaning materials used in miscellaneous metal
product and plastic part surface coating processes.
To control VOC emissions from miscellaneous metal and plastic part surface coatings,
we are recommending the following three options: (1) VOC content limits for each coating
category based on the use of low-VOC content coatings and specified application methods to
achieve good transfer efficiency; (2) equivalent VOC emission rate limits based on the use of a
combination of low-VOC coatings, specified application methods, and add-on controls; or (3) an
overall VOC control efficiency of 90 percent for facilities that choose to use add-on controls
instead of low-VOC content coatings and specified application methods.
We are recommending that states provide all three options described above in their
RACT rules for miscellaneous metal products and plastic parts coatings. That is, we are
recommending that States not include just one option and exclude the other two. All three
options are recommended to be included, together, so as to provide flexibility to facilities as they
reduce their VOC emissions in response to State RACT determinations.
The low-VOC coatings recommendation (Option 1) consists of VOC content limits in
terms of mass of VOC per volume of coating, as applied, excluding water and exempt
compounds, and the use of specified application methods.
The equivalent emission rate limit recommendation (Option 2) consists of emission rate
limits in terms of mass of VOC emitted per volume of coating solids, as applied, and the use of
specific application methods. This option is intended only for facilities using a combination of
low-VOC coatings, specific application methods, and add-on control equipment on a coating unit
to meet the recommended limits for mass of VOC emitted per volume of coating solids.
The VOC emission rate limits in Option 2 (VOC per volume solids) were converted from
the VOC content limits in Option 1 using an assumed VOC density of 7.36 Ib/gallon (883
g/liter). The units of VOC per volume solids are used in Option 2 instead of VOC per volume
coating, less water and exempt compounds (as in Option 1), because the former units are more
compatible with the use of an add-on control, which is among the control measures contemplated
under Option 2. As the efficiency of the control device increases, the emission rate, expressed as
VOC per volume solids, decreases in a measurable and predictable manner. The same is not true
for VOC per volume coating, less water and exempt compounds, because these units cannot be
27
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directly related to VOC emissions unless the volume of water and exempt compounds is known
and accounted for in each coating.
In addition, we are recommending the specified use of one or more of the following
coating application methods in conjunction with the use of low-VOC content coatings in options
1 and 2: electrostatic application, HVLP spray, flow coat, roller coat, dip coat (including
electrodeposition), airless spray, air-assisted airless spray, or other coating application methods
capable of achieving a transfer efficiency equivalent to or better than that achieved by HVLP
spraying.
Under option 3, a facility would use an emission capture system and add-on control
device to achieve an overall emission capture and control efficiency of at least 90 percent. The
facility would not have to limit the VOC content of the coating materials, and would not need to
use any particular coating application method.
The first two options are expected to achieve equivalent VOC emission reductions. The
third option provides facilities the flexibility to use a high efficiency add-on control in lieu of
low VOC coatings and specified application methods, especially when the use of high VOC
coatings is necessary or desirable. The third option is expected to achieve an emission reduction
at least as great as the first two options.
We are recommending that all VOC-containing materials (i.e., coatings, thinners, and any
other additives) used by each miscellaneous metal and plastic part surface coating unit should be
included when determining the coating unit's emission rate.
For Option 1, we are recommending the VOC content limits and application method, as
well as the exemptions, in the following State regulations:
South Coast AQMD's Rule 1106.1 (as amended February 12, 1999) for Pleasure
Craft Coating Operations.
South Coast AQMD' s Rule 1107 (March 6, 1996) for Coating of Metal Parts and
Products.
South Coast AQMD's Rule 1125 (as amended January 13, 1995) for Metal
Container, Closure, And Coil Coating.
South Coast AQMD's Rule 1145 (February 14, 1997) for Plastic, Rubber, Leather,
And Glass Coatings.
• Michigan Rule 336.1632 (as amended April 28, 1993) for Emission of Volatile
Organic Compounds From Existing Automobile, Truck, And Business Machine
Plastic Part Coating Lines.
The limits in SCAQMD Rule 1125 and Michigan Rule 336.1632 have been in place since
the amendments noted above for these rules. As mentioned above, SCAQMD has changed the
limits for several categories in SCAQMD Rules 1107 and 1145 in subsequent amendments to
these two rules. These new limits, however, have not been in place very long. We do not have
information regarding the cost of implementing these new limits. We could not conclude that
these limits are technologically and economically feasible and, therefore, reflect RACT for all
affected facilities in ozone nonattainment areas nationwide. We are, therefore, not
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recommending the limits in SCAQMD Rules 1107 and 1145 promulgated subsequent to the
amendments to these rules noted above.
The recommended limits in the SCAQMD rules described above are more stringent than
the limits provided in other existing Federal, State, and local actions limiting VOC emissions
from these coating categories. Because of the large size of the SCAQMD and the number of
regulated sources, the facilities subject to these four SCAQMD rules are considered to be
representative of the type of sources located in other parts of the country. The recommended
limits from Rules 1107, 1125, and 1145 have been or were in effect a long time (i.e., since 1997
or earlier). The limits in Rule 1106.1, except for non-aluminum antifoulant coatings, have been
in effect since 1994, and the limit for non-aluminum antifoulant coatings has been in effect since
2001. Therefore, we believe that these limits are technically and economically feasible for
sources in other parts of the country and, therefore, have included them as our recommendations
in the final CTG.
The Michigan rule is based on the control levels provided in the 1994 ACT, which is
more stringent than the 1988 NSPS for comparable coating categories for business machines.
Michigan has a substantial number of sources subject to Rule 336.1632, and these sources'
compliance with Michigan Rule 336.1632 shows that the VOC content limits in Michigan Rule
336.1632 are technically and economically feasible. The limits in the Michigan rule have been
in effect since 1993. Therefore, we recommend in the final CTG the VOC content limits
contained in Michigan Rule 336.1632.
Specifically, for metal parts surface coatings except high performance architectural
coatings, our recommended Option 1 includes the VOC content limits in South Coast Rule 1107
(Coating of Metal Parts and Products) (March 6, 1996). As in that rule, we recommend separate
limits for baked coatings and air-dried coatings for 21 categories of coatings used on metal parts.
Option 1 also includes the four limits for drum, pail and lid coating in South Coast Rule 1125,
(Metal Container, Closure, and Coil Coating Operations). With respect to high performance
architectural coatings, we are recommending a VOC limit of 0.74 kg VOC/1 (6.2 Ib/gal) coating,
less water and exempt compounds. Liquid high performance architectural coatings currently
available and in use today contain significantly more than the 3.5 Ib VOC/gallon limit we
recommended in the draft CTG. The cost of converting to powder coatings or installing and
operating add-on controls to meet a limit of 3.5 Ib VOC/gallon generally would be unreasonable
compared to the emission reduction that would be achieved. The 6.2 Ib VOC/gallon limit
recommended in this final CTG can be achieved by the liquid high performance architectural
coatings currently available and in use today. Further reformulation to reduce VOC below the
recommended 6.2 Ib VOC/gallon limit may not be technically feasible. In light of all of the
above, we believe that the 6.2 Ib VOC/gallon limit represents RACT for high performance
architectural coatings.
For surface coating of plastic parts that are not part of automotive/transportation
equipment or business machines, Option 1 includes the VOC content limits in South Coast Rule
1145 (Plastic, Rubber, Leather, and Glass coatings) for 11 categories of plastic parts coatings
(February 14, 1997). These limits became effective January 1, 1998. As mentioned above, all
but four of these limits are still in place.
For surface coatings for automotive plastic parts and business machine plastic parts,
Option 1 includes the VOC content limits in Michigan Rule 336.1632 (Emission of Volatile
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Organic Compounds from Existing Automobile, Truck, and Business Machine Plastic Part
Coating Lines). We also recommend applying these limits to surface coating of plastic parts on
fully assembled motor vehicles, as well as separate parts. These include, for example, the
surface coating of fiberglass bodies on assembled recreational vehicles (RVs).
For surface coating of pleasure craft (recreational boats), Option 1 includes the VOC
content limits in South Coast Rule 1106.1 (Pleasure Craft Surface Coating) for the eight
categories of coatings that could be used on metal or plastic substrates. These separate
categories and limits are being included in our recommendations to recognize the unique
performance requirements of pleasure craft coatings, such as their suitability for use in marine
environments, durability, and high gloss.
We are also recommending under Option 1 specific VOC content limits for certain motor
vehicle materials used at facilities that are not automobile or light-duty truck assembly coating
facilities. Since these motor vehicle materials typically are low use materials and are often used
in areas of these facilities that would expensive to control with add-on controls (e.g., used in
open assembly areas), we are only recommending VOC content limits for these materials
(Option 1), and are not recommending VOC emission rate limits (Option 2) or an overall 90
percent control efficiency (Option 3).
We recommend that EPA Method 24 in Appendix A-7 of 40 CFR part 60, be used to
determine the VOC content of coating materials used at miscellaneous metal and plastic part
coating facilities. In addition, we recommend that manufacturer's formulation data be accepted
as an alternative to EPA Method 24. If there is a disagreement between manufacturer's
formulation data and the results of a subsequent test, we recommend that States use the test
method results unless the facility can make a demonstration to the States' satisfaction that the
manufacturer's formulation data are correct.
Consistent with the State rules which are the basis for the recommended VOC limits, we
are recommending that the recommended VOC limits and application methods not apply to
certain types of coatings and coating operations. For all coating operations, we are
recommending that the recommended VOC limits and application methods not apply to aerosol
coating products or powder coatings. Aerosol coatings are a separate category under Section
183(e), and powder coatings are an inherently low-VOC alternative to many liquid coatings.
For metal parts coatings, we are recommending that only the recommended work
practices, but not the recommended VOC limits and application methods, apply to the
following types of coatings and coating operations:
• Stencil coatings;
• Safety-indicating coatings;
• Solid-film lubricants;
• Electric-insulating and thermal-conducting coatings;
VOC limits for wood coatings (teak primers and clear wood finishes) that are included in South
Coast Rule 1106.1 are not included in these recommendations because wood surface coating is
not part of this source category under Section 183(e).
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• Magnetic data storage disk coatings; and
• Plastic extruded onto metal parts to form a coating.
For metal parts coatings, we also recommend that the recommended application methods
not apply to touch-up coatings, repair coatings, and textured finishes, but we recommend that the
recommended VOC limits and work practices apply to these coatings and coating operations.
For plastic parts coatings, we are recommending that the recommended application
methods and work practices, but not the recommended VOC limits, apply to the following types
of coatings and coating operations:
• Touch-up and repair coatings;
• Stencil coatings applied on clear or transparent substrates;
• Clear or translucent coatings;
• Coatings applied at a paint manufacturing facility while conducting performance
tests on the coatings;
• Any individual coating category used in volumes less than 50 gallons in any one
year, if substitute compliant coatings are not available, provided that the total usage
of all such coatings does not exceed 200 gallons per year, per facility;
• Reflective coating applied to highway cones;
• Mask coatings that are less than 0.5 millimeter thick (dried) and the area coated is
less than 25 square inches;
• EMI/RFI shielding coatings; and
• Heparin-benzalkonium chloride (FffiAC)-containing coatings applied to medical
devices, provided that the total usage of all such coatings does not exceed 100
gallons per year, per facility.
For plastic parts coatings, we also recommend that the recommended application methods
not apply to airbrush operations using 5 gallons or less per year of coating, but we recommend
that the VOC limits and work practices apply to these operations.
For automotive/transportation and business machine plastic part coating, we are
recommending that the recommended application methods and work practices , but not the
recommended VOC limits, apply to the following types of coatings and operations:
• Texture Coatings;
• Vacuum Metalizing Coatings;
• Gloss Reducers;
• Texture Topcoats;
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• Adhesion Primers;
• Electrostatic preparation coatings;
• Resist coatings; and
• Stencil Coatings.
For pleasure craft surface coating operations, we recommend that the recommended
application methods not apply to extreme high gloss coatings, but we recommend that the VOC
limits and work practices do apply to these coatings.
The VOC content limits can be met by averaging the VOC content of materials used on a
single surface coating unit each day (i.e., daily within-coating unit averaging). We do not
recommend the use of cross-coating unit averaging (i.e., averaging across multiple coating units)
to meet the VOC content limits. However, we have previously provided guidance on cross-line
averaging.1 The guidance is directed to State and local agencies that elect to adopt a
discretionary economic incentive program (EIP) and includes guidance on the use of cross-line
averaging.
For cleaning materials, we are recommending work practices for use with all three of
the control options to reduce VOC emissions. We are not recommending the application of
add-on controls in conjunction with these work practices. The use of add-on controls to
reduce emissions from cleaning operations at miscellaneous metal product and plastic part
surface coating facilities would be a costly option because the area to be controlled is quite large
and a large volume of air would be captured and directed to a control device. We are also not
recommending the use of a VOC content or VOC composite vapor pressure limit for cleaning
materials. We do not have information available regarding current VOC content or VOC
composite vapor pressure usage to determine a RACT limit(s) for cleaning materials used in
these numerous and various miscellaneous metal product and plastic part surface coating
operations.
We estimate that our recommendations for coatings and cleaning materials will reduce
VOC emissions from miscellaneous metal and plastic part coatings by about 35 percent (a
reduction of 7,034 Mg/yr (7,738 tpy) of VOC) from the nonattainment area facilities above the
recommended 6.8 kg/day (15 Ib/day) threshold. In our analysis of the impacts of the
recommended level of control, we have assumed that all facilities will choose to utilize the low-
VOC coating materials option. We made this assumption for two reasons. First, we believe
that low-VOC coating materials are already widely available at a cost that is not significantly
greater than the cost of coating materials with higher VOC contents. Secondly, the use of add-
on controls to reduce emissions from typical spray coating operations would be a more costly
option.
The following discussion summarizes our specific recommendations for coating
operations and cleaning materials used in miscellaneous metal product and plastic part
surface coating operations.
1 Improving Air Quality with Economic Incentive Programs. U.S. Environmental Protection Agency.
Research Triangle Park, NC. EPA-452/R-01-001. January 2001.
32
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A. Recommended Option 1 for Reducing Coating Emissions: VOC Content Limits Based on
Low-VOC Coatings
We are recommending separate sets of emission limits for metal parts coatings, plastic
parts coatings, automotive/transportation and business machine plastic parts, and pleasure craft
coatings. For the metal parts coatings, we are recommending separate emission limits for baked
and air-dried coatings. Provided in the following five tables are the recommended emission
limits expressed in terms of mass of VOC per volume of coating (excluding water and exempt
compounds, as applied).
Table 2. Metal Parts and Products VOC Content Limits
Coating Category
General One Component
General Multi Component
Camouflage
Electric-Insulating Varnish
Etching Filler
Extreme High-Gloss
Extreme Performance
Heat-Resistant
High Performance Architectural
High Temperature
Metallic
Military Specification
Mold-Seal
Pan Backing
Prefabricated Architectural Multi-
Component
Prefabricated Architectural One-
Component
Pretreatment Coatings
Repair and Touch Up
Silicone Release
Solar-Absorbent
Vacuum-Metalizing
Drum Coating, New, Exterior
Drum Coating, New, Interior
Drum Coating, Reconditioned, Exterior
Drum Coating, Reconditioned, Interior
Air Dried
kg VOC/1
coating
0.34
0.34
0.42
0.42
0.42
0.42
0.42
0.42
0.74
0.42
0.42
0.34
0.42
0.42
0.42
0.42
0.42
0.42
0.42
0.42
0.42
0.34
0.42
0.42
0.50
Ib VOC/gal
coating
2.8
2.8
3.5
3.5
3.5
3.5
3.5
3.5
6.2
3.5
3.5
2.8
3.5
3.5
3.5
3.5
3.5
3.5
3.5
3.5
3.5
2.8
3.5
3.5
4.2
Baked
kg VOC/1
coating
0.28
0.28
0.42
0.42
0.42
0.36
0.36
0.36
0.74
0.42
0.42
0.28
0.42
0.42
0.28
0.28
0.42
0.36
0.42
0.36
0.42
0.34
0.42
0.42
0.50
Ib VOC/gal
coating
2.3
2.3
3.5
3.5
3.5
3.0
3.0
3.0
6.2
3.5
3.5
2.3
3.5
3.5
2.3
2.3
3.5
3.0
3.5
3.0
3.5
2.8
3.5
3.5
4.2
33
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Table 3. Plastic Parts And Products VOC Content Limits
Coating Category
General One Component
General Multi Component
Electric Dissipating Coatings and Shock-Free Coatings
Extreme Performance
Metallic
Military Specification
Mold-Seal
Multi-colored Coatings
Optical Coatings
Vacuum-Metalizing
kg VOC/liter
coating
0.28
0.42
0.80
0.42
(2-pack coatings)
0.42
0.34 (1 pack)
0.42 (2 pack)
0.76
0.68
0.80
0.80
Ibs VOC/gal
coating
2.3
3.5
6.7
3.5
(2-pack coatings)
3.5
2.8 (1 pack)
3.5 (2 pack)
6.3
5.7
6.7
6.7
Table 4. Automotive/Transportation and Business Machine Plastic Parts VOC Content
Limits
Coating Category
kg VOC/liter coating
Ibs VOC/gal coating
Automotive/Transportation Coatings1
I. High Bake Coatings - Interior and Exterior Parts
Flexible Primer
Non-flexible Primer
Base Coats
Clear Coat
Non-basecoat/clear coat
0.54
0.42
0.52
0.48
0.52
4.5
3.5
4.3
4.0
4.3
II. Low Bake/Air Dried Coatings - Exterior Parts
Primers
Basecoat
Clearcoats:
Non-basecoat/clearcoat
III. Low Bake/Air Dried Coatings -
Interior Parts
IV. Touchup and Repair Coatings
0.58
0.60
0.54
0.60
0.60
0.62
4.8
5.0
4.5
5.0
5.0
5.2
Business Machine Coatings
I. Primers
II. Topcoat
III. Texture Coat
IV. Fog Coat
V. Touchup and repair
0.35
0.35
0.35
0.26
0.35
2.9
2.9
2.9
2.2
2.9
1 For red, yellow, and black automotive coatings, except touch up and repair coatings, the recommended
limit is determined by multiplying the appropriate limit in this table by 1.15.
34
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Table 5. Pleasure Craft Surface Coating VOC Content Limits
Coating Category
Extreme High Gloss Topcoat
High Gloss Topcoat
Pretreatment Wash Primers
Finish Primer/Surfacer
High Build Primer Surfacer
Aluminum Substrate Antifoulant Coating
Other Substrate Antifoulant Coating
All other pleasure craft surface coatings for metal
or plastic
kg VOC/liter
coating
0.49
0.42
0.78
0.42
0.34
0.56
0.33
0.42
Ibs VOC/gal
coating
4.1
3.5
6.5
3.5
2.8
4.7
2.8
3.5
Table 6. Motor Vehicle Materials VOC Content Limits
Coating Category
Motor vehicle cavity wax
Motor vehicle sealer
Motor vehicle deadener
Motor vehicle gasket/gasket sealing material
Motor vehicle underbody coating
Motor vehicle trunk interior coating
Motor vehicle bedliner
Motor vehicle lubricating wax/compound
kg VOC/liter
coating
0.65
0.65
0.65
0.20
0.65
0.65
0.20
0.70
Ibs VOC/gal
coating
5.4
5.4
5.4
1.7
5.4
5.4
1.7
5.8
B. Recommended Option 2 for Reducing Coating VOC Emissions: Emission Rate Limits
Based on Low-VOC Coatings and Add-on Controls - VOC per Volume Solids
The recommended emission limits can also be expressed in terms of mass of VOC
per volume of coating solids, as applied. This recommendation is intended for facilities that use
a combination of low-VOC coatings and add-on control equipment on a coating unit. Using an
assumed VOC density of 7.36 pounds per gallon, the equivalent limits in terms of mass of VOC
per volume of solids, as applied, are provided in the following three tables. As noted earlier, for
the motor vehicle materials listed in Table 6 under Option 1, above, we are not recommending
alternative emission rate limits (VOC per volume solids).
35
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Table 7. Metal Parts and Products VOC Emission Rate Limits (VOC per Volume
Solids)
Coating Category
General One Component
General Multi Component
Camouflage
Electric-Insulating Varnish
Etching Filler
Extreme High-Gloss
Extreme Performance
Heat-Resistant
High Performance Architectural
High Temperature
Metallic
Military Specification
Mold-Seal
Pan Backing
Prefabricated Architectural Multi-
Component
Prefabricated Architectural One-
Component
Pretreatment Coatings
Silicone Release
Solar-Absorbent
Vacuum-Metalizing
Drum Coating, New, Exterior
Drum Coating, New, Interior
Drum Coating, Reconditioned, Exterior
Drum Coating, Reconditioned, Interior
Air Dried
kg VOC/1
solids
0.54
0.54
0.80
0.80
0.80
0.80
0.80
0.80
4.56
0.80
0.80
0.54
0.80
0.80
0.80
0.80
0.80
0.80
0.80
0.80
0.54
0.80
0.80
1.17
Ib VOC/gal
solids
4.52
4.52
6.67
6.67
6.67
6.67
6.67
6.67
38.0
6.67
6.67
4.52
6.67
6.67
6.67
6.67
6.67
6.67
6.67
6.67
4.52
6.67
6.67
9.78
Baked
Kg VOC/1
solids
0.40
0.40
0.80
0.80
0.80
0.61
0.61
0.61
4.56
0.80
0.80
0.40
0.80
0.80
0.40
0.40
0.80
0.80
0.61
0.80
0.54
0.80
0.80
1.17
Ib VOC/gal
solids
3.35
3.35
6.67
6.67
6.67
5.06
5.06
5.06
38.0
6.67
6.67
3.35
6.67
6.67
3.35
3.35
6.67
6.67
5.06
6.67
4.52
6.67
6.67
9.78
36
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Table 8. Plastic Parts And Products VOC Emission Rate Limits (VOC per Volume
Solids)
Coating Category
General One Component
General Multi Component
Electric Dissipating Coatings and Shock-Free Coatings
Extreme Performance
Metallic
Military Specification
Mold-Seal
Multi-colored Coatings
Optical Coatings
Vacuum-Metalizing
kg VOC/liter solids
0.40
0.80
8.96
0.80
(2-pack coatings)
0.80
0.54 (1 pack)
0.80 (2 pack)
5.24
3.04
8.96
8.96
Ibs VOC/gal solids
3.35
6.67
74.7
6.67
(2-pack coatings)
6.67
4.52 (1 pack)
6.67 (2 pack)
43.7
25.3
74.7
74.7
Table 9. Automotive/Transportation and Business Machine Plastic Parts VOC
Emission Rate Limits
(VOC per Volume Solids)
Coating Category
kg VOC/liter solids
Ibs VOC/gal solids
Automotive/Transportation Coatings1
I. High Bake Coatings - Interior and Exterior Parts
Flexible Primer
Non-flexible Primer
Base Coats
Clear Coat
Non-basecoat/clear coat
1.39
0.80
1.24
1.05
1.24
11.58
6.67
10.34
8.76
10.34
II. Low Bake/ Air Dried Coatings - Exterior Parts
Primers
Basecoat
Clearcoats:
Non-basecoat/clearcoat
III. Low Bake/ Air Dried Coatings -
Interior Parts
IV. Touchup and Repair Coatings
1.66
1.87
1.39
1.87
1.87
2.13
13.80
15.59
11.58
15.59
15.59
17.72
Business Machine Coatings
I. Primers
II. Topcoat
III. Texture Coat
IV. Fog Coat
V. Touchup and repair
0.57
0.57
0.57
0.38
0.57
4.80
4.80
4.80
3.14
4.80
1 For red, yellow, and black automotive coatings, except touch up and repair coatings, the recommended
limit is determined by multiplying the appropriate limit in this table by 1.15.
37
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Table 10. Pleasure Craft Surface Coating VOC Emission Rate Limits
(VOC per Volume Solids)
Coating Category
Extreme High Gloss Topcoat
High Gloss Topcoat
Pretreatment Wash Primers
Finish Primer/Surfacer
High Build Primer Surfacer
Aluminum Substrate Antifoulant Coating
Other Substrate Antifoulant Coating
All other pleasure craft surface coatings for metal
or plastic
kg VOC/liter
solids
1.10
0.80
6.67
0.80
0.55
1.53
0.53
0.80
Ibs VOC/gal
solids
9.2
6.7
55.6
6.7
4.6
12.8
4.4
6.7
C. Recommended Option 3 for Reducing Coating VOC Emissions: Add-on Controls In Lieu
of Low-VOC Coatings and Specified Application Methods
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 with an overall control efficiency of 90 percent in lieu of using
low-VOC coatings and specified application methods. This control option, like the two options
described above, applies to all coatings and thinners applied to miscellaneous metal and plastic
part components or products, except as described above for motor vehicle materials.
For both recommended options 2 and 3, available add-on devices include, for example,
oxidizers, adsorbers, absorbers, and concentrators. Add-on devices coupled with capture
systems to collect the VOC being released at the affected facilities can achieve an overall control
efficiency of 90 percent.
D. Work Practices for Coating-Related Activities
In addition to the control options above, this CTG recommends work practices to further
reduce VOC emissions from miscellaneous metal and plastic part surface coating-related
activities. Although VOC reductions achieved by implementing the recommended work
practices may not be quantifiable, they are beneficial to the overall goal of reducing VOC
emissions. We recommend work practices for storage, mixing operations, and handling
operations for coatings, thinners, and coating-related waste materials. We recommend these
practices for use with all three of the control options described above.
Specifically, we recommend the following work practices: (1) store all VOC-containing
coatings, thinners, and coating-related waste materials in closed containers; (2) ensure that
mixing and storage containers used for VOC-containing coatings, thinners, and coating-related
waste materials are kept closed at all times except when depositing or removing these materials;
(3) minimize spills of VOC-containing coatings, thinners, and coating-related waste materials;
and (4) convey VOC-containing coatings, thinners, and coating-related waste materials from one
location to another in closed containers or pipes.
38
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E. Work Practices for Cleaning Materials
This CTG recommends work practices to reduce VOC emissions from cleaning materials
used in miscellaneous metal product and plastic part surface coating operations. These cleaning
materials include both materials used to clean surfaces before coating (surface preparation) and
to clean application equipment between coating jobs. Although VOC reductions achieved by
implementing the recommended work practices may not be quantifiable, they are beneficial to
the overall goal of reducing VOC emissions. We recommend work practices for storage, mixing,
and handling operations for cleaning materials. We recommend these practices for use with all
three of the control options described above
Specifically, we recommend that, at a minimum, the work practices include the
following: (1) store all VOC-containing cleaning materials and used shop towels in closed
containers; (2) ensure that storage containers used for VOC-containing cleaning 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 (5) minimize VOC emission from cleaning
of application, storage, mixing, and conveying equipment by ensuring that equipment cleaning is
performed without atomizing the cleaning solvent and all spent solvent is captured in closed
containers.
VII. Cost Effectiveness of Recommended Control Options
We used the 2002 National Emissions Inventory (NET) database to estimate the number
of miscellaneous metal product and plastic part manufacturing facilities. Based on the 2002
NEI, we estimated that there are a total of 3,925 miscellaneous metal product and plastic part
facilities in the U.S. Using the 2004 ozone nonattainment designations, we estimated that a
total of 2,539 of these facilities are in ozone nonattainment areas. Based on the NEI VOC
emissions data, 1,269 of the 2,539 facilities in ozone nonattainment areas emitted at or above
the 6.8 kg/day (15 Ib/day) recommended VOC emissions applicability threshold. These 1,269
facilities emitted a total of about 20,098 Mg/yr of VOC (22,108 tpy), or an average of about
15.5 Mg/yr (17.0 tpy) of VOC per facility.
As previously mentioned, the recommendations in this CTG are similar to the South
Coast regulations governing miscellaneous metal product and plastic part surface coating
operations, and Michigan Rule 336.1632. It is not known if the cost effectiveness related to the
implementation of these regulations was estimated during their development, and no cost
estimates could be found. Although the 2004 NESHAP regulate organic HAP, the 2004
NESHAP cost estimates are relevant to this CTG's recommended levels of control because they
are based on the use of similar control measures (i.e., product substitution/reformulation and work
practices) for miscellaneous metal product and plastic part coatings and cleaning materials.
Therefore, cost-effectiveness estimates for the recommended control levels were determined
using the approach used during development of the two 2004 NESHAP.
