[Federal Register: July 10, 2007 (Volume 72, Number 131)]
[Proposed Rules]
[Page 37581-37605]
[DOCID:fr10jy07-28]

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Part II

Environmental Protection Agency

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40 CFR Part 59

 Consumer and Commercial Products: Control Techniques Guidelines in
Lieu of Regulations for Paper, Film, and Foil Coatings; Metal Furniture
Coatings; and Large Appliance Coatings; Proposed Rule

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ENVIRONMENTAL PROTECTION AGENCY

40 CFR Part 59

[EPA-HQ-OAR-2007-0454; FRL-8336-7]
RIN 2060-A014

Consumer and Commercial Products: Control Techniques Guidelines
in Lieu of Regulations for Paper, Film, and Foil Coatings; Metal
Furniture Coatings; and Large Appliance Coatings

AGENCY: Environmental Protection Agency (EPA).

ACTION: Proposed rule.

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SUMMARY: Pursuant to section 183(e)(3)(C) of the Clean Air Act, EPA
proposes to determine that control techniques guidelines will be
substantially as effective as national regulations in reducing
emissions of volatile organic compounds in ozone national ambient air
quality standard nonattainment areas from the following three product
categories: Paper, film, and foil coatings; metal furniture coatings;
and large appliance coatings. Based on this determination, EPA may
issue Control Techniques Guidelines in lieu of national regulations for
these product categories. EPA has prepared draft Control Techniques
Guidelines for the control of volatile organic compound emissions from
each of the product categories covered by this proposed determination.
Once finalized, these Control Techniques Guidelines will provide
guidance to the States concerning EPA's recommendations for reasonably
available control technology-level controls for these product
categories. EPA further proposes to take final action to list the three
Group III consumer and commercial product categories addressed in this
notice pursuant to Clean Air Act section 183(e).

DATES: Comments: Written comments on the proposed determination must be
received by August 9, 2007, unless a public hearing is requested by
July 20, 2007. If a hearing is requested on the proposed determination,
written comments must be received by August 24, 2007. We are also
soliciting written comments on the draft CTGs and those comments must
be submitted within the comment period for the proposed determination.
    Public Hearing. If anyone contacts EPA requesting to speak at a
public hearing concerning the proposed determination by July 20, 2007,
we will hold a public hearing on July 25, 2007. The substance of any
such hearing will be limited solely to EPA's proposed determination
under Clean Air Act (CAA or the Act) section 183(e)(3)(C) that the
Control Techniques Guidelines (CTGs) for the three Group III product
categories will be substantially as effective as regulations in
reducing volatile organic compound (VOC) emissions in ozone
nonattainment areas. Accordingly, if a commenter has no objection to
EPA's proposed determination under CAA section 183(e)(3)(C), but has
comments on the substance of a draft CTG, the commenter should submit
those comments in writing.

ADDRESSES: Submit your comments, identified by applicable docket ID
number, by one of the following methods:
     Federal eRulemaking Portal: http://www.regulations.gov.

Follow the on-line instructions for submitting comments.
     E-mail<EMAIL_ADDRESS>     Fax:<PHONE_NUMBER>.
     Mail: Comments concerning the Proposed Determination
should be sent to: Consumer and Commercial Products, Group III--
Determination to Issue Control Techniques Guidelines in Lieu of
Regulations, Docket No. EPA-HQ-OAR-2007-0454. Comments concerning any
draft CTG should be sent to the applicable docket, as noted below:
Consumer and Commercial Products--Paper, Film, and Foil Coatings,
Docket No. EPA-HQ-OAR-2007-0336; Consumer and Commercial Products--
Metal Furniture Coatings, Docket No. EPA-HQ-OAR-2007-0334; or Consumer
and Commercial Products--Large Appliance Coatings, Docket No. EPA-HQ-
OAR-2007-0329, Environmental Protection Agency, EPA Docket Center,
Mailcode 6102T, 1200 Pennsylvania Ave., NW., Washington, DC 20460.
Please include a total of two copies.
     Hand Delivery: EPA Docket Center, Public Reading Room, EPA
West, Room 3334, 1301 Constitution Ave., NW., Washington, DC 20460.
Such deliveries are only accepted during the Docket's normal hours of
operation, and special arrangements should be made for deliveries of
boxed information.
    Instructions: Direct your comments to the applicable docket. EPA's
policy is that all comments received will be included in the public
docket without change and may be made available online at http://www.regulations.gov
, including any personal information provided,

unless the comment includes information claimed to be confidential
business information (CBI) or other information whose disclosure is
restricted by statute. Do not submit information that you consider to
be CBI or otherwise protected through http://www.regulations.gov or e-mail.

