Control Techniques Guidelines for
Miscellaneous Industrial Adhesives
-------
This page intentionally left blank
-------
EPA-453/R-08-005
September 2008
Control Techniques Guidelines for
Miscellaneous Industrial Adhesives
U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Sector Policies and Programs Division
Research Triangle Park, NC
-------
This page intentionally left blank
-------
TABLE OF CONTENTS
I. Introduction 1
II. Background and Overview 2
III. Applicability 3
IV. Process Description and Sources of VOC Emissions 4
A. Process Description 5
1. Surface Preparation 5
2. Adhesive Application 5
3. Cleaning Activities 7
B. Sources of VOC Emissions 7
1. Adhesives 8
2. Cleaning Materials 8
V. Available Controls and Regulatory Approaches 9
A. Available Controls for VOC Emissions from Adhesives 9
1. Pollution Prevention Measures 9
2. Emission Capture and Add-on Control Systems 10
B. Available Controls for VOC Emissions from Cleaning Materials 13
1. Product Substitution/Reformulation 13
2. Work Practice Procedures 13
C. Existing Federal, State, and Local Recommendations or Regulations 14
1. Existing State and Local VOC Requirements 14
VI. Recommended Control Options 15
A. Adhesive and Adhesive Primer Emission Limits 17
B. Adhesive Application Methods 19
C. Add-on Controls for Adhesive Application Operations 19
D. Work Practices for Adhesive-Related Activities 19
E. Work Practices for Cleaning Materials 20
VII. Cost Effectiveness of Recommended Control Options 20
VIII. References 21
LIST OF APPENDICES
Appendix A - Definitions
Appendix B - Summary of State and Local Requirements for VOC Emissions from Adhesives
and Adhesive Primers
Appendix C - Summary of State and Local Requirements for Application Method and
Efficiency
-------
This page intentionally left blank.
11
-------
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 Industrial Adhesives are
included on the current section 183(e) list.
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
industrial adhesive application processes. In developing this CTG, EPA, among other things,
evaluated the sources of VOC emissions from miscellaneous industrial adhesives application
processes 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 industrial adhesives.
States can use the recommendations in this CTG to inform their own determination as to
what constitutes RACT for VOCs for miscellaneous industrial adhesive application processes 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.
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 industrial adhesives, 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 industrial adhesives.
II. Background and Overview
There are no previous EPA actions that affect miscellaneous industrial adhesive
application operations.
In 1998, the California Air Resources Board (ARB) issued a guidance document that
includes ARB's determination of Reasonably Available Control Technology (RACT) and Best
Available Retrofit Control Technology (BARCT) for Adhesives and Sealants1. The 1998 ARB
document presented RACT and BARCT for controlling VOC emissions from the commercial
and industrial application of adhesives and sealants. The ARB RACT determination prescribes
VOC emission limits for various industrial adhesives and sealants and was developed based on
eight existing California air pollution control district rules for adhesives and sealants that were in
effect in 1998. Those eight districts included Bay Area (BAAQMD), El Dorado County
(EDCAPCD), Placer County (PCAPCD), Sacramento Metropolitan (SMAQMD), South Coast
(SCAQMD), Ventura County (VCAPCD), Yolo-Solano (YSAQMD), and San Diego County
(SDCAPCD).
Since the development of the ARB RACT determination, five additional California air
pollution control districts have adopted rules based on the ARB RACT standards, resulting in a
total of 13 air pollution control districts in California having established rules for adhesives.
In 2007, the Ozone Transport Commission issued its Model Rule for Adhesives and
Sealants. The model rule was based almost entirely on the 1998 California ARB RACT
determination. The model rule is designed for adoption by member states in 2009. To date, only
Maryland has adopted an adhesives rule based on the OTC model rule. Connecticut, Delaware,
District of Columbia, Maine, Massachusetts, New Hampshire, New Jersey, New York,
Pennsylvania, Rhode Island, Vermont, and Virginia are all either currently in various stages of
formal rule adoption or are developing a proposed rule.
At least eight California Districts and Maryland regulate cleaning materials used in
adhesive application processes. These regulations require a combination of work practice,
equipment standards, and limits on the VOC content, boiling point, or composite vapor pressure
-------
of the solvent. Some California District rules allow the use of add-on controls as an alternative
to the VOC content/boiling point/vapor pressure limits for cleaning materials.
EPA developed the recommended approaches contained in this document after reviewing
the 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 industrial adhesives, including the types of adhesive materials and
the application processes, and identifies the sources of VOC emissions from those processes.
Section V describes the available control approaches for addressing VOC emissions from this
product category and summarizes State and local approaches for addressing such emissions.
Section VI provides our recommendations for RACT for miscellaneous industrial adhesives
application processes. 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
miscellaneous industrial adhesives and adhesive primer application processes. Please see section
IV of this CTG for a description of the miscellaneous industrial adhesives category under section
183(e) of the CAA. This section addresses EPA's recommendations as to the scope of entities to
which the RACT recommendations in this CTG should apply. As explained above, this
document is a guidance document and provides information for States to consider in determining
RACT. When State and local pollution control agencies develop RACT rules, they may elect to
adopt control approaches that differ from those described in this document and/or promulgate
applicability criteria that differ from those recommended here.
In terms of applicability, we recommend that the control approaches discussed in section
VI of this CTG apply to each miscellaneous industrial adhesive application process1 at a facility
where the total actual VOC emissions from all miscellaneous industrial adhesive application
processes, including related cleaning activities, at that facility are equal to or exceed 6.8 kg/day
(15 Ib/day), or an equivalent level such as 3 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. 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 adhesives, such as radiation cured
adhesives (these adhesives 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 6 percent of
the total reported VOC emissions from miscellaneous industrial adhesive application processes
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
1 An application process consists of a series of one or more adhesive applicators and any associated drying area
and/or oven wherein an adhesive is applied, dried, and/or cured. An application process ends at the point where the
adhesive is dried or cured, or prior to any subsequent application of a different adhesive. It is not necessary for an
application process to have an oven or flash-off area.
-------
recommended applicability threshold, aggregate emissions, before consideration of control, from
all miscellaneous industrial adhesive application processes (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.
The 2002 National Emission Inventory (NET) was used as the source of emissions data
and other information concerning facilities operating miscellaneous industrial adhesive
application processes.
In developing this CTG, the 2002 NEI database was queried for facilities likely
performing miscellaneous industrial adhesive application based on Source Classification Code
(SCC) 40200701, 40200706, 40200707, 40200710, 40200711, and 40200712. This activity
resulted in 1,048 facilities with miscellaneous industrial adhesive application processes in the
2002 NEI, and VOC emissions totaled an estimated 8,660 Mg/yr (9,546 tpy) from adhesive
application processes. Of the 1,048 facilities identified in the 2002 NEI, 720 facilities were
located in ozone nonattainment areas and 180 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 180 facilities emitted an estimated 4,428 Mg (4,881 tons) of VOC in 2002 from adhesive
application processes.
IV. Process Description and Sources of VOC Emissions
The miscellaneous industrial adhesives product category includes adhesives (including
adhesive primers used in conjunction with certain types of adhesives) used at industrial
manufacturing and repair facilities for a wide variety of products and equipment that operate
adhesives application processes.