In our analysis of the impacts of implementing the recommended levels of control in this
CTG, we have assumed that all miscellaneous metal product and plastic part surface coating
facilities will choose to utilize the low-VOC coating materials option. We made this assumption
for two reasons. First, since facilities are meeting equivalent State limits, we believe that low-
VOC coating materials that can meet the recommended control levels in this CTG are already
39
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available at a cost that is not significantly greater than the cost of coating materials with higher
VOC contents. Secondly, the use of add-on controls to reduce emissions from typical spray
coating operations is a more costly option.
According to studies performed for the development of the two 2004 NESHAP for
miscellaneous metal parts and plastic parts surface coating operations, the cost averaged across
all sizes of facilities was estimated to be $10,500 per facility. We believe that this estimate also
represents the cost of implementing this CTG's recommended VOC limits because the NESHAP
were based on similar control measures. That is, the NESHAP were based on reformulating
coatings to lower the HAP content and this CTG is based on reformulating coatings to lower the
VOC content. We assumed that the costs for reformulation under the NESHAP (e.g., costs for
research and development, raw materials, production, and marketing the reformulated products)
would be representative of the costs for reformulation to lower VOC content under the
recommended control options. Therefore, for the 1,296 facilities we identified as emitting more
than 6.8 kg/day (15 Ib/day) in ozone nonattainment areas, we estimate the total annual cost to be
$13.6 million, based on the use of low-VOC content coatings. We estimate that the
recommendations in this CTG will reduce VOC emissions from miscellaneous metal and plastic
part coating by about 35 percent of 20,056 Mg/yr (22,108 tpy). This is a reduction of 7,034
Mg/yr (7,738 tpy of VOC) from the 1,296 facilities. Therefore, we estimate the cost
effectiveness to be $1,933 per Mg ($1,758 per ton) of VOC emission reduction.
We believe that the work practice recommendations in this CTG will result in a net cost
savings. Implementing work practices reduces the amount of cleaning materials used by
reducing the amount that evaporates and is wasted. Similarly, we also believe that the
recommendation to use the specified coating application methods will also result in net cost
savings. Increasing the transfer efficiency of coating application to reduce VOC emissions will
also reduce coating consumption and costs. However, these cost savings cannot be accurately
estimated.
40
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VIII. References
Guideline Series. Control of Volatile Organic Emissions from Existing Stationary Sources -
Volume VI: Surface Coating of Miscellaneous Metal Parts and Products. Publication No. EPA-
450/2-78-015. U.S. Environmental Protection Agency, Research Triangle Park, NC. June 1978.
40 CFR 60 Subpart TTT - Standards of Performance for Industrial Surface Coating: Surface
Coating of Plastic Parts for Business Machines. Applicable to affected facilities for which
construction, modification, or reconstruction begins after January 8, 1986.
Alternative Control Techniques Document: Surface Coating of Automotive/Transportation and
Business Machine Plastic Parts. Publication No. EPA-453/R-94-017. U.S. Environmental
Protection Agency, Research Triangle Park, NC. February 1994.
National Emission Standards for Hazardous Air Pollutants for Miscellaneous Metal Parts and
Products Surface Coating (40 CFR 63, subpart MMMM).
National Emission Standards for Hazardous Air Pollutants for Plastic Parts and Products Surface
Coating (40 CFR 63, subpart PPPP).
State of California Air Resources Board. Determination of Reasonably Available Control
Technology for Metal Parts and Products Coating Operations. ARE Publication No. ARB/SSD-
93-003. December 10, 1992.
South Coast (California) AQMD Rule 1106.1, Pleasure Craft Coating Operations. Amended
February 12, 1999).
South Coast (California) AQMD Rule 1107, Coating of Metal Parts and Products. As amended
March 6, 1996.
South Coast (California) AQMD Rule 1125, Metal Container, Closure, and Coil Coating. As
amended January 13, 1995.
South Coast (California) AQMD Rule 1145, Plastic, Rubber, Leather, And Glass Coatings. As
amended February 14, 1997.
Michigan Rule 336.1632 (rule 632) for Emission of Volatile Organic Compounds From Existing
Automobile, Truck, And Business Machine Plastic Part Coating Lines. Amended April 28, 1993.
41
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Appendix A
Cover Page of 1978 CTG for Surface Coating of Miscellaneous Metal Parts and
Products
-------
Appendix B
Cover Page of 1994 ACT for Surface Coating of Automotive/Transportation and
Business Machine Plastic Parts
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Appendix C
Summary of State and Local Rules for VOC Emissions from Metal Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit
Achieved By
AL Etowah, Mobile, and
Russell Counties
All VOC sources with a potential VOC emission rate of greater
than or equal to 100 tons/year
This rule does not apply to the surface coating of the following
metal parts and products: automobiles and light-duty trucks;
metal cans; flat metal sheets and strips in the form of rolls or
coils; magnet wire for use in electrical machinery; metal
furniture; large appliances; exterior of airplanes; automobile
refinishing; customized coating of automobiles and trucks, if
production is less than 35 vehicles per day; and exterior of
marine vessels.
1. 0.52 kg/L (4.3 Ib/gal) of coating delivered to
a coating applicator that applies clear coatings;
2. 0.42 kg/L (3.5 Ib/gal) of coating delivered to
a coating applicator in a coating application
system that is air dried or forced warm air dried
at temperatures up to 90° C (194° F);
3. 0.42 kg/L (3.5 Ib/gal) of coating delivered to
a coating applicator that applies extreme
performance coatings; and,
4. 0.36 kg/L (3.0 Ib/gal) of coating delivered to
a coating applicator for all other coatings and
coating application systems.
AL
Jefferson County
All VOC sources with a potential VOC emission rate of greater
than or equal to 100 tons/year
This rule shall not apply to the surface coating of the following
metal parts and products: automobiles and light-duty trucks;
metal cans; flat metal sheets and strips in the form of rolls or
coils; magnet wire for use in electrical machinery; metal
furniture; large appliances; exterior of airplanes; automobile
refinishing; customized coating of automobiles and trucks, if
production is less than 35 vehicles per day and if the VOC
emission rate from the customized coating operation does not
exceed 60 tons per year based on an annual rolling average
calculated at the end of each calendar month; exterior of
marine vessels; and fabricated metal parts and products under
the major Standard Industrial Classification Code of Group No.
34 if the VOC emissions rate is less than a potential ten tons
per calendar year (10 TPY) before an add-on VOC control
device.
1. 0.52 kg/L (4.3 Ib/gal) of coating delivered to
a coating applicator that applies clear coatings;
2. 0.42 kg/L (3.5 Ib/gal) of coating delivered to
a coating applicator in a coating application
system that is air dried or forced warm air dried
at temperatures up to 90° C (194° F);
3. 0.42 kg/L (3.5 Ib/gal) of coating delivered to
a coating applicator that applies extreme
performance coatings;
4. 0.36 kg/L (3.0 Ib/gal) of coating delivered to
a coating applicator for all other coatings and
coating application systems, excluding powder
coating systems; and
5. 0.05 kg/L (0.4 Ib/gal) of coating delivered to
a coating applicator for all powder coating
systems.
AZ
Facilities engaged in the surface coating of miscellaneous metal
parts and products
1. 4.3 Ib/gal (0.5 kg/L) of coating delivered to a
coating applicator that applies clear coatings.
2. 3.5 Ib/gal (0.42 kg/L) of coating delivered to a
coating applicator in a coating application system
that is air dried or forced warm air dried at
C-l
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Appendix C
Summary of State and Local Rules for VOC Emissions from Metal Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit
Achieved By
temperatures up to 194°F (90°C).
3.3.5 Ib/gal (0.42 kg/L) of coating delivered to a
coating applicator that applies extreme performance
coatings.
4. 3.0 Ib/gal (0.36 kg/L) of coating delivered to a
coating applicator for all other coatings and
application systems.
AZ
Maricopa County
Other metal parts and products
This rule is not applicable to coatings having a VOC content,
minus exempt compounds, of less than 0.15 Ib VOC/gal
(18g/L) nor to solvents having a VOC content of material less
than 0.15 Ib VOC/gal.
This rule does not apply to the following operations:
Aerospace coating operations; Architectural coating, including
buildings and erected structures; Cleaning: VOC loss from
cleaning or stripping a surface for coating or other purpose is
regulated elsewhere; Marine vessel exterior refmishing;
Polyester coatings applied to polyester composites; Printing
and graphic arts coating; Semiconductor manufacturing;
Coating a highway vehicle or mobile equipment; Wood:
Coating Wood Furniture or Coating Wood Millwork.
Extreme performance coatings are exempt from the VOC limits
when used under certain conditions:
(1) Used on internal combustion engine components that are
normally above 250°F (121°C) during use; or
(2) Used at temperatures above 250°F (121°C) on items that
are both included under SIC (Standard Industrial Classification,
1987) codes 3661, 3663, 3669, 3677, 3678, 3679, or 3769 and
are electronic products in space vehicles and/or are
communications equipment.
The following are exempt from the limits of this rule:
Air-Dried Coating 3.5 Ib/gal
Baked Coating [above 200°F (93°C)] 3.0 Ib/gal
Silicone Release Coating: Baked or Air-Dried 3.5
Ib/gal
C-2
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Appendix C
Summary of State and Local Rules for VOC Emissions from Metal Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit
Achieved By
Coating with an aerosol can; Touch up or repair-coating
operations; Low usage coatings which in aggregate of all
formulations do not exceed 55 gallons (208 liters) per year
facility-wide if the operator updates usage records of these
coatings on each day of their use; A small surface-coating
source (SSCS) as defined in the rule; A Quality Class Q
protective coating that is used on equipment, structures, and/or
components within a containment facility of a nuclear power
plant; A tactical military-equipment coating that is approved in
an MCESD Air Pollution Permit subsequent to a sufficient
demonstration by the user that no compliant substitute exists.
AR
Pulaski County
1. 0.52 kg/1 (4.3 Ib/gal) of coating delivered to
a coating applicator that applies clear coatings;
2. 0.42 kg/1 (3.5 Ib/gal) of coating delivered to
a coating applicator in a coating application
system that utilizes air or forced air dryers;
3. 0.42 kg/1 (3.5 Ib/gal) of coating delivered to
a coating applicator that applies extreme
performance coatings; and
4. 0.36 kg/1 (3.0 Ib/gal) of coating delivered to
a coating applicator for all other coatings and
coating application systems.
5. The above emission limitations shall include
all VOC emissions from both coating and
solvent washing unless the solvent is directed
into containers that prevent evaporation.
The emission limits
shall be achieved by:
1. The application of
low solvent coating
technology;
2. An incineration
system which oxidizes
at least 90.0 percent of
the nonmethane volatile
organic compounds
(VOC) measured as
total combustible
carbon to carbon
dioxide and water; or
3. An equivalent means
of VOC removal. The
equivalent means must
be certified by the
owner or operator and
approved by the
Director.
C-3
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Appendix C
Summary of State and Local Rules for VOC Emissions from Metal Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit
Achieved By
CA
Antelope Valley AQMD
This rule applies to all metal coatings operations except those
performed on aerospace assembly, magnet wire, marine craft,
motor vehicle, metal container, and coil coating operations.
The limits of this rule, shall not apply to: Stencil coatings; A
facility which uses a total of less than one gallon of coating,
including any VOC-containing materials added to the original
coating as supplied by the manufacturer, subject to this rule, in
any one day; Total noncompliant coating use per facility that
does not exceed 55 gallons per rolling 12-month period; Safety-
indicating coatings; Magnetic data storage disk coatings; Solid-
film lubricants; the application of coatings and use of cleaning
solvents while conducting performance tests on the coatings at
paint manufacturing facilities; high performance architectural,
vacuum metalizing, and/or pretreatment coatings used at a
facility which has the potential to emit a total of 10 tons or less
per year of VOCs, before application of add-on controls;
aerosol coating products
Coating - Air Dried
General 2.8 Ib/gal
Military Specification 2.8 Ib/gal
Etching Filler 3.5 Ib/gal
Solar-Absorbent 3.5 Ib/gal
Heat-Resistant 3.5 Ib/gal
Extreme High-Gloss 3.5 Ib/gal
Metallic 3.5 Ib/gal
Extreme Performance 3.5 Ib/gal
Prefabricated Architectural Component 3.5
Ib/gal
Touch Up 3.5 Ib/gal
Repair 3.5 Ib/gal
Silicone Release 3.5 Ib/gal
High Performance Architectural 3.5 Ib/gal
Camouflage 3.5 Ib/gal
Vacuum-Metalizing 3.5 Ib/gal
Mold-Seal 3.5 Ib/gal
High-Temperature 3.5 Ib/gal
Electric-Insulating Varnish 3.5 Ib/gal
Pan Backing 3.5 Ib/gal
Pretreatment Coatings 3.5 Ib/gal
Coating - Baked
General 2.3 Ib/gal
Military Specification 2.3 Ib/gal
Etching Filler 3.5 Ib/gal
Solar-Absorbent 3.0 Ib/gal
Heat-Resistant 3.0 Ib/gal
Extreme High-Gloss 3.0 Ib/gal
Metallic 3.5 Ib/gal
Extreme Performance 3.0 Ib/gal
C-4
-------
Appendix C
Summary of State and Local Rules for VOC Emissions from Metal Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit
Achieved By
Prefabricated Architectural Component 2.3
Ib/gal
TouchUp3.01b/gal
Repair 3.0 Ib/gal
Silicone Release 3.5 Ib/gal
High Performance Architectural 3.5 Ib/gal
Camouflage 3.5 Ib/gal
Vacuum-Metalizing 3.5 Ib/gal
Mold-Seal 3.5 Ib/gal
High-Temperature 3.5 Ib/gal
Electric-Insulating Varnish 3.5 Ib/gal
Pan Backing 3.5 Ib/gal
Pretreatment Coatings 3.5 Ib/gal
CA
Bay Area AQMD
The limits shall not apply to the use of any coating used in
volumes less than 75.7 liters (20 gal) in any one calendar year;
the application of adhesives; touch-up operations; Light-
duty.and medium-duty motor vehicles; Metal containers and
closures (cans, drums, lids, etc.) and metal coil; Magnet wire
for use in electrical machinery; Metal furniture or large
appliances; Aircraft or aerospace vehicles; Motor vehicle and
mobile equipment coating operations; Marine vessels and
component parts; Stationary structures and their appurtenances
which require architectural coatings, except where baked
coatings are applied; Magnetic data storage disks; Test panels
for evaluation of coating performance; coating operations
employing hand-held aerosol cans; coatings that are applied by
template in order to add designs, letters and/or numbers to the
products; the use of any powder coating provided the emission
of VOC to the atmosphere does not exceed that which is
equivalent to the use of coatings which comply with those
limits; any solid film lubricant; any electrical cathode coating;
any chemical milling maskant coating.
The requirements shall not apply to the following specialty
coatings, provided that the VOC of those coatings does not
Coating - Air Dried
General Coatings - 2.8 Ib/gal
Camouflage - 3.5 Ib/gal
High Gloss-3.5 Ib/gal
Heat Resistant - 3.5 Ib/gal
High Performance Architectural - 3.5 Ib/gal
Metallic Topcoat - 3.5 Ib/gal
High Performance Architectural - 3.5 Ib/gal
Silicone Release - 3.5 Ib/gal
Solar Absorbent - 3.5 Ib/gal
Extreme Performance - 3.5 Ib/gal
High Temperature - 3.5 Ib/gal
Coating - Baked
General Coatings - 2.3 Ib/gal
Camouflage - 3 Ib/gal
High Gloss - 3 Ib/gal
Heat Resistant - 3 Ib/gal
High Performance Architectural - 3.5 Ib/gal
C-5
-------
Appendix C
Summary of State and Local Rules for VOC Emissions from Metal Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit
Achieved By
exceed the following VOC limits in grams per liter (Ib/gal) and
provided that the requirements of the limited exemption
petition are met. High Performance Architectural 750 (6.2);
Pretreatment Wash Primer 780 (6.5); Silicone Release 700
(5.8); Extreme Performance 750 (6.2); High Temperature 550
(4.6).
Metallic Topcoat - 3 Ib/gal
High Performance Architectural - 3.5 Ib/gal
Silicone Release - 3.5 Ib/gal
Solar Absorbent - 3 Ib/gal
Extreme Performance - 3.5 Ib/gal
High Temperature - 3.5 Ib/gal
CA
Butte County AQMD
Each stationary source may use a total volume of less than 55
gallons per calendar year of any coating materials exceeding
the VOC content limits provided the recordkeeping & reporting
requirements are met.
Each stationary source may use a volume of less than 200
gallons per calendar year of any aluminum coating for window
frames and door frames and/or pretreatment wash primer
exceeding the VOC content limits provided the recordkeeping
& reporting requirements are met.
The requirements of this Rule shall not apply to:
Coating of prefabricated architectural components or structures
not coated in a shop environment; Motor vehicles including
automotive, truck or heavy equipment finishing or refinishing,
excluding radiators, drive trains, differentials, and engine
components; Adhesives and other materials; Magnetic data
storage discs; Safety-indicating coatings; Stencil coatings;
Conformal coatings; and Hand lettering.
The provisions of this Rule shall not apply to coatings and
coating removers (strippers) sold in non-refillable aerosol
containers having a capacity of one liter (1.1 quarts) or less.
Coating - Air Dried
General Coatings - 2.8 Ib/gal
Camouflage - 3.5 Ib/gal
Etching Filler - 3.5 Ib/gal
Extreme Performance - 3.5 Ib/gal
Heat Resistant - 3.5 Ib/gal
High Gloss-3.5 Ib/gal
High Performance Architectural - 3.5 Ib/gal
High Temperature - 3.5 Ib/gal
Metallic-3.5 Ib/gal
Mold Seal-3.5 Ib/gal
Pan Backing - 3.5 Ib/gal
Pretreatment Wash Primer - 3.5 Ib/gal
Silicone Release - 3.5 Ib/gal
Solar Absorbent - 3.5 Ib/gal
Vaccuum-Metalizing - 3.5 Ib/gal
Coating - Baked
General Coatings - 2.3 Ib/gal
Camouflage - 3 Ib/gal
Etching Filler-3.5 Ib/gal
Extreme Performance - 3.5 Ib/gal
Heat Resistant - 3 Ib/gal
High Gloss - 3 Ib/gal
High Performance Architectural - 3.5 Ib/gal
High Temperature - 3.5 Ib/gal
C-6
-------
Appendix C
Summary of State and Local Rules for VOC Emissions from Metal Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit
Achieved By
Metallic - 3 Ib/gal
MoldSeal-3.51b/gal
Pan Backing - 3.5 Ib/gal
Pretreatment Wash Primer - 3.5 Ib/gal
Silicone Release - 3.5 Ib/gal
Solar Absorbent - 3 Ib/gal
Vaccuum-Metalizing - 3.5 Ib/gal
CA
Kern County AQMD
Requirements of this Rule shall not apply to any combination
of coatings, provided total allowed facility VOC emissions
from use of all coatings does not exceed 15 pounds in any one
day.
Requirements of this Rule shall not apply to application of
coatings to automobiles, light duty trucks, aircraft, aerospace
vehicles, marine vessels, cans, coils, or magnetic wire or to
powder coatings
Requirements of this Rule shall not apply to an operation
subject to requirements of Rule 410.4A (Motor Vehicle and
Mobile Equipment Refinishing Operations).
Coatings - Air Dried
All other coatings - 2.8 Ib/gal
Camouflage - 3.5 Ib/gal
Extreme Performance - 3.5 Ib/gal
Heat Resistant - 3.5 Ib/gal
High Gloss-3.5 Ib/gal
High Performance Architectural - 3.5 Ib/gal
High Temperature - 3.5 Ib/gal
Metallic Topcoat - 3.5 Ib/gal
Pretreatment Wash Primer - 2.8 Ib/gal
Silicone Release - 3.5 Ib/gal
Solar Absorbent - 3.5 Ib/gal
Coatings - Baked
All other coatings - 2.3 Ib/gal
Camouflage - 3 Ib/gal
Extreme Performance - 3 Ib/gal
Heat Resistant - 3 Ib/gal
High Gloss - 3 Ib/gal
High Performance Architectural - 3.5 Ib/gal
High Temperature - 3.5 Ib/gal
Metallic Topcoat - 3.5 Ib/gal
Pretreatment Wash Primer - 2.3 Ib/gal
Silicone Release - 3.5 Ib/gal
Solar Absorbent - 3 Ib/gal
In lieu of complying
with VOC content
limits specified, air
pollution control
equipment with a
capture efficiency of at
least 85% and a control
device efficiency of at
least 90% may be used.
C-7
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Appendix C
Summary of State and Local Rules for VOC Emissions from Metal Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit
Achieved By
CA
Mojave Desert AQMD
The limits shall not apply to any facility that does not exceed
10 tons per year of Theoretical Potential Emissions of VOC.
This Rule shall apply to all metal coating operations, except
those performed on Aircraft or Aerospace Vehicles; Magnet
Wire; Metal Containers, Closures and Coils; marine vessel
exteriors; Motor Vehicles; Motor Vehicle Assembly Lines;
Mobile Equipment; or those operations subject to the coating
provisions of any other source-specific rule of the District.
The provisions of this Rule shall not apply to aerosol coating
products;
The provisions of this Rule shall not apply to: Any facility
which has a daily usage of less than one gallon of coating,
including any VOC-containing materials added to the original
coating as supplied by the manufacturer, subject to this Rule;
Total noncompliant coating use per facility that does not
exceed 55 gallons per year; Stencil Coatings; Safety-indicating
Coatings; Magnetic Data Storage Disk Coatings; Solid-film
Lubricants; Adhesives; the coating of Motor Vehicle bodies at
Motor Vehicle Rework facilities.
The provisions of this Rule shall not apply to the application of
coatings and use of cleaning solvents while conducting
Performance Tests on the coatings at paint manufacturing
facilities.
Coating - Air Dried
General-3.51b/gal
Military Specification - 3.5 Ib/gal
Etching Filler - 3.5 Ib/gal
Solar-Absorbant - 3.5 Ib/gal
Heat-Resistant - 3.5 Ib/gal
High-Gloss -3.5 Ib/gal
Extreme High Gloss - 3.5 Ib/gal
Metallic-3.5 Ib/gal
Extreme-Performance - 3.5 Ib/gal
Prefabricated Architectural Component - 3.5
Ib/gal
Touch-Up-3.5 Ib/gal
Repair- 3.5 Ib/gal
Silicone-Release - 3.5 Ib/gal
High-Performance - 3.5 Ib/gal
Architectural - 3.5 Ib/gal
Camouflage - 3.5 Ib/gal
Vacuum-Metalizing - 3.5 Ib/gal
Mold-Seal-3.5 Ib/gal
High-Temperature - 3.5 Ib/gal
Electric-Insulating Varnish - 3.5 Ib/gal
Pan-Backing - 3.5 Ib/gal
Pretreatment Wash Primer - 3.5 Ib/gal
Clear Coating - 4.3 Ib/gal
Coating - Baked
General - 3 Ib/gal
Military Specification - 3 Ib/gal
Etching Filler - 3.5 Ib/gal
Solar-Absorbant - 3 Ib/gal
Heat-Resistant - 3 Ib/gal
In lieu of complying
with the VOC content
limitations, air pollution
control equipment with
a capture and control
system Combined
Efficiency of at least
85%, may be used.
-------
Appendix C
Summary of State and Local Rules for VOC Emissions from Metal Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit
Achieved By
High-Gloss - 3 Ib/gal
Extreme High Gloss - 3 Ib/gal
Metallic-3.5 Ib/gal
Extreme-Performance - 3 Ib/gal
Prefabricated Architectural Component - 2.3
Ib/gal
Touch-Up - 3 Ib/gal
Repair - 3 Ib/gal
Silicone-Release - 3.5 Ib/gal
High-Performance - 3.5 Ib/gal
Architectural - 3.5 Ib/gal
Camouflage - 3.5 Ib/gal
Vacuum-Metalizing - 3.5 Ib/gal
Mold-Seal-3.5 Ib/gal
High-Temperature - 3.5 Ib/gal
Electric-Insulating Varnish - 3.5 Ib/gal
Pan-Backing - 3.5 Ib/gal
Pretreatment Wash Primer - 3.5 Ib/gal
Clear Coating - 4.3 Ib/gal
CA Monterrey Bay Unified
AQMD
The provisions of this Rule shall not apply to aircraft or
aerospace vehicle coatings, marine vessel exteriors, plastic
coatings, magnetic wire coatings, motor vehicle coatings and
mobile equipment coatings.
The provisions of this Rule shall not apply to stencil coatings,
safety temperature- indicating coatings, powder coatings, and
adhesives.
The provisions of this Rule shall not apply to any combination
of coatings used for coating metal parts and products in a total
volume less than 55 gallons/year (208 liters/year) per facility .
Coating - Air Dried
General-3.5 Ib/gal
Camouflage - 3.5 Ib/gal
Etching Filler-3.5 Ib/gal
Extreme Performance - 3.5 Ib/gal
Heat-Resistant - 3.5 Ib/gal
High Gloss-3.5 Ib/gal
High Performance-Architectural - 3.5 Ib/gal
High Temperature - 3.5 Ib/gal
Metallic - 3.5 Ib/gal
Mold-Seal-3.5 Ib/gal
Pan Backing - 3.5 Ib/gal
Pretreatment Wash Primer - 6.5 Ib/gal
Add-on controls may be
used provided that the
combined efficiency of
capture and control of
the system is not less
than 90 percent by
weight in reducing
volatile organic
compounds;
C-9
-------
Appendix C
Summary of State and Local Rules for VOC Emissions from Metal Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit
Achieved By
The provisions of this Rule shall not apply to coatings sold in
non-refillable aerosol containers.
Silicone Release - 3.5 Ib/gal
Solar-Absorbent - 3.5 Ib/gal
Vacuum-Metalizing - 3.5 Ib/gal
Coating - Baked
General - 3 Ib/gal
Camouflage - 3 Ib/gal
Etching Filler-3.5 Ib/gal
Extreme Performance - 3.5 Ib/gal
Heat-Resistant - 3.5 Ib/gal
High Gloss - 3 Ib/gal
High Performance-Architectural - 3.5 Ib/gal
High Temperature - 3.5 Ib/gal
Metallic - 3 Ib/gal
Mold-Seal-3.5 Ib/gal
Pan Backing - 3.5 Ib/gal
Pretreatment Wash Primer - 6.5 Ib/gal
Silicone Release - 3.5 Ib/gal
Solar-Absorbent - 3 Ib/gal
Vacuum-Metalizing - 3.5 Ib/gal
CA
Northern Sierra AQMD
Provisions of this Rule shall apply to surface coating of metal
parts or products in portions of the Northern Sierra Air Quality
Management District that are designated as Non-attainment for
any federal ambient air quality standard for ozone.
Requirements of this Rule shall not apply to any combination
of coatings, provided total uncontrolled facility VOC emissions
from use of all coatings does not exceed 15 pounds in any one
day.
Requirements of this Rule shall not apply to application of
coatings to automobiles, light duty trucks, aircraft, aerospace
vehicles, marine vessels, cans, coils, or magnetic wire or to
Coating - Air Dried
All Other Coatings 3.5 Ib/gal
Camouflage 3.5 Ib/gal
Clear Coating 3.5 Ib/gal
Extreme-Performance 3.5 Ib/gal
High Performance Architectural 3.5 Ib/gal
High Temperature 3.5 Ib/gal
Metallic Topcoat 3.5 Ib/gal
Pretreatment Wash Primer 3.5 Ib/gal
Silicone Release 3.5 Ib/gal
Coating - Baked
In lieu of complying
with VOC content
limits air pollution
control equipment with
a VOC capture
efficiency of at least
85% and a control
device efficiency of at
least 90% may be used.
C-10
-------
Appendix C
Summary of State and Local Rules for VOC Emissions from Metal Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit
Achieved By
powder coatings, except the rule does apply to the customized
top coating of automobiles and trucks with production of 35 or
more vehicles per day.
All Other Coatings 3.0 Ib/gal
Camouflage 3.5 Ib/gal
Clear Coating 4.3 Ib/gal
Extreme-Performance 3.5 Ib/gal
High Performance Architectural 3.5 Ib/gal
High Temperature 3.5 Ib/gal
Metallic Topcoat 3.5 Ib/gal
Pretreatment Wash Primer 3.5 Ib/gal
Silicone Release 3.5 Ib/gal
CA Sacramento Metro
AQMD
The limits shall not apply to the use of materials exceeding the
VOC content limits in a total volume less than 55 gallons per
calendar year, per stationary
Source provided the recordkeeping & reporting requirements
are met.
