Control Techniques Guidelines for
Metal Furniture Coatings
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EPA 453/R-07-005
September 2007
Control Techniques Guidelines for
Metal Furniture 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 5
1. Surface Preparation 6
2. Coating Application 6
3. Cleaning activities 8
B. Sources of VOC Emissions 9
1. Coatings 9
2. Cleaning Materials 11
V. Available Controls and Regulatory Approaches 11
A. Available Controls for VOC Emissions from Coatings 11
1. Pollution Prevention Measures 12
2. Emission Capture and Add-on Control Systems 13
B. Available Controls for VOC Emissions from Cleaning Materials 15
1. Product Substitution/Reformulation 16
2. Work Practice Procedures 16
C. Existing Federal, State, and Local Recommendations or Regulations 16
1. The 1977 CTG 16
2. The 1982 NSPS 19
3. The 2003 NESHAP 19
4. Existing State and Local VOC Requirements 21
VI. Recommended Control Options 22
A. Emission Limit Based on Low-VOC Coatings 23
B. Optional Add-on Controls for Coating Operations 24
C. Work Practices for Coating-Related Activities 25
D. Work Practices for Cleaning Materials 25
VII. Cost Effectiveness of Recommended Control Options 25
VIII. References 26
Appendix A: 1977 CTG for Metal Furniture Coating
Appendix B: Summary of State and Local Regulations for Metal Furniture Coating (not
including California)
Appendix C: Summary of California Air District Regulations for Metal Furniture Coating
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I. Introduction
Clean Air Act (CAA) section 172(c)(l) 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 (Sept. 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 (Mar. 18, 1999). Metal Furniture
coatings 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 metal furniture
coating. In developing this CTG, EPA, among other things, evaluated the sources of VOC
emissions from the metal furniture coating industry and the available control approaches for
addressing these emissions, including the costs of such approaches. Based on available
information and data, EPA provides recommendations for RACT for metal furniture coating.
States can use the recommendations in this CTG to inform their own determination
as to what constitutes RACT for VOCs for metal furniture coatings in their particular
nonattainment areas. There are several hazardous air pollutants (HAPs) that are also VOCs.
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
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State rules that adopt different approaches for RACT for VOCs from metal furniture
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 metal furniture coatings. States
subject only to the RACT requirements in CAA section 172(c)(l) may take action in
response to this CTG, as necessary to achieve attainment of the national primary ambient air
quality standards.
II. Background and Overview
There have been three federal actions that affect metal furniture surface coating
operations. In December 1977, EPA issued a CTG document (1977 CTG) for controlling
VOC emissions from surface coating of metal furniture.1 In October 1982, EPA
promulgated the new source performance standards (NSPS) for surface coating of metal
furniture (1982 NSPS).2 In May 2003, EPA promulgated the National Emission Standards
for Hazardous Air Pollutants: Surface Coating of Metal Furniture (2003 NESHAP).3
The 1977 CTG, the 1982 NSPS and the 2003 NESHAP provide a thorough
discussion of the metal furniture coating industry, the nature of VOC emissions (or in the
case of the 2003 NESHAP, volatile HAP emissions) from this industry, available control
technologies for addressing such emissions, the costs of available control options, and other
items. The 1977 CTG recommends and the 1982 NSPS establishes VOC emissions limits,
whereas the 2003 NESHAP establishes organic HAP emissions limits and does not address
non-HAP VOC.
At least 36 States and several local jurisdictions have specific regulations that
control VOC emissions from metal furniture coating (or for metal parts and products coating
in general). 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 1977 CTG, the 1982 NSPS, and the 2003 NESHAP and existing State and
local VOC emission reduction approaches.
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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 metal furniture surface coating industry, including the types of metal
furniture 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 this product category and summarizes
Federal, State and local approaches for addressing such emissions. Section VI provides our
recommendations for RACT for metal furniture 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 stemming
from the use of coatings in metal furniture surface coating operations. Coatings include
paints, sealants, caulks, inks, adhesives, and maskants.a 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 metal furniture surface coating unitb at a facility where
the total actual VOC emissions from all metal furniture 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 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 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 metal furniture 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
a Decorative, protective, or functional materials that consist only of protective oils for metal, acids, bases, or
any combination of these substances are not considered metal furniture coatings.
b 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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whether a facility meets our recommended applicability threshold, aggregate emissions,
before consideration of control, from all metal furniture 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.
The 2002 National Emission Inventory (NEI) and a questionnaire sent to industry by
EPA during the development of the 2003 NESHAP development (data requested by EPA in
1997 and 1998) were used as the source of emissions data and statistical information
concerning the metal furniture surface coating industry as a whole. There were several
discrepancies in the number of facilities reported in the 2002 NEI versus the 1997 and 1998
NESHAP questionnaires.
Results from the NESHAP questionnaires indicated that there were approximately
3000 facilities that produce metal furniture parts or products. These facilities were located
throughout the U.S., with the highest concentration of facilities in California, Michigan,
New York, Florida, and Illinois.4 Although information regarding HAP emissions was the
main focus of the NESHAP questionnaires, information regarding VOC emissions was
submitted from 22 of the 85 facilities surveyed. These facilities reported actual VOC
emissions totaling approximately 1,300 tpy for 1997/1998. This total only accounts for
VOC emissions generated by these metal furniture facilities from coatings.
In developing this CTG, the 2002 NEI database was queried for VOC emissions
generated by facilities that were listed under the following SIC codes: 2514, 2522, 2531,
2542, 2599, 3429, 3469, 3495, 3645, 3646, 3821, and 3843 (the SIC used for the 2003
NESHAP development). This query resulted in 456 facilities as compared to the 3,000
facilities identified during the development of the 2003 NESHAP. The VOC emissions
from the 456 metal furniture surface coating facilities in the 2002 NEI totaled approximately
7,980 tpy. This total accounts for all of the VOC emissions generated by these facilities and
does not specify the amount generated by just metal furniture coating operations. Of the 456
facilities identified in the 2002 NEI, 289 facilities were located in ozone nonattainment areas
and 143 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 143 facilities emitted
approximately 3,400 tons of VOC in 2002.
As stated above, the information presented in BID for the 2003 NESHAP indicated
that there are about 3,000 metal furniture facilities in the United States. This information
was based on 1997 Census data for the Standard Industrial Classification (SIC) codes that
describe the metal furniture industry. In contrast, the 2002 Census data (obtained using the
North American Industry Classification (NAICS) codes that correspond to the previously
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used SIC codes) indicated that there are about 1,000 metal furniture facilities. We have
found that the NAICS codes are in some cases very broad in their description of applicable
products. As a result, some of the NAICS codes include parts and products that are beyond
the scope of the metal furniture industry as defined in this document. Thus, the 2002 Census
data for the number of facilities listed under these NAICS tend to overestimate the number
of metal furniture surface coating facilities by including facilities that do not manufacture
metal furniture parts or products. Therefore, we believe that the NEI data most accurately
predict the total number of metal furniture facilities.
IV. Process Description and Sources of VOC Emissions
The metal furniture coatings product category under section 183(e) of the CAA
includes the coatings that are applied to the surfaces of metal furniture. A metal furniture
substrate is the furniture or components of furniture constructed either entirely or partially
from metal. Metal furniture includes, but is not limited to, the following types of products:
household, office, institutional, laboratory, hospital, public building, restaurant, barber and
beauty shop, and dental furniture, as well as components of these products. Metal furniture
also includes office and store fixtures, partitions, shelving, lockers, lamps and lighting
fixtures, and wastebaskets. Metal furniture coatings include paints and adhesives and are
typically applied without a primer. Higher solids and powder coatings are used extensively
in the metal furniture surface coating industry. Metal furniture coatings provide a covering,
finish, or functional or protective layer, and can also provide a decorative finish to metal
furniture.
A. Process Description
Metal furniture coatings serve decorative, protective and functional purposes.
Coatings protect the metal from corrosion by providing resistance to moisture, heat, and
sometimes the outdoor elements. Coatings for each type of metal furniture have special
requirements and contain unique properties because each type will be exposed to somewhat
different corrosive elements. The coating must also be durable and have excellent adhesion
properties to avoid peeling or chipping. Finally, the coatings for many products provide
decorative appeal.
The metal furniture manufacturing process may be divided into four main unit
operations: (1) raw material preparation, (2) surface preparation, (3) coating and adhesive
application operations, and (4) assembly. In addition, cleaning activities are performed in
support of the surface coating operation. The majority of the raw material preparation
operations and assembly operations are mechanical in nature and involve no VOC
emissions. Surface preparation, coating application operations, and cleaning activities
utilize VOC-containing compounds (i.e., coatings, thinners, and/or cleaning materials) and
are further described below.
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1. Surface Preparation
Before a metal furniture component or 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 involves
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 furniture components 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 corrosivity of acid solutions is a concern.
The cleaning step is followed by a phosphate treatment. 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 furniture component or product is typically
sent through several rinse stages in series. A counterflow rinsing system is commonly
utilized. A counterflow rinsing system is a sequence of rinse steps in which replenished
rinse water moves in the opposite direction of the component or product flow. The
components or products being cleaned progress from dirtier to cleaner rinse water. The
system maximizes water use by adding fresh water only at the final rinse step in the
sequence. Thus, the metal furniture components or products are exposed to the cleanest
rinse water just before proceeding to the next treatment step.
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. Although the steel shot is recycled back to the enclosure
containing the metal furniture parts or components, a small amount of particulate matter
emissions is generated by this operation. However, the cleaning operation does not involve
any liquid chemicals, and no wastewater discharge is produced.
2. Coating Application
Surface coating is accomplished by applying a coating to the metal part, followed by
curing or drying the coating. The coating itself may be in the form of a liquid or powder,
and may be applied by spraying or dipping.
There are several different types of applicators that may be used to apply coatings.
The most common types of coating applicators include: air atomized spray coating,
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electrostatic spray coating, high volume/low pressure (HVLP) spray coating, dip coating,
flow coating, roll coating, electrocoating, and autophoretic coating.4
Spray coating is an application process where coatings are spray applied in a booth
by manual or automatic means. In some instances, productivity is maximized by using
automatic 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 furniture
component or product, and through a dry filter bank. Waterwash booths are less commonly
used in the metal furniture industry. In a waterwash booth, air is drawn through a
continuous curtain of moving water and overspray is removed by contact with the water. In
addition, overspray hits the booth walls and is washed down by the water flow. In booths
equipped with dry filters and waterwash booths, the overspray can be collected on a series of
baffles in front of the the dry filters or waterwash, and 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.
In electrostatic spraying, the coating is charged and the part is grounded thereby
attracting the atomized coating to the part. Nearly all metal furniture spray coatings are
electrostatically applied.
HVLP systems have improved nozzles which provide better air and fluid flow, and
allows for gentler atomization of the air stream. These nozzles or atomizers shape the
air/spray pattern and guide the atomized coating particles to the product being coated.
Dip coating is another available method for applying liquid coating. It is typically
used on parts that do not require a high-quality appearance, such as interior components of a
filing cabinet. The metal furniture components or products to be coated are manually or
automatically dipped into a tank containing the coating. The metal furniture components or
products 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 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 by adding thinner (water or
solvent, depending on the coating used).
Flow coating is similar to dip coating and involves conveying the metal furniture
component 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.
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Roll coating application is used for high viscosity coatings, particularly adhesives,
and for small surface areas. In most instances, the adhesive is activated by pressure, not
heat. The adhesive is typically spray applied to both the substrate and laminate, and then the
two parts are assembled.
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. The only reported
use of autophoretic coatings for metal furniture applications was a black coating, which
effectively limits its use to parts hidden from view.
Powder coatings are applied almost exclusively by means of electrostatic spray in the
metal furniture surface coating industry. The electrostatic spray gun directs the flow of
powder to the product. If a powder recovery system is used, the oversprayed powder is
recovered and recycled. 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.
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, with the exception of
adhesives which are activated by pressure. For liquid spray and dip coating operation, 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 furniture components or products 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 metal furniture
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.
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B. Sources of VOC Emissions
Primarily, VOC emissions from metal furniture surface coating processes result from
the evaporation of the volatile components of the coatings and cleaning materials.0 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).
1. Coatings
The primary VOC emissions from metal furniture coatings occur during coating
application/flash-off and drying/curing of the coatings. 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. The transfer efficiency (the percent of coating
applied to the metal furniture component or product) 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 furniture component or product,
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.4
After being coated by any of the typical coating methods (e.g., spray coating or dip
coating), the metal furniture components or products 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 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.
For powder coatings, the curing/drying step melts the powder and forms a
continuous coating on the metal furniture component or product. For liquid coatings, this
0 In a previous notice, EPA identified specific categories, including metal furniture surface coating, the
cleaning operations of which would not be covered by EPA's 2006 CTG for industrial cleaning solvents
(71 FR 44522, 44540, October 5, 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.
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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 metal furniture industry. Due to increased regulation at
the State and federal level, the industry has steadily moved to lower VOC content coatings.
These alternative coatings include powder 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 furniture
manufacturing industry has increased. Many metal furniture manufacturing 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 in other industries,
most often when there is a primer applied to the substrate prior to the waterborne coating.
The use of waterborne coatings is limited in the metal furniture manufacturing industry
because they tend to corrode mild steel and some stainless steels, and the primer keeps the
water from contacting the metal substrate. Because primers are used only rarely in the metal
furniture industry, the use of waterborne coatings is more limited in this industry.