The miscellaneous industrial adhesives product category does not include adhesives that
are addressed by CTGs already issued for categories listed under CAA Section 183(e) or by
earlier CTGs. These include the CTGs issued under Section 183(e) for aerospace coatings; metal
furniture coatings; large appliance coatings; flat wood paneling coatings; paper, film, and foil
coatings; offset lithographic printing and letterpress printing; and flexible package printing. Coil
coating, fabric coating, and rubber tire manufacturing were not listed under CAA Section 183(e),
however, they were the subject of earlier CTGs which address adhesives used in those processes.
Motor vehicle adhesives, glass bonding primers, and weatherstrip adhesives that are used
at a facility that is not an automobile or light-duty truck assembly coatings facility, are addressed
in this CTG for miscellaneous industrial adhesives. Please see section VI of this CTG for our
VOC control recommendations for these motor vehicle materials. The VOC control
recommendations for these motor vehicle materials in the CTG for miscellaneous industrial
adhesives are the same as the VOC control recommendations for similar materials used at
-------
automobile and light-duty truck assembly coating facilities, which are addressed in the final
automobile and light-duty truck assembly coatings CTG.
A. Process Description
Adhesives are used for joining surfaces in assembly and construction of a large variety of
products. Adhesives allow for faster assembly speeds, less labor input, and more ability for
joining dissimilar materials than other fastening methods. Although there are a wide variety of
adhesives formulated from a multitude of synthetic and natural raw materials, all adhesives can
be generally classified as solution/waterborne, solvent-borne, solventless or solid (e.g., hot melt
adhesives), pressure sensitive, hot-melt, or reactive (e.g., epoxy adhesives and ultraviolet-curable
adhesives). Adhesives can also be generally classified according to whether they are structural
or nonstructural. Structural adhesives are commonly used in industrial assembly processes and
are designed to maintain product structural integrity.
1. Surface Prep arati on
The vast majority of adhesives require the application of a primer to the substrate before
the adhesive is applied. Adhesive primers are usually applied in very thin films, and serve to wet
the substrate surface and provide improved bonding capability for the adhesive. Adhesive
primers are commonly solvent-borne materials3.
2. Adhesive Application
Adhesive application is accomplished by applying an adhesive to a substrate, followed by
curing or drying the adhesive. The adhesive itself may be in the form of an aerosol applied by
spraying, or liquid applied by spraying, rolling, or dipping.
There are several different types of applicators that may be used to apply adhesives, and
are generally similar or identical to surface coating application techniques. The most common
types of applicators include: air atomized spray, electrostatic spray, high volume/low pressure
(HVLP) spray, dip coating, flow coating, brush or roll coating, electrocoating, and hand
application.
Spray application operations are typically performed in a spray booth by manual or
automated (e.g., robotic) means to capture overspray, remove solvent vapors from the workplace,
and to keep the application 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 substrate, and through a dry filter bank. Waterwash booths are less
commonly used than dry filter booths. 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 adhesive application operation.
-------
Several different types of application technologies are used to apply adhesives, and the
selection of the application technology can significantly affect the amount of adhesive used and
the resulting VOC emissions from the application process.
Conventional air spray application uses compressed air at high pressure (e.g., 30 to 90
pounds per square inch, psi) to pull the adhesive from a reservoir and atomize the adhesive as it
is expelled from the spray gun tip. The mixture of air and atomized adhesive then deposits the
adhesive on the substrate. Because of the high pressure of air used, most of the adhesive does
not land on the substrate and is carried away from the substrate as over spray and is wasted. The
fraction of adhesive solids that reaches the substrate is termed transfer efficiency, and
conventional air spray has a relatively low transfer efficiency compared to other application
methods. Therefore, many application processes have adopted other types of spray application
to use adhesives more efficiently.
Airless Spray. With airless spray, a pump forces the adhesive 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 adhesive droplets is
larger, the spray cloud is less turbulent, and the transfer efficiency is typically superior to
conventional air spray.
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 adhesive. 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 adhesives is greater because of the lower fluid and air pressure.
Electrostatic Spray. In electrostatic spray application, the adhesive and substrate are
oppositely charged. The substrate is grounded and attracts the negatively charged adhesive
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
adhesive loss and lower VOC emissions.
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
better air and fluid flow at the lower air pressure, and shape the air/spray pattern and guide the
atomized adhesive particles to the substrate. 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 adhesives. It is typically
used for large complicated parts where it would be difficult to use other methods. The substrates
are manually or automatically dipped into a tank containing the adhesive. The substrates are
then withdrawn from the tank and any excess adhesive is allowed to drain, thus achieving very
high 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 adhesive,
-------
solvent losses occur from the tank. To maintain the desired adhesive viscosity in the tank, these
losses are compensated by adding thinner (water or solvent, depending on the adhesive used).
Flow coating is similar to dip coating and involves conveying the substrate over an
enclosed sink, where the adhesive is applied at low pressure as the item passes under a series of
nozzles. Excess adhesive drains back into the sink, is filtered, and pumped back into a holding
tank. A typical flow coater tank is enclosed and is smaller than the equivalent dip coating tank.
As a result, less adhesive is used and less solvent is evaporated than in dip tank operations. This
application method results in an increase in production rate.
Roll coating, brush coating, and hand application are often used for high viscosity
adhesives and for application onto small surface areas.
Electrocoating (electrodeposition) is a specialized form of dip coating where opposite
electric charges are applied to the waterborne adhesive and the substrate. The adhesive is
deposited on the part by means of electrical attraction, which produces a more uniform
application on the substrate than traditional dip application.
After each of the adhesive application operations described above, the applied adhesive is
usually air dried or cured. For liquid spray and dip coating operations, the substrate is typically
first slowly moved through a flash-off area after the adhesive is applied. The adhesive is either
then allowed a specified drying time to allow tackification before bonding, or the substrate is
immediately bonded.
3. Cleaning Activities
Cleaning activities other than surface preparation and priming also occur at facilities
operating miscellaneous industrial adhesive application processes. Cleaning materials are used
during these activities to remove adhesive residue or other unwanted materials from equipment
related to application 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 industrial adhesives result from evaporation of
the solvents contained in many of the primers, adhesives and cleaning materials during adhesive
application and drying processes, as well as during surface preparation and cleaning processes
associated with adhesives application. The primary VOC emissions from miscellaneous
industrial adhesives occur during application and flash-off.
A lesser amount of emissions occur from mixing and as the adhesive dries. Essentially
all of the remaining VOC in the organic solvent contained in the adhesives is emitted during the
drying process. The VOC emissions from mixing of adhesives occur from displacement of
VOC-laden air in containers used to mix adhesives containing solvents (thinners) prior to
adhesive 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 following discussion describes these primary emission sources (adhesives and
cleaning materials).
1. Adhesives
The VOC emissions from adhesive application occur when solvent evaporates from the
adhesive as it is being applied to the substrate. The transfer efficiency (the percent of adhesive
solids deposited on the substrate) of an application method affects the amount of VOC emitted
during application. The more efficient an application method is in transferring adhesives to the
substrates, the lower the volume of adhesives (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 adhesives, electrostatic spray coating is more
efficient than conventional air atomized spray, with transfer efficiency typically ranging from 60
to 90 percent.