The limits shall not apply to the use of any aluminum coating
for window frames and door frames exceeding the VOC
content limit in a volume less than 200 gallons per calendar
year, per stationary source provided the recordkeeping &
reporting requirements are met.
The limits shall not apply to the use of any pretreatment wash
primer that exceeds the VOC content limits in a volume of less
than 200 gallons per calendar year, per stationary source
provided the recordkeeping & reporting requirements are met.
The requirements of this rule shall not apply to: Coating of
prefabricated architectural components or structures not coated
in a shop environment which are regulated by Rule 442 -
Architectural Coatings; Motor vehicles including automotive,
truck or heavy equipment finishing or refinishing, excluding
radiators, drive trains, differentials, and engine components
which are regulated by Rule 459 - Automotive, Truck and
Heavy Equipment Refinishing Operations; Aircraft or
aerospace vehicles, components and tooling which are
Coating - Air Dried
Aluminum Coating for Window & Door
Frames - 3.5 Ib/gal
Camouflage - 3.5 Ib/gal
Electrical Insulating - 2.8 Ib/gal
Extreme High Gloss - 3.5 Ib/gal
Extreme Performance - 3.5 Ib/gal
Heat Resistant - 3.5 Ib/gal
Metallic/Iridescent - 3.5 Ib/gal
Non-skid-3.5 Ib/gal
Prefabricated Architectural Component - 3.5
Ib/gal
Pretreatment Wash Primer - 3.5 Ib/gal
Silicone Release - 3.5 Ib/gal
Solar Absorbent - 3.5 Ib/gal
All Other coatings - 2.8 Ib/gal
Coating - Baked
Aluminum Coating for Window & Door
Frames - 3.5 Ib/gal
Camouflage - 3 Ib/gal
Electrical Insulating - 2.3 Ib/gal
Extreme High Gloss - 3 Ib/gal
C-ll
-------
Appendix C
Summary of State and Local Rules for VOC Emissions from Metal Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit
Achieved By
regulated by Rule 456 - Aerospace Assembly and Component
Coating Operations; Cans, coils, or magnetic wire which are
regulated by Rule 452 - Can Coating; Adhesives and other
materials which are regulated by Rule 460 - Adhesives and
Sealants; Magnetic data storage discs; Safety-indicating
coatings; Stencil coatings; Conformal Coatings; and Hand
Lettering.
The provisions of this rule shall not apply to coatings and
coating removers (strippers) sold in non-refillable aerosol
containers having a capacity of one liter (1.1 quarts) or less.
Extreme Performance - 3.5 Ib/gal
Heat Resistant - 3 Ib/gal
Metallic/Iridescent - 3.5 Ib/gal
Non-skid - 3 Ib/gal
Prefabricated Architectural Component - 2.3
Ib/gal
Pretreatment Wash Primer - 3.5 Ib/gal
Silicone Release - 3.5 Ib/gal
Solar Absorbent - 3 Ib/gal
All Other coatings - 2.3 Ib/gal
CA
San Diego AQMD
The provisions of this rule shall not apply to the following:
(i) Any coating operation where 20 gallons or less of coatings
are applied per consecutive 12-month period.
(ii) Any powder coating operation which uses less than 0.5
gallons per day of any surface preparation or cleaning material
containing volatile organic compounds.
(iii) Coatings applied to motor vehicles, excluding the
application of coatings to component parts or accessories
during original manufacture.
(iv) Coatings applied using non-refillable handheld aerosol
spray containers.
(v) Coatings applied to metal surfaces for the specific purpose
of protecting the metal substrate from corrosive attack by
storage battery electrolytes.
(vi) The application of the following coatings: Cathode
coatings; Chemical milling maskants; Magnetic tape storage
disks coatings; Safety indicating coatings; Solid film
lubricants; Stencil coatings; and Wet fastener installation
coatings.
The limits shall not apply to the following:
(i) Pretreatment wash primers with a VOC content, as applied,
of less than 780 grams of VOC per liter of coating, less water
Coating - Air Dried
All Other coatings - 2.8 Ib/gal
Chemical Agent Resistant - 3.5 Ib/gal
Heat Resistant - 3.5 Ib/gal
High Gloss-3.5 Ib/gal
High Performance Architectural - 3.5 Ib/gal
Metallic Topcoat - 3.5 Ib/gal
Pretreatment Wash Primer - 3.5 Ib/gal
Solar Absorbent - 3.5 Ib/gal
Coating - Baked
All Other coatings - 2.3 Ib/gal
Chemical Agent Resistant - 3.5 Ib/gal
Heat Resistant - 3 Ib/gal
High Gloss - 3 Ib/gal
High Performance Architectural - 3.5 Ib/gal
Metallic Topcoat - 3 Ib/gal
Pretreatment Wash Primer - 3.5 Ib/gal
Solar Absorbent - 3 Ib/gal
In lieu of complying
with VOC content
limits air pollution
control equipment that
has a combined
emissions capture and
control device
efficiency of at least 85
percent by weight may
be used.
C-12
-------
Appendix C
Summary of State and Local Rules for VOC Emissions from Metal Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit
Achieved By
and exempt compounds, provided that not more than 500
gallons of all pretreatment wash primers are used at a stationary
source in each consecutive 12-month period.
(ii) High performance architectural coatings with a VOC
content, as applied, of less than 750 grams of VOC per liter of
coating, less water and exempt compounds, used at a stationary
source which has continuously maintained a District Permit to
Operate for each high performance architectural coating
operation since November 1, 1993.
CA San Joaquin Valley
AQMD
An operator at a given facility may use up to a total of 55
gallons of non-compliant coatings per rolling, consecutive 365-
day period.
The requirements of this rule shall not apply to touch-up and
repair.
The requirements of this rule shall not apply to the application
of coatings to aircraft, aerospace vehicles, marine vessels, can,
coils, and magnetic wire.
Through December 31, 2008, the provisions of this rule shall
not apply to an operation subject to the requirements of Rule
4602 (Motor Vehicle and Mobile Equipment Coating
Operations). On and after January 1, 2009, the provisions of
this rule shall not apply to an operation subject to the
requirements of Rule 4612 (Motor Vehicle and Mobile
Equipment Operations Phase II).
The provisions of this rule shall not apply to polyester resin
operations and the application of polyester resin materials to
metal parts and products.
The provisions of this rule shall not apply to stripping of cured
coatings, cured adhesives, and cured inks, except the stripping
of such materials from spray application equipment.
Coating - Air Dried
Camouflage - 3.5 Ib/gal
Extreme Performance - 3.5 Ib/gal
Heat Resistant - 3.5 Ib/gal
High Gloss-3.5 Ib/gal
High Performance Architectural - 3.5 Ib/gal
High Temperature - 3.5 Ib/gal
Metallic Topcoat - 3.5 Ib/gal
Pretreatment Wash Primer - 3.5 Ib/gal
Silicone Release - 3.5 Ib/gal
Solar Absorbent - 3.5 Ib/gal
Solid Film Lubricant - 7.3 Ib/gal
General - 2.8 Ib/gal
Dip coating of steel joists (SIC 3441)
-2.8 Ib/gal for coatings with a viscosity, as
applied, of more than 45.6 centistokes at 78°F
or an average dry-film thickness of greater than
2.0 mils;
-3.32 Ib/gal for coatings with a viscosity, as
applied, of less than or equal to 45.6
centistokes at 78°F and an average dry-film
thickness of less than or equal to 2.0 mils.
Coating - Baked
Camouflage - 3 Ib/gal
In lieu of complying
with the applicable
VOC content limits, an
operator may control
emissions from coating
operations with an
APCO-approved VOC
emission control system
C-13
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Appendix C
Summary of State and Local Rules for VOC Emissions from Metal Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit
Achieved By
Extreme Performance - 3.5 Ib/gal
Heat Resistant - 3 Ib/gal
High Gloss - 3 Ib/gal
High Performance Architectural - 3.5 Ib/gal
High Temperature - 3.5 Ib/gal
Metallic Topcoat - 3 Ib/gal
Pretreatment Wash Primer - 3.5 Ib/gal
Silicone Release - 3.5 Ib/gal
Solar Absorbent - 3.5 Ib/gal
Solid Film Lubricant - 7.3 Ib/gal
General - 2.3 Ib/gal
CA
San Luis Obispo
The provisions of this Rule shall not apply to: Aircraft or
aerospace vehicle coating operations; Marine vessel exteriors
(below water-line); Automobile refinishing; or
Architectural surface coating,
The provisions of this Rule shall not apply to: Any coating used
in volumes of less than 20 gallons in any calendar year,
provided that the source demonstrates that no complying
coatings are available; and Stationary sources using not more
than four (4) gallons of paint, varnish, lacquer, thinner, and
other solvent containing materials in any one day based on a
monthly operating day average, provided the recordkeeping
requirements are satisfied.
Coating - Air Dried
General - 2.8 Ib/gal
Military Specification - 2.8 Ib/gal
Metallic - 3.5 Ib/gal
Zinc Filled Primers - 3.5 Ib/gal
Etching filler - 6 Ib/gal
Solar Abosrbent - 3.5 Ib/gal
Heat-Resistant - 3.5 Ib/gal
Extreme-High Gloss - 3.5 Ib/gal
Extreme-Performance - 3.5 Ib/gal
Prefabricated Architectural Component - 3.5
Ib/gal
Touch-up - 3.5 Ib/gal
Repair- 3.5 Ib/gal
Silicone Release - 3.5 Ib/gal
High-performance Architectural - 6.3 Ib/gal
Camouflage - 3.5 Ib/gal
Vacuum-metalizing - 6.7 Ib/gal
Mold Seal - 6.3 Ib/gal
High-temperature - 6 Ib/gal
Electric-Insulating Varnish - 5.2 Ib/gal
C-14
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Appendix C
Summary of State and Local Rules for VOC Emissions from Metal Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit
Achieved By
Pretreatment Wash Primer - 6.5 Ib/gal
Coating - Baked
General - 2.3 Ib/gal
Military Specification - 2.3 Ib/gal
Metallic - 3 Ib/gal
Zinc Filled Primers - 3.5 Ib/gal
Etching filler - 6 Ib/gal
Solar Abosrbent - 3 Ib/gal
Heat-Resistant - 3 Ib/gal
Extreme-High Gloss - 3 Ib/gal
Extreme-Performance - 3 Ib/gal
Prefabricated Architectural Component - 2.3
Ib/gal
Touch-up - 3 Ib/gal
Repair - 3 Ib/gal
Silicone Release - 3.5 Ib/gal
High-performance Architectural - 6 Ib/gal
Camouflage - 3 Ib/gal
Vacuum-metalizing - 6.7 Ib/gal
Mold Seal - 6.3 Ib/gal
High-temperature - 6 Ib/gal
Electric-Insulating Varnish - 5.2 Ib/gal
Pretreatment Wash Primer - 6.5 Ib/gal
CA
South Coast AQMD
The limits of this rule shall not apply to:Stencil coatings;
Safety-indicating coatings; Magnetic data storage disk
coatings; Solid-film lubricants; or Electric-insulating and
thermal-conducting coatings.
The limits of this rule do not apply to the application of
coatings and use of cleaning solvents while conducting
performance tests on the coatings at paint manufacturing
facilities.
Coating - Air Dried
General 1-component-2.3 Ib/gal
General multi-component - 2.8 Ib/gal
Military Specification- 2.8 Ib/gal
Etching Filler - 3.5 Ib/gal
Solar Absorbent - 3.5 Ib/gal
Heat Resistant - 3.5 Ib/gal
Extreme High Gloss - 2.8 Ib/gal
C-15
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Appendix C
Summary of State and Local Rules for VOC Emissions from Metal Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit
Achieved By
The limits of this rule shall not apply to high performance
architectural, vacuum-metalizing, and/or pretreatment
coatings used at a facility which has the potential to emit a total
of 10 tons or less per year of VOCs, before application of add-
on controls.
The limits of this rule shall not apply to aerosol coating
products.
The limits of this rule shall not apply to the use of essential
public service coatings provided such aggregate use does not
exceed 55 gallons in any one calendar year per facility.
The limits of this rule shall not apply to the use of optical anti-
reflective coatings provided such aggregate use does not
exceed 10 gallons in any one calendar year, per facility.
The limits shall not apply to electrocoatings, provided the VOC
content of coating concentrates do not exceed 450 grams per
liter, less water and less exempt compounds, and the usage of
coating concentrates is less than 66 gallons per calendar month,
per facility, including any VOC-containing materials added to
the concentrate, as supplied by the manufacturer, and any
VOC-containing materials added to the bath as make-up
solvents.
The limits shall not apply to photoresist operations applying
liquid photoresist coating used for photofabrication of metal
substrates with a thickness not exceeding 0.060 inches provided
the annual usage per facility is 10 gallons or less.
Metallic-3.5 Ib/gal
Extreme Performance - 3.5 Ib/gal
Prefabricated Architectural 1-Component - 2.3
Ib/gal
Prefabricated Architectural Multi-Component -
2.8 Ib/gal
Touch up - 3.5 Ib/gal
Repair- 3.5 Ib/gal
Silicone Release - 3.5 Ib/gal
High Performance Architectural - 3.5 Ib/gal
Camouflage - 3.5 Ib/gal
Vaccuum-Metalizing - 3.5 Ib/gal
Mold Seal-3.5 Ib/gal
High Temperature - 3.5 Ib/gal
Electric Insulating Varnish - 3.5 Ib/gal
Pan Backing - 3.5 Ib/gal
Pretreatment Coatings - 3.5 Ib/gal
Coating - Baked
General 1-component-2.3 Ib/gal
General multi-component - 2.3 Ib/gal
Military Specification-2.3 Ib/gal
Etching Filler - 3.5 Ib/gal
Solar Absorbent - 3.0 Ib/gal
Heat Resistant - 3.0 Ib/gal
Extreme High Gloss - 3.0 Ib/gal
Metallic-3.5 Ib/gal
Extreme Performance - 3.0 Ib/gal
Prefabricated Architectural 1-Component - 2.3
Ib/gal
Prefabricated Architectural Multi-Component -
2.3 Ib/gal
Touch up - 3.0 Ib/gal
C-16
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Appendix C
Summary of State and Local Rules for VOC Emissions from Metal Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit
Achieved By
Repair- 3.0 Ib/gal
Silicone Release - 3.5 Ib/gal
High Performance Architectural - 3.5 Ib/gal
Camouflage - 3.5 Ib/gal
Vaccuum-Metalizing - 3.5 Ib/gal
Mold Seal-3.5 Ib/gal
High Temperature - 3.5 Ib/gal
Electric Insulating Varnish - 3.5 Ib/gal
Pan Backing - 3.5 Ib/gal
Pretreatment Coatings - 3.5 Ib/gal
CA
Ventura County AQMD
The limits of this rule do not apply to any one coating provided
that no complying coatings are available, and total usage of all
noncomplying coatings has not exceeded 55 gallons in any
calendar year.
This rule does not apply to:
Aircraft or aerospace vehicle coating operations; Marine vessel
exteriors; Motor vehicle and mobile equipment coating; or
Aerosol coating products.
This rule shall not apply to any stationary source that emits less
than 200 pounds of ROC in every rolling period of 12
consecutive calendar months from metal parts and products
coating operations.
Coating - Air Dried
All other coatings 2.8 Ib/gal
Camouflage 3.5 Ib/gal
Extreme Performance 3.5 Ib/gal
Etching Filler 3.5 Ib/gal
Heat Resistant 3.5 Ib/gal
High Gloss 3.5 Ib/gal
High Performance Architectural 3.5 Ib/gal
High Temperature 3.5 Ib/gal
Laboratory Furniture 2.8 Ib/gal
Metallic 3.5 Ib/gal
Mold Seal 3.5 Ib/gal
Pan Backing 3.5 Ib/gal
Pretreatment Wash Primer 2.8 Ib/gal
Silicone Release 3.5 Ib/gal
Solar Absorbent 3.5 Ib/gal
VacuumMetalizing 3.5 Ib/gal
Coating - Baked
All other coatings 2.3 Ib/gal
Camouflage 3.0 Ib/gal
In lieu of complying
with VOC content
limits air pollution
control equipment may
be used, under certain
conditions.
C-17
-------
Appendix C
Summary of State and Local Rules for VOC Emissions from Metal Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit
Achieved By
Extreme Performance 3.0 Ib/gal
Etching Filler 4 3.5 Ib/gal
Heat Resistant 3.0 Ib/gal
High Gloss 3.0 Ib/gal
High Performance Architectural 3.5 Ib/gal
High Temperature 3.5 Ib/gal
Laboratory Furniture 2.8 Ib/gal
Metallic 3.0 Ib/gal
Mold Seal 3.5 Ib/gal
Pan Backing 3.5 Ib/gal
Pretreatment Wash Primer 2.3 Ib/gal
Silicone Release 3.5 Ib/gal
Solar Absorbent 3.0 Ib/gal
VacuumMetalizing 3.5 Ib/gal
C-18
-------
Appendix C
Summary of State and Local Rules for VOC Emissions from Metal Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit
Achieved By
CA
Yolo Solano AQMD
The limits shall not apply to coatings used in volumes of less
than 50 gallons per year.
The provisions of Section 300 shall not apply to the following:
Stencil coatings; Safety-temperature indicating coatings;
Powder coatings; and Adhesive coatings upon the effective
compliance dates of Rule 2.31, Adhesives.
The limits shall not apply to the application of coatings while
conducting performance tests on the coatings at paint
manufacturing facilities.
The provisions of this rule shall not apply to coating operations
subject to the provisions of Rule 2.26, Motor Vehicle and
Mobile Equipment Coating Operations.
Coating - Air Dried
General Coatings - 2.8 Ib/gal
Etching Filler-3.5 Ib/gal
Solar-Absorbent - 3.5 Ib/gal
Heat-Resistant - 3.5 Ib/gal
High Gloss-3.5 Ib/gal
Metallic - 3.5 Ib/gal
Extreme Performance - 3.5 Ib/gal
Silicone Release - 3.5 Ib/gal
High Performance Architectural - 3.5 Ib/gal
Camouflage - 3.5 Ib/gal
Vacuum-Metalizing - 3.5 Ib/gal
Mold-Seal-3.5 Ib/gal
High Temperature - 3.5 Ib/gal
Pan Backing - 3.5 Ib/gal
Pretreatment Wash Primer - 3.5 Ib/gal
Coating - Baked
General Coatings - 2.3 Ib/gal
Etching Filler - 3.5 Ib/gal
Solar-Absorbent - 3.0 Ib/gal
Heat-Resistant - 3.0 Ib/gal
High Gloss-3.0 Ib/gal
Metallic-3.0 Ib/gal
Extreme Performance - 3.5 Ib/gal
Silicone Release - 3.5 Ib/gal
High Performance Architectural - 3.5 Ib/gal
Camouflage - 3.0 Ib/gal
Vacuum-Metalizing - 3.5 Ib/gal
Mold-Seal-3.5 Ib/gal
High Temperature - 3.5 Ib/gal
Pan Backing - 3.5 Ib/gal
Alternatively, a person
may comply with the
provisions by using air
pollution control
equipment, provided
that the overall
efficiency (capture
efficiency multiplied by
destruction efficiency)
of the system shall not
be less than 85 percent
by weight in reducing
volatile organic
compounds.
C-19
-------
Appendix C
Summary of State and Local Rules for VOC Emissions from Metal Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit
Achieved By
Pretreatment Wash Primer - 3.5 Ib/gal
CO All provisions of this
regulation apply to the
Denver 1-hour ozone
attainment/maintenance
area, and to any non-
attainment area for the 1-
hour ozone standard.
Limits are not applicable to sources whose actual emissions,
including fugitive emissions, before add-on controls, are less
than 6.8 kilograms (15 Ibs.) per day and less than 1.4 kilograms
(3 Ibs.) per hour. Emissions from all sources within the same
control technique guidance group shall be totaled to determine
actual emissions.
This subsection is not applicable to the surface coating of the
following metal parts and products: Automobiles and light-duty
trucks; Metal cans; Flat metal sheets and strips in the form of
rolls or coils; Large appliances; Magnet wire for use in
electrical machinery; and Metal furniture.
This subsection is not applicable to the following special
purpose coatings:
Division-approved exemptions for high performance coatings
on a case-by-case basis; and Full exterior repainting of
automobiles and light-duty trucks if fewer than 18 vehicles are
painted per day
1. Clear coatings: 0.52 kg/L(4.3 Ib/gal)
2. Extreme Performance Coatings:
0.42 kg/L (3.5 Ib/gal)
3. Air-Dried Coatings: 0.42 kg/L (3.5 Ib/gal)
4. Other coatings and systems: 0.36 kg/L (3.0
Ib/gal) delivered to a coating applicator for all
other coatings and coating application systems.
the emission limits
designated for that
process shall be
achieved by:
1. use of coatings with
proportions of VOC
less than or equal to the
maximums specified by
the applicable
sub section of this
regulation; or
2. use of the specified
equipment and
procedures prescribed
by the applicable
sub section of this
regulation; or
3. use of an alternative
means of control which
satisfies the
requirements of 5.e and
f below and section
II.D; or
4. use of crossline
averaging.
CT
Applies to any premises which have actual VOC emissions of
15 Ib/day or more (with some exceptions).
The following categories are excluded: automobile and light-
duty trucks; metal cans; flat metal sheets and strips in the form
of rolls or coils; plastic and glass objects; magnet wire for use
in electrical machinery; metal furniture; the exterior surface of
assembled aircraft; automobile refmishing; customized top
coating of automobiles and trucks, if production is less than
A) 0.52 kg/L of coating delivered to a coating
applicator that applies clear coat;
B) 0.42 kg/L of coating delivered to a coating
applicator in a coating application system that
is air dried or forced warm air dried at
temperatures up to 90 degrees C
C) 0.42 kg/L of coating delivered to a coating
applicator that applies extreme performance
coatings
C-20
-------
Appendix C
Summary of State and Local Rules for VOC Emissions from Metal Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit
Achieved By
five vehicles per day; and the exterior surface of assembled
marine vessels.
An owner or operator may use, in aggregate, up to 55 gallons
of coatings than exceed the emission limitations of this rule at
such premise for any twelve consecutive months.
D) 0.36 kg/L of coating delivered to a coating
applicator for all other coatings, adhesives,
fillers or sealants and coating applications
systems
E) 0.75 kg/L of coating delivered to a coating
applicator which applies high performance
architectural aluminum coatings, provided that
1) such applicator is located at the premises
which emits 3,333 Ib VOC per month or less
from such applicator, 2) such applicator was an
existing source in CT on or before Nov 1, 1994
DE
The emission limits in this Section do not apply to any coating
unit within a facility whose actual emissions without control
devices from all miscellaneous metal part and products coating
units within the facility are less than 6.8 kg (15 Ib) of VOC per
day.
This Section does not apply to the coating of the following
metal parts and products that are covered by other Sections of
this regulation: Automobiles and light-duty trucks; Metal cans;
Flat metal sheets and strips in the form of rolls or coils;
Magnet wire for use in electrical machinery; Metal furniture;
Large appliances; and Heavy-duty trucks that use
electrodeposition (EDP) to apply prime coat.
This Section does not apply to: Exterior of completely
assembled aircraft; Exterior of major aircraft subassemblies, if
approved by the Department as part of a State Implementation
Plan (SIP) revision; Automobile, light-duty truck, and heavy-
duty truck refinishing; Customized top coating of automobiles
and trucks, if production is less than 35 vehicles per day;
Exterior of completely assembled marine vessels; Exterior of
major marine vessel subassemblies if approved by the
Department as part of a SIP revision.
1. Clear coating (0.52 kg/L, 4.3 Ib/gal)
2. Steel pail and drum interior coating (0.52
kg/L, 4.3 Ib/gal)
3. Air-dried coating (0.42 kg/L, 3.5 Ib/gal)
4. Extreme performance coating (0.42 kg/L,
3.5 Ib/gal)
5. All other coatings (0.36 kg/L, 3.0 Ib/gal)
An owner or operator of
a miscellaneous metal
parts and products
coating unit subject to
this Section may
comply with this
Section by:
1. Installing and
operating a capture
system on that unit.
2. Installing and
operating a control
device on that unit.
3. Determining for
each day the overall
emission reduction
efficiency needed to
demonstrate
compliance.
iv. Demonstrating each
day that the overall
emission reduction
efficiency achieved for
that day,
is greater than or equal
C-21
-------
Appendix C
Summary of State and Local Rules for VOC Emissions from Metal Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit
Achieved By
to the overall emission
reduction efficiency
required for that day.
FL Limits apply to existing
VOC-emitting facilities in
all designated ozone
nonattainment and air
quality maintenance
areas... and apply to new
and modified VOC-
emitting facilities in all
designated ozone
nonattainment and air
quality maintenance areas
[with some exemptions].
Emissions units which in combination with all other emissions
units at the facility that emit VOC at rates of not more than 15
pounds (6.8 kilograms) in any one day and not more than 3
pounds (1.4 kilograms) in any one hour are exempt.
The provisions shall not apply to the surface coating of the
following metal parts and products: Automobiles and light-duty
trucks; Metal cans; Flat metal sheets and strips in the form of
rolls or coils; Magnet wire for use in electrical machinery;
Metal furniture; Large appliances; Exterior of airplanes;
Automobile refinishing; Customized top coating of
automobiles and trucks if production is less than 35 vehicles
per day; and Exterior of marine vessels.
1. 4.3 Ib/gal of coating (0.52 kg/L) delivered to
a coating applicator that applies clear coatings;
2. 3.5 Ib/gal of coating (0.42 kg/L) delivered to
a coating applicator in a coating application
system that is air dried or forced warm air dried
at temperatures up to 194 degrees F (90
degrees C);
3. 3.5 Ib/gal of coating (0.42 kg/L) delivered to
a coating applicator that applies extreme
performance coatings; or,
4. 3.0 Ib/gal of coating (0.36 kg/L) elivered to
a coating applicator for all other coatings and
coating application systems.
The emission limits
shall be achieved by:
1. The application of
low solvent coating
technology; or,
2. Incineration,
provided that 90
percent of the volatile
organic compounds
(VOC measured as total
combustible carbon)
which enter the
incinerator are oxidized
to carbon dioxide and
water.
GA Sources located outside
Cherokee, Clayton, Cobb,
Coweta, DeKalb,
Douglas, Fayette, Forsyth,
Fulton, Gwinnett, Henry,
Paulding, and Rockdale
counties whose potential
emissions of VOC are not
more than 100 tons per
year are not subject;
Sources located within
Cherokee, Clayton, Cobb,
Coweta, DeKalb,
Douglas,
Fayette, Forsyth, Fulton,
Gwinnett, Henry,
Paulding, or Rockdale
The requirements of this subsection shall not apply to facilities
at which the potential to emit volatile organic compounds, from
all surface coating of miscellaneous metal parts and products, is
less than 10 tons per year.
Coatings, inks and other VOC-containing materials in use at
sources of VOC emissions shall not be subject to any
requirements of such subsections, provided the source's total
aggregate use of such materials is not in excess of 55 gallons
per year and such exemption is approved in writing by the
Division.
"Miscellaneous metal parts and products" shall not mean the
following:
automobiles and light-duty trucks; metal cans; flat metal sheets
and strips in the form of rolls or coils;
magnet wire for use in electrical machinery; metal furniture;
large appliances;
(i) 4.3 Ib/gal of coating delivered to a coating
applicator that applies clear coatings. If any
coating delivered to the coating applicator
contains more than 4.3 Ib/gal, the solids
equivalent limit shall be 10.3 Ib/gal of coating
solids delivered to the coating applicator.
(ii) 3.5 Ib/gal of coating delivered to a coating
applicator in a coating application system that
is air dried or forced warm air dried at
temperatures up to 194°F. If any coating
delivered to the coating applicator contains
more than 3.5 Ib/gal, the solids equivalent limit
shall be 6.67 Ib/gal of coating solids delivered
to the coating applicator.