The http://www.regulations.gov Web site is an ``anonymous access'' system,

which means EPA will not know your identity or contact information
unless you provide it in the body of your comment. If you send an e-
mail comment directly to EPA without going through http://www.regulations.gov,

your e-mail address will be automatically captured and included as part
of the comment that is placed in the public docket and made available
on the Internet. If you submit an electronic comment, EPA recommends
that you include your name and other contact information in the body of
your comment and with any disk or CD-ROM you submit. If EPA cannot read
your comment due to technical difficulties and cannot contact you for
clarification, EPA may not be able to consider your comment. Electronic
files should avoid the use of special characters, any form of
encryption, and be free of any defects or viruses.
    Public Hearing: If a public hearing is held, it will be held at 10
a.m. on July 25, 2007 at Building C on the EPA campus in Research
Triangle Park, NC, or at an alternate site nearby. Persons interested
in presenting oral testimony must contact Ms. Dorothy Apple, U.S. EPA,
Office of Air Quality Planning and Standards, Sector Policies and
Programs Division, Natural Resources and Commerce Group (E143-03),
Research Triangle Park, North Carolina 27711, telephone number: (919)
541-4487, fax number<PHONE_NUMBER>, e-mail address:
<EMAIL_ADDRESS>no later than July 20, 2007. Persons interested

in attending the public hearing must also call Ms. Apple to verify the
time, date, and location of the hearing. If no one contacts Ms. Apple
by July 20, 2007 with a request to present oral testimony at the
hearing, we will cancel the hearing.
    Docket: All documents in the docket are listed in the
http://www.regulations.gov index. Although listed in the index, some

information is not publicly available, e.g., CBI or other information
whose disclosure is restricted by statute. Certain other material, such
as copyrighted material, is not placed on the Internet and will be
publicly available only in hard copy form. Publicly available docket
materials are available either electronically through
http://www.regulations.gov or in hard copy at the EPA Docket Center, Public

Reading Room, EPA West, Room 3334, 1301 Constitution Ave., NW.,
Washington, DC. The Public Reading Room is open from 8:30 a.m. to 4:30
p.m., Monday through Friday, excluding legal

holidays. The telephone number for the Public Reading Room is (202)
566-1744, and the telephone number for the Air Docket is (202) 566-
1742.

FOR FURTHER INFORMATION CONTACT: For information concerning the CAA
section 183(e) consumer and commercial products program, contact Mr.
Bruce Moore, U.S. EPA, Office of Air Quality Planning and Standards,
Sector Policies and Programs Division, Natural Resources and Commerce
Group (E143-03), Research Triangle Park, North Carolina 27711,
telephone number:<PHONE_NUMBER>, fax number<PHONE_NUMBER>, e-mail
address<EMAIL_ADDRESS>For further information on technical
issues concerning the proposed determination and draft CTG for paper,
film, and foil coatings, contact: Ms. Kim Teal, U.S. EPA, Office of Air
Quality Planning and Standards, Sector Policies and Programs Division,
Natural Resources and Commerce Group (E143-03), Research Triangle Park,
North Carolina 27711, telephone number:<PHONE_NUMBER>, e-mail address:
<EMAIL_ADDRESS>For further information on technical issues

concerning the proposed determination and draft CTG for metal furniture
coatings, contact: Ms. Martha Smith, U.S. EPA, Office of Air Quality
Planning and Standards, Sector Policies and Programs Division, Natural
Resources and Commerce Group (E143-03), Research Triangle Park, North
Carolina 27711, telephone number:<PHONE_NUMBER>, e-mail address:
<EMAIL_ADDRESS>For further information on technical issues

concerning the proposed determination and draft CTG for large appliance
coatings, contact: Mr. Lynn Dail, U.S. EPA, Office of Air Quality
Planning and Standards, Sector Policies and Programs Division, Natural
Resources and Commerce Group (E143-03), Research Triangle Park, North
Carolina 27711, telephone number:<PHONE_NUMBER>, e-mail address:
<EMAIL_ADDRESS>

SUPPLEMENTARY INFORMATION:
    Entities Potentially Affected by this Action. The entities
potentially affected by this action include industrial facilities that
use the respective consumer and commercial products covered in this
action as follows:

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                                                    Examples of affected
          Category               NAICS code \a\           entities
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Paper, film, and foil         322221, 322222,       Facilities that
 coatings.                     322223, 322224,       apply coatings to
                               322225, 322226,       packaging paper,
                               322229, 325992,       paper bags,
                               326111, 326112,       laminated aluminum
                               326113, 32613,        foil, coated
                               32791, 339944.        paperboard,
                                                     photographic film,
                                                     abrasives, carbon
                                                     paper, and other
                                                     coated paper, film
                                                     and foil products.
Metal furniture coatings....  337124, 337214,       Facilities that
                               337127, 337215,       apply protective,
                               337127, 332951,       decorative, or
                               332116, 332612,       functional material
                               337215, 335121,       to metal furniture
                               335122, 339111,       components or
                               339114, 337127,       products.
                               81142.
Large appliance coatings....  335221, 335222,       Facilities that
                               335224, 335228,       apply coatings to
                               333312, 333319.       household and
                                                     commercial cooking
                                                     equipment,
                                                     refrigerators,
                                                     laundry equipment,
                                                     laundry drycleaning
                                                     and pressing
                                                     equipment.
Federal Government..........  ....................  Not affected.
State/local/tribal            ....................  State, local and
 government.                                         tribal regulatory
                                                     agencies.
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\a\ North American Industry Classification System.