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 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 wood, composite,
and metal, but are not commonly used in the metal furniture industry. Because the entire
coating must be exposed to the UV light source to achieve complete curing of the UV
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coating, UV curable coating applications present problems in the metal furniture industry.
Pigmentation used in the majority of metal furniture coatings blocks the UV light. The
shape of the metal furniture also presents curing problems. Metal furniture products
typically have bends or are box-shaped, creating areas which would be shaded from the UV
light source.
2. Cleaning Materials
Cleaning materials are another source of VOC emitted by metal furniture 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 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.d Water and exempt compounds thereby reduce the VOC composite vapor
pressure of cleaning materials in which they are present. Although use of lower pressure
cleaning materials may reduce VOC emissions, little information is available regarding the
use of cleaning materials with low VOC composite vapor pressure in the metal furniture
surface coating industry. Similarly, cleaning materials with low VOC content would
generate less VOC emissions than materials with high VOC content; however, little
information is available regarding the use of cleaning materials with low VOC content in
this industry.
V. Available Controls and Regulatory Approaches
As previously mentioned, there are two main sources of VOC emissions from metal
furniture 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
metal furniture coatings: pollution prevention measures, and emission capture and add-on
control systems. Pollution prevention is the most prevalent control technique being used by
the metal furniture surface coating industry. Add-on control systems are available to the
d 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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industry, 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 metal furniture manufacturing
industry, 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).
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 1977. 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 and often are not produced and
marketed specifically for metal furniture surface coating. Conversion to powder coatings
(for example) can lower VOC emissions greatly, and most metal furniture 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 furniture and therefore are not viable options for these products' production.
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, maximizing
the amount of coating transferred to the part through the use of application methods with
higher transfer efficiencies and proper form (spray technique), and using proper equipment
maintenance procedures.
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Equipment Substitution
The use of the more effective application equipment also reduces VOC emissions.
Conventional air atomized application systems utilize high atomizing air pressure with
typical transfer efficiencies of 25 to 40 percent.
More modern technologies, such electrostatic and high volume/low pressure (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. Nearly all metal furniture
spray coatings are electrostatically applied.
HVLP systems have improved nozzles which provide better air and fluid flow, and
allows for gentler atomization of the air stream. These nozzles or atomizers shape the
air/spray pattern and guide the atomized coating particles to the product being coated.
2. Emission Capture and Add-on Control Systems
In addition to pollution prevention measures, VOC emissions from metal furniture
surface coating application 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 metal furniture surface coating industry, EPA is aware of only a few
cases where this control technology is utilized by the industry.4 The majority of VOC
emissions from metal furniture coating operations occur in the spray booth. Spray booths
typically exhaust a high volume of air with a low concentration of VOC which can result in
a high cost of control.
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
metal furniture 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 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
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reduce the volume of exhaust air and increase 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 are typically used by the metal furniture surface coating industry:
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 used in the metal furniture surface coating
industry. 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 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 metal furniture surface coating industry.
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.5 In contrast to combustion, carbon adsorption does not destroy the VOC it removes
from the air stream. Carbon adsorbers used in metal furniture surface coating are thermally
regenerated, usually by passing steam through the carbon beds.6 The VOC are removed
from the carbon (desorbed) and transferred to the steam. The VOC-containing steam is then
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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.6 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.7
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.6
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.5 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 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 metal furniture surface coating facilities currently using these types of control
technologies.4
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 metal furniture industry include product substitution/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.
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No add-on control technologies are being used specifically for reducing VOC
emissions from cleaning operations associated with metal furniture surface coating.
However, if cleaning operations are performed within a capture system that is ducted to an
add-on control system, such as a PTE routed to a thermal oxidizer, the VOC emissions from
the cleaning operations would be reduced by destruction in the thermal oxidizer.
1. Product Substitution/Reformulation
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 metal furniture industry.
2. Work Practice Procedures
Work practice procedures are commonly used in the metal furniture industry to
reduce VOC emissions from cleaning operations. The following work practice procedures
are used to reduce VOC emissions from metal furniture cleaning operations:
• 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
• Minimize VOC emissions during cleaning operations.
C. Existing Federal, State, and Local Recommendations or Regulations
The following discussion is a summary of three EPA actions, as well as State and
local regulations, that address VOC emissions from metal furniture coating processes.
Table 1 outlines these Federal, State and local provisions and the bases for these provisions.
In addition, appendices B and C summarize the State and local provisions.
1. Thel977CTG
The 1977 CTG recommended limiting VOC emissions from each metal furniture
coating unit. 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 a
flash-off area.
For each coating unit, the 1977 CTG recommended a daily volume-weighted average
limit of 0.36 kg/1 (3.0 Ib/gal) of coating, excluding water and exempt compounds, as applied.
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Table 1. Summary of Existing Requirements
Existing Regulation
Emission Limit
Basis for Emission Limit
Metal Furniture Coating CTG
(December 1977)
Recommended VOC emission
limit of 3.0 Ib VOC/gal of
coating, excluding water and
exempt compounds, as applied
(daily volume-weighted average)
(narrow definition of coating
unit)
Calculated based on the use of
higher solids coatings (59.2
percent by volume solids) with an
assumed VOC density of 7.36
Ib/gal. Associated with a baseline
transfer efficiency of 60 percent
Metal Furniture NSPS
(October 29, 1982)
VOC emission limit of 7.5 Ib
VOC/gal of coating solids
deposited from any surface
coating operation on a metal
furniture surface coating line
(monthly volume-weighted
average) (narrow definition of
coating operation)
Based on the use of higher solids
coatings (62 percent by volume
solids) with an assumed VOC
density of 7.36 Ib/gal and a
baseline transfer efficiency of 60
percent.
Metal Furniture NESHAP
(May 23, 2003)
Existing sources: HAP emission
limit of 0.83 Ib organic HAP/ gal
coating solids used
MACT level of control based on
1997/1998 survey of coating
materials used in the industry
California - South Coast Rule
1107 (Originally adopted June 1,
1979 with last amendment
January 6, 2006)
VOC emissions limits for the
coating of metal parts and
products (which includes metal
furniture coating) of: (1) 2.3
pounds of VOC per gallon (0.275
kilograms per liter) of coating,
excluding water and exempt
compounds, as applied for
general one component coatings
(air-dried and baked) and general
multi-component baked coatings;
and (2) 2.8 pounds of VOC per
gallon (0.34 kilograms per liter)
of coating, excluding water and
exempt compounds, as applied
for general multi-component air-
dried coating. Includes specific
limits for specialty coatings such
as extreme high gloss, high
temperature, and metallic
coatings. Electrostatic
application, flow coat, dip coat,
roll coat, HVLP spray, hand
application methods, or other
coating application method
capable of achieving a transfer
efficiency equivalent or better
than that achieved by HVLP
spraying required.
Similar to the 1977 CTG but
using a coating with 69 percent
volume solids for general one-
component (air-dried and baked)
coatings and for general multi-
component baked coatings, 62
percent volume solids for general
multi-component air-dried
coatings and a transfer efficiency
of 65 percent
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Table 1. Summary of Existing Requirements
Existing Regulation
Emission Limit
Basis for Emission Limit
California - South Coast Rule
1107 (Continued)
Exempts coatings and operations
such as stencil coatings, safety-
indicating coatings, touch-up
coatings and application with
hand-held aerosol cans.
Alternative to the emissions limit
and operating equipment
requirement allows the use of
capture and control equipment to
collect at least 90 percent by
weight of the VOC emissions
generated by the sources of VOC
emissions (capture efficiency)
and reduce VOC emissions from
an emission collection system by
at least 95 percent by weight
(control efficiency).
California - Bay Area Regulation
8, Rule 14
(Originally adopted
March?, 1979 with last
amendment October 16, 2002)
Method of coating application
must have a transfer efficiency of
65% or greater and then a VOC
emission limit for baked coatings
of 2.3 Ib/gal (0.275 kg/1) of
coating, excluding water and
exempt compounds, as applied
and for air-dried coatings of 2.8
Ib/gal (0.34 kg/1) of coating,
excluding water and exempt
compounds, as applied. Includes
specific limits for specialty
coatings such as extreme high
gloss, high temperature, and
metallic coatings.
Similar to the 1977 CTGbut
using a coating with 69 percent
volume solids for baked coatings
and 62 percent volume solids for
air-dried coatings and a transfer
efficiency of 65 percent
State Regulations:
36 State and local jurisdiction
rules specifically for metal
furniture coating operations were
identified
VOC emission limit of 3.0 Ib
VOC/gal of coating, excluding
water and exempt compounds, as
applied, or an overall emission
reduction of 90 percent by
utilization of an add-on control
device
1977 CTG
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The emission limit was based on the use of low VOC content coatings and is approximately
equivalent to the use of conventional high solvent content coatings in conjunction with an
add-on control system with an overall control efficiency (taking into account capture and
control) of 81 percent. At the time, it was believed that most metal furniture facilities would
seek to meet future regulations through the use of low-VOC coatings rather than using add-
on control technologies. Cleaning materials were not addressed in the 1977 CTG.
Equivalent solid-based limits for metal furniture coating operations were presented
in A Guideline for Surface Coating Calculations " (EPA-340/1-86-016).8 For metal
furniture surface coating operations, the 1977 CTG-equivalent limit was 0.60 kg/1
(5.1 Ib/gal) of solids. These equivalent limits were calculated using an assumed VOC
density of 0.88 kg/1 (7.36 Ib/gal). This assumed VOC density is the same as that used in
calculating the limits recommended in the 1977 CTG.
2. The 1982 NSPS
The 1982 NSPS applies to metal furniture surface coating operations that
commenced construction, modification, or reconstruction after November 28, 1980. The
1982 NSPS defines surface coating operations in the rule to include prime coat and topcoat
operations, and the standards apply to the coating application station, flash-off area, and
curing oven. Any metal furniture surface coating operation that uses less than 3,842 1 /yr
coating (as applied) is required to keep records of coating usage but is exempt from the other
NSPS provisions. The 1982 NSPS establishes a monthly volume-weighted average VOC
limit of 0.90 kg VOC/1 (7.5 Ib VOC/gal) coating solids deposited. This limit was based on
the use of coatings with around 62 volume percent solids, applied at 60 percent transfer
efficiency, and using an assumed VOC density of 0.88 kg/1 (7.36 Ib/gal).
The 1982 NSPS applies to the same metal furniture surface coating operations as the
1977 CTG: the coating application area, the flash-off area, and the curing oven. Because the
1982 NSPS VOC emission limit is in terms of coating solids deposited and the 1977 CTG-
equivalent limit is in terms of coating solids used, it is difficult to directly compare the two
limits. During the implementation of the 1977 CTG, a baseline of 60 percent (i.e. 0.60 gal
of coating solids deposited per gal coating solids used)8 was used to estimate an as-applied
CTG-equivalent limit. By applying the 60-percent transfer efficiency to the 1977 CTG-
equivalent limit of 0.60 kg VOC/1 (5.1 Ib VOC/gal) solids used, the CTG-equivalent limit
would be 1.01 kg VOC/1 (8.4 Ib VOC/gal) coating solids deposited. Based on this baseline
transfer efficiency, the 1982 NSPS limit is more stringent than the 1977 CTG-equivalent
limit when converted to a solids deposited basis. Cleaning materials were not addressed in
the 1982 NSPS.
3. The 2003 NESHAP
The 2003 NESHAP applies to "major" sources of HAP emissions, which are
stationary sources that emit or have the potential to emit 10 tpy or more of any one HAP, or
25 tpy or more of any combination of HAP. In contrast to the 1977 CTG and the 1982
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NSPS, the 2003 NESHAP covers the collection of all of the following operations and
equipment at a facility:
• coating operations (which are defined to include equipment used for surface
preparation, coating application, and equipment cleaning);
• storage containers and mixing vessels in which coatings, thinners, and cleaning
materials are stored or mixed;
• manual and automated equipment and containers and pumps and piping used for
conveying coatings, thinners, and cleaning materials; and
• storage containers, pumps and piping, and manual and automated equipment and
containers used for conveying waste materials generated by a coating operation.
The 2003 NESHAP imposes an organic HAP emission limitation of 0.10 kg organic
HAP/1 (0.83 Ib organic HAP/gal) of coating solids used for sources in operation on or before
April 24, 2002 (existing sources), and no organic HAP emissions are allowed for new
sources (sources which started up after April 24, 2002). For purposes of determining
compliance, the organic HAP emissions are the total emissions from coatings, thinners, and
cleaning materials.
Compliance with the 2003 NESHAP can be demonstrated by any of three methods:
(1) 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) 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.
If a facility is demonstrating compliance by using the emission rate with add-on
controls option, the 2003 NESHAP requires the facility to develop a work practice plan to
minimize organic HAP emissions from the storage, mixing, and conveying of coatings,
thinners and cleaning materials used in the coating operations, as well as organic HAP
emissions from waste materials generated by such operations. At a minimum, the work
practice plan must include the following elements:
• All organic-HAP-containing coatings, thinners, cleaning materials, and waste
materials must be stored in closed containers. Ensure that these containers are kept
closed at all times except when depositing or removing these materials from the
containers.
• Spills of organic-HAP-containing coatings, thinners, cleaning materials, and waste
materials must be minimized.
• Organic-HAP-containing coatings, thinners, cleaning materials, and waste materials
must be conveyed from one location to another in closed containers or pipes.
• Mixing vessels which contain organic-HAP-containing coatings and other materials
must be closed except when adding to, removing, or mixing the contents.