(iii) 3.5 Ib/gal of coating delivered to a coating
applicator that applies extreme performance
coatings. If any coating delivered to the
coating applicator contains more than 3.5
The emission limits in
this subsection shall be
achieved by:
1. the application of
low solvent coating
technology where each
and every coating meets
the limit expressed in
pounds VOC per gallon
of coating, excluding
water, or
2. the application of
low solvent coating
technology where the
24-hour weighted
average of all coatings
on a single coating line
or operation meets the
C-22
-------
Appendix C
Summary of State and Local Rules for VOC Emissions from Metal Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit
Achieved By
counties whose actual
emissions of VOC are less
than 15 pounds per day
shall not be subject
aerospace manufacturing and rework operations; automobile
refmishing; customized top coating of automobiles and trucks,
if production is less than 35 vehicles per day; and exterior of
marine vessels.
Ib/gal, the solids equivalent limit shall be 6.67
Ib/gal of coating solids delivered to the coating
applicator.
(iv) 6.2 Ib/gal of coating delivered to a coating
applicator in
a high performance architectural coating
operation; and
(v) 3.0 Ib/gal of coating, delivered to a coating
applicator for all other coatings and coating
application systems. If any coating delivered
to the coating applicator contains more than 3.0
Ib/gal, the solids equivalent limit shall be 5.06
Ib/gal of coating solids delivered to the coating
applicator.
solids equivalent limit
expressed in pounds
VOC per gallon of
coating solids;
averaging across lines
is not allowed; or
3. control equipment,
including but not
limited to incineration,
carbon adsorption and
condensation, with a
capture system
approved by the
Director, provided that
90 percent of the
nonmethane volatile
organic compounds
which enter the control
equipment are
recovered or destroyed,
and that overall VOC
emissions do not
exceed the solids
equivalent limit,
expressed in pounds
VOC per gallon of
coating solids
IL State-wide, excluding
Chicago and Metro East
areas
The limitations of this Subpart shall not apply to:
1) Coating plants in which emissions of volatile organic
material as limited by the operating permit will not exceed 22.7
Mg/year (25 T/year), in the absence of air pollution control
equipment; or
2) Coating plants in which the total coating usage does not
exceed 9,463 1/yr (2,500 gal/yr);
3) Sources used exclusively for chemical or physical analysis
or determination of product quality and commercial acceptance
1) Clear coating 0.52 kg/L (4.3 Ib/gal)
2) Air dried coating 0.42 kg/L (3.5 Ib/gal)
3) Extreme performance coating 0.42 kg/L (3.5
Ib/gal)
4) Power driven fastener coating
A) Nail Coating Refer to limits in (j) (1),(2),
(3),and (5)
B) Staple, brad and finish nail unit fabrication
bonding coating 0.64 kg/L (5.3 Ib/gal)
Alternative compliance
options to the content
limits include the
application of an
afterburner system or
aggregation of emission
units
C-23
-------
Appendix C
Summary of State and Local Rules for VOC Emissions from Metal Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit
Achieved By
provided that:
A) The operation of the source is not an integral part of the
production process;
B) The emissions from the source do not exceed 363 kg
(SOOlbs) in any calendar month; and C) The exemption is
approved in writing by the Agency.
The limitations of this Subpart shall not apply to touch-up and
repair coatings, provided that the source-wide volume of such
coatings does not exceed 0.95 1 (1 quart) per eight-hour period
or exceed 209 1/yr (55 gal/yr) for any rolling twelve-month
period.
C) Staple, brad and finish nail incremental
fabrication lubricity coating 0.64 kg/L (5.3
Ib/gal)
D) Staple, brad and finish nail incremental
fabrication withdrawal resistance coating 0.60
kg/L (5.0 Ib/gal)
E) Staple, brad and finish nail unit fabrication
coating 0.64 kg/L (5.3 Ib/gal)
IL Metro East area
counties of Madison,
Monroe, and St. Clair
Does not apply to coating lines with a combined actual
emission of VOM from all lines at the source that never exceed
6.8 kg/day (15 Ibs/day) before the application of capture
systems and control devices.
The limitations shall not apply to touch-up and repair coatings,
provided that the source-wide volume of such coatings used
does not exceed 0.95 1 (1 quart) per eight- hour period or
exceed 209 1/yr (55 gal/yr) for any rolling twelve month period.
1) Clear coating 0.52 kg/L (4.3 Ib/gal)
2) Extreme performance coating
A) Air dried 0.42 kg/L (3.5 Ib/gal)
B) Baked 0.40 kg/L (3.3 Ib/gal)
3) Steel pail and drum interior Coating 0.52
kg/L (4.3 Ib/gal)
4) All other coatings
A) Air Dried 0.40 kg/L (3.3 Ib/gal)
B) Baked 0.34 kg/L (2.8 Ib/gal)
5) Metallic Coating
A) Air Dried 0.42 kg/L (3.5 Ib/gal)
B) Baked 0.36 kg/L (3.0 Ib/gal)
Alternative compliance
options to the content
limits include daily-
weighted average
limitation or the
application of capture
and control system.
IL Chicago area counties of
Cook, DuPage, Kane,
Lake, McHenry, and Will,
the Townships of Aux
Sable and Goose Lake in
Grundy County, and the
Township of Oswego in
Kendall County
Does not apply to coating lines with actual emissions of VOM
from all lines at the source subject that never exceed 6.8 kg/day
[15 Ibs/day] before the application of capture systems and
control devices.
The limitations shall not apply to touch-up and repair coatings,
provided that the source-wide volume of such coatings used
does not exceed 0.95 1 (1 quart) per eight-hour period or exceed
209 1/yr [55 gal/yr] for any rolling twelve month period.
1) Clear coating 0.52 kg/L (4.3 Ib/gal)
2) Extreme performance coating
A) Air dried 0.42 kg/L (3.5 Ib/gal)
B) Baked 0.40 kg/L (3.3 Ib/gal)
3) Steel pail and drum interior Coating 0.52
kg/L (4.3 Ib/gal)
4) All other coatings
A) Air Dried 0.40 kg/L (3.3 Ib/gal)
B) Baked 0.34 kg/L (2.8 Ib/gal)
Alternative compliance
options to the content
limits include daily-
weighted average
limitation or the
application of capture
and control system.
C-24
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Appendix C
Summary of State and Local Rules for VOC Emissions from Metal Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit
Achieved By
5) Marine engine coating
A) Air Dried 0.42 kg/L (3.5 Ib/gal)
B) Baked
i) Primer/Topcoat 0.42 kg/L (3.5 Ib/gal)
ii) Corrosion resistant basecoat 0.28 kg/L (2.3
Ib/gal)
C) Clear Coating 0.52 kg/L (4.3 Ib/gal)
6) Metallic Coating
A) Air Dried 0.42 kg/L (3.5 Ib/gal)
B) Baked 0.36 kg/L (3.0 Ib/gal)
IN
Facilities existing as of November 1, 1980 located in Clark,
Elkhart, Floyd, Lake, Marion, Porter, and St. Joseph Counties
and which are located at sources which have potential
emissions of ninety and seven-tenths (90.7) megagrams (one
hundred (100) tons) or greater per year of VOC.
Facilities, construction of which commences after November 1,
1980 in any county and which have potential emissions of
twenty-two and seven-tenths (22.7) megagrams (twenty-five
(25) tons) or greater per year of VOC.
Facilities existing as of July 1, 1990 located in Clark, Elkhart,
Floyd, Lake, Marion, Porter, and St. Joseph Counties and
which have actual emissions of greater than fifteen (15) pounds
of VOC per day before add-on controls.
Facilities, construction of which commences after July 1, 1990
located in any county and which have actual emissions of
greater than fifteen (15) pounds of VOC per day before add-on
controls.
This section is not applicable to the surface coating of the
following metal parts and products or to the following types of
coating: Any metal parts or products limited by other sections
1) 0.52 kg/L (4.3 Ib/gal) of coating, delivered
to a coating applicator that applies clear
coatings.
2) 0.42 kg/L (3.5 Ib/gal) of coating delivered to
a coating applicator in a coating application
system that is air dried or forced warm air dried
at temperatures up to 90 degrees C (194
degrees F).
3) 0.42 kg/L (3.5 Ib/gal) of coating delivered to
a coating applicator that applies extreme
performance coatings.
4) 0.36 kg/L (3 Ib/gal) of coating, delivered to
a coating applicator for all other coatings and
coating application systems.
C-25
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Appendix C
Summary of State and Local Rules for VOC Emissions from Metal Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit
Achieved By
of this rule; Exterior of airplanes; Automobile refinishing;
Customized top coating of automobiles and trucks, if
production is less than thirty-five (35) vehicles per day;
Exterior of marine vessels; Maintenance coatings of production
equipment; The application of adhesives or preparation of
adhesives; Lubricants used to prevent sticking of internally
moving parts; Chromium plated plastics; and The application
of coatings to burial caskets if the source is not located in or
adjacent to a county designated as nonattainment for ozone or
if the source is not located in or adjacent to Clark or Floyd
County.
KS The provisions of this
regulation shall be
applicable only to affected
facilities located in areas
which have been
identified as not meeting
the
national primary ambient
air quality standard for
ozone...
The provisions of this regulation shall be applicable to each
miscellaneous metal parts and products and metal furniture
coating application system at those facilities which have a VOC
potential contaminant emission rate equal to or greater than
three tons per year on a facility-wide basis.
This regulation shall not be applicable to the following
manufacturing categories which have miscellaneous metal parts
and products coating operations: automobiles and light duty
trucks; metal cans; customized top coating of automobiles and
trucks, if less than 35 vehicles per day are processed; and
automobile refinishing.
1. 4.3 Ib/gal of coating delivered to a coating
application system that applies clear coatings;
2. 3.5 Ib/gal of coating delivered to a coating
application system that is air-dried or forced
warm air-dried at temperatures up to 194° F;
3. 3.5 Ib/gal of coating delivered to a coating
application system that applies extreme
performance coatings except that coatings
applied to the interior of metal pails and metal
drums may contain 4.3 Ib/gal of coating.
4. 0.4 Ib/gal of coating delivered to a coating
application system that applies powder
coatings;
5. 3.0 Ib/gal of coating delivered to a coating
application system for any other coating
The emission limits
which will result from
the use of coatings
shall be achieved by:
1. application of
coatings which meet or
exceed the requirements
per coating application
system on a daily
weighted average basis;
or
2. application of
coatings with improved
transfer efficiency
demonstrated, through
testing, by methods
approved by the
department, to achieve
equivalent emissions
based on the weight of
VOC emitted per gallon
of solids applied as
would be emitted with
C-26
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Appendix C
Summary of State and Local Rules for VOC Emissions from Metal Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit
Achieved By
the coatings specified in
subsection (c) per
coating application
system on a daily
weighted average basis;
or
3. application for the
capture and reduction
of VOC emissions
through either
destruction or
collection, of a VOC
vapor processing
system demonstrated
through testing as
capable of maintaining
an overall VOC
emission reduction of at
least 90 percent. Use of
a VOC vapor
processing system shall
require that continuous
monitors be installed,
calibrated, operated,
and maintained.
4. any combination of
methods approved by
the department which
results in emissions,
when calculated as
pounds of VOC per
gallon of solids applied
per coating operation,
that are no greater on a
daily weighted average
C-27
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Appendix C
Summary of State and Local Rules for VOC Emissions from Metal Parts Coating
State
KY
KY
County/Area
VOC Limit Applies To
Existing sources which are located in a county or portion of a
county which is designated ozone nonattainment, for any
nonattainment classification except marginal.
This administrative regulation shall not apply to affected
facilities which are subject to local air pollution control district
regulations which have been approved by the cabinet and the
U.S. EPA.
An affected facility shall be exempt from this administrative
regulation if the total VOC emissions from all affected facilities
subject to this administrative regulation are less than or equal to
thirty (30) tons per year.
The surface coating of the following metal parts and products
are exempt from this rule: The exterior of airplanes and marine
vessels, but not parts for the exterior of airplanes and marine
vessels that are coated as a separate manufacturing or coating
operation; Automobile refinishing; and Customized top coating
of automobiles and trucks, if production is less than thirty -five
(35) vehicles per day.
Low-use coatings shall be exempt if the plantwide consumption
of these coatings in the aggregate is less than or equal to fifty-
five (55) gallons during the previous twelve (12) months.
Glass adhesive primer with VOC content equal to or less than
five and one-tenth (5.1) Ib/gal of glass adhesive primer
excluding water or exempt solvent or both, shall be exempt
from this administrative regulation.
New Sources Each affected facility commenced on or after
February 4, 1981 and located in a county or portion of a county
designated as nonattainment for ozone for any classification
VOC Limit
No person shall cause, allow, or permit an
affected facility to discharge into the
atmosphere more than 15 percent by weight of
the VOCs net input into the affected facility.
Exemptions. (1) An affected facility shall be
exempt from above if the VOC content of the
coating is:
(a) Less than 0.52 kg/1 of coating (4.3 Ib/gal)
delivered to applicators associated with clear
coat;
(b) Less than 0.42 kg/1 of coating (3.5 Ib/gal)
delivered to applicators associated with air or
forced air-dried items or items subject to
outdoor or harsh exposure or extreme
environmental conditions;
(c) Less than 0.36 kg/1 of coating (3.0 Ib/gal)
delivered to applicators associated with color
coat or first coat on untreated ferrous substrate;
or
(d) Less than 0.05 kg/1 of powder coating (0.4
Ib/gal) delivered to applicators associated with
no or infrequent color change, or a small
number of colors applied.
No person shall cause, allow, or permit an
affected facility to discharge into the
atmosphere more than 15 percent by weight of
Emission Limit
Achieved By
basis than those
achieved with the
appropriate coatings
specified in the limits.
C-28
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Appendix C
Summary of State and Local Rules for VOC Emissions from Metal Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit
Achieved By
except marginal; and
(b) Each affected facility commenced on or after June 24, 1992
which is part of a major source located in a county or portion of
a county designated attainment or marginal nonattainment for
ozone
(2) Each affected facility commenced on or after February 4,1981
but prior to June 24, 1992 which is part of a major source
located in a county or portion of a county designated attainment
or marginally nonattainment for ozone shall be exempt from
this administrative regulation except that control devices and
procedures required at the time it commenced shall continue to
be operated and maintained.
The provisions of this administrative regulation shall not apply
to affected facilities which are subject to local air pollution
control district regulations which have been approved by the
cabinet and the U.S. EPA.
The surface coating of the following metal parts and products
are exempt from this rule: The exterior of airplanes and marine
vessels, but not parts for the exterior of airplanes and marine
vessels that are coated as a separate manufacturing or coating
operation; Automobile refinishing; and Customized top coating
of automobiles and trucks, if production is less than thirty-five
(35) vehicles per day.
An affected facility shall be exempt from this administrative
regulation if the total VOC emissions from all affected facilities
subject to this administrative regulation are less than or equal to
twenty (20) tons per year.
Low-use coatings shall be exempt if the plantwide consumption
of these coatings in the aggregate is less than or equal to fifty-
five (55) gallons during the previous twelve (12) months.
Glass adhesive primer with VOC content equal to or less than
five and one-tenth (5.1) Ib/gal of glass adhesive primer,
the VOCs net input into the affected facility.
1) An affected facility shall be exempt from the
provisions of Section 3 of this administrative
regulation if the VOC content of coating is:
(a) Less than 0.52 kg/1 of coating (4.3 Ib/gal)
delivered to applicators associated with clear
coat;
(b) Less than 0.42 kg/1 of coating (3.5 Ib/gal)
delivered to applicators associated with air or
forced air-dried items or items subject to
outdoor or harsh exposure or extreme
environmental conditions;
(c) Less than 0.36 kg/1 of coating (3.0 Ib/gal)
delivered to applicators associated with color
coat or first coat on untreated ferrous substrate;
or
(d) Less than 0.05 kg/1 of powder coating (0.4
Ib/gal) delivered to applicators associated with
no or infrequent color change, or a small
number of colors applied.
C-29
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Appendix C
Summary of State and Local Rules for VOC Emissions from Metal Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit
Achieved By
excluding water or exempt solvent or both, shall be exempt
from this administrative regulation.
KY
Louisville, KY APCD
(Existing)
This regulation applies to each affected facility commenced
before May 20, 1981. Any affected facility that is ever subject
to this regulation will always be subject to it unless the affected
facility changes its process to one not covered by this
regulation.
Any affected facility shall be exempt if the total VOC
emissions from all affected facilities subject to this regulation
are less than or equal to five tons per year (potential emissions
prior to any add-on controls).
The surface coating of the following metal parts and products,
or operations, are exempt from this regulation:
The exterior of airplanes and marine vessels, but not parts for
the exterior of airplanes and marine vessels that are coated as a
separate manufacturing or coating operation; Automobile
refinishing; Customized top coating of automobiles and trucks
if production is less than 35 vehicles per day; Metallic surfaces
that are subject to other regulations; and Parts consisting of
both metallic and nonmetallic components, if a demonstration
is made that the limits of this rule cannot be met due to the
presence of the nonmetallic component.
A person shall not cause or allow the emission
of VOC from any affected facility resulting
from the coating of metallic surfaces in excess
of the applicable emission rate as follows:
1. 0.52 kg of VOC/1 (4.3 Ib of VOC/gal) of
coating as applied for clear coatings,
2. 0.42 kg of VOC/1 (3.5 Ib of VOC/gal) of
coating as applied for air-dried coatings,
3. 0.42 kg of VOC/1 (3.5 Ib of VOC/gal) of
coating as applied for extreme performance
coatings, or
4. 0.36 kg of VOC/1 (3.0 Ib of VOC/gal) of
coating as applied for all other coatings.
KY
Louisville, KY APCD
(New)
This regulation applies to each affected facility commenced on
or after May 20, 1981. Any affected facility that is ever subject
to this regulation will always be subject to it unless the affected
facility changes its process to one not covered by this
regulation.
Any affected facility shall be exempt from Section 3 if the total
VOC emissions from all affected facilities subject to this
regulation are less than or equal to five tons per year (potential
emissions prior to any add-on controls).
A person shall not cause or allow the emission
of VOC from any affected facility resulting
from the coating of metallic surfaces in excess
of the applicable emission rate as follows:
1. 0.52 kg of VOC/1 (4.3 Ib of VOC/gal) of
coating as applied for clear coatings,
2. 0.42 kg of VOC/1 (3.5 Ib of VOC/gal) of
coating as applied for air-dried coatings,
3. 0.42 kg of VOC/1 (3.5 Ib of VOC/gal) of
coating as applied for extreme performance
C-30
-------
Appendix C
Summary of State and Local Rules for VOC Emissions from Metal Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit
Achieved By
The surface coating of the following metal parts and products,
or operations, are exempt from this regulation:
The exterior of airplanes and marine vessels, but not parts for
the exterior of airplanes and marine vessels that are coated as a
separate manufacturing or coating operation; Automobile
refinishing; Customized top coating of automobiles and trucks
if production is less than 35 vehicles per day; Metallic surfaces
that are subject to other regulations; and Parts consisting of
both metallic and nonmetallic components, if a demonstration
is made that the limits of this rule cannot be met due to the
presence of the nonmetallic component.
coatings, or
4. 0.36 kg of VOC/1 (3.0 Ib of VOC/gal) of
coating as applied for all other coatings
LA
Any emission source using organic solvents having an emission
of organic solvents of more than 3 Ib (1.3kg) per hour or 15 Ib
(6.8 kg) per day.
Surface coating facilities on any property in Ascension, East
Baton Rouge, Iberville, Livingston, Pointe Coupee, and West
Baton Rouge parishes which when controlled have a potential
to emit at maximum production a combined weight (total from
the property) of VOC less than 10 tons in any consecutive 12
calendar months are exempt
Surface coating facilities on any property in parishes other than
Ascension, East Baton Rouge, Iberville,
Livingston, Pointe Coupee, and West Baton Rouge which when
uncontrolled have a potential to emit a combined weight of
VOC less than 100 Ib (45 kg) in any consecutive 24-hour
period are exempt.
Clear coat - 4.3/0.52 (Ib/gal, kg/L);
Air or force air dried items (not oven dried) -
3.5/0.42 (Ib/gal, kg/L);
Frequent color change and/or large numbers of
colors applied, or first coat on untreated ferrous
substrate - 3.0/0.36 (Ib/gal, kg/L);
Outdoor or harsh exposure or extreme
performance
characteristics - 3.5/0.42 (Ib/gal, kg/L);
No or infrequent color change, or small number
of colors
applied:
a. Powder Coating 0.4/0.05 (Ib/gal,
kg/L)
b. Other 3.0/0.36 (Ib/gal, kg/L)
Except for the emission
limits provided, any
emission source using
organic solvents having
an emission of organic
solvents of more than
three pounds (1.3
kilograms) per hour or
15 pounds (6.8
kilograms) per day shall
reduce the emission,
where feasible, by
incorporating one or
more of the following
control methods:
1. incineration,
provided 90 percent of
the carbon in
the organic compounds
being incinerated is
oxidized to
carbon dioxide
2. carbon adsorption of
the organic compounds;
C-31
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Appendix C
Summary of State and Local Rules for VOC Emissions from Metal Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit
Achieved By
3. any other equivalent
means as may be
approved by the
administrative
authority.
ME
Any surface coating unit, line or operation whose total actual
emissions of VOC from all coating units, lines or operations at
the surface coating facility are 15 Ib VOC per day or greater,
shall comply with the applicable emission limitations unless:
(l)The maximum theoretical emissions from all surface coating
operations are limited by permit or order of the Department to
1,666 Ib or less in any calendar month;
(2)The owner or operator of the surface coating facility subject
to this Chapter is and has at all times been in compliance with
the maximum theoretical emission limitation since the issuance
of the permit or order of the Department; and
(3) The total actual emissions from the surface coating facility
have not exceeded 1,666 Ib in any calendar month since
January 1990.
The following surface coating operations shall be exempt: 1.
Coating units, lines or operations whose total actual coatings
usage from all coating units, lines or operations at the surface
coating facility under the same surface coating category is less
than 50 gallons per year of coatings;
2. Facilities exclusively utilizing powder coatings or other
non-VOC methods of coating; and Surface coating of the
following: exterior of completely assembled aircraft; exterior of
major aircraft subassemblies; automobile, light-duty truck, and
heavy duty truck refinishing; exterior of completely assembled
marine vessels; and exterior of major marine vessel
subassemblies.
The owner or operator of a miscellaneous
metal parts and products coating unit shall not
cause or allow the release of VOC that exceeds
the following emission limitations:
1. Clear coating 0.52 kg/L
2. Steel pail & drum interior 0.52 kg/L
3. Air-dried coating 0.42 kg/L
4. Extreme performance coating 0.42
kg/L
All other coatings 0.36 kg/L
The owner or operator
of a surface coating
unit, line or operation
subject to this Chapter
shall choose one or
more of the three
compliance methods
below in order to
comply with the
applicable emission
limitations contained in
this Chapter.
A.Low solvent content
coating technology.
B.Daily-weighted
average limitation.
C. Add-on air pollution
control devices.
C-32
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Appendix C
Summary of State and Local Rules for VOC Emissions from Metal Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit
Achieved By
An owner or operator may use in the aggregate, up to 50
gallons of coatings that exceed the emissions limitations of this
Chapter, for any twelve (12) consecutive months.
MD
The provisions of this regulation apply to any metal surface
coating operation at a premises where the total VOC emissions
from all metal surface coating operations exceed 20 pounds
(9.1 kilograms) per day.
The provisions of this regulation do not apply to:
(a) Refinishing motor vehicles; (b) Customizing less than 20
motor vehicles per day; (c) Marine vessel coating operations
subject to Regulation .27 of this chapter; (d) Aerospace coating
operations subject to Regulation .13-1 of this chapter; (e) Brake
shoe coating operations subject to Regulation .13-2 of this
chapter; and (f) Structural steel coating operations subject to
Regulation .13-3 of this chapter.
High performance - 3.5 Ib/gal
Clear coating - 4.3 Ib/gal
Standard- 3.0 Ib/gal
A person may not use any coating to line the
interior of a metal drum or pail unless the VOC
content of the coating is 4.3 pounds per gallon
(0.51 kilogram per liter) of coating minus
water, or less.
MA
A person who owns, leases, operates, or controls a
miscellaneous metal parts and products coating lines, which has
the potential to emit equal to or greater than ten tons per year of
VOC.
Emissions of volatile organic compounds from coatings used in
small amounts are exempt from the emissions limitations. The
sum of all coatings exempted from the emission limitations
shall not exceed 55 gallons per year at any facility.
Any facility which has not, since January 1, 1991 emitted,
before the application of any air pollution control equipment,
one ton or more of volatile organic compounds in any one
calendar month, or ten or more tons of volatile organic
compounds in any consecutive 12 month time period is exempt
from the emissions limitations.
Clear Coatings -10.3 Ib VOC/gal
Coating line that is air-dried or forced warm-air
dried at temperatures up to 90°C - 6.7 Ib
VOC/gal
Extreme Performance Coating - 6.7 Ib
VOC/gal
All other coatings and coating lines - 5.1 Ib
VOC/gal
Units are Ib VOC/gallon solids applied
MI
This rule does not apply to a metallic surface coating line that
complies with both of the following provisions:
(a) 4.3 Ib of VOC emitted per gallon of
coating as applied for clear coatings.
C-33
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Appendix C
Summary of State and Local Rules for VOC Emissions from Metal Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit
Achieved By
(a) The coating line has an actual emission rate of VOC equal
to or less than 2,000 lb/ month and 10.0 tpy as of the effective
date of this amendatory rule. If the actual rate of emissions
from an exempted metallic surface coating line exceeds 2,000
Ib/month for a subsequent month or 10.0 tpy for a subsequent
year, then the provisions of this rule shall thereafter
permanently apply to the metallic surface coating line.
(b) VOC emissions from the coating line, when combined
with the total emissions of VOC from all other metallic surface
coating lines at the stationary source that are exempted by this
subrule, do not exceed 30.0 tpy.
This rule does not apply to any of the following:
(a) Automobile refinishing.
(b) Customized topcoating of less than 35 automobiles or
trucks, or both, per day.
(c) Coating of the exterior of airplanes when the part to be
coated has already been assembled on the airplane.
(d) Coating of the exterior of marine vessels when the part to
be coated has already been assembled on the marine vessel.
(e) Coating of a part consisting of both metallic and
nonmetallic components if a demonstration is made, to the
satisfaction of the department, that the limits of this rule cannot
be met due to the presence of the nonmetallic component.
A person may exclude low-use coatings that total 55 gallons or
less per rolling 12-month period at a stationary source from the
provisions of this rule
(b) 3.5 lb of VOC emitted per gallon of
coating, as applied for air-dried coatings.
(c) 3.5 lb of VOC emitted per gallon of
coating as applied for extreme performance
coatings.
(d) 4.8 lb of VOC emitted per gallon of
coating as applied for truck final repair
coatings.
(e) 4.9 lb of VOC emitted per gallon of
coating as applied for glass adhesion body
primer.
(f) 4.3 lb of VOC emitted per gallon of
coating as applied for steel pail and drum
interior coatings.
(g) 3.0 lb of VOC emitted per gallon of
coating, as applied for all other coatings.
MO Clay, Jackson and Platte
Counties
This regulation shall apply to any installation with an
uncontrolled potential to emit greater than 6.8 kg/day or 2.7 tpy
of VOC from industrial surface coating operations covered
under this rule. This includes any installation which does not
have an allowable VOC emission limit established under 10
CSR 10-6.060 or legally enforceable state implementation plan
revision and has uncontrolled potential emissions greater than
Clear Coat - 4.3 VOC/gal
Extreme Performance Coat and Air-Dried
Coating-3.5 VOC/gal
Other Coatings - 3.0 VOC/gal
C-34
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Appendix C
Summary of State and Local Rules for VOC Emissions from Metal Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit
Achieved By
or equal to 6.8 kg/day or 2.7 tpy.
This regulation is not applicable to the surface coating of the
following metal parts and products: 1. Exterior refinishing of
airplanes; 2. Automobile refinishing; 3. Customizing top
coating of automobiles and trucks, if production is less than
thirty-five (35) vehicles per day; and 4. Exterior of marine
vessels.
Railroad Cars, Farm Implements, Machinery
and Heavy Duty Trucks - 3.5 VOC/gal
MO Throughout St.
Louis City and Jefferson,
St. Charles,
Franklin and St. Louis
Counties.
This rule shall apply to any installation with actual emissions of
greater than 2 1/2 tons in any calendar year after December 1,
1989, of VOC from surface coating operations covered under
this rule. This includes any installation which does not have an
allowable VOC emission limit established under 10 CSR 10-
6.060 or legally enforceable state implementation plan revision,
which has actual VOC emissions of greater than 2 1/2 tons in
any calendar year after December 1, 1989. Once a
source is determined to exceed the applicability level of this
rule, it shall remain subject to this rule even if its actual
emissions drop below the applicability level.