    This table is not intended to be exhaustive, but rather provides a
guide for readers regarding entities likely to be affected by this
action. To determine whether your facility would be affected by this
action, you should examine the applicable industry description in
sections II.A, III.A, and IV.A of this notice. If you have any
questions regarding the applicability of this action to a particular
entity, consult the appropriate EPA contact listed in the FOR FURTHER
INFORMATION CONTACT section of this notice.
    Preparation of Comments. Do not submit information containing CBI
to EPA through http://www.regulations.gov or e-mail. Send or deliver

information identified as CBI only to the following address: Mr.
Roberto Morales, OAQPS Document Control Officer (C404-02), U.S. EPA,
Office of Air Quality Planning and Standards, Research Triangle Park,
North Carolina 27711, Attention: Docket ID EPA-HQ-OAR-2007-0454, 0336,
0334, or 0329 (as applicable). Clearly mark the part or all of the
information that you claim to be CBI. For CBI information in a disk or
CD-ROM that you mail to EPA, mark the outside of the disk or CD-ROM as
CBI and then identify electronically within the disk or CD-ROM the
specific information that is claimed as CBI. In addition to one
complete version of the comment that includes information claimed as
CBI, a copy of the comment that does not contain the information
claimed as CBI must be submitted for inclusion in the public docket.
Information so marked will not be disclosed except in accordance with
procedures set forth in 40 CFR part 2.
    World Wide Web (WWW). In addition to being available in the docket,
an electronic copy of this proposed action will also be available on
the World Wide Web (WWW) through the Technology Transfer Network (TTN).
Following signature, a copy of the proposed action will be posted on
the TTN's policy and guidance page for newly proposed or promulgated
rules at the following address: http://www.epa.gov/ttn/oarpg/. The TTN

provides information and technology exchange in various areas of air
pollution control.
    Organization of this Document. The information presented in this
notice is organized as follows:

I. Background Information and Proposed Determination
    A. The Ozone Problem
    B. Statutory and Regulatory Background
    C. Significance of CTGs
    D. General Considerations in Determining Whether a CTG Will Be
Substantially as Effective as a Regulation
    E. Proposed Determination
    F. Availability of Documents
II. Paper, Film and Foil Coatings
    A. Industry Characterization
    B. Recommended Control Techniques
    C. Impacts of Recommended Control Techniques
    D. Considerations in Determining Whether a CTG Will Be
Substantially as Effective as a Regulation
III. Metal Furniture Coatings
    A. Industry Characterization
    B. Recommended Control Techniques
    C. Impacts of Recommended Control Techniques
    D. Considerations in Determining Whether a CTG Will Be
Substantially as Effective as a Regulation
IV. Large Appliance Coatings
    A. Industry Characterization
    B. Recommended Control Techniques

    C. Impacts of Recommended Control Techniques
    D. Considerations in Determining Whether a CTG Will Be
Substantially as Effective as a Regulation
V. Statutory and Executive Order (EO) Reviews
    A. Executive Order 12866: Regulatory Planning and Review
    B. Paperwork Reduction Act
    C. Regulatory Flexibility Act
    D. Unfunded Mandates Reform Act
    E. Executive Order 13132: Federalism
    F. Executive Order 13175: Consultation and Coordination With
Indian Tribal Governments
    G. Executive Order: 13045: Protection of Children From
Environmental Health and Safety Risks
    H. Executive Order 13211: Actions Concerning Regulations That
Significantly Affect Energy Supply, Distribution, or Use
    I. National Technology Transfer and Advancement Act
    J. Executive Order 12898: Federal Actions to Address
Environmental Justice in Minority Populations and Low-Income
Populations

I. Background Information and Proposed Determination

A. The Ozone Problem

    Ground-level ozone, a major component of smog, is formed in the
atmosphere by reactions of VOC and oxides of nitrogen in the presence
of sunlight. The formation of ground-level ozone is a complex process
that is affected by many variables.
    Exposure to ground-level ozone is associated with a wide variety of
human health effects, as well as agricultural crop loss, and damage to
forests and ecosystems. Controlled human exposure studies show that
acute health effects are induced by short-term (1 to 2 hour) exposures
(observed at concentrations as low as 0.12 parts per million (ppm)),
generally while individuals are engaged in moderate or heavy exertion,
and by prolonged (6 to 8 hour) exposures to ozone (observed at
concentrations as low as 0.08 ppm and possibly lower), typically while
individuals are engaged in moderate exertion. Transient effects from
acute exposures include pulmonary inflammation, respiratory symptoms,
effects on exercise performance, and increased airway responsiveness.
Epidemiological studies have shown associations between ambient ozone
levels and increased susceptibility to respiratory infection, increased
hospital admissions and emergency room visits. Groups at increased risk
of experiencing elevated exposures include active children, outdoor
workers, and others who regularly engage in outdoor activities. Those
most susceptible to the effects of ozone include those with preexisting
respiratory disease, children, and older adults. The literature
suggests the possibility that long-term exposures to ozone may cause
chronic health effects (e.g., structural damage to lung tissue and
accelerated decline in baseline lung function).