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• Emissions of organic HAP must be minimized during cleaning of storage, mixing,
and conveying equipment.
4. Existing State and Local VOC Requirements
In addition to the EPA actions described above, at least 36 States and local
jurisdictions have regulations that control VOC emissions from metal furniture coating (or
for metal parts and products coating in general). The vast majority of these States (32
States) have incorporated the 1977 CTG VOC emissions limit of 0.36 kg VOC/1 (3.0 Ib
VOC/gal) of coating applied (minus water). Two States incorporated the CTG-equivalent
limit of 0.60 kg VOC/1 solids used. Appendix B summarizes the applicable rules for all
States except California. The applicable rules for all of the California Districts are
summarized in Appendix C. Generally, compliance with the State and local jurisdiction
emission limits can be achieved using coatings that meet the VOC emission limits or by the
installation of a capture and add-on control system. Some states specify the use of
incinerators and/or carbon adsorbers.
The California South Coast Air Quality Management District (South Coast) has
adopted limits for metal furniture coating that are more stringent than the 1977 CTG
recommendation. The VOC emission limits established by the South Coast for the surface
coatings of metal parts and products (which includes metal furniture coating) are: (1) 275
grams VOC per liter (g VOC/1) (2.3 Ib VOC/gal) of coating, excluding water and exempt
compounds, as applied for general one-component coatings (air-dried and baked) and
general multi-component baked coatings; and (2) 340 g VOC/1 (2.8 Ib VOC/gal) of coating,
excluding water and exempt compounds, as applied for general multi-component air-dried
coatings. The South Coast Regulation also includes specific limits for specialty coatings,
such as extreme high gloss, high temperature, and metallic coatings. The South Coast
regulation specifies the use of the following application methods: electrostatic application,
flow coat, dip coat, roll coat, HVLP spray, hand application methods, or other coating
application method capable of achieving a transfer efficiency equivalent or better than that
achieved by HVLP spraying. Coatings and operations such as stencil coatings, safety-
indicating coatings, touch-up coatings and application with hand-held aerosol cans are
exempt from the South Coast regulations. As an alternative to the emissions limit and
operating equipment requirement, the South Coast regulation allows the use of capture and
control equipment to collect at least 90 percent by weight of the VOC emissions generated
by the sources of VOC emissions (capture efficiency) and to reduce VOC emissions from an
emission collection system by at least 95 percent by weight (control efficiency).
The California Bay Area Air Quality Management District (Bay Area) has also
adopted limits for metal furniture coating that are more stringent than the 1977 CTG
recommendation: (1) 275 g VOC/1 (2.3 Ib VOC/gal) of coating, excluding water and exempt
compounds, as applied, for baked coatings; and (2) 340 g VOC/1 (2.8 Ib/gal) of coating,
excluding water and exempt compounds, as applied, for air-dried coating. Like the South
Coast regulations, the Bay Area regulations include specific limits for specialty coatings and
exemptions for some coatings and coating operations. In addition, the Bay Area rule
requires the use of coating application equipment that can meet a 65 percent or greater
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transfer efficiency. Per the Bay Area regulation, compliance with the standard's 65 percent
of greater transfer efficiency can be achieved by properly operated electrostatic application
or HVLP spray, flow coat, roller coat, dip coat including electrodeposition, and brush coat.
Several jurisdictions in California have requirements to regulate the VOC emissions
from cleaning materials used in the metal furniture surface coating industry. These
regulations are aimed at reducing VOC emissions from cleaning materials by combining
work practice standards with limits on the VOC content or composite vapor pressure of the
solvent being used. In some cases, the jurisdictions allow the use of add-on controls as an
alternative to the VOC content/vapor pressure limits. The different air pollution control
authorities in California have established similar work practice standards. However, the
cleaning material VOC content/vapor pressure limits vary by jurisdiction, as do the overall
control efficiency required when add-on controls are used as an alternative.
There are ten States that have cleaning material regulations that apply to metal
furniture surface coating operations. Of these, nine States do not limit the VOC
content/vapor pressure of cleaning materials. Instead, they have established equipment
standards, work practices, and/or recordkeeping requirements. There is one State that
requires work practices as well as limiting the vapor pressure of the cleaning materials.
VI. Recommended Control Options
Based on a review of the 1977 CTG, the 1982 NSPS, the 2003 NESHAP, and the
current State and local requirements discussed above, we are recommending emission limits
for controlling the VOC emissions from the coatings used by metal furniture manufacturing
facilities and work practices to further reduce VOC emissions from coatings as well as to
minimize emissions from cleaning materials used in metal furniture surface coating
processes.
To control VOC emissions from metal furniture surface coatings, we are
recommending three alternatives: (1) emission limits that can be achieved through the use of
low-VOC coatings; (2) equivalent emission limits that can be achieved through the use of
low-VOC coatings or a combination of coatings and add-on controls; and (3) an overall
control efficiency of 90 percent for add-on controls. The low-VOC coatings
recommendation consists of emission limits in terms of mass of VOC per volume of coating,
excluding water and exempt compounds, as applied and the use of specified application
methods. The equivalent emission limit recommendation consists of emission limits in
terms of mass of VOC per volume of coating solids, as applied, and the use of specific
application methods.
We estimate that these recommendations will reduce VOC emissions from metal
furniture coating by about 35 percent (a reduction of 1,200 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 alternative. We made this
assumption for two reasons. First, we believe that complying low-VOC coating materials
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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 alternative.
For cleaning materials, we are recommending work practices 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 coating application, the use of
add-on controls to reduce emissions from cleaning operations at metal furniture surface
coating 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. However, as
mentioned previously, any cleaning activities that occur within a capture system would be
controlled by the associated control device. Furthermore, 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 metal furniture surface coating
operations. Therefore, we are not recommending the use of a VOC content or VOC
composite vapor pressure limit for cleaning materials
The following discussion summarizes our specific recommendations for coating
operations and cleaning materials used in metal furniture surface coating operations.
A.
Emission Limit Based on Low-VOC Coatings
We are recommending emission limits for one-component and multi-component
general purpose coatings. In addition, we are recommending specific emission limits for
certain specialty coatings. For each of these coating types, we are recommending separate
emission limits for baked and air-dried coatings. Provided below are our recommended
emission limits expressed in terms of mass of VOC per volume of coating (excluding water
and exempt compounds, as applied):
Coating Type
General, One Component
General, Multi-Component
Extreme High Gloss
Extreme Performance
Heat Resistant
Metallic
Pretreatment Coatings
Solar Absorbent
Baked
kg/1
0.275
0.275
0.360
0.360
0.360
0.420
0.420
0.360
Ib/gal
2.3
2.3
3.0
3.0
3.0
3.5
3.5
3.0
Air Dried
kg/1
0.275
0.340
0.340
0.420
0.420
0.420
0.420
0.420
Ib/gal
2.3
2.8
2.8
3.5
3.5
3.5
3.5
3.5
The recommended emission limits can also be expressed in terms of mass of VOC
per volume of coating solids, as applied. A facility could use low-VOC coatings or a
combination of coatings and add-on control equipment on a coating unit to meet the
recommended mass of VOC per volume of coating solids limits. Using an assumed VOC
density of 7.36 pounds per gallon, the equivalent limits in terms of mass of VOC per volume
of solids, as applied, are as follows:
23
-------
Coating Type
General, One Component
General, Multi-Component
Extreme High Gloss
Extreme Performance
Heat Resistant
Metallic
Pretreatment Coatings
Solar Absorbent
Baked
kg/1
0.40
0.40
0.61
0.61
0.61
0.80
0.80
0.61
Ib/gal
o o
J.J
3.3
5.1
5.1
5.1
6.7
6.7
5.1
Air Dried
kg/1
0.40
0.55
0.55
0.80
0.80
0.80
0.80
0.80
Ib/gal
o o
J.J
4.5
4.5
6.7
6.7
6.7
6.7
6.7
We are also recommending that the following types of coatings and coating
operations be exempt from our recommended VOC content limits:
• Stencil coatings
• Safety-indicating coatings
• Solid-film lubricants
• Electric-insulating and thermal-conducting coatings
• Touch-up and repair coatings
• Coating application utilizing hand-held aerosol cans
We are recommending that all VOC-containing materials (i.e., coatings and thinners)
used by each metal furniture surface coating unit are included when determining the coating
unit's emission rate. In addition, we are recommending the use of one or more of the
following application methods: electrostatic application, HVLP spray, flow coat, roller coat,
dip coat including electrodeposition, or other coating application method capable of
achieving a transfer efficiency equivalent or better than that achieved by HVLP spraying.
The recommendations described above are based on the South Coast's metal parts and
products coating regulation, which includes metal furniture.
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.9 The guidance is directed to State and local agencies that
elect to adopt a discretionary economic incentive programs (EIP) and includes guidance on
the use of cross-line averaging.
B.
Optional Add-on Controls for Coating Operations
Should product performance requirements or other needs dictate the use of higher-
VOC materials than those that would meet the recommended emission limits, a facility
could choose to use add-on control equipment with an overall control efficiency of 90
percent. Alternatively, a facility could use a combination of coatings and add-on control
equipment on a coating unit to meet the recommended mass of VOC per volume of coating
24
-------
solids limits. Add-on devices include oxidizers and solvent recovery systems, which
coupled with capture systems to collect the VOC being released at the affected facilities, can
achieve an overall control efficiency of 90 percent. This control option, like the options
noted above, applies to all coatings and thinners applied to metal furniture components or
products.
C. Work Practices for Coating-Related Activities
In addition to the control options above, this CTG recommends work practices to
further reduce VOC emissions from metal furniture 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. 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.
D. Work Practices for Cleaning Materials
This CTG recommends work practices to reduce VOC emissions from cleaning
materials used in metal furniture surface coating operations. 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.
Specifically, we recommend the following work practices: (1) store all VOC-containing
cleaning materials and used shop towels in closed containers; (2) ensure that mixing and
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
storage, mixing, and conveying equipment.
VII. Cost Effectiveness of Recommended Control Options
We used the 2002 National Emissions Inventory (NEI) database to estimate the
number of metal furniture manufacturing facilities. Based on the 2002 NEI, we estimated
that there are a total of 456 metal furniture facilities in the U.S. Using the 2004 ozone
nonattainment designations, we estimated that a total of 289 of these facilities are in ozone
nonattainment areas. Based on the NEI VOC emissions data, 143 of the 289 facilities in
ozone nonattainment areas emitted at or above the 6.8 kg/day (15 Ib/day) recommended
VOC emissions applicability threshold. These 143 facilities emitted a total of about 3,100
25
-------
Mg of VOC per year (Mg/yr) (3,400 tons per year (tpy)), or an average of about 21 Mg/yr
(23 tpy) of VOC per facility.
As previously mentioned, the recommendations in this CTG are similar to the South
Coast regulations governing metal furniture surface coating operations. The cost
effectiveness related to the implementation of these regulations was not estimated during
their development. Therefore, cost-effectiveness estimates for the recommended control
levels were determined using the approach used during the 2003 NESHAP development.
Although the 2003 NESHAP regulates organic HAP, the 2003 NESHAP cost estimates are
relevant to this CTG's recommended levels of control because they are based on the use of
the similar control measures (i.e., product substitution/reformulation and work practices) for
metal furniture coatings and cleaning materials as those recommended in this CTG.
In our analysis of the impacts of implementing the recommended levels of control in
this CTG, we have assumed that all metal furniture surface coating facilities will choose to
utilize the low-VOC coating materials alternative. We made this assumption for two
reasons. First, we believe that low-VOC coating materials that can meet the levels of
control recommended in this CTG 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 is a
more costly alternative.
According to studies performed for the development of the 2003 NESHAP, the cost
averaged across all sizes of facilities, was as high as $1,670 per facility.4 We believe that
this estimate also represents the cost of implementing this CTG's recommended VOC limits
because the NESHAP is based on similar control measures. For the 143 facilities we
identified as emitting more than 6.8 kg/day (15 Ib/day) in ozone nonattainment areas, we
therefore estimate the total annual cost to be $240,500. We estimate that the
recommendations in this CTG will reduce VOC emissions from metal furniture coating by
about 35 percent. This is a reduction of 1,100 Mg/yr (1,200 tpy of VOC) from the 143
facilities. Therefore, we estimate the cost effectiveness to be about $220 per Mg ($200 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 cleaning materials used by
reducing the amount that evaporates and is wasted.
VIII. References
1. Control of Volatile Organic Emissions from Existing Stationary Sources - Volume
III: Surf ace Coating of Metal Furniture. Publication No. EPA-450/2-77-032. U.S.
Environmental Protection Agency, Research Triangle Park, NC. December 1977.
The 1977 CTG is included as Appendix A to this CTG.
2. U.S. Environmental Protection Agency. Standards of Performance for Surface
Coating of Metal Furniture. 40 CFR part 60, subpart EE. October 29, 1982.
26
-------
3. U.S. Environmental Protection Agency. National Emission Standards for Hazardous
Air Pollutants: Metal Furniture Surface Coating. 40 CFR part 63, subpart RRRR.
May 23, 2003.
4. National Emission Standards for Hazardous Air Pollutants (NESHAP) for Source
Category: Metal Furniture Surface Coating - BackgroundInformation for
Proposed Standards. Publication No. EPA-453/R-01-010. U.S. Environmental
Protection Agency, Research Triangle Park, NC. October 2001.
5. Handbook: Control Technologies for Hazardous Air Pollutants. EP A-625/6-91-014,
U.S. Environmental Protection Agency, Cincinnati, Ohio. June 1991.