After adhesives are applied by any of the typical application methods, the adhesive is
usually allowed a drying period. Immediately after application, a fraction of the solvents in the
adhesives flash-off. The amount of VOC emissions from flash-off depends on the type of
adhesive used, how quickly the substrate moves through the flash-off area, and the distance
between the application area and the drying area.
In spray application operations, the majority of VOC emissions occur in the spray booth.
For liquid spray applications, it is estimated that 65-80 percent of the volatiles are emitted during
the application and flash-off operations, and the remaining 20-35 percent from the drying/curing
operation.
The trend in controlling VOC emissions from solvent-borne adhesives is not to control
through a specific control technology, but rather to replace them with low VOC adhesives, some
of which can perform as well as solvent-borne adhesives. Since the late 1970's, adhesive
formulations that eliminate or reduce the amount of solvent in the formulations have been
increasing, thus reducing VOC emissions per unit amount of adhesive used.
Various types of low solvent adhesive include waterborne, hot-melt, solventless two-
component, and radiation-cured adhesives. Hot-melt adhesives are the most widely used of these
alternative processes.
2. Cleaning Materials
Cleaning materials are another source of VOC emitted by miscellaneous industrial
adhesive application processes. 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
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.2 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 adhesives used in miscellaneous
industrial adhesive application processes. 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 adhesives used in miscellaneous industrial adhesive application
processes.
V. Available Controls and Regulatory Approaches
As previously mentioned, there are two main sources of VOC emissions from
miscellaneous industrial adhesive application processes: (1) evaporation of VOC from the
adhesives and adhesive primers; and (2) evaporation of VOC from the cleaning materials. This
section summarizes the available control options for reducing these VOC emissions and existing
State, and local VOC recommendations or requirements that address these emissions.
A. Available Controls for VOC Emissions from Adhesives
There are two general emission control techniques for reducing VOC emissions from
miscellaneous industrial adhesive application processes: pollution prevention measures, and
emission capture and add-on control systems. Pollution prevention is the most prevalent control
technique being used by facilities operating miscellaneous industrial adhesive application
processes. Add-on control systems are available to industry, but few facilities utilize this control
technique. Provided below is a summary of these control techniques.
1. Pollution Prevention Measures
Pollution prevention measures that are applicable to miscellaneous industrial adhesive
application processes, including product substitution/reformulation, work practice procedures,
and equipment substitution, may be used to decrease VOC emissions from adhesive application
operations. Lower VOC content adhesives, higher solids adhesives and waterborne adhesives,
may be used to reduce VOC emissions by reducing or eliminating the organic solvent present in
the adhesive. Work practice procedures may also result in VOC emission reductions during the
application process by reducing waste. The use of efficient application equipment can reduce
VOC emission by increasing the adhesive transfer efficiency (i.e., the percentage of adhesive
solids used that is deposited onto the substrate) and reducing the amount of adhesive used and
wasted as overspray.
2 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.
-------
Product Substitution/Reformulation
One pollution prevention measure is to substitute higher-solvent adhesives with adhesives
containing little or no solvents. As previously discussed, these adhesives include waterborne
adhesives, higher solids adhesives, and reactive adhesives. Manufacturers have developed and
are continuing to develop waterborne and reactive formulations that replace conventional organic
solvent-borne adhesives. These adhesives are generally available. Conversion to waterborne
adhesives (for example) can lower VOC emissions greatly, and many miscellaneous industrial
adhesive application processes are capable of converting to these adhesives. However, the
currently available low-VOC adhesives or adhesives with no solvents do not meet the
performance requirements of some industrial manufacturing 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.
Waste is generated during adhesive material preparation, application, and equipment
cleaning. If waste is reduced, overall VOC emissions from application processes will be reduced
because less VOC adhesive material will be needed for production. Adhesive waste may be
reduced by effectively controlling material preparation, maximizing the amount of adhesive
transferred to the substrate through the use of application methods with higher transfer
efficiencies and improved spray technique, and using proper equipment maintenance procedures.
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 adhesive is charged and the substrate is grounded, thereby
attracting the atomized adhesive to the substrate. 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 adhesives 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
industrial adhesive application processes can be reduced by the use of capture systems, in
10
-------
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 facilities operating miscellaneous industrial adhesive application processes, they are generally
not used when low VOC adhesives and alternative application methods can be used to reduce
VOC emissions. The majority of VOC emissions from miscellaneous industrial adhesive
application processes 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 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 industrial
adhesive application processes occur in the spray booth. These emissions can be ducted from the
spray booth directly to the control device. 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 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 miscellaneous industrial adhesive
application 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 adhesive application processes:
oxidation, adsorption, and absorption. In addition, there are other control measures known to
reduce VOC emissions, but are not currently being widely used in facilities operating
miscellaneous industrial adhesive application processes. 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
achieve destruction efficiencies of greater than 95 percent as applied to adhesive application
operations with high and constant concentrations of VOC.
11
-------
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 adhesive application processes.
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 industrial adhesive application processes
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 recovered solvents that 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 adhesive 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.
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
12
-------
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 adhesives. However, EPA is not aware of any
miscellaneous industrial adhesive application 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
miscellaneous industrial adhesive application processes 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 industrial adhesive application
processes. 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
miscellaneous industrial adhesive application processes and whether they are feasible for the
broad types of adhesives used.
2. Work Practice Procedures
Work practice procedures are commonly used in industry to reduce VOC emissions from
cleaning operations. The following work practice procedures are used to reduce VOC emissions
from miscellaneous industrial adhesive application processes:
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.
Minimize VOC emissions during cleaning operations.
13
-------
C. Existing Federal State, and Local Recommendations or Regulations
The following discussion is a summary of State and local regulations that address VOC
emissions from miscellaneous industrial adhesive application processes. In addition, Appendices
B and C summarize the State and local provisions for adhesive VOC content limits and
application equipment requirements. There are no previous EPA actions that address
miscellaneous industrial adhesives.
1. Existing State and Local VOC Requirements
In 1998, the California Air Resources Board (ARB) issued a guidance document that
included ARB's determination of Reasonably Available Control Technology (RACT) and Best
Available Retrofit Control Technology (BARCT) for Adhesives and Sealants. This document
presented RACT and BARCT for controlling VOC emissions from the commercial and industrial
application of adhesives and sealants. The ARB RACT determination prescribes VOC emission
limits for various industrial adhesives and sealants and was developed based on eight existing
California air pollution control district rules for adhesives and sealants that were in effect in
1998. Those eight districts included Bay Area Air Quality Management District (AQMD), El
Dorado County Air Pollution Control District (APCD), Placer County APCD, Sacramento
Metropolitan AQMD, South Coast AQMD, Ventura County APCD, Yolo-Solano AQMD, and
San Diego County APCD.
The ARB based the majority of its RACT determination on limits already in effect in
South Coast AQMD, Bay Area AQMD, and Ventura County APCD, and concluded that the
VOC limits for adhesives and sealants presented in its RACT determination were achievable and
cost-effective. Furthermore, the ARB stated in its RACT determination that most of the adhesive
and sealant products being sold in 1998 were already compliant with the VOC limits that were
determined to be RACT.
Since the development of the ARB RACT determination, 5 additional California air
pollution control districts have adopted rules based on the ARB RACT standards.