B. Statutory and Regulatory Background

    Under section 183(e) of the CAA, EPA conducted a study of VOC
emissions from the use of consumer and commercial products to assess
their potential to contribute to levels of ozone that violate the
National Ambient Air Quality Standards (NAAQS) for ozone, and to
establish criteria for regulating VOC emissions from these products.
Section 183(e) of the CAA 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), and to divide the list of categories to be
regulated into four groups. EPA published the initial list in the
Federal Register on March 23, 1995 (60 FR 15264). In that notice, EPA
stated that it may amend the list of products for regulation, and the
groups of product categories, in order to achieve an effective
regulatory program in accordance with the Agency's discretion under CAA
section 183(e).
    EPA has revised the list several times. See 70 FR 69759 (Nov. 17,
2005); 64 FR 13422 (Mar. 18, 1999). Most recently, in May 2006, EPA
revised the list to add one product category, portable fuel containers,
and to remove one product category, petroleum dry cleaning solvents.
See 71 FR 28320 (May 16, 2006). As a result of these revisions, Group
III of the list comprises five product categories: Portable fuel
containers; aerosol spray paints; paper, film, and foil coatings; metal
furniture coatings; and large appliance coatings. The portable fuel
containers \2\ and aerosol spray paints categories are addressed in
separate rulemaking actions \3\; the remaining three categories are the
subject of this action.
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    \2\ EPA promulgated a national regulation for VOC emissions from
portable fuel containers on February 26, 2007 (72 FR 8428). National
VOC emission standards for aerosol coatings currently are under
development.
    \3\ Pursuant to the court's order in Sierra Club v. EPA, 1:01-
cv-01597-PLF (D.C. Cir., March 31, 2006), EPA must take final action
on the product categories in Group III by September 30, 2007.
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    Any regulations issued under section CAA 183(e) must be based on
``best available controls'' (BAC). CAA section 183(e)(1)(A) defines BAC
as ``the degree of emissions reduction that the Administrator
determines, on the basis of technological and economic feasibility,
health, environmental, and energy impacts, is achievable through the
application of the most effective equipment, measures, processes,
methods, systems or techniques, including chemical reformulation,
product or feedstock substitution, repackaging, and directions for use,
consumption, storage, or disposal.'' CAA section 183(e) also provides
EPA with authority to use any system or systems of regulation that EPA
determines is the most appropriate for the product category. Under
these provisions, EPA has previously issued ``national'' regulations
for architectural and industrial maintenance coatings, autobody
refinishing coatings, consumer products, and portable fuel
containers.\4\
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    \4\ See 63 FR 48792, 48819, and 48848 (September 11, 1998); and
72 FR 8428 (February 26, 2007).
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    CAA section 183(e)(3)(C) further provides that EPA may issue a CTG
in lieu of a national regulation for a product category where EPA
determines that the CTG will be ``substantially as effective as
regulations'' in reducing emissions of VOC in ozone nonattainment
areas. The statute does not specify how EPA is to make this
determination, but does provide a fundamental distinction between
national regulations and CTGs.
    Specifically, for national regulations, CAA section 183(e) defines
regulated entities as:

    (i) * * * manufacturers, processors, wholesale distributors, or
importers of consumer or commercial products for sale or
distribution in interstate commerce in the United States; or (ii)
manufacturers, processors, wholesale distributors, or importers that
supply the entities listed under clause (i) with such products for
sale or distribution in interstate commerce in the United States.

    Thus, under CAA section 183(e), a regulation for consumer or
commercial products is limited to measures applicable to manufacturers,
processors, distributors, or importers of the solvents, materials, or
products supplied to the consumer or industry. CAA section 183(e) does
not authorize EPA to issue national regulations that would directly
regulate end-users of these products. By contrast, CTGs are guidance
documents that recommend reasonably available control technology (RACT)
measures that States can adopt and apply to the end users of products.
This dichotomy (i.e., that EPA cannot directly regulate end-users under
CAA section 183(e), but can address end-users through a CTG) created by

Congress is relevant to EPA's evaluation of the relative merits of a
national regulation versus a CTG.