6. Pressure Sensitive Tape and Label Surface Coating Industry—Background
Information for Proposed Standards. EPA-450/3-80-003a, U.S. Environmental
Protection Agency, Research Triangle Park, North Carolina. September 1980. pp. 3-
14 to 3-15.
7. Compilation of Air Pollutant Emission Factors (AP-42), Volume I (Fifth Edition).
U.S. Environmental Protection Agency, Research Triangle Park, North Carolina.
January 1995. p. 4.2.2.6-3.
8. A Guideline for Surface Coating Calculations. U.S. Environmental Protection
Agency, Washington, D.C. Publication No. EPA-340/1-86-016. July 1986.
9. Improving Air Quality with Economic Incentive Programs. U. S. Environmental
Protection Agency. Research Triangle Park, NC. EPA-452/R-01-001. January
2001.
27
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-------
Appendix A
1977 CTG for Metal Furniture Coating
-------
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-------
EPA-450/2-77-032
December 1977
(QAQPS No. 1.2-086)
GUIDELINE SERIES
CONTROL OF VOLATILE
ORGANIC EMISSIONS
FROM EXISTING
STATIONARY SOURCES
VOLUME III: SURFACE
COATING OF METAL
FURNITURE
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Waste Management
Office *>f Air Quality Planning and SUiiJuriJs.
Research Triangle Part, North Carolina 277 IT
A-l
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A-2
-------
Appendix B
Summary of State and Local Regulations for Metal Furniture
Coating (not including California)
-------
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Table B-l. Summary of State and Local Regulations for Metal Furniture Coating (not including California)
State/Locality
Operations
Covered
VOC Numerical
Limit (minus
water and exempt
compounds)
Compliance Method
Citation
Alabama
(Jefferson County)
Metal
furniture
coating
0.36kg/l(3.01b/gal)
as applied
(excluding water)
For sources located in Jefferson County:
1. use low solvent coating technology; or
2. a capture and control system that have an
overall VOC emission reduction that meet the
applicable emission limit each day; or
3. use powder coating technology; or
4. average two or more coatings on a coating line
that has no add-on VOC control equipment if:
a. The coating is the same type of operation
(source category) and is subject to the same
limits; and
b. the coatings are on the same coating line; and
c. the coatings are averaged on the basis of
pounds of VOC emitted per gallon of coating
solids applied to the substrate; and
d. The compliance demonstration is on a 24-
hour period (calendar day); and
e. The VOC emissions shall be equal to or less
than those emitted when all the surface
coatings delivered to the application system
comply with the applicable regulated VOC
emission rate restriction.
Exemption: 55 gallons of "low-use coatings" may
be exempted on an annual rolling basis
Alabama DEM Air
Division Chapter
33S-3-6-.24 and
335-3-6-.32(3)
B-l
-------
Table B-l. Summary of State and Local Regulations for Metal Furniture Coating (not including California)
State/Locality
Alabama (except
Jefferson County)
Alaskaa
Arizona
Arizona/Pima
Arizona/Final
Operations
Covered
Metal
furniture
coating
VOC Numerical
Limit (minus
water and exempt
compounds)
0.36kg/l(3.01b/gal)
as applied
(excluding water)
Compliance Method
For sources NOT located in Jefferson County:
1 . use low solvent coating technology; or
2. 90 percent emission reduction using
incineration; or
3. another equivalent control technology
Exemptions: Sources with the potential to emit
less than 100 ton VOC/yr
Citation
Alabama DEM Air
Division Chapters
335-3-6-.01 and
335-3-6-.ll(3)
Incorporated by Reference, 40 CFR 60, Subpart EE (NSPS) and 40 CFR 63, Subpart RRRR (NESHAP)
Incorporated by Reference, 40 CFR 60, Subpart EE (NSPS) and 40 CFR 63, Subpart RRRR (NESHAP)
Incorporated by Reference, 40 CFR 60, Subpart EE (NSPS) and 40 CFR 63, Subpart RRRR (NESHAP)
' Alaska does not have applicable air regulations.
B-2
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Table B-l. Summary of State and Local Regulations for Metal Furniture Coating (not including California)
State/Locality
Arizona/Maricopa
Arkansas15
Operations
Covered
Metal
furniture
coating
Cleaning
Materials
VOC Numerical
Limit (minus
water and exempt
compounds)
0.36kg/l(3.01b/gal)
as applied
35mmHgat20°C
Compliance Method
Apply all coatings containing more than 240 g
VOC/1 (2 Ib/gal), minus exempt cmpds using:
1 . Low pressure spray gun; or
2. An electrostatic system; or
3. hydraulic pressure atomizer (including airless
and air assisted airless); or
4. non-atomizing or non-spraying application
methods; or
5. alternate methods approved by regulatory
authorities
Use control systems meeting the following:
1 . Prevent at least 85% of the VOC emitted,
except as controlled using the alternative for
very dilute streams (see 3 below)
2. Use an 87% efficient capture system;
3. Use a 90% efficient control system or for VOC
input less than 100 ppm - control to less than
20 mg VOC/M3 and the control system gets
85% control
Exemptions: Coatings and solvents with a VOC
content less than 18g VOC/1 (0.15 Ib VOC/gal).
Coatings containing less than 0.14 Ib/gal VOC.
Work practices to minimize emissions of
applicable equipment
Citation
Regulation III, Rule
336, section 301
through 306
' Arkansas does not have applicable air regulations.
B-3
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Table B-l. Summary of State and Local Regulations for Metal Furniture Coating (not including California)
State/Locality
Operations
Covered
VOC Numerical
Limit (minus
water and exempt
compounds)
Compliance Method
Citation
Colorado
Metal
furniture
coating
0.36kg/l(3.01b/gal)
1. Use compliant coatings;
2. Use emissions averaging;
3. Use a capture system approved by the
authority or a system that meets the NSPS for
Magnetic Tape
4. Use an add-on control system to meet the limit
Exemptions: metal furniture coating operations
with uncontrolled actual emissions (including
fugitives) are less than 6.8 kg/day (15 Ib/day) and
1.4kg/hr(31b/hr).
No cleaning materials regulations.
CODPHE
AQCC
Regulation No. 7
5 CCR 1001-9
Section IX.H
Connecticut
Metal
furniture
coating
0.36kg/l(3.01b/gal)
as applied
1. Compliant coatings;
2. Daily-weighted average coating content;
3. Install capture and control system that reduces
emissions by 95 percent
Exemptions: any premises with uncontrolled
actual emissions from all coating units are less than
6.8 kg VOC per day (15 Ib/day) combined
No cleaning materials regulations.
RSCA Title 22a
Section 22a-174-
20(p)
Delaware
Metal
furniture
coating
0.35 kg/1 (2.9 Ib/gal)
as applied
1. Compliant coatings;
2. Daily weighted average coating content
3. Install capture and control system that reduces
emissions by 95 percent
Exemptions: any coating unit with uncontrolled
actual emissions from all coating units are less than
15 Ib VOC/day
DNREC Regulation
24, Section 19
B-4
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Table B-l. Summary of State and Local Regulations for Metal Furniture Coating (not including California)
State/Locality
Operations
Covered
VOC Numerical
Limit (minus
water and exempt
compounds)
Compliance Method
Citation
Cleaning
Materials
Does not apply to hand-wipe cleaning operations
Use work practices to minimize emissions.
Perform a solvent usage study to determine permit
requirements. User-defined and operation specific.
Florida
Metal
furniture
coating
0.36kg/l(3.01b/gal)
as applied
(excluding water)
1. use of compliant coatings;
2. use of incineration that reduces VOC emissions
by 90 percent.
Exemptions: all emission units subject to the
same limitation that emit less than 6.8 kg VOC per
day (15 Ib/day) and 1.4 kg/hr (3 Ib/hr) combined
No cleaning material regulations.
FAC Chapter 62-
296.500, 505
B-5
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Table B-l. Summary of State and Local Regulations for Metal Furniture Coating (not including California)
State/Locality
Georgia
Hawaii0
Idaho
Operations
Covered
Metal
furniture
coating
VOC Numerical
Limit (minus
water and exempt
compounds)
3.01b/gal
(excluding water)
5.06 Ib/gal coating
solids as applied
Compliance Method
1 . use low solvent compliant coating technology
2. use 24-hr weighted average of low solvent
coating on a single coating line that meets
5.06 Ib VOC/gal coating solids (averaging
across coating lines is not allowed)
3 . use capture and control that reduces VOC
emissions by 90 percent and overall VOC
emissions do not exceed 5.06 Ib VOC/gal
coating solids
Exemptions: Sources located outside Cherokee,
Clayton, Cobb, Coweta, DeKalb, Douglas, Fayette,
Forsyth, Fulton, Gwinnett, Henry, Paulding, and
Rockdale counties with potential VOC emissions
are less than 100 tons per year; Sources located
within Cherokee, Clayton, Cobb, Coweta, DeKalb,
Douglas, Fayette, Forsyth, Fulton, Gwinnett,
Henry, Paulding, or Rockdale counties with actual
VOC emissions are less than 15 Ib/day; total use of
coatings, inks and other VOC-containing materials
is less than 55 gal/yr
No cleaning materials regulations.
Citation
GDNR
OGCA 12-9-1
391-3-l-.02(2)(y)
Incorporated by Reference, 40 CFR 60, Subpart EE (NSPS) and 40 CFR 63, Subpart RRRR (NESHAP)
! Hawaii does not have applicable air regulations.
B-6
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Table B-l. Summary of State and Local Regulations for Metal Furniture Coating (not including California)
State/Locality
Operations
Covered
VOC Numerical
Limit (minus
water and exempt
compounds)
Compliance Method
Citation
Illinois (not
including Chicago
and Metro East
areas)
Metal
furniture
coating
0.36kg/l(3.01b/gal)
1. control emissions by an afterburner system
which provides an overall 81% VOC emission
from the coating line, and 90% of the
nonmethane VOC (measured as total
combustible carbon) which enters the
afterburner.
2. the combined actual emissions from selected
coating lines (not including those constructed
or modified after 7/1/79), is less than or equal
to the combined allowable emissions calculated
using the formula provided in the regulation.
Exemptions: Coating plants in which
uncontrolled VOC emissions are limited by the
operating permit to 22.7 Mg/yr (25 tpy); or the
total coating usage does not exceed 9,463 1/yr
(2,500 gal/yr); or touch-up and repair coatings used
by a coating source if the source-wide volume is
less than 0.95 1 (1 quart) per eight-hour period or
exceeds 209 1/yr (55 gal/yr) for any rolling twelve-
month period.
No cleaning materials regulations.
Title 35, Subtitle B,
Chapter I;
Subchapter c, Part
215, SubpartF,
sections 215.204(g),
215.205(b)and
215.206 (a) and (b)
B-7
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Table B-l. Summary of State and Local Regulations for Metal Furniture Coating (not including California)
State/Locality
Operations
Covered
VOC Numerical
Limit (minus
water and exempt
compounds)
Compliance Method
Citation
Illinois (Chicago
areas)
Metal
furniture
coating, air
dried
0.34 kg/1 (2.8 Ib/gal)
Metal
furniture
coating,
baked
0.28 kg/1 (2.3 Ib/gal)
1. apply coatings that, during each day, do not
exceed the daily-weighted average VOC
content limit
2. use a capture and control system which has an
overall VOC emission reduction of 81% and
the control device has a 90% efficiency
3. capture and control system reduces VOC
emissions to meet the applicable VOC
emission limit.
Exemptions: Coating plants in which combined
actual uncontrolled VOC emissions do not exceed
6.8 kg/day (15 Ib/day); or touch-up and repair
coatings used by a coating source if the source-
wide volume is less than 0.95 1 (1 quart) per eight-
hour period or exceeds 209 1/yr (55 gal/yr) for any
rolling twelve-month period.
No cleaning material regulations.
Title 35, Subtitle B,
Chapter I;
Subchapter c, Part
218, SubpartF,
sections 218.204(g),
218.205(h),
218.207(b),
218.208(a)and(c)
B-8
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Table B-l. Summary of State and Local Regulations for Metal Furniture Coating (not including California)
State/Locality
Operations
Covered
VOC Numerical
Limit (minus
water and exempt
compounds)
Compliance Method
Citation
Illinois (Metro
East areas)
Metal
furniture
coating, air
dried
0.34 kg/1 (2.8 Ib/gal)
Metal
furniture
coating,
baked
0.28 kg/1 (2.3 Ib/gal)
1. apply coatings that, during each day, do not
exceed the daily-weighted average VOC
content limit
2. use a capture and control system which has an
overall VOC emission reduction of 81% and
the control device has a 90% efficiency
3. capture and control system reduces VOC
emissions to meet the applicable VOC
emission limit.
Exemptions: Coating plants in which combined
actual uncontrolled VOC emissions do not exceed
6.8 kg/day (15 Ib/day); or touch-up and repair
coatings used by a coating source if the source-
wide volume is less than 0.95 1 (1 quart) per eight-
hour period or exceeds 209 1/yr (55 gal/yr) for any
rolling twelve-month period.
No cleaning materials regulations.