In 2007, the Ozone Transport Commission issued a Model Rule for Adhesives and
Sealants. The Model Rule was based almost entirely on the 1998 CARB RACT determination.
The Model Rule is for adoption by member states in 2009. To date, only Maryland has adopted
an adhesives rule based on the OTC model rule. Maine and New Jersey are either currently
considering adopting or are in the process of adopting the model rule.
Some states regulate VOC emissions from adhesives as part of their regulations for
specific surface coating operations.
A total of 13 air pollution control districts in California have established rules specifically
for adhesives. The various district adhesives rules do not all contain the same categories and
limits as the ARB RACT guidance. Among these districts, the South Coast AQMD has
generally adopted the most stringent VOC content limits for the adhesives categories included in
SCAQMD Rule 1168 and in other districts with similar categories. If add-on controls are used,
South Coast Rule 1168 requires that the control system capture at least 80 percent of the VOC
emissions.
14
-------
Several California air districts require the use of specific types of high-efficiency
adhesive application methods to further reduce VOC emissions. For example, in addition to
limiting the VOC contents in the adhesives, South Coast Rule 1168 requires the use of one of 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. Alternative methods must be approved by the District based on actual transfer
efficiency measurements in a side-by-side comparison of the alternative method and an HVLP
spray gun. At least seven other District's rules that regulate emissions from adhesives are similar
to South Coast Rule 1168 in that they also require that sources use methods that achieve high
transfer efficiency.
At least eight Districts in California and Maryland regulate cleaning materials used in
adhesive application processes. These regulations require a combination of work practice and
equipment standards and limits on the VOC content, boiling point, or composite vapor pressure
of the solvent. 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. The work practice and
equipment standards that have been adopted by California Districts 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.
VI. Recommended Control Options
Based on a review of the current State and local requirements discussed above, we are
recommending various options, such as the use of low VOC content adhesives, specified
application methods and control devices, for controlling the VOC emissions from the adhesives
used by facilities operating miscellaneous industrial adhesive application processes. We are also
recommending work practices to further reduce VOC emissions from adhesives as well as to
minimize emissions from cleaning materials used in miscellaneous industrial adhesive
application processes.
To provide flexibility to facilities, we are recommending various options for controlling
VOC emissions from miscellaneous industrial adhesives. We recommend specific VOC
emission limits based on application processes (i.e., the types of adhesives and substrates). We
recommend two options for achieving the recommended emission limits: (1) through the use of
low-VOC content adhesives and specified application methods with good adhesive transfer
efficiency; or (2) through the use of a combination of low-VOC adhesives, specified application
methods, and add-on controls. As an alternative to the emission limits, we recommend an
overall control efficiency of 85 percent. This alternative provides facilities the operational
flexibility to use high efficiency add-on controls instead of low-VOC content adhesives and
specified application methods, especially when the use of high VOC adhesives is necessary or
desirable for product efficacy. We expect the 85 percent control efficiency recommendation to
result in VOC emission reduction that is equivalent to or exceed the reduction from our
recommended emission limits. Both the emission limits and the control efficiency
recommendations reflect what we have concluded to be reasonably available VOC control
15
-------
measures for miscellaneous industrial adhesives based on our review of Maryland's adhesives
rule, the OTC model rule, and the various California air district rules.
As mentioned above, we are recommending the use of adhesive application methods with
good adhesives transfer efficiency in conjunction with the use of low-VOC content adhesives.
Specifically, we recommend the following application methods: electrostatic spray, HVLP spray,
flow coat, roll coat, dip coat (including electrodeposition), airless spray, air-assisted airless
spray, or other coating application method capable of achieving good transfer efficiency.
We are recommending that the VOC emission limits and 85% control efficiency
described above not be applied to the following types of adhesives and adhesives primer
application processes:
Adhesives or adhesive primers being tested or evaluated in any research and
development, quality assurance, or analytical laboratory.
Adhesives or adhesive primers used in the assembly, repair, or manufacture of
aerospace or undersea-based weapon systems.
Adhesives or adhesive primers used in medical equipment manufacturing
operations.
Cyanoacrylate adhesive application processes.
Aerosol adhesive and aerosol adhesive primer application processes.3
Processes using polyester bonding putties to assemble fiberglass parts at fiberglass
boat manufacturing facilities and at other reinforced plastic composite
manufacturing facilities.
Processes using adhesives and adhesive primers that are supplied to the
manufacturer in containers with a net volume of 16 ounces or less, or a net weight
of one pound or less.
We recommend, however, that the work practices recommended in this CTG be
implemented to reduce VOC emissions during these types of adhesives and adhesives primer
application processes.
Our recommended emission limits are based on the OTC Model Rule for Adhesives and
Sealants. As previously mentioned, the emission limits in the OTC rule were California ARB
RACT standards, which were based on numerous California District rules and adopted by other
California District rules. Furthermore, the OTC model rule is intended for adoption by States.
In light of the above, we consider the limits in the OTC model rule to be representative of what
sources in nonattainment areas nationwide can achieve technically and economically and have
therefore adopted these VOC limits as our recommendations in the CTG.
3 Aerosol adhesives are regulated under EPA's VOC Emission Standards for Consumer Products at 40 CFR 59
subpart C. Aerosol adhesive primers are regulated as "primers" under EPA's VOC Emission Standards for Aerosol
Coatings at 40 CFR 59 subpart E.
16
-------
The recommended VOC emission limits can be met by averaging the VOC content of
materials used on a single application unit for each day (i.e., daily within-application unit
averaging). We do not recommend the use of cross-application unit averaging (i.e., averaging
across multiple application units) to meet the VOC emission limits recommended in the CTG.
However, we have previously provided guidance on cross-line averaging.4 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 for the same reasons stated above for adhesive
application. The use of add-on controls to reduce emissions from cleaning operations at
miscellaneous industrial adhesive application facilities would be a costly alternative 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 for
cleaning materials used in miscellaneous industrial adhesive application processes.
The following discussion summarizes our specific recommendations, including the
recommended VOC emission limits, application methods, add-on controls, and work practices
during miscellaneous industrial adhesive application and related cleaning processes.
A. Adhesive and Adhesive Primer Emission Limits
We are recommending separate sets of emission limits for general adhesive application
processes, specialty adhesive application processes, and adhesive primer application processes.
Provided in Table 1 are the recommended emission limits expressed in terms of mass of VOC per
volume of adhesive or adhesive primer (excluding water and exempt compounds, as applied). We
are recommending that all VOC-containing materials used by each miscellaneous industrial
adhesive application process be included when determining the emission rate of the application
process.
We also recommend that the VOC content of adhesives, other than reactive adhesives,
used at facilities operating miscellaneous industrial adhesive application processes be determined
using EPA Method 24. We recommend that the procedure for reactive adhesives in Appendix A
of the NESHAP for surface coating of plastic parts (40 CFR part 63, subpart PPPP) be used to
determine the VOC content of reactive adhesives. In addition, we recommend that
manufacturer's formulation data be accepted as an alternative to these methods. 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.
General adhesive application processes are those processes that are not specifically
identified in Table 1 below as specialty adhesives application processes. Table 1 below includes
4 Improving Air Quality with Economic Incentive Programs. U.S. Environmental Protection Agency.
Research Triangle Park, NC. EPA-452/R-01-001. January 2001.