C. Significance of CTGs

    CAA section 172(c)(1) provides that state implementation plans
(SIPs) for nonattainment areas must include ``reasonably available
control measures'' (RACM), including RACT, for sources of emissions.
Section 182(b)(2) provides that States must revise their ozone SIPs to
include RACT for each category of VOC sources covered by any CTG
document issued after November 15, 1990, and prior to the date of
attainment. Those ozone nonattainment areas that are subject to CAA
section 172(c)(1) and submit an attainment demonstration seeking more
than 5 years from the date of designation to attain must also meet the
requirements of CAA section 182(b)(2) and revise their ozone SIPs in
response to any CTG issued after November 15, 1990, and prior to the
date of attainment. Other ozone nonattainment areas subject to CAA
section 172(c)(1) may take action in response to this guidance, as
necessary to attain.
    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
notices, EPA has addressed how states can meet the RACT requirements of
the Act. Significantly, RACT for a particular industry is determined on
a case-by-case basis, considering issues of technological and economic
feasibility.
    EPA provides States with guidance concerning what types of controls
could constitute RACT for a given source category through issuance of a
CTG. The recommendations in the CTG are based on available data and
information and may not apply to a particular situation based upon the
circumstances. States can follow the CTG and adopt State regulations to
implement the recommendations contained therein, or they can adopt
alternative approaches. In either event, 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 process, whether they meet the RACT requirements
of the Act and EPA's regulations. To the extent a State adopts any of
the recommendations in a CTG into its State RACT rules, interested
parties can raise questions and objections about the substance of the
guidance and the appropriateness of the application of the guidance to
a particular situation during the development of the State rules and
EPA's SIP approval process.
    We encourage States in developing their RACT rules to consider
carefully the facts and circumstances of the particular sources in
their States because, as noted above, RACT is determined on a case-by-
case basis, considering issues of technological and economic
feasibility. For example, a state may decide not to require 90 percent
control efficiency at facilities that are already well controlled, if
the additional emission reductions would not be cost-effective. States
may also want to consider reactivity-based approaches, as appropriate,
in developing their RACT regulations.\5\ Finally, if States consider
requiring more stringent VOC content limits than those recommended in
the draft CTGs, states may also wish to consider averaging, as
appropriate. In general, the RACT requirement is applied on a short-
term basis up to 24 hours.\6\ However, EPA guidance permits averaging
times longer than 24 hours under certain conditions.\7\ The EPA's
``Economic Incentive Policy'' \8\ provides guidance on use of long-term
averages with regard to RACT and generally provides for averaging times
of no greater than 30 days. Thus, if the appropriate conditions are
present, States may consider the use of averaging in conjunction with
more stringent limits. Because of the nature of averaging, however, we
would expect that any State RACT Rules that allow for averaging also
include appropriate recordkeeping and reporting requirements.
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    \5\ ``Interim Guidance on Control of Volatile Organic Compounds
in Ozone State Implementation Plans,'' 70 FR 54046 (September 13,
2005).
    \6\ See, e.g., 52 FR at 45108, col. 2, ``Compliance Periods''
(November 24, 1987). ``VOC rules should describe explicitly the
compliance timeframe associated with each emission limit (e.g.,
instantaneous or daily). However, where the rules are silent on
compliance time, EPA will interpret it as instantaneous.''
    \7\ Memorandum from John O'Connor, Acting Director of the Office
of Air Quality Planning and Standards, January 20, 1984, ``Averaging
Times for Compliance with VOC Emission Limits--SIP Revision
Policy.''
    \8\ ``Improving Air Quality with Economic Incentive Programs,
January 2001,'' available at http://www.epa.gov/region07/programs/artd/air/policy/search.htm
.

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    By this action, we are making available draft CTGs that cover three
product categories in Group III of the CAA section 183(e) list. These
CTGs are guidance to the States and provide recommendations only. A
State can develop its own strategy for what constitutes RACT for these
three product categories, and EPA will review that strategy in the
context of the SIP process and determine whether it meets the RACT
requirements of the Act and its implementing regulations.
    Finally, CAA section 182(b)(2) provides that a CTG issued after
1990 specify the date by which a State must submit a SIP revision in
response to the CTG. In the draft CTGs at issue here, EPA provides that
States should submit their SIP revisions within 1 year of the date that
the CTGs are finalized.

D. General Considerations in Determining Whether a CTG Will Be
Substantially as Effective as a Regulation

    CAA Section 183(e)(3)(C) authorizes EPA to issue a CTG in lieu of a
regulation for a category of consumer and commercial products if a CTG
``will be substantially as effective as regulations in reducing VOC
emissions'' in ozone nonattainment areas. The statute does not specify
how EPA is to make this determination.
    On July 13, 1999 (64 FR 37773), EPA issued a final determination
pursuant to CAA section 183(e)(3)(C), concluding that CTGs for wood
furniture coatings, aerospace coatings, and shipbuilding and repair
coatings were substantially as effective as national regulations in
reducing emissions of VOC from these products in areas that violate the
NAAQS for ozone. On October 5, 2006 (71 FR 58745), EPA issued a similar
final determination for flexible packaging printing materials,
lithographic printing materials, letterpress printing materials,
industrial cleaning solvents, and flat wood paneling coatings.
Recognizing that the statute does not specify any criteria for making a
determination under CAA section 183(e)(3)(C), EPA, in 1999 and 2006,
considered several relevant factors, including: (1) The product's
distribution and place of use; (2) the most effective entity to target
to control emissions--in other words, whether it is more effective to
achieve VOC reductions at the point of manufacture of the product or at
the point of use of the product; (3) consistency with other VOC control
strategies; and (4) estimates of likely VOC emission reductions in
ozone nonattainment areas which would result from the regulation or
CTG. EPA believes that these factors are useful for evaluating whether
the rule or CTG approach would be best from the perspective of
implementation and enforcement of an effective strategy to achieve the
intended VOC emission reductions. As we consider other product
categories in the current and