Title 35, Subtitle B,
Chapter I;
Subchapter c, Part
219 SubpartF,
sections 219.204(g),
219.205(a),
219.207(b),
219.208(a) and (c)
B-9
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Table B-l. Summary of State and Local Regulations for Metal Furniture Coating (not including California)
State/Locality
Operations
Covered
VOC Numerical
Limit (minus
water and exempt
compounds)
Compliance Method
Citation
Indiana
Metal
furniture
coating
0.36kg/l(3.01b/gal)
(excluding water)
1. use compliant coatings
2. carbon adsorption
3. incineration
4. higher solids coatings
5. waterborne coatings
6. equivalent emission limitation based on
transfer efficiency
Exemptions: Facilities existing before 1/1/80 not
located in Clark, Elkhart, Floyd, Lake, Marion,
Porter, and St. Joseph Counties which have
potential emissions less than 90.7 Mg/yr (100 tpy);
Facilities constructed after 1/1/80 located in any
county with potential emissions less than
22.7 Mg/yr (25 tpy), Facilities existing before
7/1/90 and not located in Clark, Elkhart, Floyd,
Lake, Marion, Porter, and St. Joseph Counties and
facilities constructed after 7/1/90 and located in
any county with actual uncontrolled emissions less
thanlSlb VOC/day
No cleaning material regulations.
IDEM Air Pollution
Control Board title
326
326 IAC 8-1-2,
8-2-1,8-2-6,8-2-11
Iowa
Incorporated by Reference, 40 CFR 60, Subpart EE (NSPS) and 40 CFR 63, Subpart RRRR (NESHAP)
Kansas
Metal
furniture
coating
3.01b/gal
1. use compliant coatings
2. use coatings that meet limit on a daily weighted
average basis
3. capture and control system with an overall
emission reduction of at least 90%
Exemptions: Facility with facility-wide VOC PTE
less than 3 tpy. Facilities located outside of ozone
nonattainment areas.
Kansas AQR 28-19-
73(c), (f), (k)
B-10
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Table B-l. Summary of State and Local Regulations for Metal Furniture Coating (not including California)
State/Locality
Operations
Covered
VOC Numerical
Limit (minus
water and exempt
compounds)
Compliance Method
Citation
Kentucky
Metal
furniture
coating
3.0 Ib/gal for new
sources or 15 % by
weight of VOCs net
input into the
facility for existing
sources
Exemptions: Coatings with VOC content less than
0.36 kg/1 (3.0 Ib/gal). Facility with actual
uncontrolled emissions less than 3 Ib/hr; 15 Ib/day;
or 10 tpy based on maximum production and 8,760
hr/yr. Low use coating if plantwide consumption is
less than or equal to 55 gal/previous 12 months.
No cleaning materials regulations.
401KAR61:120
B-ll
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Table B-l. Summary of State and Local Regulations for Metal Furniture Coating (not including California)
State/Locality
Operations
Covered
VOC Numerical
Limit (minus
water and exempt
compounds)
Compliance Method
Citation
Louisiana
Metal
furniture
coating
0.36kg/l(3.01b/gal)
(minus water and
exempt solvent)
1. capture system with at least 80% efficiency
2. Low solvent coating
3. incinerator with at least 90% control efficiency
4. carbon adsorption
Exemptions: All emission units subject to the
same limitation that emit less than 6.8 kg VOC per
day (15 Ib/day) and 1.3 kg/hr (3 Ib/hr) combined.
Surface coating facilities in Ascension, Calcasieu,
East Baton Rouge, Iberville, Livingston, Pointe
Coupee, and West Baton Rouge parishes that when
controlled have a potential to emit a combined
weight (total from the property) of VOCs less than
10 tons in any consecutive 12 calendar months are
exempt from the provisions of Subsection C.
Surface coating facilities on any property in
parishes other than Ascension, Calcasieu, East
Baton Rouge, Iberville, Livingston, Pointe Coupee,
and West Baton Rouge that when uncontrolled
have a potential to emit a combined weight of
VOCs less than 100 pounds (45 kilograms) in any
consecutive 24-hour period are exempt from the
provisions of Subsection C.
No cleaning materials regulations.
LAC Title 33
2123.A, C
B-12
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Table B-l. Summary of State and Local Regulations for Metal Furniture Coating (not including California)
State/Locality
Maine
Operations
Covered
Metal
furniture
coating
VOC Numerical
Limit (minus
water and exempt
compounds)
0.36kg/l(3.01b/gal)
Compliance Method
1 . Low solvent coating
2. Capture and control system that gets 95%
control or 4.9 Ib/gal solids
Exemptions: maximum theoretical VOC
emissions from all coating units, lines or operations
under the same surface coating category less than
10 tpy. Or Coating units, lines or operations whose
total actual coatings usage from all coating units,
lines or operations under the same surface coating
category is less than 50 gal/yr of coatings. OR
facilities that use powder coatings or other non-
VOC coating methods.
No cleaning materials regulations.
Citation
06 096 Chapter 129
l.A, l.E, 3.D
B-13
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Table B-l. Summary of State and Local Regulations for Metal Furniture Coating (not including California)
State/Locality
Operations
Covered
VOC Numerical
Limit (minus
water and exempt
compounds)
Compliance Method
Citation
Maryland
Metal
furniture
coating
0.36kg/l(3.01b/gal)
1. use low VOC coatings or adhesives;
2. use a control device that, results in an emission
reduction equal to or greater than the emission
reduction that would have been achieved by
complying low use VOC coatings
3. reduce emissions by using water-based
coatings, resins, inks, or similar products that
contain less than 25 percent VOC by volume of
the volatile portion of the product; or
4. an alternative method approved by authority
No cleaning materials regulations.
ACM Subtitle 11
26.11.19.02 and .08
Massachusetts
Metal
furniture
coating
5.1 Ib/gal solids
applied
1. Use low/no solvent coatings
2. Use add-on controls
3. Use daily weighted averaging
Exemptions: facilities for which the total amount
of all coatings exempted is less than 55 gal on a 12-
month rolling period and facilities with
uncontrolled VOC emissions less than 15 Ib/day
Keep records of cleaning materials usage.
310CMR7.18(3)
B-14
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Table B-l. Summary of State and Local Regulations for Metal Furniture Coating (not including California)
State/Locality
Michigan
Minnesota
Mississippi
Missouri
Montana
Operations
Covered
Metal
furniture
coating
VOC Numerical
Limit (minus
water and exempt
compounds)
3.01b/gal(as
applied, minus
water), or
8.4 Ib/gal coating
solids applied
Compliance Method
1 . Use compliant coatings
2. Use volume weighted average emissions
coating content
3. Use add-on controls combined with volume
weighted average
Exemptions: Facilities with a combined actual
VOC emission rate less than 100 Ib/day or
2,000 Ib/month and facilities may exclude low-use
coatings that total 55 gallons or less per rolling 12-
month period.
No cleaning materials regulations.
Citation
R336. 1610(2), (7),
(8), (11)
Incorporated by Reference, 40 CFR 60, Subpart EE (NSPS) and 40 CFR 63, Subpart RRRR (NESHAP)
Incorporated by Reference, 40 CFR 60, Subpart EE (NSPS) and 40 CFR 63, Subpart RRRR (NESHAP)
Metal
furniture
coating
3.01b/gal(as
applied, minus
water)
1 . Comply with daily volume-weighted average,
as applied, on a Ib/gal coating basis
2. comply with daily volume-weighted average,
as applied, on a Ib/gal coating solids basis;
3 . comply with a combination of capture and
control system and daily volume-weighted
average.
Exemptions: Does not apply to sources located
outside of Clay, Jackson, and Platte counties. And
sources with total uncontrolled potential VOC
emissions is less than 6.8 kg/day (2.7 tpy)
No cleaning materials regulations.
10 CSR 10-
2.230(1)(A) and (B),
(4) and (5)
Incorporated by Reference, 40 CFR 60, Subpart EE (NSPS) and 40 CFR 63, Subpart RRRR (NESHAP)
B-15
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Table B-l. Summary of State and Local Regulations for Metal Furniture Coating (not including California)
State/Locality
Nebraska
Nevadad
New Hampshire
New Jersey
New Mexico6
Operations
Covered
VOC Numerical
Limit (minus
water and exempt
compounds)
Compliance Method
Citation
Incorporated by Reference, 40 CFR 60, Subpart EE (NSPS) and 40 CFR 63, Subpart RRRR (NESHAP)
Metal
furniture
coating
Metal
furniture
coating
0.36kg/l(3.01b/gal)
0.36kg/l(3.01b/gal)
(minus water)
1 . use compliant coatings
2. add-on control device or bubble and comply
with solids-based emission rate
Exemptions: Minor VOC sources with total VOC
emissions less than 5 tpy. Sources that already
meet or exceed RACT requirements. Facilities
with VOC PTE less than 10 tpy.
No cleaning materials regulations.
1. Control emissions by 90 percent
2. control emissions such that the hourly VOC
emission rate does not exceed a calculated max
hourly emission rate
Exemptions: Total surface coating formulation
containing VOC are applied at a rate less than 1A
gallon per hour and 2 1A gallons per day. Surface
coating operations with VOC PTE less than 3 Ib/hr.
No cleaning materials regulations.
NHCAR, Chapter
ENV-A 1200,
1204.02(b), (c), (d),
1204.12
NJAC Title 7,
Chapter 27,
sub chapter 16
7:27-16.7
Incorporated by Reference, 40 CFR 60, Subpart EE (NSPS) and 40 CFR 63, Subpart RRRR (NESHAP)
Nevada has no air regulations applicable to the Metal Furniture industry.
' New Mexico has a local agency with air regulations, but they could not be accessed on the Internet.
B-16
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Table B-l. Summary of State and Local Regulations for Metal Furniture Coating (not including California)
State/Locality
New York
North Carolina
North Dakota*
Operations
Covered
Metal
furniture
coating
VOC Numerical
Limit (minus
water and exempt
compounds)
3.01b/gal
5.1 Ib/gal coating
solids, as applied or
if using a control
device, 3.01b/gal
coating, as applied
Compliance Method
1 . Use a VOC incinerator that with 80% removal
efficiency
2. determine overall removal efficiency of an air
cleaning device on a solids as applied basis
unless the air cleaning device has an 85%
removal efficiency
Exemptions: Low-use coatings where the
combined facility-wide usage is less than 55
gallons on a 12-month rolling average
Use work practices to minimize VOC emissions
from cleaning materials.
Exemptions: Sources with VOC emissions less
than 15 Ib/day
No cleaning materials regulations.
Citation
NY ECL part 228
Sections 228. 1,3,
and 7
NCAC 2D.0922
Incorporation by Reference, 40 CFR 60, Subpart EE (NSPS)
f North Dakota does not have applicable air regulations.
B-17
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Table B-l. Summary of State and Local Regulations for Metal Furniture Coating (not including California)
State/Locality
Ohio (Ashtabula,
Butler, Clark,
Clermont,
Cuyahoga,
Delaware,
Franklin, Geauga,
Greene, Hamilton,
Lake, Licking,
Lorain, Lucus,
Mahoning,
Medina, Miami,
Montgomery,
Portage, Stark,
Summit,
Trumbull, Warren,
and Wood
Counties)
Operations
Covered
Metal
furniture
coating
VOC Numerical
Limit (minus
water and exempt
compounds)
3.01b/gal coating
OR
5.1 Ib/gal solids (if
using a control
system)
Compliance Method
1 . Use compliant coatings; or
2. Use a capture and control system that meets the
5.1 Ib VOC/gal solids limit; or
3. Use a capture and control system with an
overall VOC emission reduction greater than
81%, by weight, in the overall VOC emissions
from the coating line; and the control
equipment has an VOC emission reduction
efficiency of 90% by weight; or
4. An alternative emission limitation based upon
a transfer efficiency (determined using a test
method) greater than 60 percent.
Exemptions: Total VOC emissions from coating
operations are less than 15 Ib/day before add-on
control.
Citation
OAC 3745-21-09(1)
B-18
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Table B-l. Summary of State and Local Regulations for Metal Furniture Coating (not including California)
State/Locality
Operations
Covered
VOC Numerical
Limit (minus
water and exempt
compounds)
Compliance Method
Citation
Ohio (remaining
64 counties)
Metal
furniture
coating
3.01b/gal coating
OR
5.1 Ib/gal solids (if
using a control
system)
1. Use compliant coatings; or
2. Use a capture and control system that meets the
5.1 Ib VOC/gal solids limit; or
3. Use a capture and control system with an
overall VOC emission reduction greater than
81%, by weight, in the overall VOC emissions
from the coating line; and the control
equipment has an VOC emission reduction
efficiency of 90% by weight; or
4. An alternative emission limitation based upon
a transfer efficiency (determined using a test
method) greater than 60 percent.
Exemptions: Existing facilities (for which
construction or modification commenced before
October 19, 1979) and have the potential to emit
less than 100 tpy VOC. Total VOC emissions
from coating operations are less than 15 Ib/day
before add-on control.
OAC 3745-21-09(1)
Oklahoma
Attainment areas
Metal
furniture
coating,
various
coating
types
4.8-6.51b/gal
1. compliant coatings
2. incineration, absorption, adsorption, or other
process so long as emissions are no more than
they would be using compliant coatings
Exemptions: sources that emit less than 100
Ib/dayofVOC.
Include VOC emissions from cleanup in
determining compliance
Title 252, Chapter
100,252:100-37-25
B-19
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Table B-l. Summary of State and Local Regulations for Metal Furniture Coating (not including California)
State/Locality
Oklahoma
Tulsa County
Oregon
Operations
Covered
Metal
furniture
coating,
various
coating
types
Metal
furniture
coating
VOC Numerical
Limit (minus
water and exempt
compounds)
3.0-4.31g/gal
3.01b/gal
(as applied)
Compliance Method
1 . compliant coatings
2. incineration, absorption, or other equipment so
long as emissions are no more than they would
be using compliant coatings, and at least 85%
overall control efficiency
Include VOC emissions from cleanup in
determining compliance.