17
-------
recommended VOC emission limits for general adhesives application processes based on the
substrates that are being bonded during these processes. For general adhesive application
processes using an adhesive to bond dissimilar substrates, we recommend that the highest VOC
emission limit apply. Appendix A contains definitions of each of the application processes
identified in Table 1 below.
Table 1. Recommended VOC Emission Limits for General and Specialty Adhesive
Application Processes
General Adhesive Application Processes
Reinforced Plastic Composite
Flexible vinyl
Metal
Porous Material (Except Wood)
Rubber
Wood
Other Substrates
Specialty Adhesive Application Processes
Ceramic Tile Installation
Contact Adhesive
Cove Base Installation
Floor Covering Installation (Indoor)
Floor Covering Installation (Outdoor)
Floor Covering Installation (Perimeter Bonded Sheet Vinyl)
Metal to Urethane/Rubber Molding or Casting
Motor Vehicle Adhesive
Motor Vehicle Weatherstrip Adhesive
Multipurpose Construction
Plastic Solvent Welding (ABS)
Plastic Solvent Welding (Except ABS)
Sheet Rubber Lining Installation
Single-Ply Roof Membrane Installation/Repair (Except EPDM)
Structural Glazing
Thin Metal Laminating
Tire Repair
Waterproof Resorcinol Glue
Adhesive Primer Application Processes
Motor Vehicle Glass Bonding Primer
Plastic Solvent Welding Adhesive Primer
Single-Ply Roof Membrane Adhesive Primer
Other Adhesive Primer
Recommended VOC Emission Limit1*2
(g/D
200
250
30
120
250
30
250
Ob/gal)
1.7
2.1
0.3
1.0
2.1
0.3
2.1
Recommended VOC Emission Limit1
(g/D
130
250
150
150
250
660
850
250
750
200
400
500
850
250
100
780
100
170
db/gal)
1.1
2.1
1.3
1.3
2.1
5.5
7.1
2.1
6.3
1.7
3.3
4.2
7.1
2.1
0.8
6.5
0.8
1.4
Recommended VOC Emission Limit1
(g/1)
900
650
250
250
Ob/gal)
7.5
5.4
2.1
2.1
1 Emission limits are mass of VOC per volume of adhesive or adhesive primer excluding water and exempt
compounds, as applied.
2 If an adhesive is used to bond dissimilar substrates together, then the applicable substrate category with the
highest VOC emission limit is recommended as the limit for such application.
18
-------
B. Adhesive Application Methods
In addition to the VOC emission limits in Section A, we recommend that one of the
following application methods be used in conjunction with using low-VOC adhesives or
adhesive primers:
Electrostatic spray.
. HVLP spray.
Flow coat.
Roll coat or hand application, including non-spray application methods similar to
hand or mechanically powered caulking gun, brush, or direct hand application.
Dip coat (including electrodeposition).
Airless spray.
Air-assisted airless spray.
Other adhesive application method capable of achieving a transfer efficiency
equivalent to or better than that achieved by HVLP spraying.
C. Add-on Controls for Adhesive Application Operations
Should product performance requirements or other needs dictate the use of higher-VOC
materials than those that would meet the recommended emission limits, a facility could choose to
use add-on control equipment with an overall control efficiency of 85 percent. Alternatively, a
facility could use a combination of adhesives and add-on control equipment on an application
unit to meet the recommended mass of VOC per volume of adhesive or adhesive primer limits.
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 85 percent. This control option, like the options
noted above, applies to all adhesives and adhesive primers applied in miscellaneous adhesive
application processes.
D. Work Practices for Adhesive-Related Activities
In addition to the control options above, this CTG recommends work practices to further
reduce VOC emissions from miscellaneous industrial adhesive application-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
adhesives, thinners, and adhesive-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
adhesives, adhesive primers, and process-related waste materials in closed containers; (2) ensure
that mixing and storage containers used for VOC-containing adhesives, adhesive primers, and
19
-------
process-related waste materials are kept closed at all times except when depositing or removing
these materials; (3) minimize spills of VOC-containing adhesives, adhesive primers, and
process-related waste materials; and (4) convey VOC-containing adhesives, adhesive primers,
and process-related waste materials from one location to another in closed containers or pipes.
E. Work Practices for Cleaning Materials
This CTG recommends work practices to reduce VOC emissions from cleaning materials
used in miscellaneous industrial adhesive application processes. These cleaning materials
include both materials used to clean surfaces before adhesive or adhesive primer application
(surface preparation) and to clean application equipment. 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 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 facilities operating miscellaneous industrial adhesive application processes. Based on the
2002 NEI, we estimated that there are a total of 1,048 such facilities in the U.S. Using the 2004
ozone nonattainment designations, we estimated that a total of 720 of these facilities are in ozone
nonattainment areas. Based on the NEI VOC emissions data, 180 of the 720 facilities in ozone
nonattainment areas emitted at or above the 6.8 kg/day (15 Ib/day) recommended VOC
emissions applicability threshold from miscellaneous industrial adhesive application processes.
These 180 facilities emitted a total of about 4,428 Mg/yr of VOC (4,881 tpy), or an average of
about 25 Mg/yr (27 tpy) of VOC per facility.
As previously mentioned, we are recommending in this CTG the VOC limits in the OTC
rule. We also mentioned earlier that the emission limits in the OTC rule were the California
ARE RACT standards, which were based on eight California Districts' adhesives rules
(including the Ventura County APCD regulation) and have been adopted by other California
Districts and Maryland. The ARB based its cost effectiveness estimate on an analysis performed
by Ventura County APCD in 19934 for a facility that manufactures commercial furniture. We
therefore use the cost analyses by Ventura County APCD and the California ARB scaled to 2007
dollars to estimate the cost effectiveness of our recommendations in this CTG. These cost
estimates are relevant to this CTG's recommended levels of control because they are based on
20
-------
the use of similar control measures (i.e., product substitution/reformulation and work practices) for
miscellaneous industrial adhesive application processes.
In our analysis of the impacts of implementing the recommended levels of control in this
CTG, we have assumed that all miscellaneous industrial adhesive application facilities will
choose to utilize the low-VOC adhesive materials alternative. We made this assumption for two
reasons. First, since facilities are meeting equivalent State and local limits, we believe that low-
VOC adhesives that can meet the recommended control levels in this CTG are already available
at a cost that is not significantly greater than the cost of adhesives with higher VOC contents.
Secondly, the use of add-on controls to reduce emissions from typical adhesive application
processes is a more costly alternative.
According to the 1993 Ventura County APCD Rule 74.20 Staff Report and the 1998
California ARB RACT determination, the annualized cost for a facility to convert to waterborne
adhesives was estimated to be $2,300 (1993$). Using the producer price index for adhesive
manufacturing and scaling the 1993 annualized cost to 2007, we estimate the annualized cost to
be $3,356. We believe that this estimate also represents the cost of implementing this CTG's
recommended VOC limits because the Ventura County APCD regulation and the ARB RACT
determination is based on similar control measures. We assume that facilities in California and
Maryland are already implementing the recommended measures in this CTG. For the facilities
we identified as emitting more than 6.8 kg/day (15 Ib/day) in ozone nonattainment areas outside
of California and Maryland, we estimate the total annual cost to be $603,997, based on the use of
low-VOC content adhesives. We estimate that the recommendations in this CTG will reduce
VOC emissions from miscellaneous industrial adhesives application processes by about 64
percent. This is a reduction of 2,070 Mg/yr (2,281 tpy of VOC) from these facilities. Therefore,
we estimate the cost effectiveness to be $292 per Mg ($265 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 adhesive application methods will also result in net cost
savings. Increasing the transfer efficiency of adhesive application to reduce VOC emissions will
also reduce adhesive consumption and costs. However, these cost savings cannot be accurately
estimated.