future phases of regulation under CAA section 183(e), there may be
other factors that are relevant to the CAA section 183(e)(3)(C)
determination for given product categories. EPA believes that in making
these determinations, no single factor is dispositive. On the contrary,
for each product category, we must weigh the factors and make our
determination based on the unique set of facts and circumstances
associated with that product category. For purposes of making the
determination, EPA analyzed the components of the draft CTGs for the
product categories at issue and compared the draft CTGs to the types of
controls and emission strategies possible through a regulation. As we
explained in 1999, it would be unreasonable for EPA, in effect, to have
to complete both the full rulemaking and full CTG development processes
before being able to make a determination under CAA section
183(e)(3)(C) validly. EPA believes that it is possible for the Agency
to make a determination between what a rule might reasonably be
expected to achieve versus what a CTG might reasonably be expected to
achieve, without having to complete the entire rulemaking and CTG
processes. To conclude otherwise would result in unnecessary wasting of
limited time and resources by the Agency and the stakeholders
participating in the processes. Moreover, such an approach would be
directly contrary to CAA section 183(e)(3)(C), which authorizes EPA to
issue a CTG in lieu of a regulation if it determines that the CTG
``will be substantially as effective as'' a regulation in reducing VOC
emissions in ozone nonattainment areas.
    With regard to the three product categories at issue here, EPA
notes that it does not have reliable quantitative data that would
enable it to conduct a ton-by-ton comparison of the likely emission
reductions associated with a national regulation versus a CTG. Although
we conducted such a comparative analysis in 1999 for the product
categories of wood furniture coatings, aerospace coatings and
shipbuilding and repair coatings, (64 FR 37773, July 13, 1999), such
analysis is not necessary for evaluating likely VOC emission
reductions, particularly, where, as in our Group II action (71 FR
58745, October 5, 2006) and here, a CTG can achieve significant
emission reductions from end-users of the consumer and/or commercial
products at issue, which cannot be achieved through regulation under
CAA section 183(e). In addition, for the reasons described below, a
regulation governing the manufacturers and suppliers of these products
would be unlikely to achieve the objective of reducing VOC emissions
from these products in ozone nonattainment areas.

E. Proposed Determination

    Based on the factors identified above and the facts and
circumstances associated with each of the Group III product categories,
EPA proposes to determine that CTGs for paper, film, and foil coatings;
metal furniture coatings; and large appliance coatings will be
substantially as effective as national regulations in reducing VOC
emissions from facilities located in ozone nonattainment areas.
    In each of the three product category sections below, we provide a
general description of the industry, identify the sources of VOC
emissions associated with the industry, summarize the recommended
control techniques in the draft CTG and describe the impacts of those
techniques, and discuss the considerations supporting our proposed
determination under CAA section 183(e)(3)(C) that a CTG will be
substantially as effective as a regulation in reducing VOC emissions in
ozone nonattainment areas from the product category at issue.
    The specific subsections below that address our proposed
determination for each product category are organized into two parts,
each of which addresses two of the factors relevant to the CAA section
183(e)(1)(C) determination. The first part addresses whether it is more
effective to target the point of manufacture of the product or the
point of use for purposes of reducing VOC emissions and discusses
whether our proposed approach is consistent with existing Federal,
State and local VOC reduction strategies. The second part addresses the
product's distribution and place of use and discusses the likely VOC
emission reductions associated with a CTG, as compared to a regulation.
    Finally, we propose to find that these three product categories are
appropriate for inclusion on the CAA section 183(e) list in accordance
with the factors and criteria that EPA used to develop the original
list. See Consumer and Commercial Products: Schedule for Regulation, 60
FR 15264 (Mar. 23, 1995).

F. Availability of Documents

    EPA has prepared draft CTG documents covering the three consumer
and commercial products source categories addressed in this action.
Each of the draft CTGs addresses, among other things, RACT
recommendations, cost impacts, and existing Federal, state and local
VOC control strategies. These draft CTGs are available for public
comment and are contained in the respective dockets listed in the
ADDRESSES section of this notice.

II. Paper, Film, and Foil Coatings

A. Industry Characterization

1. Source Category Description
    This category of consumer and commercial products includes the
coatings that are applied to paper, film, and foil in manufacturing
products for the following industry sectors: Pressure sensitive tapes
and labels, photographic film; industrial and decorative laminates; and
flexible packaging.\9\ The category also includes coatings applied
during miscellaneous paper, film, and foil surface coating operations
for several products including: corrugated and solid fiber boxes; die-
cut paper, paperboard, and cardboard; converted paper and paperboard,
not elsewhere classified; folding paperboard boxes, including sanitary
boxes; manifold business forms and related products; plastic aseptic
packaging; and carbon paper and inked ribbons. Paper, film, and foil
surface coating can be described as a web coating process, which is a
process that applies a continuous layer of coating material across the
entire width or any portion of the width of a web substrate for any of
the following reasons: (1) To provide a covering, finish, or functional
or protective layer to a substrate; (2) to saturate a substrate for
lamination; or (3) to provide adhesion between two substrates for
lamination. The web coating operations and emission control techniques
do not vary significantly among the sectors of the paper, film, and
foil industry.
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    \9\ Coating performed on or in-line with any offset
lithographic, screen, letterpress, flexographic, rotogravure, or
digital printing press is not part of the paper, film and foil
coating category. The application of inks, coatings and adhesives on
or in-line with rotogravure or flexographic printing presses used in
the production of flexible packaging is addressed in the CTG for
Flexible Package Printing (EPA 453/R-06-003, September 2006). The
application of inks, coatings and adhesives on or in-line with
publication rotogravure printing presses is addressed in the CTG for
Graphic Arts: Rotogravure and Flexography (EPA 450/2-78-033). The
application of inks, coatings and adhesives on or in-line with
offset lithographic or letterpress printing presses is addressed in
the CTG for Offset Lithographic Printing and Letterpress Printing
(EPA 453/R-06-002, September 2006).
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2. Processes, Sources of VOC Emissions, and Controls
    The coatings and cleaning materials \10\ used in paper, film, and
foil surface