1 . Use low solvent coatings;
2. Use an incineration system that gets 90%
control or
3 . An equivalent means of control
Exemptions: Sources whose potential VOC
emissions are less than 10 tpy (or 3 Ib VOC/hr or
15 Ib VOC/day actual).
Keep records of cleaning materials usage.
Citation
Title 252, Chapter
100,252:100-39-46
OAR 340-232-0 160
B-20
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Table B-l. Summary of State and Local Regulations for Metal Furniture Coating (not including California)
State/Locality
Operations
Covered
VOC Numerical
Limit (minus
water and exempt
compounds)
Compliance Method
Citation
Pennsylvania
Metal
furniture
coating
0.61 kg/1 coating
solids
(5.06 Ib/gal coating
solids)
1. Use compliant coatings, as applied.
2. Use combination of compliant coatings and
capture and control systems
Exemptions: A facility that has had actual VOC
emissions less than 1.4 kg/hr (3 Ib/hr), 7 kg/day
(15 Ib/day) or 2,455 kg/yr (2.7 tpy) during any
calendar year since January 1, 1987
No cleaning materials regulations.
129-52
Rhode Island
5.06 Ib/gal coating
solids or
3.0 Ib/gal coating
(excluding water
and exempt
solvents)
Reduce VOC emissions by 95% using a control
system;
Use compliant coatings;
Use control systems to meet coating content
limits;
Use daily-weighted averaging
Use an approved alternative method
Exemptions: Actual uncontrolled VOC emissions
are less than 15 Ib/day since 12/31/89.
Keep records of cleaning materials usage
Air Pollution
Control Regulation
No. 19
South Carolina
Metal
furniture
coating
0.36 kg/1 (3.0 Ib/gal)
as applied
1. Low solvent technology
2. incineration that reduces VOC emissions by 90
percent
3. carbon bed solvent recovery or
4. alternative technology
Exemptions: plants with total potential VOC
emissions less than 550 pounds (250 kilograms) in
any one day (nominal size - 100 tons per year) or
more than 150 pounds (68 kilograms) in any one
hour.
Keep records of cleanup materials.
62.5, St. 5, Part D
B-21
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Table B-l. Summary of State and Local Regulations for Metal Furniture Coating (not including California)
State/Locality
Operations
Covered
VOC Numerical
Limit (minus
water and exempt
compounds)
Compliance Method
Citation
South Dakota
Incorporated by Reference, 40 CFR 63, Subpart RRRR (NESHAP)
Tennessee
Metal
furniture
coating
0.36 kg/1
(3.01b/gal),
excluding water
and/or exempt
compounds, as
applied
1. Use compliant coatings;
2. Meet limit using weighted average VOC
content
3. Reduce emissions by 95% using capture and
control system
Exemptions: Facilities located in Davidson,
Rutherford, Sumner, Williamson, or Wilson
County with actual uncontrolled VOC emissions
from all metal furniture coating operations less
than 6.8 kg (15 Ib) per day or whose max
theoretical VOC emissions from all paper coating
operations are less than 10 tpy. Facilities in
Hamilton or Shelby County with potential VOC
emissions from all metal furniture coating
operations less than 25 tpy, Facilities located in
any other county with potential VOC emissions
from all metal furniture coating operations less
than 100 tpy.
No cleaning materials regulations.
1200-3-18-17
B-22
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Table B-l. Summary of State and Local Regulations for Metal Furniture Coating (not including California)
State/Locality
Operations
Covered
VOC Numerical
Limit (minus
water and exempt
compounds)
Compliance Method
Citation
Texasg
Utah
Metal
furniture
coating
0.36kg/l(3.01b/gal)
coating or
5.1 Ib/gal coating
solids
1. use low solvent technology coatings;
2. reduce VOC emissions by 90% using an
incinerator
3. use a carbon adsorber
4. use water-borne electrodeposition
5. use water-borne spray, dip, or flowcoat
6. use powder coatings
7. use higher solids coatings
Exemptions: Sources whose VOC emissions are
less than 6.8 kg (15 Ib) in any 24 hour period, nor
more than 1.4 kg (3 Ib) in any one hour
Work practices to minimize VOC emissions from
cleaning materials.
R307-340-2, 5, and
11
Vermont
Metal
furniture
coating,
various
coatings
3.0-4.31b/gal
1. Daily weighted average of VOC content must
comply with VOC limit.
2. install capture and control device where the
overall reduction efficiency is greater than or
equal to the required reduction efficiency (an
efficiency is not specified).
Exemptions: Metal furnitue coating sources that
have actual uncontrolled VOC emissions less than
5 Ib/day.
No cleaning materials regulations.
5-253.13
; Could not access Texas air regulations website.
B-23
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Table B-l. Summary of State and Local Regulations for Metal Furniture Coating (not including California)
State/Locality
Virginia
Washington
West Virginia
Operations
Covered
Metal
furniture
coating
VOC Numerical
Limit (minus
water and exempt
compounds)
3.01b/gal, as
applied (excluding
water)
Compliance Method
1 . Use of waterborne or electrodeposited
waterborne coatings;
2. Use of high-solids coatings;
3 . Use of powder coatings;
4. Carbon adsorption;
5. Incineration; or
6. Any technology with an equivalent control
efficiency when compared to the use of a
coating complying with the VOC limit
No cleaning materials regulations.
Citation
9 VAC 5-40-46 10,
4630, 4640
Incorporated by Reference, 40 CFR 60, Subpart EE (NSPS) and 40 CFR 63, Subpart RRRR (NESHAP)
Metal
furniture
coating
Cleaning
materials
0.36kg/l(3.01b/gal)
coating
6.8 kg/day
(15 Ib/day)
1 . Daily weighted emission limitation
2. use a capture and control system with an
overall emission reduction of 95%
Exemptions: coating operations at facilities with
uncontrolled actual VOC emissions less than
6.8 kg (15 Ib) per day.
Use work practices to minimize emissions.
Do not use VOCs for cleanup activities unless
equipment is used to collect the cleaning
compounds and to minimize their evaporation to
the atmosphere.
§45-21-16
B-24
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Table B-l. Summary of State and Local Regulations for Metal Furniture Coating (not including California)
State/Locality
Wisconsin
Wyoming
Operations
Covered
Metal
furniture
coating
VOC Numerical
Limit (minus
water and exempt
compounds)
0.36kg/l(3.01b/gal)
coating
Compliance Method
1 . Use of low solvent coatings
2. Use a vapor recovery system
3. Use incinerator with a 90% emission reduction
4. Daily volume-weighted average
Exemptions: coating operations at facilities with
uncontrolled actual VOC emissions less than
0.68 kg (1 5 Ib) per day.
No cleaning materials regulations.
Citation
NR 422.04, 10
Incorporated by Reference, 40 CFR 60, Subpart EE (NSPS) and 40 CFR 63, Subpart RRRR (NESHAP)
B-25
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Appendix C
Summary of California Air District Regulations for Metal Furniture
Coating
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Table C-l. Summary of California Air District Regulations for Metal Furniture Coating
Operation
Material
voc
limitation
Compliance Requirements
Citation
Antelope Valley Air Pollution Control District
Metal coating
General coatings,
air dried
General coatings,
baked
Specialty coatings
(non-military), air
dried
Specialty coatings
(non-military),
baked
Solvent cleaning
materials
Content limit
of340g/las
applied (less
water and
exempt
compounds)
Content limit
of275g/las
applied (less
water and
exempt
compounds)
Content limit
of420g/las
applied (less
water and
exempt
compounds)
Content limit
of 275-420 g/1
as applied (less
water and
exempt
compounds)
Content limit
of 950 g/1
(7.91 g/gal) and
VOC
composite
partial pressure
of 35 mmHg
@20°C (68°F)
1 . Use compliant coatings; or use an collection system that has a capture
efficiency of at least 90%, by weight and the control device has an
emission reduction efficiency of 95% by weight or to an outlet
concentration of 50 ppmv (as carbon)
2. Coatings must be applied using the following types of equipment:
electrostatic attraction, flow, roll, dip, HVLP, or hand application.
Alternative coating methods must be approved and achieve at least
65% transfer efficiency.
3 . Solvent cleaning must use one of the following: wipe cleaning; closed
containers or hand held spray bottles w/out propellant-induced force;
cleaning equipment which has a solvent container that is closed at all
times (except when adding or removing parts or during repair); remote
reservoir cleaner; non-atomized solvent flow where solvent is collected
in a container or collection system that is closed at all times except for
solvent collection and pressure relief (as needed) openings; and solvent
flushing methods where solvent is collected in a container or collection
system that is closed at all times except for solvent collection and
pressure relief (as needed) openings (discharged solvent must be
collected into containers without atomizing into the air and solvent
may be flushed through the system by air or hydraulic pressure or by
pumping).
4. All VOC-containing solvents must be stored in non-absorbent, non-
leaking containers which must be kept closed at all times, except when
filling or emptying. Cloth and paper containing with VOC-laden
solvents should be stored in closed, non-absorbent, non-leaking
containers.
5. Use closed containers for disposal of cloth or paper used in stripping
cured coatings that are impregnated with solvent containing VOC
AVAQMDRule 1107
and 1171
C-l
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Table C-l. Summary of California Air District Regulations for Metal Furniture Coating
Operation
Material
voc
limitation
Compliance Requirements
Citation
Bay Area Air Quality Management District
Metal
furniture
coating
Air dried coatings
Baked coatings
Specialty
coatings, air dried
Specialty
coatings, baked
Content limit
of340g/l
(2.8 Ib/gal), as
applied (less
water)
Content limit
of275g/l
(2.3 Ib/gal), as
applied (less
water)
Content limit
of420g/l
(3.5 Ib/gal), as
applied (less
water)
Content limit
of 360-420 g/1
(3.0-
3.5 Ib/gal), as
applied (less
water)
1 . Use an approved control system.
2. Use low-solvent coatings that meet the content limit.
3 . Use closed containers to store or dispose of cloth or paper laden with
organic compounds that is used for surface preparation, cleanup or
coating removal.
4. Close containers of fresh solvent, coating, or catalyst when not in use.
5. Materials used for cleanup of spray equipment and surface preparation
must contain no more than 50 g/1 (0.42 Ib/gal) VOC.
BAAQMD 8-14
C-2
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Table C-l. Summary of California Air District Regulations for Metal Furniture Coating
Operation
Material
voc
limitation
Compliance Requirements
Citation
El Dorado County Air Quality Management District
Machinery,
process, or
operation with
the potential
to emit
organic
compounds
Solvent
Cleaners
Any that come
into contact with
a flame, or are
baked, heat cured,
or heat-
polymerized in
the presence of O2
Any that are
conducted at or
below ambient
temperatures
Solvents used on
substrates during
the manufacturing
process or for
surface
preparation
Solvents used for
maintenance and
repair
15 Ib/day and
31b/hr
40 Ib/day and
81b/hr
(emissions
from air or
heat drying for
the first 12
hours must be
included)
70 g VOC/1
material
900 g VOC/1
material and a
composite
partial pressure
of 20 mm Hg
or less at 20°C
(68°F)
1 . Reduce VOC emissions by 85% or more; or equip process with B ACT
2. Do not dispose or allow the release of organic compounds from
storage or transfer operations of more than 1.5 gal of liquid (or
equivalent amount of vapor).
Exemptions: (1) stationary storage containers less than 250 gal; (2) any
single use or operation which annually uses a total volume of VOC which is
less than the emission limits, unless it is part of a large operation subject ot
regulation; and (3) sources in existence before March 1, 1984.
1 . Use complaint cleaning materials AND Use one of the following
cleaning devices or methods:
a. Wipe cleaning;
b. Non propellant spray bottles or containers
c. Cleaning equipment which has a solvent container that can be, and
is, closed during cleaning operations, except when depositing and
removing objects, and is closed during non-operation with the
exception of maintenance and repair to the cleaning equipment
itself;
d. 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
EDCAQMDRule216
EDCAQMD Rule 235
C-3
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Table C-l. Summary of California Air District Regulations for Metal Furniture Coating
Operation
Material
Solvents used for
cleaning coatings
or adhesives
application
equipment
Solvents used for
cleaning polyester
resin application
equipment
voc
limitation
950 g VOC/1
material and a
composite
partial pressure
of 35 mmHg
orlessat20°C
(68°F)
200 g VOC/1
material; or
1, 100 g VOC/1
and composite
partial pressure
of 1.0 mmHg
orlessat20°C
(68°F) or
solvent
reclamation
system
Compliance Requirements
e. 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.
2. Use a collection and control system that collects at least 90 percent
of the emissions and reduces VOC emissions by at least 95 percent or
has an outlet concentration less than 50 ppmw (as carbon)
Citation
C-4
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Table C-l. Summary of California Air District Regulations for Metal Furniture Coating
Operation
Material
voc
limitation
Compliance Requirements
Citation
Great Basin Unified Air Pollution Control District
Organic
solvents or
solvent
containing
materials
Any that come
into contact with
a flame, or are
baked, heat cured,
or heat-
polymerized in
the presence of O2
Photochemically
reactive solvent
(except solvents
that are baked,
heat cured or
heat-
polymerized)
Non-
photochemically
reactive solvent
(except solvents
that are baked,
heat cured or
heat-
polymerized)
15 Ib/day and
31b/hr
40 Ib/day and
81b/hr
(emissions
from air or
heat drying for
the first 12
hours must be
included)
3,000 Ib/day
and 450 Ib/hr
(emissions
from air or
heat drying for
the first 12
hours must be
included)
1 . Reduce VOC emissions by 85% or more
2. Control emissions by incineration with an emission reduction of 90%
or use adsorption, or another approved method of control.