VIII. References
1. State of California Air Resources Board. Determination of Reasonably Available Control
Technology and Best Available Retrofit Control Technology for Adhesives and Sealants.
December 1998.
2. Ozone Transport Commission. Model Rule for Adhesives and Sealants. Available at
http://www.otcair.org/proj ects_details.asp?FID=99&fview=stationary#
3. State of California Air Resources Board. Determination of Reasonably Available Control
Technology and Best Available Retrofit Control Technology for Adhesives and Sealants.
December 1998.
21
-------
4. Ventura County Air Pollution Control District. Staff Report Rule 74.20, Adhesives and
Sealants. June 8, 1993.
22
-------
Appendix A
Definitions
-------
This page intentionally left blank
-------
Definitions
Acrylonitrile-butadiene-styrene or ABS welding means any process to weld
acrylonitrile-butadiene-styrenepipe.
Adhesive means any chemical substance that is applied for the purpose of bonding two
surfaces together other than by mechanical means.
Adhesive primer means any product intended by the manufacturer for application to a
substrate, prior to the application of an adhesive, to provide a bonding surface.
Aerosol adhesive or adhesive primer means an adhesive or adhesive primer packaged
as an aerosol product in which the spray mechanism is permanently housed in a non-refillable
can designed for handheld application without the need for ancillary hoses or spray equipment.
Ceramic tile installation adhesive means any adhesive intended by the manufacturer for
use in the installation of ceramic tiles.
Chlorinated polyvinyl chloride plastic or CPVC plastic welding means a polymer of
the vinyl chloride monomer that contains 67% chlorine and is normally identified with a CPVC
marking.
Chlorinated polyvinyl chloride welding or CPVC welding means an adhesive labeled
for welding of chlorinated polyvinyl chloride plastic.
Contact bond adhesive means an adhesive that: (i) is designed for application to both
surfaces to be bonded together, and (ii) is allowed to dry before the two surfaces are placed in
contact with each other, and (iii) forms an immediate bond that is impossible, or difficult, to
reposition after both adhesive-coated surfaces are placed in contact with each other, and (iv) does
not need sustained pressure or clamping of surfaces after the adhesive-coated surfaces have been
brought together using sufficient momentary pressure to establish full contact between both
surfaces. Contact adhesive does not include rubber cements that are primarily intended for use
on paper substrates. Contact adhesive also does not include vulcanizing fluids that are designed
and labeled for tire repair only.
Cove base means a flooring trim unit, generally made of vinyl or rubber, having a
concave radius on one edge and a convex radius on the opposite edge that is used in forming a
junction between the bottom wall course and the floor or to form an inside corner.
Cove base installation adhesive means any adhesive intended by the manufacturer to be
used for the installation of cove base or wall base on a wall or vertical surface at floor level.
Cyanoacrylate adhesive means any adhesive with a cyanoacrylate content of at least 95
percent by weight.
A-l
-------
EPDM roof membrane means a prefabricated single sheet of elastomeric material
composed of ethylene propylenediene monomer and that is field applied to a building roof using
one layer or membrane material.
Flexible vinyl means non-rigid polyvinyl chloride plastic with at 5 percent by weight
plasticizer content.
Indoor floor covering installation adhesive means any adhesive intended by the
manufacturer for use in the installation of wood flooring, carpet, resilient tile, vinyl tile, vinyl
backed carpet, resilient sheet and roll or artificial grass. Adhesives used to install ceramic tile
and perimeter bonded sheet flooring with vinyl backing onto a non-porous substrate, such as
flexible vinyl, are excluded from this category.
Laminate means a product made by bonding together two or more layers of material.
Metal to urethane/rubber molding or casting adhesive means any adhesive intended
by the manufacturer to bond metal to high density or elastomeric urethane or molded rubber
materials, in heater molding or casting processes, to fabricate products such as rollers for
computer printers or other paper handling equipment.
Motor vehicle adhesive means an adhesive, including glass bonding adhesive, used at a
facility that is not an automobile or light-duty truck assembly coating facility, applied for the
purpose of bonding two vehicle surfaces together without regard to the substrates involved.
Motor vehicle glass bonding primer means a primer, used at a facility that is not an
automobile or light-duty truck assembly coating facility, applied to windshield or other glass, or
to body openings, to prepare the glass or body opening for the application of glass bonding
adhesives or the installation of adhesive bonded glass. Motor vehicle glass bonding primer
includes glass bonding/cleaning primers that perform both functions (cleaning and priming of the
windshield or other glass, or body openings) prior to the application of adhesive or the
installation of adhesive bonded glass.
Motor vehicle weatherstrip adhesive means an adhesive, used at a facility that is not an
automobile or light-duty truck assembly coating facility, applied to weatherstripping materials
for the purpose of bonding the weatherstrip material to the surface of the vehicle.
Multipurpose construction adhesive means any adhesive intended by the manufacturer
for use in the installation or repair of various construction materials, including but not limited to
drywall, subfloor, panel, fiberglass reinforced plastic (FRP), ceiling tile and acoustical tile.
Outdoor floor covering installation adhesive means any adhesive intended by the
manufacturer for use in the installation of floor covering that is not in an enclosure and that is
exposed to ambient weather conditions during normal use.
Panel installation means the installation of plywood, pre-decorated hardboard (or
tileboard), fiberglass reinforced plastic, and similar pre-decorated or non-decorated panels to
studs or solid surfaces using an adhesive formulated for that purpose.
A-2
-------
Perimeter bonded sheet flooring installation means the installation of sheet flooring
with vinyl backing onto a nonporous substrate using an adhesive designed to be applied only to a
strip of up to four inches wide around the perimeter of the sheet flooring.
Plastic solvent welding adhesive means any adhesive intended by the manufacturer for
use to dissolve the surface of plastic to form a bond between mating surfaces.
Plastic solvent welding adhesive primer means any primer intended by the
manufacturer for use to prepare plastic substrates prior to bonding or welding.
Plastic foam means foam constructed of plastics.
Plastics means synthetic materials chemically formed by the polymerization of organic
(carbon-based) substances. Plastics are usually compounded with modifiers, extenders, and/or
reinforcers and are capable of being molded, extruded, cast into various shapes and films, or
drawn into filaments.
Polyvinyl chloride plastic or PVC plastic means a polymer of the chlorinated vinyl
monomer that contains 57% chlorine.
Polyvinyl chloride welding adhesive or PVC welding adhesive means any adhesive
intended by the manufacturer for use in the welding of PVC plastic pipe.
Porous material means a substance that has tiny openings, often microscopic, in which
fluids may be absorbed or discharged, including, but not limited to, paper and corrugated
paperboard. For the purposes of this CTG, porous material does not include wood.
Reinforced plastic composite means a composite material consisting of plastic
reinforced with fibers.