coating operations are sources of VOC emissions. The coating line is
the main source of VOC emissions. The remaining emissions are
principally from cleaning operations. VOC emissions from surface
preparation, solvent handling and storage, and waste/wastewater
operations are small. The following discussion describes the sources of
VOC from the coatings and cleaning materials.
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    \10\ In a previous notice, EPA identified specific categories,
including paper, film, and foil coating, the cleaning operations of
which would not be covered by EPA's 2006 CTG for industrial cleaning
solvents (71 FR 44522, 44540 (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.
---------------------------------------------------------------------------

    The VOC in coatings are emitted from the coating line. In general,
a coating line consists of a series of one or more unwind/feed
stations; one or more coating applicators; one or more flash-off areas
(the area between two consecutive coating applicators or between a
coating applicator and a drying oven); one or more drying ovens; and
one or more rewind/cutting stations. The majority, usually greater than
90 percent, of the VOC in the coatings volatilizes in the drying ovens.
A smaller amount of VOC in the coatings volatilizes at the coating
applicator and flash-off area. The amount of VOC emitted from coatings
varies depending on the type of coatings being used. The types of
coatings used in the paper, film, and foil surface coating industry
include solvent-borne and waterborne coatings, as well as radiation-
cure coatings, hot-melt adhesives and other 100 percent solids
coatings.
    Solvent-borne coatings are widely used in the paper, film, and foil
surface coating industry. Solvent-borne coating formulations typically
range from 40 to 80 percent solvents by weight, as supplied by the
manufacturer. The solvent-borne coatings may be diluted by the users
with additional solvents prior to being used. The primary solvents in
solvent-borne coatings include methanol, methyl ethyl ketone, toluene,
and xylene. A significant part of the volatiles in waterborne coating
is water, although some VOC-containing solvents may be used at up to 30
percent of the volatiles. Most coating equipment used for solvent-borne
coatings can also be used for waterborne coatings.
    Radiation cure coatings, hot-melt adhesives and other 100 percent
solids coatings such as wax coatings, wax laminations, extrusion
coatings, extrusion laminations, and cold seal coatings typically
contain no solvent. Accordingly, these coatings emit very little VOC.
More information on coatings is provided in the draft CTG.
    Common techniques to reduce emissions from paper, film, and foil
coatings include the use of low-VOC content coatings and the operation
of add-on control systems where low-VOC content coatings cannot be used
due to performance requirements calling for higher VOC coatings. An
add-on control system consists of a capture system and a control
device. The majority of VOC emissions from paper, film and foil coating
occur in the drying oven. These emissions can be ducted from the drying
oven directly to a control device. The drying oven is therefore
typically the principal element of the capture system. In addition,
hoods, floor sweeps or enclosures can be used to collect VOC emissions
that occur in the coating application and flash-off areas, and route
them to a control device.
    The most common add-on controls in use at paper, film, and foil
surface coating facilities are thermal oxidizers and carbon adsorbers,
both of which achieve greater than 90 percent control.
    The design of the capture system and the choice of the control
device can greatly contribute to the overall VOC control efficiency,
which is a combination of both capture and control efficiency. Please
see the draft CTG for further detailed descriptions of add-on controls
and capture systems that we reviewed in developing the draft CTG.
    As previously mentioned, another source of VOC emissions from
paper, film, and foil surface coating operations is cleaning materials.
Cleaning materials are used for several purposes, including washing
equipment, removing residues from coating applicators, and cleaning
spray guns. These materials are typically mixtures of organic solvents
and represent less than 2 percent of the VOC emissions from paper,
film, and foil surface coating operations. Work practices are widely
used throughout the paper, film, and foil surface coating industry as a
means of reducing VOC emissions from the cleaning materials during
cleaning operations. These measures include covering cleaning material
mixing tanks; storing cleaning solvents and solvent-soaked rags and
wipes in closed containers; and cleaning spray guns in an enclosed
system. Another means of reducing VOC emission from paper, film, and
foil cleaning materials is the use of low-VOC content or low vapor
pressure cleaning materials. Within the industry, there are controlled
cleaning operations where cleaning is automated, enclosed and vented to
a control device. Use of recycled solvents for cleaning is also typical
in the industry.
3. Existing Federal, State and Local VOC Control Strategies
    There are three previous EPA actions that affect paper, film, and
foil surface coating operations. In 1977, EPA issued a CTG document
entitled ``Control of Volatile Organic Emissions from Existing
Stationary Sources--Volume II: Surface Coating of Cans, Coils, Paper,
Fabrics, Automobiles, and Light-Duty Trucks'' (EPA-450/2-77-008) (1977
CTG). The 1977 CTG provided RACT recommendations for controlling VOC
emissions from paper coating and fabric \11\ coating operations. The
1977 CTG recommended RACT for paper coating as 0.35 kilogram/liter (kg/
l) (2.9 pound/gallon (lb/gal)) of coating, excluding water and exempt
compounds, as applied. These recommended limits were based on the use
of conventional solvent-borne coatings and oxidation of the dryer oven
exhaust which achieved an overall VOC control efficiency of 81 percent.
These recommended limits were expressed in terms of a compliant
coating's VOC content to encourage the development and use of low-VOC
content coatings. Equivalent solids-based limits were presented in ``A
Guideline for Surface Coating Calculations'' (EPA-340/1-86-016). For
paper coating, the equivalent limit was 0.58 kg/l (4.8 lb/gal) of
solids. These equivalent limits were calculated using an assumed VOC
density of 0.88 kg/l (7.36 lb/gal). This assumed VOC density is the
same as that used in calculating the limits recommended in the 1977
CTG.
---------------------------------------------------------------------------