Exemptions: (1) transport of storage of organic containing materials; (2)
the volatile content of materials consists of only water and non-
photochemically reactive organic solvents containing less than 20% by
volume of VOC, and does not come into contact with a flame; (3) the
volatile content of materials consists of only water and non-
photochemically reactive organic solvents and more than 50% by volume of
VOC is evaporated prior to entering a chamber heated above ambient
temperature, and does not come into contact with a flame; and (4) the
solvent content is less than 5% by volume of non-photochemically reactive
organic solvents, and does not come into contact with a flame.
GBUAPCDRule417
C-5
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Table C-l. Summary of California Air District Regulations for Metal Furniture Coating
Operation
Material
voc
limitation
Compliance Requirements
Citation
Imperial County Air Pollution Control District
Organic
solvents or
solvent
containing
materials
Any that come
into contact with
a flame, or are
baked, heat cured,
or heat-
polymerized in
the presence of O2
Photochemically
reactive solvent
(except solvents
that are baked,
heat cured or
heat-
polymerized)
15 Ib/day and
31b/hr
40 Ib/day and
81b/hr
(emissions
from air or
heat drying for
the first 12
hours must be
included)
1 . Emissions from cleanup with photo-chemically reactive solvents must
be included in compliance determination
2. Reduce VOC emissions by 85% or more using a capture and control
system (an incinerator must have an emission reduction of 90% or
more).
Exemptions: (1) transport of storage of organic containing materials; and
(2) the volatile content of materials consists of only water and non-
photochemically reactive organic solvents containing less than 20% by
volume of VOC, and does not come into contact with a flame; and (3) use,
application, evaporation, or drying halogenated hydrocarbons or
perchloroethylene.
ICAPCDRule417
C-6
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Table C-l. Summary of California Air District Regulations for Metal Furniture Coating
Operation
Material
VOC
limitation
Compliance Requirements
Citation
Kern County Air Pollution Control District
Metal
Coatings
General coatings,
air dried
General coatings,
baked
Specialty
coatings, air dried
Specialty
coatings, baked
Surface cleaning
and stripping
materials
Content limit
of420g/l(3.5
Ib/gal) (less
water and
exempt
compounds)
Content limit
of275g/l(2.3
Ib/gal) (less
water and
exempt
compounds)
Content limit
of 340-420 g/1
(2.8-3.5 Ib/gal)
(less water and
exempt
compounds)
Content limit
of 275-420 g/1
(2.3-3.5 Ib/gal)
(less water and
exempt
compounds)
Content limit
of 200 g/1 (1.7
Ib/gal) (less
water and
exempt
compounds)
1. Use compliant coatings.
2. Use air pollution control equipment with a capture efficiency of at
least 85% and a control device efficiency of at least 90%.
3. Coatings must be applied using electrostatic, electrodeposition,
HVLP, brush, dip, roll, or other method that achieves at least 65%
transfer efficiency.
KCAPCDRule410-4
C-7
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Table C-l. Summary of California Air District Regulations for Metal Furniture Coating
Operation
Material
VOC
limitation
Compliance Requirements
Citation
Coating
application
equipment
cleaning materials
Content limit
of950g/l(7.9
Ib/gal) (less
water and
exempt
compounds)
and VOC
partial pressure
<35 mmHg at
20°C
C-8
-------
Table C-l. Summary of California Air District Regulations for Metal Furniture Coating
Operation
Material
voc
limitation
Compliance Requirements
Citation
Mojave Desert Air Quality Management District
Metal parts
and products
General coatings,
air dried
General coatings,
baked
Specialty coatings
(non-military), air
dried
Specialty coatings
(non-military),
baked
Content limit
of420g/l(3.5
Ib/gal) (less
water and
exempt
compounds)
Content limit
of360g/l(3.0
Ib/gal) (less
water and
exempt
compounds)
Content limit
of 420-520 g/1
(3.5-4.3 Ib/gal)
(less water and
exempt
compounds)
Content limit
of 275-420 g/1
(2.3-3.5 Ib/gal)
(less water and
exempt
compounds)
1. Use compliant coatings.
2. Use air pollution control equipment with combined capture and control
efficiency of at least 85%.
3 . Cleanup solvent must be collected in closed container.
4. Coating application equipment must be disassembled and cleaned in an
enclosed system.
5. Coatings must be applied using electrostatic, HVLP, dip, hand
application, or other equivalent method.
MDAQMD Rule 1115
C-9
-------
Table C-l. Summary of California Air District Regulations for Metal Furniture Coating
Operation
Material
VOC
limitation
Compliance Requirements
Citation
Surface
preparation and
cleanup solvent
Content limit
of200g/l
(1.67 Ib/gal)
(less water and
exempt
compounds);
or
Boiling point >
190°C; or
Total VOC
vapor pressure
<20 mmHg at
20°C
C-10
-------
Table C-l. Summary of California Air District Regulations for Metal Furniture Coating
Operation
Material
voc
limitation
Compliance Requirements
Citation
Monterey Bay Unified Air Pollution Control District
Organic
solvents or
solvent
containing
materials
Metal parts
and products
Any that come
into contact with
a flame, or are
baked, heat cured,
or heat-
polymerized at a
temperature of
194°F (90°C) in
the presence of O2
Any that do not
come into contact
with a flame, or
are not baked,
heat cured, or
heat-polymerized
General coatings,
air dried
General coatings,
baked
Specialty
coatings, air
dried
15 Ib/day
40 Ib/day
(emissions
from air or
heat drying for
the first 12
hours must be
included)
Content limit
of420g/l(3.5
Ib/gal) (less
water and
exempt
compounds)
Content limit
of360g/l(3.0
Ib/gal) (less
water and
exempt
compounds)
Content limit
of 420-780 g/1
(3.5-6.5 Ib/gal)
(less water and
exempt
compounds)
1 . Emissions from cleanup with solvents must be included in compliance
determination
2. Reduce VOC emissions by 85% or more using a capture and control
system (an incinerator must have an emission reduction of 90% or
more).
Exemptions: (1) transport or storage of solvent materials; (2) any source in
existing prior to March 19, 2001 with actual VOC emissions less than 15
Ib/day (solvents that are baked, heat-cured, heat-polymerized or exposed to
flame) or 40 Ib/day (solvents that are not baked, heat-cured, heat-
polymerized or exposed to flame)
1. Use compliant coatings.
2. Use air pollution control equipment with combined capture and control
efficiency of at least 90%.
Exemptions: facilities that use less than 55 gallons of coating per year
MBUAPCDRule416
MBUAPCD Rule 434
C-ll
-------
Table C-l. Summary of California Air District Regulations for Metal Furniture Coating
Operation
Material
VOC
limitation
Compliance Requirements
Citation
Specialty
coatings, baked
Content limit
of 360-780 g/1
(3.0-6.5 Ib/gal)
(less water and
exempt
compounds)
C-12
-------
Table C-l. Summary of California Air District Regulations for Metal Furniture Coating
Operation
Material
voc
limitation
Compliance Requirements
Citation
Placer County Air Pollution Control District
Organic
solvents or
solvent
containing
materials
Any that come
into contact with
a flame, or are
baked, heat cured,
or heat-
polymerized in
the presence of O2
Photochemically
reactive solvent
(except solvents
that are baked,
heat cured or
heat-
polymerized)
Non-
photochemically
reactive solvent
(except solvents
that are baked,
heat cured or
heat-
polymerized)
Phenolic resin
coating
15 Ib/day and
31b/hr
40 Ib/day and
81b/hr
(emissions
from air or
heat drying for
the first 12
hours must be
included)
3,000 Ib/day
and 450 Ib/hr
(emissions
from air or
heat drying for
the first 12
hours must be
included)
1.75 Ib
VOC/gal
coating as
applied (except
for water and
exempt
compounds)
1 . Reduce VOC emissions by 85% or more by incineration (if incinerator
has an emission emission reduction of 90% or more), adsorption, or
another approved method of control.
3 . Do not dispose or allow the release of organic compounds from storage
or transfer operations of more than 1.5 gal of liquid (or equivalent
amount of vapor).
4. Emissions from cleanup with solvents must be included in compliance
determination
Exemptions: (1) transport of storage of organic containing materials; (2)
the volatile content of materials consists of only water and non-
photochemically reactive organic solvents containing less than 20% by
volume of VOC, and does not come into contact with a flame; and (3) the
solvent content is less than 20% by volume of non-photochemically
reactive organic solvents, and does not come into contact with a flame.
PLAAPCDRule219
C-13
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Table C-l. Summary of California Air District Regulations for Metal Furniture Coating
Operation
Solvent
Cleaners
Material
Solvents used on
substrates during
the manufacturing
process or for
surface
preparation
Solvents used for
maintenance and
repair
Solvents used for
cleaning coatings
or adhesives
application
equipment
Solvents used for
cleaning polyester
resin application
equipment
voc
limitation
70 g VOC/1
material
900 g VOC/1
material and a
composite
partial pressure
of 20 mm Hg
or less at 20°C
(68°F)
950 g VOC/1
material and a
composite
partial pressure
of 35 mmHg
or less at 20°C
(68°F)
200 g VOC/1
material; or
1, 100 g VOC/1
and composite
partial pressure
of 1.0 mmHg
orlessat20°C
(68°F) or
solvent
reclamation
system
Compliance Requirements
1 . Use complaint cleaning materials AND Use one of the following
cleaning devices or methods:
a. Wipe cleaning;
b. Non propellant spray bottles or containers
c. No spray discharge into open air
2. Use a collection and control system that collects at least 90 percent of
the emissions and reduces VOC emissions by at least 95 percent or
has an outlet concentration less than 50 ppmw (as carbon)
Citation
PLAAPCD Rule 240
C-14
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Table C-l. Summary of California Air District Regulations for Metal Furniture Coating
Operation
Material
voc
limitation
Compliance Requirements
Citation
Sacramento Metropolitan Air Quality Management District
Metal parts
and products
Air dried coatings
Baked coatings
Strippers
Solvent for
cleanup of
application
equipment and
surface
preparation
Content limit
of340g/l(2.8
Ib/gal) (less
water and
exempt
compounds)
Content limit
of275g/l(2.3
Ib/gal) (less
water and
exempt
compounds)
Content limit
of200g/l(1.7
Ib/gal) (less
water and
exempt
compounds)
Content limit
of72g/l(0.6
Ib/gal) (less
water and
exempt
compounds)
1. Use compliant coatings.
2. Use emission control equipment with an overall control efficiency of at
least 85%.
3 . Use closed containers for disposal of cloth, paper, or sponges.
4. Do not use VOC-containing material for cleaning coating application
equipment unless cleanup solvent VOC content limit is met or cleaning
is performed in an enclosed cleaner.
5. Coatings must be applied using roll, dip, electrostatic, flow, HVLP,
LVLP, hand application, or other approved method.
SMAQMD Rule 451
C-15
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Table C-l. Summary of California Air District Regulations for Metal Furniture Coating
Operation
Material
VOC
limitation
Compliance Requirements
Citation
Solvent
Cleaning
Materials
General cleaning
activities, product
cleaning during
manufacturing or
surface
preparation for
coatings,
adhesives,
sealants, or ink
application;
Repair and
maintenance
cleaning
50 g VOC/1
(0.42 Ib/gal)
Use complaint cleaning materials AND Use one of the following
cleaning devices or methods:
a. Wipe cleaning;
b. Cleaning with closed containers or by using hand held spray
bottles or containers without a propellant-induced force;
c. Using cleaning equipment which has a solvent container that is
closed during cleaning operations, except when depositing and
removing objects, and is closed during non-operation with the
exception of maintenance and repair to the cleaning equipment
itself;
d. Using a remote reservoir degreaser, non-vapor degreaser, or vapor
degreaser used as required under Rule 454.
e. Using 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.
Use a collection and control system that collects at least 90 percent of
the emissions and reduces VOC emissions by at least 95 percent or
has an outlet concentration less than 50 ppmw (as carbon)
KCAPCD Rule 466
C-16
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Table C-l. Summary of California Air District Regulations for Metal Furniture Coating
Operation
Material
voc
limitation
Compliance Requirements
Citation
San Diego County Air Pollution Control District
Metal parts
and products
General coatings,
air dried
General coatings,
baked
Specialty
coatings, air dried
Specialty
coatings, baked
Content limit
of 340 g/1 (less
water and
exempt
compounds)
Content limit
of 275 g/1 (less
water and
exempt
compounds)
Content limit
of 420 g/1 (less
water and
exempt
compounds)
Content limit
of 360-420 g/1
(less water and
exempt
compounds)
1 . Use compliant coatings or reduce VOC emissions using a control
system with a combined collection and abatement efficiency of 85% by
weight or more.
2. Cleaning of coating application equipment alternatively can be carried
out in a manner that minimizes emissions or within enclosed
equipment.
Exemption: Any coating operation that uses less than 20 gallons of coating
per consecutive 12-month period.