This rule is not applicable to the surface coating of the
following metal parts and products:
1. Automobile refinishing;
2. Customizing top coating of automobiles and trucks, if
production is less than thirty-five (35) vehicles per day; and
3. Exterior of marine vessels.
Clear Coat - 4.3 Ib VOC/gal
Extreme Performance and Air Dried Coatings •
3.5 Ib VOC/gal
All Other Coatings - 3.0 Ib VOC/gal
Railroad Cars, Farm Implements, Machinery
and Heavy Duty Trucks - 3.5 VOC/gal
NC Cabarrus, Gaston,
Lincoln, Mecklenburg,
Rowan, Union, Iredell,
and Mecklenburg
Counties.
Facilities with the potential to emit 100 tons or more volatile
organic
compounds per year in the following areas:
1. Cabarrus County
2. Gaston County
3. Lincoln County
4. Mecklenburg County
5. Rowan County
6. Union County
C-35
Emissions of volatile organic compounds from
any coating line shall not exceed:
1. 10.3 pounds of volatile organic compounds
per gallon of solids delivered to a coating
applicator that applies clear coatings;
2. 6.7 pounds of volatile organic compounds
per gallon of solids delivered to a coating
applicator in a coating application system that
-------
Appendix C
Summary of State and Local Rules for VOC Emissions from Metal Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit
Achieved By
7. Davidson Township and Coddle Creek Township in Iredell
County
8. And all sources located in Mecklenburg County that were
required to comply before July 5, 1995.
utilized air or forced air driers;
3. 6.7 pounds of volatile organic compounds
per gallon of solids delivered to a coating
applicator that applies extreme performance
coatings;
4. 5.1 pounds of volatile organic compounds
per gallon of solids delivered to a coating
applicator that applies coatings of five or more
color changes or of five or more colors or
applies the coating that is the first coat on
untreated ferrous substrate; or
5. where there are less than five color changes
and less than five colors are applied:
• 0.4 pounds of volatile organic compounds
per gallon of solids delivered to a coating
applicator that applies powder coatings; or
• 5.1 pounds of volatile organic compounds
per gallon of solids delivered to a coating
applicator for any other type of coating.
Any source which has chosen to control
emissions of volatile organic compounds and
which has installed air pollution control
equipment may comply with the limits below:
1. 4.3 pounds of volatile organic compounds
per gallon of coating, excluding water and
exempt compounds, delivered to a coating
applicator that applies clear coatings;
2. 3.5 pounds of volatile organic compounds
per gallon of coating, excluding water and
exempt compounds, delivered to a coating
applicator in a coating application system that
utilized air or forced air driers;
3. 3.5 pounds of volatile organic compounds
per gallon of coating, excluding water and
C-36
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Appendix C
Summary of State and Local Rules for VOC Emissions from Metal Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit
Achieved By
exempt compounds, delivered to a coating
applicator that applies extreme performance
coatings;
4. 3.0 pounds of volatile organic compounds
per gallon of coating, excluding water and
exempt compounds, delivered to a coating
applicator that applies coatings of five or more
color changes or of five or more colors or
applies the coating that is the first coat on
untreated ferrous substrate; or
5. where there are less than five color changes
and less than five colors are applied:
• 0.4 pounds of volatile organic compounds
per gallon of coating, excluding water and
exempt compounds, delivered to a coating
applicator that applies powder coatings; or
• 3.0 pounds of volatile organic compounds
per gallon, excluding water and exempt
solvents, delivered to a coating applicator
for any other type of coating.
NH
Any miscellaneous metal coating operations have combined
potential VOC emissions during any consecutive 12-month
period which are equal or exceed 10 tons of VOCs.
(1) For a coating that is a clear or transparent
top coat, 0.52 kg VOC/1 (4.3 Ib VOC/gallon) of
coating, as applied, excluding water and
exempt compounds;
(2) For a coating that is air dried, 0.42 kg
VOC/1 (3.5 Ib VOC/gallon) of coating, as
applied, excluding water and exempt
compounds;
(3) For a coating that is used in extreme
environmental conditions, 0.42 kg VOC/1 (3.5
Ib VOC/gallon) of coating, as applied,
excluding water and exempt compounds; and
(4) For all other coatings, 0.36 kg VOC/1 (3.0
Ib VOC/gallon) of coating, as applied,
excluding water and exempt compounds.
1. Applying coatings
that meet the
established emission
limits.
2. Implementing add-
on control techniques or
a bubble and complying
with the solids-based
emission rate limits
calculated using the
procedures of Env-A
1204.04(d); or
3. Meeting either a
coatings-based or
C-37
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Appendix C
Summary of State and Local Rules for VOC Emissions from Metal Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit
Achieved By
solids-based modified
emission rate limit as
approved by the
director and EPA in
accordance with the
RACT order provisions
of Env-A 1204.05 and
Env-A 1204.06 in the
event that the source
owner or operator
demonstrates that the
specified emission rate
limits cannot be met
because of
technological or
economic reasons.
NJ
Any operation in which the total surface coating formulations
containing VOC are applied in excess of one half gallon per
hour and two and one half gallons per day.
Maximum allowable VOC content per volume
of coating minus water for Miscellaneous
Metal Parts and Products
Clear Coating - 4.3 Ibs/gal
Air Dried Coating - 3.5 Ibs/gal
Extreme Performance Coating- 3.5 Ibs/gal
All Other Coatings - 3.0 Ibs/gal
New Jersey also has an "Alternative Maximum
Allowable VOC Limit" for sources that meet
minimum transfer efficiency. Those
alternatives are listed below.
3.0 Ibs/gal - 34 percent TE
3.2 Ibs/gal - 37 percent TE
3.4 Ibs/gal - 42 percent TE
3.6 Ibs/gal - 47 percent TE
3.8 Ibs/gal - 52 percent TE
1. Coating formulation
2. VOC emissions
control apparatus
C-38
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Appendix C
Summary of State and Local Rules for VOC Emissions from Metal Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit
Achieved By
4.0 Ibs/gal - 58 percent TE
4.2 Ibs/gal - 65 percent TE
NY Statewide, New York City
Metro Area, and Orange
County Metro Area
1. Located in the New York City metropolitan area.
2. Located in the Lower Orange County metropolitan area, for
which the annual potential to emit volatile organic compounds
(VOCs) from all sources at the facility, regardless of process
type but excluding combustion installations, equal or exceeds
10 tons.
3. Located outside the New York City metropolitan area and
the Lower Orange County metropolitan area, for which the
annual potential to emit VOCs from all sources at the facility,
regardless of process type but excluding combustion
installations, equals or exceeds 10 tons.
1. Clear Coatings - 4.3 Ib/gal;
2. Force Air Dried or Air Dried at90°C-3.5
Ib/gal;
3. Extreme Performance Coatings - 3.5 Ib/gal;
4. Other miscellaneous meta coatings - 3.0
Ib/gal;
1. Point of sale
restriction
2. Control devices
3. Process specific
RACT variance is
granted by regulating
authority.
OH Statewide, and Clark,
Greene, Miami, and
Montgomery counties
specifically.
Any miscellaneous metal parts or products coating line which
uses more than:
1. For Clark, Greene, Miami, and Montgomery counties, eight
gallons of coating per day; and
2. For all other counties, ten gallons per day.
1. 4.3 pounds of VOC per gallon of coating,
excluding water and exempt solvents, or, if a
control system is employed, 10.3 pounds of
VOC per gallon of solids for a clear coating;
2. 4.0 pounds of VOC per gallon of coating,
excluding water and exempt solvents, or, if a
control system is employed, 8.8 pounds of
VOC per gallon of solids for a zinc rich primer
coating;
3. 3.5 pounds of VOC per gallon of coating,
excluding water and exempt solvents, or, if a
control system is employed, 6.7 pounds of
VOC per gallon of solids for an extreme
performance coating;
4. 3.5 pounds of VOC per gallon of coating,
excluding water and exempt solvents, or, if a
control system is employed, 6.7 pounds of
Compliant coatings or
control systems.
C-39
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Appendix C
Summary of State and Local Rules for VOC Emissions from Metal Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit
Achieved By
VOC per gallon of solids for any coating that is
dried at temperatures not exceeding two
hundred degrees Fahrenheit;
5. 4.3 pounds of VOC per gallon of coating,
excluding water and exempt solvents, or, if a
control system is employed, 10.3 pounds of
VOC per gallon of solids for the interior
coating of a steel pail or drum;
6. 3.5 pounds of VOC per gallon of coating,
excluding water and exempt solvents, or, if a
control system is employed, 6.7 pounds of
VOC per gallon of solids for the exterior
coating of a steel pail or drum;
7. 4.9 pounds of VOC per gallon of coating,
excluding water and exempt solvents, for a
glass adhesion body primer coating used for
the installation of any glass windows during
the assembly of automobiles and trucks;
8. 3.0 pounds of VOC per gallon of coating,
excluding water and exempt solvents, or, if a
control system is employed, 5.1 pounds of
VOC per gallon of solids for any coating that is
not listed above.
OK
All new installations of any equipment or processes after the
effective date of December 28, 1974, and all existing
installations of any equipment or processes in use that are
located in Tulsa County or Oklahoma County after the effective
date of June 9, 1981.
No coating operation with VOC emissions
shall use coatings that, as applied, contain
VOCs in excess of the amounts listed below.
Limits are expressed in pounds of VOC per
gallon of coating, excluding the volume of any
water and exempt organic compounds.
1. Alkyd primer - 4.8
2. Vinyls-6.0
3. NC lacquers -6.4
1. Low VOC coatings.
2. Developing a plant-
wide emission plan
instead of having each
coating line comply
with the VOC content
limitations that
sufficient reductions in
emissions of VOCs
C-40
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Appendix C
Summary of State and Local Rules for VOC Emissions from Metal Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit
Achieved By
4. Acrylics - 6.0
5. Epoxies - 4.8
6. Maintenance finishes - 4.8
7. Custom products finish - 6.5
may be obtained by
controlling other
sources within the plant
to the extent necessary
to compensate for all
excess emissions that
result from one or more
coating lines not
achieving the
limitation.
OR Portland, Medford, and
Salem Metro Areas
Sources, new or existing, whose potential to emit volatile
organic compounds of more than 10 tons per year (or 3 Ib.
VOC/hr or 15 Ib. VOC/day actual) and are located in the in the
Portland and Medford AQMA's and in the Salem SATS.
1. Clear Coatings 4.3 Ib/gal;
2. Force Air Dried or Air Dried 3.5 Ib/gal;
3. Extreme Performance Coatings 3.5 Ib/gal;
4. Other Coatings (i.e., Powder, oven dried)
3.0 Ib/gal;
5. High Performance Architectural Coatings
3.5 Ib/gal.
1. The application of
low solvent content
coating technology;
2. An incineration
system which oxidizes
at least 90.0 percent of
the nonmethane volatile
organic compounds
entering the incinerator
(VOC measured as total
combustible carbon) to
carbon dioxide and
water; or
3. An equivalent means
of VOC removal. The
equivalent means must
be approved by the
Department and will be
incorporated in the
source's Air
Contaminant Discharge
Permit or Title V
Permit, and shall not
become effective until
C-41
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Appendix C
Summary of State and Local Rules for VOC Emissions from Metal Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit
Achieved By
approved by EPA as a
source-specific SIP
revision. Other
alternative emission
controls approved by
the Department and
allowed by EPA may
be used to provide an
equivalent means of
VOC removal.
PA
Applies to a surface coating process category, regardless of the
size of the facility, which emits or has emitted VOCs into the
outdoor atmosphere in quantities greater than 3 pounds (1.4
kilograms) per hour, 15 pounds (7 kilograms) per day or 2.7
tons (2,455 kilograms) per year during any calendar year
Maximum VOC emissions in pounds VOC per
gallon coating solids:
Clear Coating -10.34
Air Dried Coating - 6.67
Extreme Performance Coating - 6.67
All Other Coatings - 5.06
These limits are equivalent to state limits in
Ibs/gal coating
1. Clear Coating - 4.3 Ibs/gal
2. Air Dried Coating - 3.5 Ibs/gal
3. Extreme Performance Coating- 3.5 Ibs/gal
4. All Other Coatings-3.0 Ibs/gal
Compliance by the use
of a low VOC coating,
a control technology
with demonstration of
capture efficiency, or an
alternative method of
compliance as approved
by the regulating
authority.
RI
Applies to all surface coating facilities for which actual
uncontrolled emissions that have been greater than 15 pounds
of volatile organic compounds in any one day after December
31, 1989.
Surface coating lines must meet the emission
limitations given below in either pounds of
VOC per gallon of coating (minus water) or in
pounds of VOC per gallon of solids,
depending on the method of compliance:
1. Clear Coating - 4.3 Ibs/gal
2. Steel pail and drum interiors - 4.3 Ibs/gal
1. Installation of an
approved control
system such that the
total emission reduction
from the controlled
coating line is 95
percent or greater over
uncontrolled volatile
organic compound
C-42
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Appendix C
Summary of State and Local Rules for VOC Emissions from Metal Parts Coating
State
SC
County/Area
Statewide except in the
following six counties:
Anderson, Bamberg,
Barnwell, Chesterfield,
VOC Limit Applies To
Affected sources include those which utilize coating
application systems for miscellaneous metal parts and products
in the following industries:
(i) Large Farm Machinery;
VOC Limit
3. Air Dried Coating - 3.5 Ibs/gal
4. Extreme Performance Coating- 3.5 Ibs/gal
5. All Other Coatings -3.0 Ibs/gal
If more than one emission limitation applies to
a specific coating, then the least stringent
emission limitation shall be applied.
1. Clear Coating - 4.3 Ibs/gal
2. Air Dried Coating - 3.5 Ibs/gal
3. Extreme Performance Coating- 3.5 Ibs/gal
Emission Limit
Achieved By
emissions, or
2. Coating
reformulation such that
the emission limitation
of Subsection 19.3.1 is
met for all coatings on
any coating lines using
this method of
compliance, or
3. Installation of
control equipment to
reduce emissions to the
equivalent of the
emission limitations of
Subsection 19.3.1 as
calculated on a solids
applied basis, or
4. Use of daily-
weighted averaging, as
determined by the
procedures in Appendix
A of this regulation, to
achieve the emissions
limitations in
Subsection 19.3.1 for
all surface coating
operations except the
coating of flat wood
paneling;
4. An alternative
equivalent method of
control as approved by
the regulating authority.
1. The application of
low solvent content
coating technology; or,
2. Incineration,
C-43
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Appendix C
Summary of State and Local Rules for VOC Emissions from Metal Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit
Achieved By
Darlington and Hampton.
(ii) Small Farm Machinery;
(iii) Small Appliances;
(iv) Commercial Machinery;
(v) Industrial Machinery;
(vi) Fabricated Metal Products;
(vii) Any other industrial category which coats metal parts or
products under the Standard
Industrial Classification Code 33 (primary metal industries), 34
(fabricated metal products), 35 (non-electric machinery), 36
(electric machinery), 37 (transportation equipment), 38
(miscellaneous instruments), and 39 (miscellaneous
manufacturing industries).
4. All Other Coatings- 3.0 Ibs/gal
provided that 90
percent of the
nonmethane volatile
organic compounds
(VOC measured as total
combustible carbon)
which enter the
incinerator are oxidized
to carbon dioxide and
water; or,
3. Carbon bed solvent
recovery system; or,
4. Alternative controls
as allowed under
Section I, Part C;
5. A capture system
must be used in
conjunction with
emission control
equipment systems.
TN Rule applies Statewide.
Sources in Davidson,
Knox, Rutherford, Shelby,
Sumner, Williamson, or
Wilson Counties may
have additional reporting
requirements. .
1. In Davidson, Rutherford, Sumner, Williamson, or Wilson
County whose actual emissions without control devices from
all miscellaneous metal parts and products coating lines within
the facility are less than 6.8 kilograms (kg) (15 pounds [lb]) of
volatile organic compounds (VOC's) per day or whose
maximum theoretical emissions from all miscellaneous metal
parts and products coating lines within the facility are less than
10 tons of VOC per year;
2. In Hamilton or Shelby County whose potential VOC
emissions from all miscellaneous metal parts and products
coating lines within the facility are more than 25 tons of VOC
per year; or
3. In any other county whose potential VOC emissions from
all miscellaneous metal parts and products coating lines within
the facility are more than 100 tons of VOC per year.
1. High performance architectural coating - 6.2
Ib/gal
2. Heavy-duty truck touch-up - 4.8 Ib/gal
3. Clear coating - 4.3 Ib/gal
4. Steel pail and drum interior - 4.3 Ib/gal
5. Air-dried coating-3.5 Ib/gal
6. Extreme performance coating - 3.5 Ib/gal
7. All other coatings - 3.0 Ib/gal
As an alternative to the
emission limits, coating
operations can meet the
following:
1.) No owner or
operator of a
miscellaneous metal
parts and products
coating line that applies
multiple coatings
during the same day
shall apply coatings on
that line during any day
whose weighted
C-44
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Appendix C
Summary of State and Local Rules for VOC Emissions from Metal Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit
Achieved By
average VOC content
exceeds the weighted
average VOC content
limit calculated using
VOC content factors
contained in the rule.
2.) An owner or
operator of a
miscellaneous metal
parts and products
coating line subject to
this rule may comply
with this rule by:
i. Installing and
operating a capture
system and a control
device on that line;
ii. Determining for
each day the overall
emission reduction
efficiency needed to
demonstrate
compliance. The
overall emission
reduction needed is the
lesser of the value
calculated according to
the procedure in this
chapter or 95 percent;
and
iii. Demonstrating each
day that the overall
emission reduction
efficiency achieved is
greater than or equal to
C-45
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Appendix C
Summary of State and Local Rules for VOC Emissions from Metal Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit
Achieved By
the overall emission
reduction efficiency
required.
(c) An owner or
operator of a
miscellaneous metal
parts and products
coating line subject to
this rule shall ensure
that:
i. A capture system and
control device are
operated at all times
that the line is in
operation, and the
owner or operator
demonstrates
compliance with this
rule through the
applicable coating
analysis and capture
system and control
device efficiency test
methods specified in
this chapter, and;
ii. The control device is
equipped with the
applicable monitoring
equipment specified in
this chapter, and the
monitoring equipment
is installed, calibrated,
operated, and
maintained according to
the vendor's
C-46
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Appendix C
Summary of State and Local Rules for VOC Emissions from Metal Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit
Achieved By
specifications at all
times the control device
is in use.
TX Brazoria, Chambers,
Collin, Dallas, Denton, El
Paso, Ellis, Fort Bend,
Galveston, Gregg, Hardin,
Harris, Jefferson, Johnson,
Kaufman, Liberty,
Montgomery, Nueces,
Orange, Parker,
Rockwall,Tarrant,
Victoria, and Waller
Counties.
Beaumont/Port Arthur,
Dallas/Fort Worth, El
Paso, and
Houston/Galveston metro
areas may have more
detailed compliance
demonstration and
reporting requirements
Surface coating operations on a property which, when
uncontrolled, would emit a combined weight of VOC of more
than 3 pounds per hour and 15 pounds in any consecutive
24-hour period
1. 4.3 pounds per gallon (0.52 kg/liter) of
coating (minus water and exempt solvent)
delivered to the application system as a clear
coat; or as an interior protective coating for
pails and drums;
2. 3.5 pounds per gallon (0.42 kg/liter) of
coating (minus water and exempt solvent)
delivered to the application system as a low-
bake coating; or that utilizes air or forced air
driers;
3. 3.5 pounds per gallon (0.42 kg/liter) of
coating (minus water and exempt solvent)
delivered to the application system as an
extreme performance coating, including
chemical milling maskants; and
4. 3.0 pounds per gallon (0.36 kg/liter) of
coating (minus water and exempt solvent)
delivered to the application system for all other
coating applications, including high-bake
coatings that pertain to MMPP.
1. Low VOC compliant
coatings
2. Emissions control
system or capture and
abatement system
3. Alternative
compliance options,
such as improved
transfer efficiency, with
approval of regulating
authority.
UT
The surface coating of miscellaneous metal parts and products
if the potential uncontrolled emissions of VOC is greater than
10 tons per year.
Applicable industries include:
(a) Large farm machinery (b) Small farm machinery
(c) Small appliance
(d) Commercial machinery
(e) Industrial machinery
(f) Fabricated metal products
(g) Any other industrial category which coats metal parts or
products under the standard Industrial Classification Code of
1. 0.52 kg/L (4.3 Ib/gal) of coating delivered to
a coating applicator that applies clear coatings;
2. 0.42 kg/L (3.5 Ib/gal) of coating delivered to
a coating applicator in a coating application
system that is air dried or forced warm air dried
at temperatures up to 90° C (194° F);
3. 0.42 kg/L (3.5 Ib/gal) of coating delivered to
a coating applicator that applies extreme
performance coatings;
4. 0.36 kg/L (3.0 Ib/gal) of coating delivered to
a coating applicator for all other coatings and
coating application systems, excluding powder
The emission limits
shall be achieved by:
(a) The application of
low solvent technology;
or
(b) An incineration
system which oxidizes
a minimum of 90
percent of the non-
methane volatile
organic compounds
(VOC measures as total
C-47
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Appendix C
Summary of State and Local Rules for VOC Emissions from Metal Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit
Achieved By
major group 33 (primary metal industries), major group 34
(fabricated metal products), major group 35 (nonelectric
machinery), major group 36 (electrical machinery), major
group 37 (transportation equipment) major group 38
(miscellaneous instruments), and major group 39
(miscellaneous manufacturing industries).
coating systems;
combustible carbon) to
carbon dioxide and
water.
VT
1. This subsection applies to any miscellaneous metal parts and
products coating unit, except automobile, light-duty and heavy-
duty truck refinishing.
2. The emission limits in this subsection do not apply to any
coating unit within a source whose actual emissions without
control devices from all miscellaneous metal part and product
coating units within the source are less than 5 tons of VOCs per
year.
3. Any source that becomes or is currently subject to this
subsection shall remain so even if emissions from the source
later fall below the applicability threshold.
1. Clear coating - 4.3 Ib/gal
2. Steel pail and drum interior coating - 4.3
Ib/gal
3. Air-dried coating-3.5 Ib/gal
4. Extreme performance coating - 3.5 Ib/gal
5. All other coatings - 3.0 Ib/gal
Low VOC coatings or
installing and operating
a control device and
demonstrating its
efficiency.
VA Areas located within
designated Emissions
Control Areas of (counties
unless other wise listed as
City):
Arlington, Fairfax,
Loudoun, Prince William,
Stafford, Alexandria City,
Fairfax City, Falls Church
City, Manassas City,
Manassas Park City,
Spotsylvania,
Fredericksburg City,
Charles City, Chesterfield
, Hanover
Henrico, Prince George,
Applies to sources of volatile organic compounds in volatile
organic compound emissions control areas that emit more than
2.7 tons per year, 15 pounds per day and three pounds per hour,
based on the actual emission rate. All volatile organic
compound emissions from purging or washing solvents shall be
considered in applying the exemption levels specified in this
subsection.
The provisions of this article do not apply to the following:
1. Coating application systems used exclusively for
determination of product quality and commercial acceptance
provided:
a. The operation is not an integral part of the production
process;
b. The emissions from all product quality coating application
systems do not exceed 400 pounds in any 30 day period; and
1. 4.3 pounds per gallon of coating, excluding
water, delivered to the coating applicator that
applies clear coatings;
2. 3.5 pounds per gallon of coating, excluding
water, delivered to a coating applicator in a
coating application system that utilizes air or
forced air driers;
3. 3.5 pounds per gallon of coating, excluding
water, delivered to a coating applicator that
applies extreme performance coatings, or
4. 3.0 pounds per gallon of coating, excluding
water, delivered to a coating applicator for all
other coatings and coating application systems.
The control technology
should consist of one of
the following:
1. Use of
electrodeposited
waterborne coatings;
2. Use of waterborne
coatings;
3. Use of high-solids
coatings;
4. Use of powder
coatings;
5. Carbon adsorption;
6. Incineration; or
7. Any technology of
equal or greater control
C-48
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Appendix C
Summary of State and Local Rules for VOC Emissions from Metal Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit
Achieved By
Colonial Heights City,
Hopewell City, Petersburg
City, Richmond City,
Gloucester, Isle of Wight,
James City, York,
Chesapeake City,
Hampton City, Newport
News City, Norfolk City,
Poquoson City,
Portsmouth City, Suffolk
City, Virginia Beach City,
Williamsburg City,
Botetourt, Frederick,
Roanoke, Roanoke City,
Salem City, Winchester
City
c. The exemption is approved by the board.
2. Vehicle refinishing operations.
3. Vehicle customized coating operations, if production is less
than 20 vehicles per day.
4. Fully assembled aircraft and marine vessel exterior coating
operations.
No owner or other person shall use any coating
application system or equipment unless
reasonable precautions are taken to minimize
the discharge or emissions from cleaning or
purging operations. Reasonable precautions
may include the following:
1. The use of capture or control devices or
both;
2. The use of detergents, high pressure water,
or other non-volatile cleaning methods;
3. The minimization of the quantity of volatile
organic compounds used to clean lines of
equipment; and
4. The adjustment of production schedules to
minimize coating changes thereby reducing the
need for frequent cleaning or purging of a
system.
efficiency when
compared to the use of
a coating complying
with 9VAC5-40-4780
A, provided such
technology is approved
by the Air Quality
Board.
WA
Applies to specified emission sources of VOCs located in or
operating within designated ozone non-attainment areas of the
state of Washington that exceed 300 kg (660 Ibs) per month of
VOC emissions.
1. 0.52 kg/L (4.3 Ib/gal) of coating delivered to
a coating applicator that applies clear coatings;
2. 0.42 kg/L (3.5 Ib/gal) of coating delivered to
a coating applicator in a coating application
system that is air dried or forced warm air dried
at temperatures up to 90° C (194° F);
3. 0.42 kg/L (3.5 Ib/gal) of coating delivered to
a coating applicator that applies extreme
performance coatings;
4. 0.36 kg/L (3.0 Ib/gal) of coating delivered to
a coating applicator for all other coatings and
coating application systems, excluding powder
coating systems; and
5. 0.05 kg/L (0.4 Ib/gal) of coating delivered to
a coating applicator for all powder coating
systems.
The emission limits
shall be achieved by:
1. The application of
low solvent coating
technology; or
2. An incineration
system that oxidizes at
least ninety percent of
the VOCs (VOC
measured as total
combustible carbon) to
carbon dioxide and
water; or
3. An equivalent means
of VOC reduction
C-49
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Appendix C
Summary of State and Local Rules for VOC Emissions from Metal Parts Coating
State
WV
WI
County/Area
Putnam County, Kanawha
County, Cabell County,
Wayne County, and Wood
Counties.
Door, Kenosha,
VOC Limit Applies To
Any new or existing source that employs surface coating
operations and that the total actual VOC emissions from all
such equipment at the facility exceed 450 pounds in any
calendar month.
It does not apply to:
1. Exterior of completely assembled aircraft;
2. Exterior of major aircraft subassemblies, if approved by the
Director and the U.S. EPA;
3. Automobile and truck refinishing;
4. Customized top coating of automobiles and trucks, if
production is less than 35 vehicles per day;
5. Exterior of completely assembled marine vessels; or
6. Exterior of major marine vessel subassemblies
Surface Coating facilities with greater than 6.8 kilograms (15
VOC Limit
1. 0.52 kg/L (4.3 Ib/gal) of coating delivered to
a coating applicator that applies clear coatings;
2. 0.42 kg/L (3.5 Ib/gal) of coating delivered to
a coating applicator in a coating application
system that is air dried or forced warm air dried
at temperatures up to 90° C (194° F);
3. 0.42 kg/L (3.5 Ib/gal) of coating delivered to
a coating applicator that applies extreme
performance coatings;
4. 0.36 kg/L (3.0 Ib/gal) of coating delivered to
a coating applicator for all other coatings and
coating application systems.
1. 0.52 kilograms per liter (4.3 pounds per
Emission Limit
Achieved By
certified by the
owner(s) or operator(s)
and approved by
regulating authority.