Rubber means any natural or manmade rubber substrate, including but not limited to,
styrene-butadiene rubber, polychloroprene (neoprene), butyl rubber, nitrile rubber,
chlorosulfonated polyethylene and ethylene propylene diene terpolymer.
Sheet rubber lining installation means the process of applying sheet rubber liners by
hand to metal or plastic substrates to protect the underlying substrate from corrosion or abrasion.
These operations also include laminating sheet rubber to fabric by hand.
Single-ply roof membrane means a prefabricated single sheet of rubber, normally
ethylene-propylenediene terpolymer, that is field applied to a building roof using one layer of
membrane material. For the purposes of this CTG, single-ply roof membrane does not include
membranes prefabricated from ethyl ene-propylenediene monomer (EPDM).
Single-ply roof membrane installation and repair adhesive means any adhesive
labeled for use in the installation or repair of single-ply roof membrane. Installation includes, as
a minimum, attaching the edge of the membrane to the edge of the roof and applying flashings to
vents, pipes and ducts that protrude through the membrane. Repair includes gluing the edges of
A-3
-------
torn membrane together, attaching a patch over a hole and reapplying flashings to vents, pipes or
ducts installed through the membrane.
Single-ply roof membrane adhesive primer means any primer labeled for use to clean
and promote adhesion of the single-ply roof membrane seams or splices prior to bonding.
Structural glazing means a process that includes the application of adhesive to bond
glass, ceramic, metal, stone or composite panels to exterior building frames.
Subfloor installation means the installation of subflooring material over floor joists,
including the construction of any load bearing joists. Subflooring is covered by a finish surface
material.
Thin metal laminating adhesive means any adhesive intended by the manufacturer for
use in bonding multiple layers of metal to metal or metal to plastic in the production of electronic
or magnetic components in which the thickness of the bond line(s) is less than 0.25 millimeters.
Tire repair means a process that includes expanding a hole, tear, fissure or blemish in a
tire casing by grinding or gouging, applying adhesive and filling the hole or crevice with rubber.
Waterproof resorcinol glue means a two-part resorcinol-resin-based adhesive designed
for applications where the bond line must be resistant to conditions of continuous immersion in
fresh or salt water.
A-4
-------
Appendix B
Summary of State and Local Requirements for VOC Emissions from
Adhesives and Adhesive Primers
-------
This page intentionally left blank
-------
Appendix B. Summary of State and Local Requirements for VOC Emissions from Adhesives and Adhesive Primers
California District
Rule Citation
Antelope
Valley
Rule 1168
Bay Area
Rule 8-51
El Dorado
County
Rule 236
Placer
County
Rule 235
Sacramento
Metropolitan
Rule 460
San Diego
County
Rule 67.21
San Joaqu in
Valley
Rule 4653
General Adhesive Application Processes
Fiberglass
Flexible vinyl
Flexible vinyl to other substrate
Metal
Other Substrates
Plastic Foams
Porous Material
Porous Material (e.g. wood, plastic foam, but not
a plastic)
Porous Material (except wood and plastic foam)
Porous Material (except wood)
Rubber
Wood
200
30
120
120
30
30
250
120
120
250
30
200
30
120
120
30
200
250
250
30
250
120
120
250
200
250
30
250
120
250
200
30
250
120
30
250
120
120
250
30
Specialty Adhesive Application Processes
ABS Welding
Adhesive Primer for Plastic
Carpet Pad Installation
Cellulosic plastic welding (except ethyl cellulose)
Ceramic Tile Installation
Computer Diskette Manufacturing
Contact Adhesive - General
Contact Adhesive - Special
Contact Adhesive - Specialty Substrate
Contact Adhesive
Cove Base Installation
CPVC Welding
Dry Wall and Panel Installation
Elastomeric Adhesive
Floor covering installation (except ceramic tile)
400
250
150
130
350
150
270
200
400
130
850
150
490
350
250
150
130
350
150
250
200
400
130
850
200
150
490
400
130
850
250
250
150
490
400
130
850
250
400
150
490
750
400
130
250
250
490
B-l
-------
Appendix B. Summary of State and Local Requirements for VOC Emissions from Adhesives and Adhesive Primers
California District
Rule Citation
Floor covering installation
Immersible Product Manufacturing
Indoor Carpet Adhesives
Indoor Floor Covering Installation
Metal to Urethane/Rubber Molding or Casting
Adhesive
Multipurpose Architectural (except cove base
installation)
Multipurpose Construction
Nonmembrane Roof Installation/Repair
Non- Vinyl Backed Indoor Carpet Installation
Other Plastic Cement Welding Adhesive
Other Plastic Welding
Outdoor Floor Covering Installation
Perimeter Bonded Sheet Vinyl Flooring
Installation
Plastic Cement Welding
PVC Welding
Rubber Floor Installation
Rubber Vulcanization Bonding
Sheet rubber lining installation adhesive
Single-Ply Roof Material Installation/Repair
Single-Ply Roof Membrane Installation/Repair
Adhesive
Solvent welding adhesive
Staple and Nail Manufacturing
Structural Glazing
Structural Wood Member Adhesive
Styrene-acrylonitrile welding adhesive
Subfloor Installation
Thin Metal Laminating
Antelope
Valley
Rule 1168
150
250
285
150
200
Bay Area
Rule 8-51
650
150
200
300
500
350
660
510
850
250
100
780
El Dorado
County
Rule 236
150
250
250
150
200
Placer
County
Rule 235
150
250
200
300
450
250
510
250
100
250
Sacramento
Metropolitan
Rule 460
150
250
200
300
450
250
660
510
250
100
780
San Diego
County
Rule 67.21
150
150
850
200
300
510
250
660
510
850
250
100
780
San Joaqu in
Valley
Rule 4653
200
450
660
510
850
250
640
100
B-2
-------
Appendix B. Summary of State and Local Requirements for VOC Emissions from Adhesives and Adhesive Primers
California District
Rule Citation
Tire Retread
Top and Trim Installation
Traffic Marking Tape Adhesive
VCT and Asphalt Tile Installation
Waterproof Resorcinol Glue
Wood Flooring Installation
Antelope
Valley
Rule 1168
150
150
Bay Area
Rule 8-51
100
540
170
El Dorado
County
Rule 236
150
150
Placer
County
Rule 235
100
170
Sacramento
Metropolitan
Rule 460
100
170
San Diego
County
Rule 67.21
100
170
San Joaqu in
Valley
Rule 4653
170
Adhesive Primer Application Processes
Automotive Glass
Plastic Cement Welding
Single-Ply Roof Membrane
Traffic Marking Tape
Other
Natural gas pipeline tape adhesive primer
Included
Above
700
650
150
250
Included
Above
700
650
150
250
700
400
250
150
250