SDAPCD Rule 67.3
C-17
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Table C-l. Summary of California Air District Regulations for Metal Furniture Coating
Operation
Material
VOC
limitation
Compliance Requirements
Citation
Surface
preparation and
cleanup solvent
Content limit
of200g/l
(1.67 Ib/gal)
(less water and
exempt
compounds);
or
Boiling point >
190°C; or
Total VOC
vapor pressure
<20 mmHg at
20°C
C-18
-------
Table C-l. Summary of California Air District Regulations for Metal Furniture Coating
Operation
Material
voc
limitation
Compliance Requirements
Citation
San Joaquin Valley Unified Air Pollution Control District
Metal parts
and products
General coatings,
air dried
General coatings,
baked
Specialty
coatings, air dried
Specialty
coatings, baked
Surface
preparation,
repair, and
maintenance
solvents
Content limit
of340g/l(2.8
Ib/gal) (less
water and
exempt
compounds)
Content limit
of275g/l(2.3
Ib/gal) (less
water and
exempt
compounds)
Content limit
of420g/l(3.5
Ib/gal) (less
water and
exempt
compounds)
Content limit
of 360-420 g/1
(3.0-3.5 Ib/gal)
(less water and
exempt
compounds)
Content limit
of 50 g/1 (0.42
Ib/gal) (less
water and
exempt
compounds)
1. Use compliant coatings or reduce VOC emissions using a control
system with a combined collection and abatement efficiency of 90% by
weight or more.
2. Cleaning of coating application equipment alternatively can be carried
out in a manner that minimizes emissions or within enclosed
equipment.
3 . Coatings must be applied using the following application equipment:
electrostatic, electrodeposition, HVLP, flow, roll, dip, brush,
continuous, or other method that achieves at least 65% transfer
efficiency.
Exemption: Any coating operation that uses less than 20 gallons of coating
per consecutive 365-day period.
SJVUAPCD Rule 4603
C-19
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Table C-l. Summary of California Air District Regulations for Metal Furniture Coating
Operation
Material
Coating
application
equipment
cleaning solvents
voc
limitation
Content limit
of550g/l(4.6
Ib/gal) (less
water and
exempt
compounds)
Compliance Requirements
Citation
C-20
-------
Table C-l. Summary of California Air District Regulations for Metal Furniture Coating
Operation
Material
voc
limitation
Compliance Requirements
Citation
San Luis Obispo County Air Pollution Control District
Metal parts
and products
General coatings,
air dried
General coatings,
baked
Specialty
coatings, air dried
Specialty
coatings, baked
Content limit
of340g/l(2.8
Ib/gal) (less
water and
exempt
compounds)
Content limit
of275g/l(2.3
Ib/gal) (less
water and
exempt
compounds)
Content limit
of 340-800 g/1
(2.8-6.7 Ib/gal)
(less water and
exempt
compounds)
Content limit
of 275-800 g/1
(2.3-6.7 Ib/gal)
(less water and
exempt
compounds)
1. Must apply coatings using electrostatic, flow, dip, HVLP, or
equivalent.
2. VOC-containing materials must be stored in closed containers.
3 . Cannot use VOC-containing materials for spray equipment cleanup
unless an enclosed gun washer is used or a gun washer using a solvent
with a vapor pressure less than 45 mmHg (0.87 psi) at 20°C (68°F).
Exemptions: (1) coatings used in volumes of less than 20 gal/yr;
(2) sources using not more than 4 gal/day (monthly average) of solvent-
containing materials; (3) sources using a control device demonstrated to
have the same emission reduction as this rule.
SLOCAPCD Rule 411
C-21
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Table C-l. Summary of California Air District Regulations for Metal Furniture Coating
Operation
Material
voc
limitation
Compliance Requirements
Citation
Santa Barbara County Air Pollution Control District
Metal parts
and products
General coatings,
air dried
General coatings,
baked
Industrial
maintenance
coatings, air dried
Powder coatings
Content limit
of 340 g/1 (less
water and
exempt
compounds)
Content limit
of 275 g/1 (less
water and
exempt
compounds)
Content limit
of 420 g/1 (less
water and
exempt
compounds)
Content limit
of 50 g/1 (less
water and
exempt
compounds)
1. Use add-on control system with at least 90% capture efficiency and
95% control efficiency.
2. Apply coatings using the following methods: electrostatic, flow, dip,
HVLP, electrodeposition, hand application, touch-up guns, or other
approved method that achieves at least 65% transfer efficiency.
3. Store reactive VOC-containing materials in closed containers.
4. Organics in coating thinners and reducers shall not be photochemically
active.
Exemptions: (1) coatings used in volumes less than 20 gal/day; total of all
such coatings not to exceed 55 gal/yr.
SBAPCD Rule 322, 330
C-22
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Table C-l. Summary of California Air District Regulations for Metal Furniture Coating
Operation
Material
voc
limitation
Compliance Requirements
Citation
Shasta County Air Quality Management District
Organic
solvents or
solvent
containing
materials
Any that come
into contact with
a flame, or are
baked, heat cured,
or heat-
polymerized in
the presence of O2
at temperatures
above 400°F
Photochemically
reactive solvent
(except solvents
that are baked,
heat cured or
heat-
polymerized)
Any
photochemically
reactive substance
15 Ib/day
40 Ib/day
40 Ib/day
1 . Reduce VOC emissions by 85%
2. Include emissions from the cleanup with photochemically reactive
solvents in compliance determination
Exemptions: (1) use, application, evaporation, or drying halogenated
hydrocarbons orperchloroethylene.
SHAAQMD Rule 3:4
C-23
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Table C-l. Summary of California Air District Regulations for Metal Furniture Coating
Operation
Material
voc
limitation
Compliance Requirements
Citation
South Coast Air Quality Management District
Metal parts
and products
General coatings,
one component
(air-dried and
baked)
General coatings,
multicomponent,
air dried
General coatings,
multicomponent,
baked
Specialty
coatings, air dried
and baked
Cleaning
materials
Content limit
of275g/las
applied
(excluding
water and
exempt
compounds)
Content limit
of 340 g/1 as
applied (except
water and
exempt
compounds)
Content limit
of 275 g/1 as
applied
(excluding
water and
exempt
compounds)
Content limit
of 275-420 g/1
as applied
(excluding
water and
exempt
compounds)
Content limit
of 25 g/1 (0.21
Ib/gal)
1 . Use compliant materials ; or use an collection system that has a capture
efficiency of at least 90% by weight and the control device has an
emission reduction efficiency of 95% by weight or to an outlet
concentration of 5 ppmv VOC.
2. Coatings must be applied using hand application methods, HVLP
spray, flow, roll, dip. Alternative coating methods must be approved.
3 . Containers and mixing tanks must be free from leaks and covered
except when adding or removing materials, cleaning or when the
container is empty.
4. Solvent cleaning must use one of the following: wipe cleaning; closed
containers or hand held spray bottles w/out propellant-induced force;
cleaning equipment which has a solvent container that is closed at all
times (except when adding or removing parts or during repair); remote
reservoir cleaner; non-atomized solvent flow where solvent is collected
in a container or collection system that is closed at all times except for
solvent collection and pressure relief (as needed) openings; and solvent
flushing methods where solvent is collected in a container or collection
system that is closed at all times except for solvent collection and
pressure relief (as needed) openings (discharged solvent must be
collected into containers without atomizing into the air and solvent may
be flushed through the system by air or hydraulic pressure or by
pumping).
5. All VOC-containing solvents must be stored in non-absorbent, non-
leaking containers which must be kept closed at all times, except when
filling or emptying. Cloth and paper containing with VOC-laden
solvents should be stored in closed, non-absorbent, non-leaking
containers.
6. Use closed containers for disposal of cloth or paper used in stripping
cured coatings that are impregnated with solvent containing VOC.
7. Stripping materials limited to 200 g/1
Exemption: Any application process that has VOC emissions less than
14.3 Ib (6.5 kg) per day
SCAQMDRule 1107
and 1171
C-24
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Table C-l. Summary of California Air District Regulations for Metal Furniture Coating
Operation
Material
VOC
limitation
Compliance Requirements
Citation
Tehama County Air Pollution Control District
Organic
solvents or
solvent
containing
materials
Any that come
into contact with
a flame, or are
baked, heat cured,
or heat-
polymerized in
the presence of O2
at temperatures
above 400°F
Photochemically
reactive solvent
(except solvents
that are baked,
heat cured or
heat-
polymerized)^
Any
photochemically
reactive substance
15 Ib/day
40 Ib/day
40 Ib/day
1. Reduce VOC emissions by 85%
2. Include emissions from the cleanup with photochemically reactive
solvents in compliance determination
Exemptions: (1) use, application, evaporation, or drying halogenated
hydrocarbons orperchloroethylene.
TCAPCD Rule 4:22
C-25
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Table C-l. Summary of California Air District Regulations for Metal Furniture Coating
Operation
Material
voc
limitation
Compliance Requirements
Citation
Ventura County Air Pollution Control District
Metal parts
and products
General coatings,
air dried
General coatings,
baked
Specialty
coatings, air dried
Content limit
of 340 g
ROC/1 (2.8
Ib/gal), as
applied
(excluding
water and
exempt
compounds)
Content limit
of 275 g
ROC/1 (2.3
Ib/gal), as
applied
(excluding
water and
exempt
compounds)
Content limit
of 340-420 g
ROC/1 (2.8-3.5
Ib/gal), as
applied
(excluding
water and
exempt
compounds)
1 . Use compliant materials or reduce emissions by a combined capture
and destruction efficiency of 85%.
2. Apply coatings using electrostatic, flow, dip, HVLP, hand, or other
approved method that achieves at least 65% transfer efficiency.
3 . Use enclosed gun washer and solvent with a vapor pressure of <45
mmHg at 20°C.
Exemptions: (1) source that emits <200 Ib ROC/rolling 12-month period;
(2) Cleaning solvent ROC limit does not apply where total usage of
noncomplying cleaners does not exceed 5 gal/rolling 12-month period.
VCAPCDRule74.12
C-26
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Table C-l. Summary of California Air District Regulations for Metal Furniture Coating
Operation
Material
VOC
limitation
Compliance Requirements
Citation
Specialty
coatings, baked
Surface
preparation and
cleanup solvents
Content limit
of 275-420 g
ROC/1 (2.3-3.5
Ib/gal), as
applied
(excluding
water and
exempt
compounds)
70 g ROC/1
material used
C-27
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Table C-l. Summary of California Air District Regulations for Metal Furniture Coating
Operation
Material
VOC
limitation
Compliance Requirements
Citation
Yolo-Solano Air Quality Management District
Metal parts
and products
General coatings,
air dried
General coatings,
baked
Specialty
coatings, air dried
Content limit
of 340 g
ROC/1 (2.8
Ib/gal), as
applied
(excluding
water and
exempt
compounds)
Content limit
of 275g
ROC/1 (2.3
Ib/gal), as
applied
(excluding
water and
exempt
compounds)
Content limit
of 420 g
ROC/1 (3.5
Ib/gal), as
applied
(excluding
water and
exempt
compounds)
1. Use capture and control system with overall control efficiency of at
least 85%.
2. Do not use VOC-containing materials for cleanup unless collected in a
closed container or guns cleaned in an enclosed washer.
3. Use closed container for disposal of cloth, paper, and other materials
containing solvents.
4. Apply coatings using electrostatic, HVLP, flow, dip, hand, or roll.
Exemptions: (1) coatings used in volumes less than 55 gal/yr
C-28
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Table C-l. Summary of California Air District Regulations for Metal Furniture Coating
Operation
Solvent
Cleaners
Material
Specialty
coatings, baked
Surface
preparation
solvents
Solvents used on
substrates during
the manufacturing
process or for
surface
preparation
Solvents used for
maintenance and
repair
Solvents used for
cleaning coatings
or adhesives
application
equipment
voc
limitation
Content limit
of 360-420 g
ROC/1 (3. 0-3. 5
Ib/gal), as
applied
(excluding
water and
exempt
compounds)
200 g/1
200 g VOC/1
material
900 g VOC/1
material and a
composite
partial pressure
of 20 mm Hg
or less at 20°C
(68°F)
950 g VOC/1
material and a
composite
partial pressure
of 35 mmHg
or less at 20°C
(68°F)
Compliance Requirements
2. Use complaint cleaning materials AND Use one of the following
cleaning devices or methods:
a. Wipe cleaning;
b. Spray bottles or containers with a maximum capacity of 16 fluid
ounces 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, and is closed during non-operation with the
exception of maintenance and repair to the cleaning equipment
itself;
d. Cleaning device or mechanism which has been determined by the
Air Pollution Control Officer to result in equivalent or lower
emissions;
e. Remote reservoir cold cleaner used
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
Citation
YSAQMD2.31,
Section 300
C-29
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Table C-l. Summary of California Air District Regulations for Metal Furniture Coating
Operation
Material
Solvents used for
cleaning polyester
resin application
equipment
voc
limitation
200 g VOC/1
material; or
1, 100 g VOC/1
and composite
partial pressure
of 1.0 mmHg
orlessat20°C
(68°F) or
solvent
reclamation
system
Compliance Requirements
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.
3. Use a collection and control system that collects at least 90 percent of
the emissions and reduces VOC emissions by at least 95 percent or has
an outlet concentration less than 50 ppmw (as carbon)
Citation
C-30
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United States Office of Air Quality Planning and Standards Publication No. EPA 453/R-07-005
Environmental Protection Sector Policies and Programs Division September 2007
Agency Research Triangle Park, NC
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