1. Installing and
operating a capture
system on that line;
2. Installing and
operating a control
device on that line;
3. Determining for
each day the overall
emission reduction
efficiency needed to
demonstrate
compliance. The
overall emission
reduction needed for a
day is the lesser of the
value calculated
according to the
procedure in section
43.2. for that day or 95
percent; and
d. Demonstrating each
day that the overall
emission reduction
efficiency achieved for
that day, as determined
in section 44. 3., is
greater than or equal to
the overall emission
reduction efficiency
required for that day.
1. The application of
C-50
-------
Appendix C
Summary of State and Local Rules for VOC Emissions from Metal Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit
Achieved By
Kewaunee, Manitowoc,
Milwaukee, Ozaukee,
Racine, Sheboygan,
Walworth, Washington
and Waukesha Counties.
pounds) in any one day with all emission control equipment
inoperative.
gallon) of coating, excluding water, delivered
to a coating applicator that applies clear
coatings.
2. 0.42 kilograms per liter (3.5 pounds per
gallon) of coating, excluding water, delivered
to a coating applicator that applies extreme
performance coatings.
3. 0.36 kilograms per liter (3.0 pounds per
gallon) of coating, excluding water, delivered
to a coating applicator for all other coatings.
4. 0.52 kilograms per liter (4.3 pounds per
gallon) of coating, excluding water, delivered
to a coating applicator that applies clear
coatings.
5. 0.42 kilograms per liter (3.5 pounds per
gallon) of coating, excluding water, delivered
to a coating applicator for all other coatings.
low solvent content
coating or ink
technology.
2. A vapor recovery
system which recovers
the solvent for reuse.
3. Incineration or
catalytic oxidation,
provided that 90% of
the nonmethane VOCs
(VOC measured as total
combustible carbon)
which enter the
incinerator or oxidation
unit are oxidized to
non-organic
compounds.
4. An equivalent
system or approach
demonstrated to reliably
control emissions to a
level at or below the
applicable emission
limit and approved by
the department.
WI
Statewide
1. Surface Coating facilities with greater than 6.8 kilograms
(15 pounds) in any one day with all emission control equipment
inoperative.
2. Surface coating facilities located in the county of Brown,
Calumet, Dane, Dodge, Fond du Lac, Jefferson, Outagamie,
Rock or Winnebago and which have actual emissions of VOCs
from all surface coating process within the facility of more than
10 tons per year with all emission control equipment
inoperative.
No owner or operator of a miscellaneous metal
parts or products coating line may cause, allow
or permit the emission of any VOCs in excess
of 0.78 kilograms per liter (6.50 pounds per
gallon).
1. The application of
low solvent content
coating or ink
technology.
2. A vapor recovery
system which recovers
the solvent for reuse.
3. Incineration or
catalytic oxidation,
provided that 90% of
C-51
-------
Appendix C
Summary of State and Local Rules for VOC Emissions from Metal Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit
Achieved By
3. Surface coating facilities located outside the counties of
Brown, Calumet, Dane, Dodge, Door, Fond du Lac, Jefferson,
Kenosha, Kewaunee, Manitowoc, Milwaukee, Outagamie,
Ozaukee, Racine, Rock, Sheboygan, Walworth, Washington,
Waukesha and Winnebago and which have total emissions of
VOCs from the facility, with all emission control equipment
inoperative, of more than 100 tons per year.
the nonmethane VOCs
(VOC measured as total
combustible carbon)
which enter the
incinerator or oxidation
unit are oxidized to
non-organic
compounds.
4. An equivalent
system or approach
demonstrated to reliably
control emissions to a
level at or below the
applicable emission
limit and approved by
the department.
C-52
-------
Appendix D
Summary of State and Local Rules for VOC Emissions from Plastic Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit Achieved By
AZ
Maricopa County
Plastic parts and products
Not Defined as Flexible 3.5 Ib/gal
Flexible:
Primer 4.1 Ib/gal
Color Topcoat 3.8 Ib/gal
Basecoat/Clear Coat (Combined System) for either coat
4.5 Ib/gal
CA
Antelope Valley AQMD
Plastics, glass and rubber
coatings
Emissions limits stated in coating Ib per gal
General Coatings:
One-component - 2.3
Two-component - 3.5
Military Spec. Coating:
One-component - 2.8
Two-component - 3.5
Multi-Colored Coatings -5.7
Mold Seal Coatings - 6.3
Vacuum Metalizing Coatings - 6.7
Mirror Backing:
Curtain Coated - 4.2
Roll Coated-3.6
Optical Coatings - 6.7
Electric Dissipating Coatings and Shock-Free Coatings - 3.0
Metallic Coatings - 3.5
A person may comply with by using
air pollution control equipment,
provided that the VOC emissions from
such operations or materials are
reduced in accordance with the
provisions below:
(A) The control device shall reduce
VOC emissions from an emission
collection system by at least 95
percent, by weight, or the
concentration of VOC in the output of
the air pollution control device shall be
less than 50 PPM calculated as carbon
with no dilution.
(B) The owner/operator demonstrates
that the system collects at least 90
percent, by weight, of the VOC
emissions generated by the sources of
emissions.
CA
Bay Area AQMD
Plastic Parts and Products
A person shall not apply to any plastic part or product any
coating with a VOC content in excess of 340 grams of VOC per
liter of coating applied (2.8 Ib/gal), excluding water.
A person shall not apply to any flexible part or product any
coating which has a VOC content in excess of the following
Emissions to the atmosphere are to be
controlled to an equivalent level by use
of an air pollution abatement device
with an abatement device efficiency of
at least 85%.
E-l
-------
Appendix D
Summary of State and Local Rules for VOC Emissions from Plastic Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit Achieved By
limits expressed as grams of VOC per liter (Ib VOC per gal) of
coating applied.
Flexible primer 490 grams/liter (4.1 Ib/gal)
Color topcoat 450 grams/liter (3.8 Ib/gal)
Base coat/clear coat (combined system) 540 grams/liter (4.5
Ib/gal)
A person shall not apply to any plastic part or product any
specialty coating with VOC content in excess of the following
limits, expressed as grams of VOC per liter (Ib VOC per gal) of
coating applied.
Camouflage 420 grams/liter (3.5 Ib/gal)
Conductive 325 grams/liter (2.7 Ib/gal)
Metallic Topcoat 420 grams/liter (3.5 Ib/gal)
Extreme Performance 750 grams/liter (6.2 Ib/gal)
High Gloss 420 grams/liter (3.5 Ib/gal)
Optical 800 grams/liter (6.7 Ib/gal)
Any person using the above coatings shall also comply with the
following provisions:
a. Usage is limited to 3785 liters (1000 gal) in any calendar
year.
b. Requirements of Section 8-31-401 must be satisfied.
CA
South Coast AQMD
Coating Ib per gal
Electrical dissipating and shock free coatings-3.0
Extreme performance 2-component coatings-3.5
General 1-component coating-1.0
General 2-component coating-2.5 (after 1-1-'06); 1.0 (after 1-1-
'08)
Metallic coatings-3.5
Military spec 1-component coatings-2.8
A person may comply with by using
air pollution control equipment,
provided that the VOC emissions from
such operations or materials are
reduced in accordance with the
provisions below:
(A) The control device shall reduce
VOC emissions from an emission
collection system by at least 95
E-2
-------
Appendix D
Summary of State and Local Rules for VOC Emissions from Plastic Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit Achieved By
Military spec 2-component coatings-3.5
Mold seal coatings-6.3
Multi-colored coatings-5.7
Optical coatings-0.4
Vacuum metalizing-6.7
percent, by weight, or the
concentration of VOC in the output of
the air pollution control device shall be
less than 50 PPM calculated as carbon
with no dilution.
(B) The owner/operator demonstrates
that the system collects at least 90
percent, by weight, of the VOC
emissions generated by the sources of
emissions.
DE
Limits do not apply to plastic
parts coating facilities whose
plant-wide actual emissions,
without control devices, from
all plastic parts coating
operations, are less than 6.8 kg
(151b)ofVOCsperday.
Automotive/Transportation Coating Category
I. Auto Interiors
1) High-Bake Colorcoats - 4.1 Ib VOC/gal (0.49 kg VOC/L)
2) High-Bake Primers - 3.8 Ib VOC/gal (0.46 kg VOC/L)
3) Low-Bake Colorcoats - 3.2 Ib VOC/gal (0.38 kg VOC/L)
4) Low-Bake Primers - 3.5 Ib VOC/gal (0.42 kg VOC/L)
II. Auto Exteriors (Flexible and Non-Flexible)
1) High-Bake Coatings
a) Colorcoats - 4.6 Ib VOC/gal (0.55 kg VOC/L)
b) Clearcoats - 4.3 Ib VOC/gal (0.52 kg VOC/L)
c) Primers - 5 Ib VOC/gal (0.6 kg VOC/L)
d) Primers-Non-Flexible - 4.5 Ib VOC/gal (0.54 kg VOC/L)
2) Low-Bake Coatings
a) Primers - 5.5 Ib VOC/gal (0.66 kg VOC/L)
b) Red and Black Colorcoats - 5.6 Ib VOC/gal (0.67 kg
VOC/L)
c) Colorcoats - All Other Colors - 5.1 Ib VOC/gal (0.61 kg
VOC/L)
d) Clearcoats - 4.5 Ib VOC/gal (0.54 kg VOC/L)
III. Auto Specialty
1) Vacuum Metalizing Basecoats and Texture Coatings - 5.5 Ib
VOC/gal (0.66 kg VOC/L)
As an alternative to compliance with
the emission limits of this Section, an
owner or operator may meet the
requirements of a daily-weighted
average limitation or installing control
devices
E-3
-------
Appendix D
Summary of State and Local Rules for VOC Emissions from Plastic Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit Achieved By
2) Black and Reflective Argent Coatings, Soft Specialty
Coatings, and Air Bag Cover Coatings - 5.9 Ib VOC/gal (0.71
kg VOC/L)
3) Gloss Flatteners, Vacuum Metalizing Topcoats, and Texture
Topcoat. - 6.4 Ib VOC/gal (0.77 kg VOC/L)
4) Stencil Coatings, Adhesion Primers, Ink Pad Printing
Coatings, Electrostatic Prep Coats, and Resist Coatings - 6.8 Ib
VOC/gal (0.81 kg VOC/L)
5) Headlamp Lens Coatings - 7.4 Ib VOC/gal (0.89 kg VOC/L)
Business Machine Coating Category
I. Primers -1.2 Ib VOC/gal (0.14 kg VOC/L)
II. Clearcoats 2.3 Ib VOC/gal (0.28 kg VOC/L)
III. Colorcoats/ Texture coats 2.3 Ib VOC/gal (0.28 kg VOC/L)
IV. EMI/RFI Coatings 4.0 Ib VOC/gal (0.48 kg VOC/L)
V. Specialty Coatings
1) Soft Coatings - 4.3 Ib VOC/gal (0.52 kg VOC/L)
2) Plating Resist Coatings - 5.9 Ib VOC/gal (0.71 kg VOC/L)
3) Plating Sensitizer Coatings - 7.1 Ib VOC/gal (0.85 kg
VOC/L)
IL Chicago, IL area counties
of Cook, DuPage, Kane,
Lake, McHenry, and Will,
the Townships of Aux
Sable and Goose Lake in
Grundy County, and the
Township of Oswego in
Kendall County
Does not apply to coating lines
with actual emissions of VOM
from all lines at the source
subject that never exceed 6.8
kg/day [15 Ibs/day] before the
application of capture systems
and control devices
Automotive/Transportation kg/1 (Ib/gal)
1) Interiors
A) Baked
i) Color coat 0.49 (4.1)
ii) Primer 0.46 (3.8)
B) Air Dried
i) Color coat 0.38 (3.2)
ii) Primer 0.42 (3.5)
2) Exteriors (flexible and nonflexible)
A) Baked
i) Primer 0.60 (5.0)
ii) Primer non-flexible 0.54 (4.5)
E-4
Alternative compliance options to the
content limits include daily-weighted
average limitations or the application
of capture and control system.
-------
Appendix D
Summary of State and Local Rules for VOC Emissions from Plastic Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit Achieved By
iii) Clear coat 0.52 (4.3)
iv) Color coat 0.55 (4.6)
B) Air Dried
i) Primer 0.66 (5.5)
ii) Clear coat 0.54 (4.5)
iii) Color coat (red & black) 0.67 (5.6)
iv) Color coat (others) 0.61 (5.1)
3) Specialty
A) Vacuum metallizing basecoats, texture basecoats 0.66 (5.5)
B) Black coatings, reflective argent coatings, air bag cover
coatings, and soft coatings 0.71 (5.9)
C) Gloss reducers, vacuum metallizing topcoats, and texture
topcoats 0.77 (6.4)
D) Stencil coatings, adhesion primers, ink pad coatings,
electrostatic prep coatings, and resist coatings 0.82 (6.8)
E) Head lamp lens coatings 0.89 (7.4)
Business Machine kg/1 (Ib/gal)
1) Primer 0.14 (1.2)
2) Color coat (non-texture coat) 0.28 (2.3)
3) Color coat (texture coat) 0.28 (2.3)
4) Electromagnetic interference/radio frequency interference
(EMI/RFI) shielding coatings 0.48 (4.0)
5) Specialty Coatings
A) Soft coat 0.52 (4.3)
B) Plating resist 0.71 (5.9)
C) Plating sensitizer 0.85 (7.1)
IL Metro East area,
counties of Madison,
Monroe, and St. Clair
Does not apply to coating lines
with a combined actual
emissions of VOM from all
lines at the source subject that
never exceed 6.8 kg/day (15
Ibs/day) before the application
of capture systems and control
Automotive/Transportation kg/1 (Ib/gal)
1) Interiors
A) Baked
i) Color coat 0.49 (4.1)
ii) Primer 0.46 (3.8)
B) Air Dried
Alternative compliance options to the
content limits include daily-weighted
average limitations or the application
of capture and control system.
E-5
-------
Appendix D
Summary of State and Local Rules for VOC Emissions from Plastic Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit Achieved By
devices.
i) Color coat 0.38 (3.2)
ii) Primer 0.42 (3.5)
2) Exteriors (flexible and nonflexible)
A) Baked
i) Primer 0.60 (5.0)
ii) Primer non-flexible 0.54 (4.5)
iii) Clear coat 0.52 (4.3)
iv) Color coat 0.55 (4.6)
B) Air Dried
i) Primer 0.66 (5.5)
ii) Clear coat 0.54 (4.5)
iii) Color coat (red & black) 0.67 (5.6)
iv) Color coat (others) 0.61 (5.1)
3) Specialty
A) Vacuum metallizing basecoats, texture basecoats 0.66 (5.5)
B) Black coatings, reflective argent coatings, air bag cover
coatings, and soft coatings 0.71 (5.9)
C) Gloss reducers, vacuum metallizing topcoats, and texture
topcoats 0.77 (6.4)
D) Stencil coatings, adhesion primers, ink pad coatings,
electrostatic prep coatings, and resist coatings 0.82 (6.8)
E) Head lamp lens coatings 0.89 (7.4)
Business Machine kg/1 (Ib/gal)
1) Primer 0.14 (1.2)
2) Color coat (non-texture coat) 0.28 (2.3)
3) Color coat (texture coat) 0.28 (2.3)
4) Electromagnetic interference/radio frequency interference
(EMI/RFI) shielding coatings 0.48 (4.0)
5) Specialty Coatings
A) Soft coat 0.52 (4.3)
B) Plating resist 0.71 (5.9)
C) Plating sensitizer 0.85 (7.1)
E-f
-------
Appendix D
Summary of State and Local Rules for VOC Emissions from Plastic Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit Achieved By
IN Lake, Porter, Clark or
Floyd Counties
This rule shall apply to
stationary sources located in
Lake, Porter, Clark, or Floyd
County that emit or have the
potential to emit VOCs at
levels equal to or greater than
25 tpy in Lake and Porter
Counties and 100 tpy in Clark
and Floyd Counties. This rule
shall also apply to sources that
have coating facilities which
emit or have the potential to
emit a total equal to or greater
than ten 10 tpy of VOCs in
Floyd, Clark, Lake, or Porter
County.
Affected facilities must implement one (1) of the following
emissions reduction measures on or before May 31, 1995:
(1) Achieve an overall VOC reduction from baseline actual
emissions of at least ninety-eight percent (98%) by the
documented reduction in use of VOC containing materials or
install an add-on control system that achieves an overall control
efficiency of ninety-eight percent (98%).
(2) Where it can be demonstrated by the source that control
technology does not exist that is reasonably available and both
technologically and economically feasible to achieve a ninety-
eight percent (98%) reduction in VOC emissions, a source shall
achieve an overall VOC reduction of at least eighty-one percent
(81%) from baseline actual emissions with the documented
reduction in use of VOC containing materials or install an add-
on control system that achieves an overall control efficiency of
eighty-one percent (81%).
(3) Achieve an alternative overall emission reduction with the
application of reasonably available control technology (RACT)
that has been determined as reasonably available by the U.S.
EPA and the department. A petition developed in accordance
with the procedures in 326 IAC 8-1-5 shall accompany the
request for an alternative overall emission reduction. The
petition
shall be submitted to the department on or before December 31,
1994. The department may approve an extension until
February 28, 1995, for submittal of the petition provided the
request is received by the department prior to December
31,1994.
MA
Applies to any person who
owns, leases, operates or
controls plastic parts surface
coating line(s) which in total
have the potential to emit,
before the application of air
Emission Limits for Surface Coating of Plastic Parts
using Low/no VOC Coatings (Ibs VOC/gal solids as applied)
Business Machines/Miscellaneous Plastic Parts
Color coating 3.4
Color/texture coating 3.4
Primer Coating 1.4
E-7
-------
Appendix D
Summary of State and Local Rules for VOC Emissions from Plastic Parts Coating
State
MD
County/Area
VOC Limit Applies To
pollution control equipment,
equal to or greater than 50 tons
per year of volatile organic
compounds.
This regulation applies to a
person who owns or operates
VOC Limit
EMI/RFI 8.8
Automotive Interior Parts Coating
Colorcoat 5.7
Primer 6.7
Automotive Exterior Flexible Parts Coating
Colorcoat 9.3
Clearcoat 6.7
Primer 11.6
Automotive Exterior Rigid (non-flexible) Parts Coating
Colorcoat 9.3
Clearcoat 6.7
Primer 6.7
Emission Source Emission Limitation w/ Add-on Controls (Ibs
VOC/gal solids as applied)
Business Machines/Miscellaneous Plastic Parts
Color coating 1.7
Color/texture coating 1.7
Primer Coating 1.4
EMI/RFI 1.9
Automotive Interior Parts Coating
Colorcoat 3.6
Primer 1.4
Automotive Exterior Flexible Parts Coating
Colorcoat 2.8
Clearcoat 2.4
Primer 4. 8
Automotive Exterior Rigid (non-flexible) Parts Coating
Colorcoat 2.8
Clearcoat 2.4
Primer 3. 6
Plastic vehicle parts: 3.0 Ib/gallon (0.36 kg/liter)
Decorative coating of other plastic parts: 5.9 Ib/gallon (0.70
Emission Limit Achieved By
-------
Appendix D
Summary of State and Local Rules for VOC Emissions from Plastic Parts Coating
State
MI
MO
County/Area
Kent, Livingston,
Macomb, Monroe,
Muskegon, Oakland,
Ottawa, St. Clair,
Washtenaw, and Wayne
Counties
Throughout St.
VOC Limit Applies To
any coating or printing
installation that is listed in and
that has VOC emissions equal
to or greater than 20 Ib of
VOC/day
Automobile, truck, or business
machine plastic part coating
This rule shall apply to any
VOC Limit
kg/liter)
Emissions limits for automotive and truck plastic parts coating
in pounds of volatile organic compounds allowed to be emitted
per gallon of coating (minus water) as applied:
1 . High bake coating-exterior and interior parts
Primer
(i) Flexible coating - 4.5
(ii) Nonflexible coating - 3.5
Topcoat
(i) Basecoat - 4.3
(ii) Clearcoat - 4.0
(iii) Non-basecoat/clearcoat- 4.3
2. Air-dried coating-exterior parts3
(a) Primer -4. 8
(b) Topcoat
(i) Basecoat - 5.0
(ii) Clearcoat - 4.5
(iii) Non-basecoat/clearcoat - 4.5
3. Air-dried coating-interior parts - 5.2
4. Touch-up and repair - 5.0
Emission limits for business machines plastic parts coating in
pounds of volatile organic compounds allowed to be emitted
per gallon of coating (minus water) as applied:
1. Prime -2. 9
2. Topcoat -2. 9
3. Texture coat - 2.9
4. Fog coat -2. 2
5. Touch-up and repair - 2.9
Plastic Parts 3. 5 Ib/gal
Emission Limit Achieved By
E-9
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Appendix D
Summary of State and Local Rules for VOC Emissions from Plastic Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit Achieved By
Louis City and Jefferson,
St. Charles,
Franklin and St. Louis
Counties.
installation with actual
emissions of greater than 2 1/2
tons in any calendar year after
December 1, 1989, of VOC
from surface coating operations
covered under this rule. This
includes any installation which
does not have an allowable
VOC emission limit established
under 10 CSR 10-6.060 or
legally enforceable state
implementation plan revision,
which has actual VOC
emissions of greater than 2 1/2
tons in any calendar year after
December 1, 1989. Once a
source is determined to exceed
the applicability level of this
rule, it shall remain subject to
this rule even if its actual
emissions drop below the
applicability level.
NH
Any plastic parts coating
operations have combined
potential VOC emissions
during any consecutive 12-
month period after December
31, 1989 which are equal or
exceed 50 tons of VOC.
Coating of Plastic parts for Automotive Interiors
high bake prime coating, 3.8 Ib VOC/gallon
high bake color coating, 4.1 Ib VOC/gallon
low bake prime coating, 3.5 Ib VOC/gallon
low bake color coating, 3.2 Ib VOC/gallon
Coating of Plastic parts for Automotive Exteriors
high bake flexible prime coating, 5.0 Ib VOC/gallon
highbake nonflexible prime coating, 4.5 Ib VOC/gallon
high bake color coating, 4.6 Ib VOC/gallon
highbake clear coating, 4.3 Ib VOC/gallon
low bake prime coating, 5.5 Ib VOC/gallon
Coating of non-Automotive plastic parts
prime coating, 1.2 Ib VOC/gallon
1. Applying coatings that meet the
established emission limits.
2. Implementing add-on control
techniques or a bubble and complying
with the solids-based emission rate
limits calculated using the procedures
of Env-A 1204.04(d); or
3. Meeting either a coatings-based or
solids-based modified emission rate
limit as approved by the director and
EPA in accordance with the RACT
order provisions of Env-A 1204.05 and
E-10
-------
Appendix D
Summary of State and Local Rules for VOC Emissions from Plastic Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit Achieved By
nontexture color coating, 2.3 Ib VOC/gallon
texture color coating, 2.3 Ib VOC/gallon
electromagnetic interference (EMI) shielding, 4.0 Ib
VOC/gallon
radio frequency interference (RFI) shielding, 4.0 Ib
VOC/gallon
soft coatings, 4.3 Ib VOC/gallon
plating resist, 5.9 Ib VOC/gallon
plating sensitizer, 7.1 Ib VOC/gallon
Env-A 1204.06 in the event that the
source owner or operator demonstrates
that the specified emission rate limits
cannot be met because of technological
or economic reasons.
NY Statewide, New York City
Metro Area, and Orange
County Metro Area
1. All facilities performing
surface coating located in the
New York City metropolitan
area.
2. All facilities performing
surface coating located in the
Lower Orange County
metropolitan area, for which
the annual potential to emit
volatile organic compounds
(VOCs) from all sources at the
facility, regardless of process
type but excluding combustion
installations, equal or exceeds
25 tons.
3. All facilities performing
surface coating located outside
the New York City
metropolitan area and the
Lower Orange County
metropolitan area, for which
the annual potential to emit
VOCs from all sources at the
facility, regardless of process
Maximum permitted pounds of VOC per gallon of coating less
water and excluded VOC for Plastic Parts Coating:
1. Color topcoat -3.8 Ib/gal;
2. Clear Coat - 4.8 Ib/gal
1. Point of sale restriction
2. Control devices
3. Process specific RACT variance is
granted by regulating authority.
E-ll
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Appendix D
Summary of State and Local Rules for VOC Emissions from Plastic Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit Achieved By
type but excluding combustion
installations, equals or exceeds
50 tons.
TN Davidson,
Rutherford, Sumner,
Williamson and Wilson
Counties
Any plastic parts coating line
within a facility whose
potential VOC emissions from
all plastic parts coating lines
within the facility are greater
than 25 tons of volatile organic
compounds (VOC's) per year
and coats plastic components
for automotive or other
transportation equipment
including interior and/or
exterior parts for automobiles,
trucks, tractors, lawn mowers,
other mobile equipment,
business machines, medical
equipment housing,
entertainment equipment
housing, miscellaneous plastic
parts, including toys, musical
equipment housing, sporting
goods, outdoor signs, and
architectural structures such as
doors, floors, and window
frames.
Emission limits listed below in Ibs/gal:
1. Business machines, Medical equipment housing,
Entertainment equipment housing and
Miscellaneous plastic parts:
Primer-1.20
Color-2.30
Color/texture - 2.30
EMI/RFI - 2.50
2. Automotive Coating:
(i)Auto Interior:
High Bake Colorcoat -4.1
High Bake Primer-3.8
Low Bake Colorcoat - 3.2
Low Bake Primer - 3.5
(ii) Auto Exterior
Flexible/Nonflexible
(unless otherwise noted)
High Bake Colorcoat - 4.7
High Bake Clearcoat - 4.3
High Bake Primer-5.0
(Flexible)
High Bake Primer-4.5
(Nonflexible)
Low Bake Colorcoat - 5.6
(Red & Black)
Low Bake Colorcoat -5.1
Low Bake Primer - 5.5
Low Bake Clear - 4.5
An owner or operator of a plastic
coating line subject to this rule may
comply with this rule by:
(i) Installing and operating a capture
system and a control device on that
line;
(ii) Determining for each day the
overall emission reduction efficiency
needed to demonstrate compliance.
The overall emission reduction needed
is the lesser of the value calculated
according to the procedure in this
chapter or 95 percent;
(iii) Demonstrating each day that the
overall emission reduction efficiency
achieved is greater than or equal to the
overall emission reduction efficiency
required.
An owner or operator of a plastic
coating line subject to this rule electing
to comply with an add on control shall
ensure that:
(i) A capture system and control
device are operated at all times that the
line is in operation, and the owner or
operator demonstrates compliance with
this rule through the applicable coating
analysis and capture system and
E-12
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Appendix D
Summary of State and Local Rules for VOC Emissions from Plastic Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit Achieved By
Automotive Specialty
(i) Group A-l Coatings: - 5.5
Vacuum Metallizing, Basecoats, Texture Basecoats
(ii) Group A-2 Coatings: - 5.9
Black and Reflective, Argent, Air Bag Cover Coatings, Soft
Coatings
(iii) Group B Coatings: - 6.4
Gloss Reducers, Vacuum Metallizing Topcoats, Texture
Topcoats
(iv) Group C Coatings: - 6.8
Stencil, Adhesion Primer/Promoter, Ink Pad, Electrostatic Prep,
Resist
(v) Headlight Lens Coating - 7.4
control device efficiency test methods
described in the rule.
(ii) The control device is equipped
with the applicable monitoring
equipment, and the monitoring
equipment is installed, calibrated,
operated, and maintained according to
the vendor's specifications at all times
the control device is in use.
WI Kewaunee, Kenosha,
Manitowoc, Milwaukee,
Ozaukee, Racine,
Sheboygan, Washington
or Waukesha counties
Applies to plastic parts coating
at facilities which are located in
Kenosha, Milwaukee, Ozaukee,
Racine, Washington or
Waukesha county and have
maximum theoretical emissions
of VOC from the facility,
excluding any maximum
theoretical emissions of VOC
of 25 tons per year or more,
and plastic parts coating at
facilities that are located in
Kewaunee, Manitowoc, or
Sheboygan county and have
maximum theoretical emissions
of VOC from the facility,
excluding any maximum
theoretical emissions of VOC
of 100 tons per year or more.
VOC content limitations for coatings
used in plastic parts coating in pounds/gallons of coating,
excluding water, as applied
(a) Automotive/transportation
1. Interiors
a. Baked
Prime coats - 3.8
Other nonclear coatings -4.1
b. Air dried
Prime coats - 3.5
Other nonclear coatings - 4.9
2. Exteriors
a. Baked
Nonelastomeric prime coats - 4.5
Elastomeric prime coats - 5.0
Clear coats -4.3
Other coatings - 4.6
b. Air dried
1. The application of low solvent
content coating or ink technology.