700
650
250
150
250
600
650
250
B-3
-------
Appendix B. Summary of State and Local Requirements for VOC Emissions from Adhesives and Adhesive Primers
California District / State
Rule Citation
Santa
Barbara
County
Rule 353
Shasta
County
Rule 3:32
South Coast
Rule 11 68
Tchama
County
Rule 4:40
Ventura
County
Rule 74.20
Yolo-Solano
Rule 2.33
Maryland
(OTC
Model Rule)
COMAR
26.11.3S
General Adhesive Application Processes
Fiberglass
Flexible vinyl
Flexible vinyl to other substrate
Metal
Other Substrates
Plastic Foams
Porous Material
Porous Material (e.g. wood, plastic foam, but not
a plastic)
Porous Material (except wood and plastic foam)
Porous Material (except wood)
Rubber
Wood
200
250
250
30
250
120
120
250
200
250
30
250
120
250
80
30
50
50
30
200
250
250
30
250
120
120
250
200
250
250
30
250
120
150
30
30
250
120
150
200
250
30
250
120
250
Specialty Adhesive Application Processes
ABS Welding
Adhesive Primer for Plastic
Carpet Pad Installation
Cellulosic plastic welding (except ethyl cellulose)
Ceramic Tile Installation
Computer Diskette Manufacturing
Contact Adhesive - General
Contact Adhesive - Special
Contact Adhesive - Specialty Substrate
Contact Adhesive
Cove Base Installation
CPVC Welding
Dry Wall and Panel Installation
Elastomeric Adhesive
400
130
850
400
250
150
490
400
130
850
250
250
150
490
325
50
65
350
250
80
50
490
50
400
130
850
250
250
150
490
400
100
130
200
200
150
490
130
400
130
850
250
150
490
B-4
-------
Appendix B. Summary of State and Local Requirements for VOC Emissions from Adhesives and Adhesive Primers
California District / State
Rule Citation
Floor covering installation (except ceramic tile)
Floor covering installation
Immersible Product Manufacturing
Indoor Carpet Adhesives
Indoor Floor Covering Installation
Metal to Urethane/Rubber Molding or Casting
Adhesive
Multipurpose Architectural (except cove base
installation)
Multipurpose Construction
Nonmembrane Roof Installation/Repair
Non- Vinyl Backed Indoor Carpet Installation
Other Plastic Cement Welding Adhesive
Other Plastic Welding
Outdoor Floor Covering Installation
Perimeter Bonded Sheet Vinyl Flooring
Installation
Plastic Cement Welding
PVC Welding
Rubber Floor Installation
Rubber Vulcanization Bonding
Sheet rubber lining installation adhesive
Single-Ply Roof Material Installation/Repair
Single-Ply Roof Membrane Installation/Repair
Adhesive
Solvent welding adhesive
Staple and Nail Manufacturing
Structural Glazing
Structural Wood Member Adhesive
Styrene-acrylonitrile welding adhesive
Subfloor Installation
Santa
Barbara
County
Rule 3S3
150
850
200
300
510
250
660
510
850
250
100
Shasta
County
Rule 3:32
150
250
200
300
450
250
660
510
250
100
South Coast
Rule 1168
50
70
150
250
510
60
850
250
100
140
50
Tchama
County
Rule 4:40
150
250
200
300
450
250
660
510
250
100
Ventura
County
Rule 74.20
150
200
300
500
510
250
100
100
Yolo-Solano
Rule 2.33
150
200
450
250
450
640
100
Maryland
(OTC
Model Rule)
COMAR
26.11.3S
150
850
200
300
510
250
660
510
850
250
100
B-5
-------
Appendix B. Summary of State and Local Requirements for VOC Emissions from Adhesives and Adhesive Primers
California District / State
Rule Citation
Thin Metal Laminating
Tire Retread
Top and Trim Installation
Traffic Marking Tape Adhesive
VCT and Asphalt Tile Installation
Waterproof Resorcinol Glue
Wood Flooring Installation
Santa
Barbara
County
Rule 3S3
780
100
170
Shasta
County
Rule 3:32
780
100
540
170
South Coast
Rule 1168
100
250
50
100
Tchama
County
Rule 4:40
780
100
540
170
Ventura
County
Rule 74.20
100
150
Yolo-Solano
Rule 2.33
Maryland
(OTC
Model Rule)
COMAR
26.11.3S
780
100
170
Adhesive Primer Application Processes
Automotive Glass
Plastic Cement Welding
Single-Ply Roof Membrane
Traffic Marking Tape
Other
Natural gas pipeline tape adhesive primer
700
650
250
150
250
700
650
250
150
250
Included
Above
700
400
250
150
250
700
650
250
250
Included
Above
700
650
250
150
250
B-6
-------
Appendix C
Summary of State and Local Requirements for Application Method and
Control Efficiency
-------
This page intentionally left blank
-------
Appendix C. Summary of State and Local Requirements for Application Method and Efficiency
California District
Rule Citation
Antelope
Valley
Rule 1168
Bay Area
Rule 8-51
El Dorado
County
Rule 236
Placer
County
Rule 235
Sacramento
Metropolitan
Rule 460
San Diego
County
Rule 67.21
San Joaquin
Valley
Rule 4653
Adhesive Application Method
Aerosol Cans
Air- Assisted Airless Spray
Air-Atomized (for contact adhesives)
Airless Spray, Air-Assisted Airless Spray, Air-
Atomized Spray (for contact adhesives)
Airless Spray, Air-Assisted Airless Spray, Air-
Atomized Spray (for viscosity 200 cp or grater)
Brush or Roll Coat
Dip Coat
Electrodeposition
Electrostatic Spray
Flow Coat
Hand Application
HVLP Spray
LVLP Spray
Other, Transfer Efficiency Minimum
X
X
X
X
X
X
X
65%
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
x, none
specified
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
65%
Add-On Control Efficiency
Capture Efficiency
Control Efficiency
Overall Efficiency
Overall VOC Reduction Efficiency
85%
80%bywt
90%bywt
95%bywt
85%
90%bywt
95%bywt
85%bywt
85%bywt
C-l
-------
Appendix C. Summary of State and Local Requirements for Application Method and Efficiency
California District / State
Rule Citation
Santa
Barbara
County
Rule 353
Shasta
County
Rule 3:32
South Coast
Rule 11 68
Tchama
County
Rule 4:40
Ventura
County
Rule 74.20
Yolo-Solano
Rule 2.33
Maryland
(OTC
Model Rule)
COMAR
26.11.35
Adhesive Application Method
Aerosol Cans
Air- Assisted Airless Spray
Air-Atomized (for contact adhesives)
Airless Spray, Air-Assisted Airless Spray, Air-
Atomized Spray (for contact adhesives)
Airless Spray, Air-Assisted Airless Spray, Air-
Atomized Spray (for viscosity 200 cp or grater)
Brush or Roll Coat
Dip Coat
Electrodeposition
Electrostatic Spray
Flow Coat
Hand Application
HVLP Spray
LVLP Spray
Other, Transfer Efficiency Minimum
X
X
X
X
X
X
X
X
X
X
x, none
specified
X
X
X
X
X
X
X
65%
X
X
X
X
X
X
X
X
X
X
x, none
specified
x
x
X
X
X
X
X
X
X
X
x, none
specified
Add-On Control Efficiency
Capture Efficiency
Control Efficiency
Overall Efficiency
Overall VOC Reduction Efficiency
85%bywt
90%bywt
95%bywt
80%
90%bywt
95%bywt
85%bywt
85%bywt
85%bywt
C-2
-------
United States Office of Air Quality Planning and Standards Publication No. EPA 453/R-08-005
Environmental Protection Air Quality Strategies and Standards Division September 2008
Agency Research Triangle Park, NC
------- |