2. A vapor recovery system which
recovers the solvent for reuse.
3. Incineration or catalytic oxidation,
provided that 90% of
the nonmethane VOCs (VOC
measured as total combustible carbon)
which enter the incinerator or
oxidation unit are oxidized to
non-organic compounds.
4. An equivalent system or approach
demonstrated to reliably
control emissions to a level at or below
the applicable emission limit and
approved by the department.
E-13
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Appendix D
Summary of State and Local Rules for VOC Emissions from Plastic Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit Achieved By
Prime coats - 5.5
Clear coats -4.5
Other coatings, red and black - 5.6
Other coatings - 5.1
3. Specialty
a. Adhesive primers - 6.8
b. Air bag cover coatings - 5.9
c. Anti-glare safety coatings - 6.4
d. Electrostatic prep coatings - 6.8
e. Head lamp lens coatings - 7.4
f. Pad printing coatings - 6.8
g. Reflective argent coatings - 5.9
h. Resist coatings - 6.8
i. Soft coatings - 5.9
j. Stencil coatings - 6.8
k. Texture basecoats - 5.5
1. Texture topcoats - 6.4
m. Vacuum metallizing basecoats - 5.5
n. Vacuum metallizing topcoats - 6.4
(b) Business machine
1. Prime coats -2.9
2. Other nonclear coatings - 2.9
3. Specialty
a. Electromagnetic interference/radio frequency interference
(EMI/RFI) shielding coatings - 4.0
b. Resist coatings - 5.9
c. Sensitizer coatings -7.1
d. Soft coatings -4.3
(c) Miscellaneous categories
1. Air cleaner covers - 6.0
2. Building exterior molding, trim, shutters and weather
E-14
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Appendix D
Summary of State and Local Rules for VOC Emissions from Plastic Parts Coating
State
County/Area
VOC Limit Applies To
VOC Limit
Emission Limit Achieved By
stripping - 6.2
3. Building interior molding and trim - 2.5
4. Cosmetic cases
a. Opaque coatings - 4.8
b. Other coatings - 5.9
5. Personal hygiene razors
a. Soft coatings - 5.5
b. Other coatings - 6.2
6. Signs
a. Mask coatings - 0.8
b. Opaque coatings - 5.9
c. Other coatings - 6.5
7. Smoke detector covers - 6.2
E-15
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Appendix E
Summary of California Air District Requirements for VOC Emissions from Pleasure Craft Surface Coating
County/Area
VOC Limit Applies to
VOC Limit
Emission Limit Achieved By
Bay Area Air
Quality
Management
District
(BAAQMD)
RULE 43 -
SURFACE
PREPARATION
AND COATING
OF MARINE
VESSELS
Applies to coating of any marine
vessel, component or structure
intended for exposure to a marine
environment.
VOC limits listed below in Ibs/gal:
Anti-Foulant - 3.3
Heat Resistant (Air Dried) - 3.5
Heat Resistant (Baked) - 3.0
High-Gloss (Air Dried) - 2.8
High-Gloss (Baked) - 2.3
High-Temperature - 4.2
Inorganic Zinc - 2.8
Navigational Aids - 4.6
Pretreatment Wash Primer - 3.5
Specialty Interior - 2.8
Sealant Coat for Wire Spray Aluminum -5.1
Special Marking -4.1
Tack Coat-5.1
Repair and Maintenance Thermoplastic - 2.8
Extreme High-Gloss (Air Dried) - 4.1
Extreme High-Gloss (Baked) - 3.5
Low Activation Interior Coating - 3.5
Unless emissions to the atmosphere are
controlled by an approved emission control
system with an overall abatement efficiency of at
least 85%, any person using solvent for surface
preparation or cleanup or any person mixing,
using or disposing of coatings containing organic
solvent:
(i) Shall use closed containers for the storage or
disposal of cloth or paper used for solvent
surface preparation and cleanup.
(ii) Shall close containers of coating, catalyst,
and fresh or spent solvent when not in use.
(iii) Shall not use organic solvent for the cleanup
of spray equipment, including paint lines, with a
VOC content in excess of 50 g/1 (0.42 Ibs/gal)
unless either (i) the solvent is pressurized though
spray equipment with atomizing air off or
dispensed from a small non-atomizing container,
and collected and stored in a closed container
until recycled or properly disposed of offsite, or
(ii) a spray gun washer subject to and in
compliance with the requirements of Regulation
8, Rule 16 is used.
E-l
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Mojave Desert Air
Quality
Management
District
(MDAQMD)
RULE 1106-
MARINE
COATING
OPERATIONS
Applies to all marine coating
operations of both commercial
boats and ships, pleasure craft and
their appurtenances, and to the
coating of buoys and oil drilling
rigs, or their parts and
components intended for the
marine environments, which
occur within the Mojave Desert
Air Quality Management District.
Air-Dried VOC limits listed below in g/L, followed by
baked VOC limits in g/L in parenthases where
applicable.
1. Exteriors
Elastomeric Adhesives with 15%, by weight, Natural or
Synthetic Rubber - 730
Extreme Performance - 420 (360)
Extreme High-Gloss - 490 (420)
Finish Primer/Surfacer - 420
General Use - 340 (275)
Heat Resistant - 420 (360)
High Build Primer/Surfacer - 340
High-Gloss - 340 (275)
High-Temperature - 500
Inorganic Zinc (high-build) - 340
Metallic Heat Resistant - 530
Mist-610
Nonskid - 340
Organic Zinc - 360
Pretreatment Wash Primer - 780 (780)
Repair and Maintenance of Thermoplastics - 550 (550)
Sealant for Wire-Sprayed Aluminum - 610
Special Marking - 490 (490)
Specialty Interior - 340
Tack Coat-610
Teak Primer - 775
Topcoats - Extreme High Gloss - 490
Topcoats - High Gloss - 420
Weld-through Preconstruction Primer - 340
2. Antifoulant
Non-Pleasure Craft - 400
Aluminum Substrate for Pleasure Craft - 560
Other Substrates for Pleasure Craft - 330
3. Miscellaneous Parts
Air Flask-340
Antenna - 530
Navigational Aids - 340
A person shall not apply any coatings to marine
vessels and appurtenances subject to the
provisions of this Rule, unless the coating is
applied with equipment properly operated
according to the manufacturer's suggested
guidelines, and using one of the following
application methods:
(a) Electrostatic attraction; or
(b) High Volume Low Pressure (HVLP) spray
equipment; or
(c) Dip coat; or
(d) Hand application methods; or
(e) Other coating application methods as are
demonstrated to have a transfer efficiency at least
equal to one of the above methods, and which are
used in a manner that the parameters under which
they were tested are permanent features of the
method. Prior to their use, such coating
applications shall be approved in writing by the
APCO.
E-2
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Ventura County
Air Pollution
Control District
(VCAPCD)
RULE 74.24.1 -
PLEASURE
CRAFT
COATING AND
COMMERCIAL
BOATYARD
OPERATIONS
Applies to any person who
applies, specifies the use of, or
supplies coatings for pleasure
craft, and their parts or
components. The provisions of
this rule also apply to any person
who applies, specifies the use of,
or supplies marine coatings that
are used at a commercial
boatyard.
ROC limits in grams of ROC per liter of coatings less
water and exempt organic compounds:
1. Exteriors
Finish Primer(One-Component) - 420
Finish Primer(Two-Component) - 420
High Build Primer Surfacer - 340
Marine Deck Sealant Primer - 760
Pretreatment Wash Primer - 780
Topcoats (One-Component) - 490
Topcoats (Two-Component) - 650
Other Coatings - 420
2. Antifoulant
Aluminum Substrates - 580
Other Substrates - 400
1. No person shall apply any coating to an entire
vessel or their exterior parts and components
unless one of the following methods is properly
used:
a. Hand application methods
b. High-Volume, Low-Pressure (HVLP)
application
c. Any other coating application method which
has been demonstrated to be capable of achieving
a transfer efficiency of at least 65 percent.
2. No person shall use ROC-containing materials
which have more than 200 grams of ROC per
liter of material for surface preparation.
South Coast Air
Quality
Management
District
(SCAQMD)
RULE 1106.1-
PLEASURE
CRAFT
COATING
OPERATIONS
Applies to all coating operations
of pleasure craft, or their parts and
components, for the purpose of
refmishing, repairing,
modification, or manufacturing
such craft. Also applies to
establishments engaged in
activities described in the United
States Office of Management and
Budget's 1987 Standard Industrial
Classification Manual, under
Standard Industrial Classification
(SIC) codes 3732 - Boat Building
and Repairing and 4493 -
Marinas.
VOC limits listed below in g/L:
1. Topcoats
Extreme High Gloss - 490
High Gloss - 420
2. Antifoulant
Aluminum Substrate - 560
Other Substrates - 330
3. Exteriors
Pretreatment Wash Primers - 780
Finish Primer/Surfacer - 420
High Build Primer Surfacer - 340
Teak Primer - 775
Others - 420
1. Solvent cleaning of coating application
equipment, parts, products, tools, machinery,
equipment, and general work areas, and the
storage and disposal of VOC-containing
materials used in solvent cleaning operations,
shall be carried out in accordance with Rule 1171
(Solvent Cleaning Operations).
2. A person shall not apply pleasure craft
coatings subject to the requirements of this rule
with a coating containing carbon tetrachloride or
any of the Group II exempt compounds as
defined in paragraph (b)(4) except for: methylene
chloride; perchloroethylene; cyclic, branched, or
linear, completely methylated siloxanes (VMS);
or parachlorobenzotrifluoride (PCBTF).
E-3
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San Diego County
Air Pollution
Control District
(SDCAPCD)
RULE 67.18-
MARINE
COATING
OPERATIONS
Applies to marine coating
operations including the coating
of marine and fresh water vessels,
oil drilling platforms, navigational
aids and component parts; and
structures intended for exposure
to a marine environment.
Air-Dried VOC limits listed below in g/L, followed by
baked VOC limits in g/L in parenthases where
applicable.
Air Flask - 340
Antenna Coating - 340
Antifoulant Coating (except for pleasure craft) - 400
Antifoulant Coating (for pleasure craft) - 330 (Effective
June 13, 1995)
Finish Primer 600
Heat Resistant Coating - 420 (360)
High Gloss Coating - 420 (360)
High Solids Epoxy Coating - 280
High Temperature Coating - 500
Impregnating Sealer - 700
Inorganic Zinc Coating - 340
Low Activation Interior Coating - 420
Mist Coating-610
Navigational Aids Speciality Coating - 550
Organic Zinc Coating - 340
Pleasure Craft Topcoat - 650
Preconstruction Zinc Primer - 650
Pretreatment Wash Primer - 420
Primer Surfacer - 340
Radar Exterior Topcoat - 340
Sealing Coat for Thermal Spray Aluminum - 610
Special Marking Coating - 420
Specialty Interior Coating - 340
Tack Coat-610
Thermoplastic Coatings used in a Repair and
Maintenance Coating Operation - 550
In lieu of complying with provisions of
Subsections (d)(l), (d)(2), (d)(3), and/or (d)(4) of
this rule, a person may use an air pollution
control system which:
(i) has been installed in accordance with an
Authority to Construct; and
(ii) includes an emission collection system which
captures organic gaseous emissions, including
emissions associated with applicable coating,
equipment cleaning, and surface preparation
operations, and transports the captured emissions
to an air pollution control device; and
(iii) has a combined emissions capture and
control device efficiency of at least 85 percent by
weight.
E-4
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Antelope Valley
Air Quality
Management
District
(AVAQMD)
RULE 1106.1 »
PLEASURE
CRAFT
COATING
OPERATIONS
Applies to all coating operations
of pleasure craft, or their parts and
components, for the purpose of
refmishing, repairing,
modification, or manufacturing
such craft. This rule shall also
apply to establishments engaged
in activities described in the
United States Office of
Management and Budget's 1987
Standard Industrial Classification
Manual, under Standard Industrial
Classification (SIC) codes 3732 -
Boat Building and Repairing and
4493 - Marinas.
VOC limits listed below in g/L:
1. Topcoats
Extreme High Gloss - 490
High Gloss - 420
2. Antifoulant
Aluminum Substrate - 560
Other Substrates -150
3. Exteriors
Pretreatment Wash Primers - 780
Finish Primer/Surfacer - 420
High Build Primer Surfacer - 340
Teak Primer - 775
Others - 420
A person shall not apply coatings subject to this
rule unless the coating is applied by use of one of
the following methods:
(i) Hand Application Methods, or
(ii) High Volume, Low Pressure (HVLP) Spray,
or
(iii) such other alternative spray application
method as is demonstrated, in accordance with
the provisions of paragraph (e)(2), to be capable
of achieving equivalent or better transfer
efficiency than the application method listed in
subparagraph (c)(2)(B), and for which written
approval of the District's Executive Officer has
been obtained to use this method.
E-5
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Appendix F
Summary of State and Local Requirements for Coating Application Equipment
State
County/Area
Requirement
Applies To
Requirement
AZ
Maricopa County
Application methods for
surface coatings
A person shall employ one of the following for all applications of surface coating containing more than 2 pounds of
VOC per gallon (240 g/L) minus exempt compounds:
302.1 A low pressure spray gun; or
302.2 An electrostatic system; or
302.3 A system that atomizes principally by hydraulic pressure, including "airless" and "air assisted airless"; or
302.4 Non-atomizing or non-spraying application methods, such as but not limited to dipping, rolling, or brushing; or
302.5 Any method which is approved by the Administrator of the Federal EPA and the Control Officer as having a
transfer efficiency of 65% or greater.
CA
Antelope Valley
AQMD
A person shall not apply VOC-containing coatings to metal parts and products subject to the provisions of this rule
unless the coating is applied with properly operating equipment according to an operating procedure specified by the
equipment manufacturer or the Executive Officer, or designee, and by the use of one of the following methods:
(A) Electrostatic attraction, or
(B) Flow coat, or
(C) Dip coat, or
(D) Roll coater, or
(E) High-Volume, Low-Pressure (HVLP) Spray, or
(F) Hand Application Methods, or
(G) Such other coating application methods as are demonstrated to the Executive Officer, or designee, using EPA
approved procedures, specified in paragraph (f)(4) of this rule, to be capable of achieving at least 65 percent transfer
efficiency and for which written approval of the Executive Officer, or designee, has been obtained.
CA
Bay Area AQMD
Surface Preparation and
Coating of Plastic Parts
and Products, Spray
Application Equipment
Any person who uses spray application equipment to apply coatings to miscellaneous metal parts or products within
the District shall use one or more of the following high transfer efficiency application methods, unless emissions to
the atmosphere are controlled by an approved emission control system with an overall abatement efficiency of at
least 85 percent:
1. High-Volume, Low-Pressure (HVLP) Spray, operated in accordance with the manufacturer's recommendations; or
2. Electrostatic spray, operated in accordance with the manufacturer's recommendations; or
3. Detailing gun; or
4. Any other coating spray application that achieves an equivalent transfer efficiency compared to the spray
application methods listed above. Prior written approval from the APCO shall be obtained for each alternative
method used.
CA
Kern County
AQMD
Application Equipment
No person shall coat any metal part or product subject to provisions of this Rule unless one of the following methods
is used:
1. Brush, dip, or roll coating conducted in accordance with equipment manufacturer's recommendations,
2. Electrostatic or electrodeposition application conducted in accordance with manufacturer's recommendations,
3. High Volume Low Pressure (HVLP) spray equipment operated in accordance with equipment manufacturer's
recommendations,
H-
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Appendix F
Summary of State and Local Requirements for Coating Application Equipment
State
County/Area
Requirement
Applies To
Requirement
4. Other application method demonstrated to achieve at least 65% transfer efficiency, for example, flow or
continuous coating.
CA
Mojave Desert
AQMD
Metal Parts & Products
Coating Operations
A person shall not apply any coatings to Metal Parts and Products subject to the provisions of this Rule, unless the
coating is applied with equipment properly operated according to manufacturer's suggested guidelines, and using one
of the following application methods:
(i) Electrostatic attraction; or
(ii) High Volume Low Pressure (HVLP) Spray equipment; or
(iii) Dip coat; or
(iv) Hand Application Methods; or
(v) Other coating application methods as are demonstrated to have a Transfer Efficiency at least equal to one of the
above methods, and which are used in such a manner that the parameters under which they were tested are permanent
features of the method. Prior to their use, such coating applications shall be approved in writing by the APCO.
CA Sacramento Metro
AQMD
Application equipment for
miscellaneous metal parts
or product coatings
A person shall not apply to any miscellaneous metal part or product any coating unless one of the following
application methods is used:
1. RollCoater
2. Dip Coat
3. Electrostatic Spray
4. Flow Coat
5. High-Volume Low-Pressure (HVLP) Application Equipment
6. Low-Volume Low-Pressure (LVLP) Application Equipment
7. Hand Application Equipment, such as brush or roller
9. Any other equivalent method which has been approved in writing by the Air Pollution Control Officer and the
U.S. Environmental Protection Agency
CA
San Diego AQMD
Application equipment for
miscellaneous metal parts
or product coatings
No coatings shall be applied unless one of the following application methods is used:
1. Electrostatic spray application, or
2. Flow coat application, or
3. Dip coat application, or
4. High-volume low-pressure (HVLP) spray application, or
5. Roll coat, or
6. Hand application methods, or
7. Other coating application methods that are demonstrated to have a transfer efficiency at least equal to one of the
above application methods, and which are used in such a manner that the parameters under which they were tested
are permanent features of the method. Such coating application methods shall be approved in writing prior to use by
the Air Pollution Control Officer.
CA San Joaquin Valley
AQMD
Application equipment for
miscellaneous metal parts
or product coatings
An operator shall not use or operate any coating application equipment on any metal parts and products subject to the
provisions of this rule unless one of the following methods is used:
1. Electrostatic application;
2. Electrodeposition;
H-
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Appendix F
Summary of State and Local Requirements for Coating Application Equipment
State
County/Area
Requirement
Applies To
Requirement
3. High-Volume, Low-Pressure (HVLP) spray,
1. High-Volume, Low-Pressure (HVLP) spray equipment shall be operated in accordance with the
manufacturer's recommendations.
2. For HVLP spray guns manufactured prior to January 1, 1996, the end user shall demonstrate that the gun
meets HVLP spray equipment standards. Satisfactory proof will be either in the form of manufacturer's
published technical material or by a demonstration using a certified air pressure tip gauge, measuring the air
atomizing pressure dynamically at the center of the air cap and at the air horns.
3. A person shall not sell or offer for sale for use within the District any HVLP spray gun without a
permanent marking denoting the maximum inlet air pressure in psig at which the gun will operate within the
parameters specified in Section 3.0.
4. Flow coating;
5. Roll coating;
6. Dip coating;
7. Brush coating; or
8. Continuous coating;
9. Any other coating application method which is demonstrated to the APCO to be capable of achieving at least 65
percent transfer efficiency. The transfer efficiency shall be determined in accordance with the SCAQMD method
"Spray Equipment Transfer Efficiency Test Procedure for Equipment User," May 24, 1989, as contained in Section
6.3.8. Prior written approval from the APCO shall be obtained for each coating application method to be used
pursuant to Section 5.7.9.
10. In lieu of compliance with 1 through 9, an operator may control emissions from application equipment with a
VOC emission control system that meets the requirements of Section 5.4.
CA
South Coast
AQMD
Application equipment for
miscellaneous metal parts
or product coatings
A person shall not apply VOC-containing coatings to metal parts and products subject to the provisions of this rule
unless the coating is applied with equipment operated according to the equipment manufacturer specifications, and by
the use of one of the following methods:
(A) Electrostatic application, or
(B) Flow coat, or
(C) Dip coat, or
(D) Roll coat, or
(E) High-Volume, Low-Pressure (HVLP) Spray, or
(F) Hand Application Methods, or
(G) Such other coating application methods as are demonstrated to the Executive Officer to be capable of achieving a
transfer efficiency equivalent or better to the method listed in subparagraph (c)(l)(E) and for which written approval
of the Executive Officer has been obtained.
CA
South Coast
AQMD
Application equipment for
plastic, rubber, leather and
glass coatings
A person shall not apply coatings unless the coating is applied with equipment operated according to the
manufacturer's specifications, and by the use of one of the following methods:
(A) Electrostatic application; or
(B) Flow coater; or
H-
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Appendix F
Summary of State and Local Requirements for Coating Application Equipment
State
County/Area
Requirement
Applies To
Requirement
(C) Roll coater; or
(D) Dip coater; or
(E) Hand application methods; or
(F) High-volume, low-pressure (HVLP) spray; or
(G) Such other coating application methods as are demonstrated to the Executive Officer to be capable of achieving
at least equivalent or better transfer efficiency to the method listed in subparagraph (c)(4)(F), using District approved
procedures and for which written approval of the Executive Officer has been obtained.
MA
Statewide
Paint Spray Booths
Spray guns shall utilize one of the following methods of spray application and be maintained and operated in
accordance with the recommendations of the manufacturer:
1. Electrostatic spray application; or
2. High Volume Low Pressure (HVLP) spray application; or
3. Any other coating application method that achieves a transfer efficiency equivalent to electrostatic or HVLP spray
application and is approved by the Department in writing.
NH
Statewide
Plastic parts coating
operations, except touch-
up and repair activities.
One of the following control techniques shall be used:
(1) High volume-low pressure (HVLP) spray;
(2) Electrostatic spray;
(3) Zinc-arc spray;
(4) Air-assisted airless spray;
(5) Airless spray; or
(6) A flow coating technique.
H-
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Appendix G
Summary of State and Local Requirements for VOC Emissions from Cleaning
Operations
State County/Area
Requirement
Applies To
Requirement
CA
Antelope
Valley
AQMD
Product
Cleaning
During
Manufacturing
Process Or
Surface
Preparation For
Coating,
Adhesive, Or
Ink
Application;
Cleaning of
Coatings, or
Adhesives
Application
Equipment
Product Cleaning During Manufacturing Process Or Surface
Preparation For Coating, Adhesive, Or Ink Application:
General: 70 g/1 (0.58 Ib/gal)
Cleaning of Coatings, or Adhesives Application Equipment:
950 g/1 (7.9 Ib/gal), and 35 mm Hg @ 20oC (68oF) VOC
Composite Partial Pressure
A person may comply with by using air pollution control
equipment, provided that the VOC emissions from such
operations or materials are reduced in accordance with the
provisions below:
(A) The control device shall reduce VOC emissions from an
emission collection system by at least 95 percent, by weight, or
the concentration of VOC in the output of the air pollution
control device shall be less than 50 PPM calculated as carbon
with no dilution.
(B) The owner/operator demonstrates that the system collects at
least 90 percent, by weight, of the VOC emissions generated by
the sources of emissions.
CA
Bay Area
AQMD
Solvent
Evaporative
Loss
Minimization
Unless emissions to the atmosphere are controlled by an
approved emission control system with an overall abatement
efficiency of at least 85%, any person using organic solvent for
surface preparation and cleanup or any person mixing, using or
disposing of coatings containing organic solvent:
1. Shall use closed containers for the storage or disposal of
cloth or paper used for solvent surface preparation and cleanup.
2. Shall not use organic solvent for the cleanup of spray
equipment including paint lines with a VOC content in excess
of 50 g/1 (0.42 Ibs/gal) unless either
(i) the solvent is pressurized though spray equipment with the
atomizing air off or dispensed from a small non-atomizing
container, and collected and stored in a closed container until
recycled or properly disposed of offsite, or
(ii) a spray gun washer subject to and in compliance with the
requirements of Regulation 8, Rule 16 [Solvent cleaning
operations] is used.
3. Shall close containers of coating, catalyst or solvent when
not in use.
CA
Kern AQMD
Surface
Preparation and
Equipment
Cleanup
No person shall conduct surface preparation or equipment
cleanup for activities subject to provisions of this rule unless the
following VOC limits are met and methods are used:
1. Surface Cleaning: No material shall be used containing
VOC in excess of 200 grams per liter (1.7 Ib/gal) of material to
remove dirt, oils, or other contaminants prior to application of
surface coatings or adhesives.
H-
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Appendix G
Summary of State and Local Requirements for VOC Emissions from Cleaning
Operations
State County/Area
Requirement
Applies To
Requirement
2. Stripping: No material shall be used containing VOC in
excess of 200 grams per liter (1.7 Ib/gal) of material to strip any
coating.
3. Cleaning of Coatings Application Equipment:
Solvents used for cleaning of coatings application equipment
shall comply with both limits specified below:
a. Solvent shall have a VOC content of 950 grams or less per
liter (7.9 Ib/gal) of material; and
b. Solvent shall have a VOC composite partial pressure of 35
mm Hg or less at 20°C (68°F).
CA
Mojave
Desert
AQMD
The
requirements of
this Section
shall apply to
any person
using solvent
for Surface
Preparation,
cleanup, and
paint removal,
including paint
spray
equipment.
A person shall not use VOC-containing materials for the
cleanup of application equipment used in coating operations,
unless such material is collected in a closed container when not
in use; and
(i) The application equipment is disassembled and cleaned in an
enclosed system during the washing, rinsing and draining
processes; or
(ii) The application equipment or equipment parts are cleaned in
a container which is open only when being accessed for adding,
cleaning, or removing application equipment or when cleaning
material is being added, provided the cleaned equipment or
equipment parts are drained to the container until dripping
ceases; or
(iii) Other application equipment cleaning methods that are
demonstrated to be as effective as the equipment described
above in minimizing emissions of VOC to the atmosphere are
used, provided that the device has been approved in writing
prior to use by the APCO.
(c) A person shall not use VOC-containing materials for Surface
Preparation unless:
(i) The material contains 200 grams or less of VOC per liter of
material (1.67 pounds per gallon); or
(ii) The material has an initial boiling point of 190°C (374°F) or
greater; or
(iii) The material has a total VOC vapor pressure of 20 mm Hg
or less, at 20°C (68°F).
(d) A person shall use closed, nonabsorbent containers for the
storage or disposal of cloth, paper, or any other absorbent
material used for solvent Surface Preparation and cleanup.
CA
Northern
Sierra
AQMD
Surface
Preparation and
Equipment
Cleanup;
Cleaning-
Devices and
No person shall conduct surface preparation or equipment
cleanup for activities unless the following VOC limits are met
and methods are used:
1. Surface Cleaning: No material shall be used containing VOC
in excess of 200 grams per liter (1.7 Ib/gal) of material to
remove dirt, oils, or other contaminants prior to application of
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Appendix G
Summary of State and Local Requirements for VOC Emissions from Cleaning
Operations
State County/Area Requirement Requirement
Applies To
CA
Sacramento
Metro
AQMD
Methods
Surface
Preparation,
Cleanup, and
surface coatings or adhesives.
2. Stripping: No material shall be used containing VOC in
excess of 200 grams per liter (1.7 Ib/gal) of material to strip any
coating.
3. Cleaning of Coatings Application Equipment: Solvents used
for cleaning of coatings application equipment shall comply
with both limits specified below:
a. Solvent shall have a VOC content of 950 grams or less per
liter (7.9 Ib/gal) of material; and
b. Solvent shall have a VOC composite partial pressure of 35
mm Hg or less at 20°C (68°F).
No person shall perform solvent cleaning operations unless one
of the following cleaning devices or methods is used:
a. Wipe Cleaning.
b. Spray bottles or containers with a maximum capacity of 16
fluid ounces from which solvents are applied without a
propellant induced force.
c. Cleaning equipment having a closed solvent container during
cleaning operations, except when depositing and removing
objects to be cleaned, and closed during nonoperation except
during maintenance and repair of the cleaning equipment itself.
d. Remote reservoir cold cleaner operated in conformance with
Rule 410.3;
e. System totally enclosing guns, cups, nozzles, bowls, and
other parts during washing, rinsing, and draining procedures.
f . Non-atomized solvent flow method collecting cleaning
solvent in a container or a collection system closed except for
solvent collection openings and, if necessary, openings to avoid
excessive pressure build-up inside the container.
g. Solvent flushing method discharging solvent into a closed
container, except for solvent collection openings and, if
necessary, openings to avoid excessive pressure build-up inside
the container. Discharged solvent from such equipment shall be
collected in containers without atomizing into open air. Solvent
may be flushed through the system by air or hydraulic pressure,
or by pumping.
3.5 Storage and Disposal Requirements
Regardless of VOC content, all VOC-containing materials used
in solvent cleaning operations, such as solvents, and cloth and
paper moistened with solvents, shall be stored in non-absorbent,
non-leaking containers kept closed at all times except when
filling or emptying.
Any person subject to this rule shall comply with the following
requirements:
1 . Closed containers shall be used for the disposal of cloth,
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Appendix G
Summary of State and Local Requirements for VOC Emissions from Cleaning
Operations
State County/Area
Requirement
Applies To
Requirement
Storage
paper, or sponges used for surface preparation, cleanup, and
coating removal.
2. VOC-containing materials shall be stored in containers,
which are closed when not in use, and shall be disposed of in a
manner that the VOC are not emitted into the atmosphere.
3. Except for electrostatic spray guns, a person shall not use
VOC-containing materials for the cleanup of application
equipment used in miscellaneous metal parts and products
coating operations, unless the equipment is cleaned in an
enclosed gun cleaner, or the VOC content of the material used
does not exceed 72 grams per liter (0.6 pounds per gallon).
4. Spray gun nozzles only, may be soaked in solvent-based
materials for cleaning, provided the container (not to exceed
five (5) gallons in size) is kept tightly covered at all times
except when accessing the container.
5. Effective October 1, 1998, a person shall not perform
product cleaning or surface preparation with a material
containing VOC in excess of 72 grams per liter (0.6 pounds per
gallon).
CA
San Diego
AQMD
Surface
Preparation and
Cleanup
Solvents;
Cleaning of
Application
Equipment
A person shall not use VOC-containing materials for surface
preparation or cleanup unless:
(i) The material contains 200 grams or less of VOC per liter of
material; or
(ii) The material has an initial boiling point of 190°C (374° F)
or greater; or
(iii) The material has a total VOC vapor pressure of 20 mm Hg
or less, at 20°C (68°F).
A person shall not use VOC containing materials for the
cleaning of application equipment used in operations subject to
this rule unless:
(i) The cleaning material contains 200 grams or less of VOC per
liter of material; or
(ii) The cleaning material has an initial boiling point of 190°C
(374°F) or greater; or
(iii) The cleaning material has a total VOC vapor pressure of 20
mm Hg or less, at 20°C (68°F); or
(iv) The cleaning material is flushed or rinsed through the
application equipment in a contained manner that will minimize
evaporation into the atmosphere; or
(v) The application equipment or equipment parts are cleaned in
a container which is open only when being accessed for adding,
cleaning, or removing application equipment or when cleaning
material is being added, provided the cleaned equipment or
equipment parts are drained to the container until dripping
ceases; or
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Appendix G
Summary of State and Local Requirements for VOC Emissions from Cleaning
Operations
State County/Area
Requirement
Applies To
Requirement
(vi) A system is used that totally encloses the component parts
being cleaned during the washing, rinsing, and draining
processes; or
(vii) Other application equipment cleaning methods that are
demonstrated to be as effective as any of the equipment
described above in minimizing the emissions of VOC to the
atmosphere, provided that the device has been tested and
approved prior to use by the Air Pollution Control Officer.
CA
San Joaquin
Valley
AQMD
Product Cleaning During Manufacturing Process or Surface
Preparation for Coating Application: 50 g/1 (0.42 Ib/gal)
After 9/21/08: 25 g/1 (0.21 Ib/gal)
Cleaning of Coating Application Equipment: 550 g/1 (4.6 Ib/gal)
After 9/21/08: 25 g/1 (0.21 Ib/gal)
CA
San Luis
Obispo
AQMD
Solvent
Disposal and
clean-up
a. Surface Preparation, Clean-up or Coating Removal: Closed
containers approved by the local fire agency shall be used for
the storage or disposal of solvent-containing cloth or paper used
for surface preparation, clean-up or coating removal.
Containers shall be nonabsorbent.
b. All VOC containing materials, including but not limited to
fresh or spent solvent, coatings, and reducers, shall be kept in
closed containers when not in use.
c. Spray Equipment Clean-up Limitation: No person shall
use materials containing VOCs for spray equipment cleanup
unless:
-An enclosed gun washer is properly used for cleaning,
or
-A gun washer, approved by the APCO, is properly
used for cleaning and the composite vapor pressure of
materials used is less than 45 mm Hg (0.87 psi) at a
temperature of 20 degrees Celsius (68 F°).
d. Disposal and Evaporation of Solvents: No person shall
dispose of a total of more than one (1) quart per day of any
organic solvent by means which will permit the evaporation of
such solvent into the atmosphere. The volume of organic
solvent in any disposed material containing organic solvent
shall be included in the above total.
CA
Santa
Barbara
All reactive organic compounds-containing materials, used or
unused, including but not limited to surface coatings, thinners,
cleanup solvents, or surface preparation materials shall be stored
in closed containers and opened only during extraction or
introduction of material for mixing, use or storage.
CA
South Coast
AQMD
Product Cleaning During Manufacturing Process Or Surface
Preparation For Coating, Adhesive, Or Ink Application General
25 g/1 (0.21 Ib/gal)
Cleaning of Coatings, or Adhesives Application Equipment:
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Appendix G
Summary of State and Local Requirements for VOC Emissions from Cleaning
Operations
State County/Area
Requirement
Applies To
Requirement
25 g/1 (0.21 Ib/gal)
Cleaning Devices and Methods Requirements
A person shall not perform solvent cleaning unless one of the
following cleaning devices or methods is used:
(A) Wipe cleaning;
(B) Closed containers or hand held spray bottles from which
solvents are applied without a propellant-induced force;
(C) Cleaning equipment which has a solvent container that can
be, and is closed during cleaning operations, except when
depositing and removing objects to be cleaned, and is closed
during non-operation with the exception of maintenance and
repair to the cleaning equipment itself;
(D) Cleaning device which is listed in the Office of Operations'
manual "Alternative Devices for Rule 1171 Compliance" dated
July 1, 1991. The Executive Officer shall periodically update
the manual to identify any additional cleaning devices
determined by the Executive Officer to result in equivalent or
lower emissions;
(E) Remote reservoir cleaner used pursuant to the provisions of
paragraph (c)(3);
(F) Non-atomized solvent flow method where the cleaning
solvent is collected in a container or a collection system which
is closed except for solvent collection openings and, if
necessary, openings to avoid excessive pressure build-up inside
the container; or
(G) Solvent flushing method where the cleaning solvent is
discharged into a container which is closed except for solvent
collection openings and, if necessary, openings to avoid
excessive pressure build-up inside the container. The
discharged solvent from the equipment must be collected into
containers without atomizing into the open air. The solvent may
be flushed through the system by air or hydraulic pressure, or by
pumping.
CA
Ventura
AQMD
Surface
Preparation and
Clean-up
No person shall use any material which contains more than 70
grams of ROC per liter of material for substrate surface
cleaning. Substrate surface cleaning performed in a vapor
degreaser shall not be subject to this ROC content limit.
No person shall use organic solvent for cleanup unless:
-An enclosed gun washer or "low emission spray gun cleaner"
that has been approved in writing by the APCO is properly used
for spray equipment cleaning, and
The ROC composite partial pressure of organic solvent used for
cleanup, including spray equipment cleaning, is less than 45 mm
Hg at 20 oC.
CO
Fugitive
1. Control techniques and work practices shall be implemented
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Appendix G
Summary of State and Local Requirements for VOC Emissions from Cleaning
Operations
State County/Area
Requirement
Applies To
Requirement
emission
control
at all times to reduce VOC emissions from fugitive sources.
Control techniques and work practices include, but are not
limited to:
a. tight-fitting covers for open tanks;
b. covered containers for solvent wiping cloths;
c. proper disposal of dirty cleanup solvent.
2. Emissions of organic material released during clean-up
operations, disposal, and other fugitive emissions shall be
included when determining total emissions, unless the source
owner or operator documents that the VOCs are collected and
disposed of in a manner that prevents evaporation to the
atmosphere.
FL
All volatile organic compound emissions from solvent washings
shall be considered in the emission limitations unless the solvent
is directed into containers that prevent evaporation into the
atmosphere.
GA
All VOC emissions from solvent washings shall be considered
in the emission limitations unless the solvent is directed into
containers that prevent evaporation into the atmosphere.
IN
Solvent sprayed from application equipment during cleanup or
color changes shall be directed into containers. Such containers
shall be closed as soon as such solvent spraying is complete,
and the waste solvent shall be disposed of in such a manner that
evaporation is minimized.
ME
Handling,
Storage and
Disposal of
Materials
Containing
VOC at any
subject surface
coating facility
A. Vapor-tight containers shall be used for the storage of spent
or fresh VOC and for the storage or disposal of cloth or paper
impregnated with VOC that are used for surface preparation,
clean up or coating removal.
B. The use of VOC is prohibited for cleanup operations unless
equipment is used to collect the cleaning compounds and to
minimize their evaporation to the atmosphere. The owner or
operator of a surface coating unit, line or operation subject to
this Chapter shall comply with the following work practice
standards:
(1) Spray gun cleaning. The owner or operator of a surface
coating unit, line or operation subject to this Chapter shall
collect all organic solvent used to clean spray guns into a
normally closed container.
(2) Line cleaning. The owner or operator of a surface coating
unit, line or operation subject to this Chapter shall pump or
drain all organic solvent used for line cleaning into a normally
closed container.
(3) Spray booth cleaning. The owner or operator of a surface
coating unit, line or operation subject to this Chapter shall not
use compounds containing more than 8.0 percent by weight of
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Appendix G
Summary of State and Local Requirements for VOC Emissions from Cleaning
Operations
State County/Area
Requirement
Applies To
Requirement
VOC for cleaning spray booth components other than
conveyers, continuous coaters and their enclosures, and/or metal
filters, unless the spray booth is being refurbished. If the spray
booth is being refurbished, that is, the spray booth coating or
other material used to cover the booth is being replaced, the
affected source shall use no more than 1.0 gallon of organic
solvent to prepare the booth prior to applying the booth coating.
(4) Washoff operations. The owner or operator of a surface
coating unit, line or operation subject to this Chapter shall
control emissions from washoff operations by:
(a) Using normally closed tanks for washoff; and
(b) Minimizing dripping by tilting or rotating the part to drain as
much organic solvent as possible.
MA
For surface preparation, prior to coating, the VOC content of
any surface preparation solution shall not exceed 1.67 pounds
per gallon. This requirement is not applicable to cleanup
solutions which are re-used as thinners/reducers for coatings.
However, for surface preparation of plastic parts the VOC
content of the surface preparation solution shall not exceed 6.5
pounds of VOC per gallon.
Spray guns shall be cleaned in a device that:
1. minimizes solvent evaporation during the cleaning, rinsing,
and draining operations;
2. recirculates solvent during the cleaning operation so that the
solvent is reused; and,
3. collects spent solvent in a container with a tight-fitting cover
so that it is available for proper disposal or recycling.
NH
Miscellaneous
Metal Parts
Surface
Coating
emission limits
All VOC emissions from solvent washing shall be considered in
the emission limitations unless the solvent is directed into
containers that prevent evaporation into the atmosphere.
NY
Statewide
Handling,
storage and
disposal of
volatile organic
compounds.
Within the work area(s) associated with a coating line, the
owner or operator of a facility subject to this Part must:
(a) use closed, non-leaking containers to store or dispose of
cloth or other absorbent applicators impregnated with VOC
solvents that are used for surface preparation, cleanup or coating
removal;
(b) store in closed, non-leaking containers spent or fresh VOC
solvents to be used for surface preparation, cleanup or coating
removal;
(c) not use VOC solvents to cleanup spray equipment unless
equipment is used to collect the cleaning compounds and to
minimize VOC evaporation;
1. an enclosed spray gun cleaning system that is kept
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Appendix G
Summary of State and Local Requirements for VOC Emissions from Cleaning
Operations
State County/Area
Requirement
Applies To
Requirement
closed when not in use;
2. non-atomized discharge of VOC solvent into a paint
waste container that is kept closed when not in use;
3. disassembling and cleaning of the spray gun in a vat
that is kept closed when not in use; or
4. atomized spray into a paint waste container that is fitted
with a device designed to capture atomized VOC solvent
emissions.
(d) not use open containers to store or dispense surface coatings
and/or inks unless production, sampling, maintenance or
inspection procedures require operational access. This
provision does not apply to the actual device or equipment
designed for the purpose of applying a coating material to a
substrate. These devices may include, but are not limited to:
spray guns, flow coaters, dip tanks, rollers, knife coaters, and
extrusion coaters;
(e) not use open containers to store or dispose of spent surface
coatings, or spent VOC solvents;
(f) minimize spills during the handling and transfer of coatings
and VOC solvents;
OK
VOC-
containing
materials used
for clean up on
miscellaneous
metal parts
surface coating
facilities with a
potential to
emit more than
10 tons per
year of VOC
from coating
operations.
VOC-containing materials used for clean up shall be considered
in the VOC content limits for miscellaneous metal parts surface
coating unless:
1. the VOC containing materials are maintained in a closed
container when not in use;
2. closed containers are used for the disposal of cloth or paper
or other materials used for surface preparation and cleanup;
3. the spray equipment is disassembled and cleaned in a VOC
vat and the vat is closed when not in use; or,
4. the VOC containing materials used for the clean up of spray
equipment are sprayed directly into closed containers.
TX
Brazoria,
Chambers,
Collin,
Dallas,
Denton, El
Paso, Ellis,
Fort Bend,
Galveston,
Gregg,
Hardin,
Harris,
Jefferson,
Equipment
cleaning
related
miscellaneous
metal parts and
products
surface coating
operations.
All VOC emissions from non-exempt solvent washings shall be
included in determination of compliance with the emission
limitations for miscellaneous metal parts surface coating (TAG
§115.421) unless the solvent is directed into containers that
prevent evaporation into the atmosphere.
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Appendix G
Summary of State and Local Requirements for VOC Emissions from Cleaning
Operations
State County/Area
Requirement
Applies To
Requirement
Johnson,
Kaufman,
Liberty,
Montgomery,
Nueces,
Orange,
Parker,
Rockwall,
T arrant,
Victoria, and
Waller
Counties.
WA
Equipment
cleaning
related
miscellaneous
metal parts and
products
surface coating
operations.
All VOC emissions from solvent washings shall be considered
in the emission limitations for miscellaneous metal parts surface
coating (WAC 173-490-205 (2)(a) unless the solvent is directed
into containers that prevent evaporation into the atmosphere.
Waste solvent shall be stored in covered containers and returned
to the supplier or to a firm which processes solvents for
disposal.
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Appendix H
Recommended Coating Category Definitions
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Recommended Coating Category Definitions and Related Definitions for Metal and
Plastic Part Surface Coating:
Separate definitions are recommended for automotive/transportation and business
machine plastic parts coating, pleasure craft coating, and for motor vehicle
materials.
If a coating does not meet a specific coating category definition, then it can be
assumed to be a general use coating and the VOC limit for "general coating" or
"other coating" is recommended to apply.
AIR-DRIED coating means a coating that is cured at a temperature below 90°C (194°F).
BAKED COATING means a coating that is cured at a temperature at or above 90°C
(194°F).
CAMOUFLAGE COATING means a coating used, principally by the military, to
conceal equipment from detection.
CLEAR COATING means a colorless coating which contains binders, but no pigment,
and is formulated to form a transparent film.
DRUM means any cylindrical metal shipping container larger than 12 gallons capacity
but no larger than 110 gallons capacity.
ELECTRIC DISSIPATING COATING means a coating that rapidly dissipates a high-
voltage electric charge.
ELECTRIC-INSULATING VARNISH means a non-convertible-type coating applied to
electric motors, components of electric motors, or power transformers, to provide
electrical, mechanical, and environmental protection or resistance.
EMI/RFI SHIELDING means a coating used on electrical or electronic equipment to
provide shielding against electromagnetic interference, radio frequency interference, or
static discharge.
ETCHING FILLER means a coating that contains less than 23 percent solids by weight
and at least 1/2-percent acid by weight, and is used instead of applying a pretreatment
coating followed by a primer.
EXTREME HIGH-GLOSS COATING means a coating which, when tested by the
American Society for Testing Material Test Method D-523 adopted in
1980, shows a reflectance of 75 or more on a 60° meter.
EXTREME-PERFORMANCE COATING means a coating used on a metal or plastic
surface where the coated surface is, in its intended use, subject to the following:
(A) Chronic exposure to corrosive, caustic or acidic agents, chemicals, chemical fumes,
chemical mixtures or solutions; or
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(B) Repeated exposure to temperatures in excess of 250° F; or
(C) Repeated heavy abrasion, including mechanical wear and repeated scrubbing with
industrial grade solvents, cleansers or scouring agents.
Extreme performance coatings include, but are not limited to, coatings applied to
locomotives, railroad cars, farm machinery, and heavy duty trucks.
HEAT-RESISTANT COATING means a coating that must withstand a temperature of at
least 400°F during normal use.
HIGH-PERFORMANCE ARCHITECTURAL COATING means a coating used to
protect architectural subsections and which meets the requirements of the Architectural
Aluminum Manufacturer Association's publication number AAMA 2604-05 (Voluntary
Specification, Performance Requirements and Test Procedures for High Performance
Organic Coatings on Aluminum Extrusions and Panels) or 2605-05 (Voluntary
Specification, Performance Requirements and Test Procedures for Superior Performing
Organic Coatings on Aluminum Extrusions and Panels).
HIGH-TEMPERATURE COATING means a coating that is certified to withstand a
temperature of 1000°F for 24 hours.
MASK COATING means thin film coating applied through a template to coat a small
portion of a substrate.
METALLIC COATING means a coating which contains more than 5 grams of metal
particles per liter of coating as applied. "Metal particles" are pieces of a pure elemental
metal or a combination of elemental metals.
MILITARY SPECIFICATION COATING means a coating which has a formulation
approved by a United States Military Agency for use on military equipment.
MOLD SEAL COATING means the initial coating applied to a new mold or a repaired
mold to provide a smooth surface which, when coated with a mold release coating,
prevents products from sticking to the mold.
MULTI-COLORED COATING means a coating which exhibits more than one color
when applied, and which means packaged in a single container and applied in a single
coat.
MULTI-COMPONENT COATING means a coating requiring the addition of a separate
reactive resin, commonly known as a catalyst or hardener, before application to form an
acceptable dry film.
ONE-COMPONENT COATING means a coating that is ready for application as it comes
out of its container to form an acceptable dry film. A thinner, necessary to reduce the
viscosity, is not considered a component.
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OPTICAL COATING means a coating applied to an optical lens.
PAN-BACKING COATING means a coating applied to the surface of pots, pans, or
other cooking implements that are exposed directly to a flame or other heating elements.
PREFABRICATED ARCHITECTURAL COMPONENT COATINGS are coatings
applied to metal parts and products which are to be used as an architectural structure.
PRETREATMENT COATING means a coating which contains no more than 12 percent
solids by weight, and at least 1/2-percent acid, by weight, is used to provide surface
etching, and is applied directly to metal surfaces to provide corrosion resistance,
adhesion, and ease of stripping.
REPAIR COATING means a coating used to re-coat portions of a previously coated
product which has sustained mechanical damage to the coating following normal coating
operations.
SHOCK-FREE COATING means a coating applied to electrical components to protect
the user from electric shock. The coating has characteristics of being of low capacitance
and high resistance, and having resistance to breaking down under high voltage.
SILICONE-RELEASE COATING means any coating which contains silicone resin and
is intended to prevent food from sticking to metal surfaces such as baking pans.
SOLAR-ABSORBENT COATING means a coating which has as its prime purpose the
absorption of solar radiation.
STENCIL COATING means an ink or a pigmented coating which is rolled or brushed
onto a template or stamp in order to add identifying letters, symbols and/or numbers.
TOUCH-UP COATING means a coating used to cover minor coating imperfections
appearing after the main coating operation.
TRANSLUCENT COATING means a coating which contains binders and pigment, and
is formulated to form a colored, but not opaque, film.
TWO-COMPONENT COATING means a coating requiring the addition of a separate
reactive resin, commonly known as a catalyst, before application to form an acceptable
dry film.
VACUUM-METALIZING COATING means the undercoat applied to the substrate on
which the metal is deposited or the overcoat applied directly to the metal film. Vacuum
metalizing/physical vapor deposition (PVD) is the process whereby metal is vaporized
and deposited on a substrate in a vacuum chamber.
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Recommended Coating Category Definitions and Related Definitions For
Automotive/Transportation and Business Machine Plastic Parts Surface Coating:
ADHESION PRIME means a coating that is applied to a polyolefm part to promote the
adhesion of a subsequent coating. An adhesion prime is clearly identified as an adhesion
prime or adhesion promoter on its accompanying material safety data sheet.
AIR-DRIED COATING means a coating that is dried by the use of air or forced warm air
at temperatures up to 90 degrees Celsius (194 degrees Fahrenheit).
BLACK COATING means a coating which meets both of the following criteria:
(i) Maximum lightness: 23 units.
(ii) Saturation: less than 2.8, where saturation equals the square root of A2 + B2.
These criteria are based on Cielab color space, 0/45 geometry. For spherical geometry,
specular included, maximum lightness is 33 units.
BUSINESS MACHINE means a device that uses electronic or mechanical methods to
process information, perform calculations, print or copy information or convert sound
into electrical impulses for transmission, including devices listed in standard industrial
classification numbers 3572, 3573, 3574, 3579, and 3661 and photocopy machines, a
subcategory of standard industrial classification number 3861.
CLEAR COATING means a coating which lacks color and opacity or is transparent and
which uses the undercoat as a reflectant base or undertone color.
COATING OF PLASTIC PARTS OF AUTOMOBILES AND TRUCKS means the
coating of any plastic part that is or shall be assembled with other parts to form an
automobile or truck.
COATING OF PLASTIC PARTS OF BUSINESS MACHINES means the coating of any
plastic part that is or shall be assembled with other parts to form a business machine.
ELECTROSTATIC PREP COAT means a coating that is applied to a plastic part solely
to provide conductivity for the subsequent application of a prime, a topcoat, or other
coating through the use of electrostatic application methods. An electrostatic prep coat is
clearly identified as an electrostatic prep coat on its accompanying material safety data
sheet.
FLEXIBLE COATING means any coating that is required to comply with engineering
specifications for impact resistance, mandrel bend, or elongation as defined by the
original equipment manufacturer.
FOG COAT means a coating that is applied to a plastic part for the purpose of color
matching without masking a molded-in texture. A fog coat shall not be applied at a
thickness of more than 0.5 mils of coating solids.
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GLOSS REDUCER means a coating that is applied to a plastic part solely to reduce the
shine of the part. A gloss reducer shall not be applied at a thickness of more than 0.5 mils
of coating solids.
HIGH BAKE coating means a coating which is designed to cure only at temperatures
Of more than 90 degrees Celsius (194 degrees Fahrenheit).
RED COATING means a coating which meets all of the following criteria:
(i) Yellow limit: the hue of hostaperm scarlet.
(ii) Blue limit: the hue of monastral red-violet.
(iii) Lightness limit for metallics: 35% aluminum flake.
(iv) Lightness limit for solids: 50% titanium dioxide white.
(v) Solid reds: hue angle of-11 to 38 degrees and maximum lightness of 23 to 45 units.
(vi) Metallic reds: hue angle of-16 to 35 degrees and maximum lightness of 28 to 45
units.
These criteria are based on Cielab color space, 0/45 geometry. For spherical geometry,
specular included, the upper limit is 49 units. The maximum lightness varies as the hue
moves from violet to orange. This is a natural consequence of the strength of the
colorants, and real colors show this effect.
RESIST COAT means a coating that is applied to a plastic part before metallic plating to
prevent deposits of metal on portions of the plastic part.
STENCIL COAT means a coating that is applied over a stencil to a plastic part at a
thickness of 1 mil or less of coating solids. Stencil coats are most frequently letters,
numbers, or decorative designs.
TEXTURE COAT means a coating that is applied to a plastic part which, in its finished
form, consists of discrete raised spots of the coating.
VACUUM-METALIZING COATINGS means topcoats and basecoats that are used in
the vacuum-metalizing process.
Recommended Coating Category Definitions and Related Definitions for Pleasure
Craft Surface Coating:
ANTIFOULANT COATING means any coating applied to the underwater portion of a
pleasure craft to prevent or reduce the attachment of biological organisms, and registered
with the United States Environmental Protection Agency (EPA) as a pesticide under the
Federal Insecticide, Fungicide, and Rodenticide Act (7 United States Code Section 136).
CLEAR WOOD FINISHES are clear and semi-transparent topcoats applied to wood
substrates to provide a transparent or translucent film.
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EXTREME HIGH GLOSS COATING means any coating which achieves at least 95
percent reflectance on a 60o meter when tested by ASTM Method D 523-89.
FINISH PRIMER/SURF ACER means a coating applied with a wet film thickness of less
then 10 mils prior to the application of a topcoat for purposes of providing corrosion
resistance, adhesion of subsequent coatings, a moisture barrier, or promotion of a uniform
surface necessary for filling in surface imperfections.
HIGH BUILD PRIMER/SURF ACER means a coating applied with a wet film thickness
of 10 mils or more prior to the application of a topcoat for purposes of providing
corrosion resistance, adhesion of subsequent coatings, or a moisture barrier, or promoting
a uniform surface necessary for filling in surface imperfections.
HIGH GLOSS COATING means any coating which achieves at least 85 percent
reflectance on a 60o meter when tested by ASTM D 523-89.
PLEASURE CRAFT are vessels which are manufactured or operated primarily for
recreational purposes, or leased, rented, or chartered to a person or business for
recreational purposes. The owner or operator of such vessels shall be responsible for
certifying that the intended use is for recreational purposes.
PLEASURE CRAFT COATING means any marine coating, except unsaturated polyester
resin (fiberglass) coatings, applied by brush, spray, roller, or other means to a pleasure
craft.
PRETREATMENT WASH PRIMER means a coating which contains no more than 12
percent solids, by weight, and at least 1/2 percent acids, by weight; is used to provide
surface etching; and is applied directly to fiberglass and metal surfaces to provide
corrosion resistance and adhesion of subsequent coatings.
TOPCOAT means any final coating applied to the interior or exterior of a pleasure craft.
Recommended Coating Category Definitions and Related Definitions for Motor
Materials:
MOTOR VEHICLE BEDLINER means a multi-component coating, used at a facility that
is not an automobile or light-duty truck assembly coating facility, applied to a cargo bed
after the application of topcoat to provide additional durability and chip resistance.
MOTOR VEHICLE CAVITY WAX means a coating, used at a facility that is not an
automobile or light-duty truck assembly coating facility, applied into the cavities of the
vehicle primarily for the purpose of enhancing corrosion protection.
MOTOR VEHICLE DEADENER means a coating, used at a facility that is not an
automobile or light-duty truck assembly coating facility, applied to selected vehicle
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surfaces primarily for the purpose of reducing the sound of road noise in the passenger
compartment.
MOTOR VEHICLE GASKET/SEALING MATERIAL means a fluid, used at a facility
that is not an automobile or light-duty truck assembly coating facility, applied to coat a
gasket or replace and perform the same function as a gasket. Automobile and light-duty
truck gasket/gasket sealing material includes room temperature vulcanization (RTV) seal
material.
MOTOR VEHICLE LUBRICATING WAX/COMPOUND means a protective
lubricating material, used at a facility that is not an automobile or light-duty truck
assembly coating facility, applied to vehicle hubs and hinges.
MOTOR VEHICLE SEALER means a high viscosity material, used at a facility that is
not an automobile or light-duty truck assembly coating facility, generally, but not always,
applied in the paint shop after the body has received an electrodeposition primer coating
and before the application of subsequent coatings (e.g., primer-surfacer). The primary
purpose of automobile and light-duty truck sealer is to fill body joints completely so that
there is no intrusion of water, gases or corrosive materials into the passenger area of the
body compartment. Such materials are also referred to as sealant, sealant primer, or
caulk.
MOTOR VEHICLE TRUNK INTERIOR COATING means a coating, used at a facility
that is not an automobile or light-duty truck assembly coating facility, applied to the
trunk interior to provide chip protection.
MOTOR VEHICLE UNDERBODY COATING means a coating, used at a facility that is
not an automobile or light-duty truck assembly coating facility, applied to the
undercarriage or firewall to prevent corrosion and/or provide chip protection.
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