    \11\ Fabric coating operations for use in pressure sensitive
tape and abrasive materials are included under paper, film, and foil
surface coating.
---------------------------------------------------------------------------

    In 1983, EPA promulgated new source performance standards (NSPS)
for pressure sensitive tape and label surface coating operations (40
CFR part 60 subpart RR).\12\ The 1983 NSPS differs from the 1977 CTG in
that it only applies to pressure sensitive tape and label surface
coating lines. The 1983 NSPS emission limits do not apply to pressure
sensitive tape and label surface coating operations that input 45
megagrams/year (Mg/yr) (50 tons per year (tpy)) or less VOC into the
coating process (other requirements such as recordkeeping and reporting
do apply). The 1983 NSPS requires a 90 percent reduction of VOC
emission. Alternatively it establishes an emission limit of 0.20 kg
VOC/kg (0.20 lb VOC/lb) solids applied based on VOC emission reduction
of 90 percent.
---------------------------------------------------------------------------

    \12\ The 1983 NSPS applies to sources that commenced
construction, reconstruction, or modification after December 30,
1980.

---------------------------------------------------------------------------

    In 2002, EPA promulgated the National Emission Standards for
Hazardous Air Pollutants (NESHAP): Paper and Other Web Coating (POWC),
40 CFR part 63 subpart JJJJ, which applies to paper, film, and foil
surface coating as well as other coating operations. The 2002 NESHAP
addresses organic hazardous air pollutant (HAP) emissions, including
VOC HAP emissions, from all web coating lines at a paper, film, and
foil surface coating facility.
    The 2002 NESHAP has different emission limitations for sources that
commenced construction or reconstruction on or before September 13,
2000 (existing sources), and sources that commenced construction or
reconstruction after September 13, 2000 (new sources). The 2002 NESHAP
emission limits for existing sources and new sources are based on
overall HAP control efficiencies of 95 percent and 98 percent,
respectively (65 FR 55334).
    The 1977 CTG, the 1983 NSPS, and the 2002 NESHAP are further
discussed in the current draft CTG document.
    In addition to the EPA actions mentioned above, at least 44 State
and several local jurisdictions have regulations that affect VOC
emissions from paper, film, and foil surface coating. Fourteen local
jurisdictions in California have generic surface coating rules. These
generic surface coating rules regulate all machinery with the potential
to emit organic compounds.
    All 44 of the States and 6 of the California jurisdictions have
regulations that address all or part of the paper, film, and foil
surface coating industry. The regulations in these State and local
jurisdictions cover the coating lines. Generally, these regulations
establish emission limits and allow compliance with the limits to be
demonstrated by using low-VOC content coatings or add-on control
systems in conjunction with higher-VOC content coatings.
    Almost all of the jurisdictions that specifically address all or
part of the paper, film, and foil surface coating industry have adopted
the recommended VOC emission limits in the 1977 CTG. However, there are
fourteen jurisdictions that have more stringent requirements than the
1977 CTG. These jurisdictions allow compliance either using compliant
coatings, or by using an add-on control system. Seven jurisdictions
have VOC emission limits that are more stringent than the 1977 CTG,
five in California and two in Illinois. The California jurisdictions
limit VOC emissions to 265 g/l (2.2 lb/gal) of coating, excluding water
and exempt compounds, as applied. The two jurisdictions in Illinois
limit VOC emissions to 0.28 kg/l (2.3 lb/gal) of coating, excluding
water and exempt compounds, as applied. As an alternative to the VOC
emission limits the California and Illinois jurisdictions allow
facilities to install capture systems and control devices to reduce VOC
emissions from these coating operations. The required overall emission
reduction, including capture and control efficiency, ranges from 55
percent to 90 percent. Specifically, the San Diego County Air Pollution
Control District (San Diego) and the Ventura County Air Pollution
Control District (Ventura) both require an overall control efficiency
of 90 percent. Finally, there are seven jurisdictions that have VOC
emission limits that are the same as the 1977 CTG. However, these
jurisdictions require 95 percent emission reduction as an alternative
to the VOC emission limit. The 95 percent overall control efficiency is
the most stringent and likely can only be met with a permanent total
enclosure that achieves 100 percent capture efficiency. A detailed
summary of the State and local regulations is presented in the draft
CTG.
    Several jurisdictions in California have requirements to regulate
the VOC content of cleaning materials used in the paper, film and foil
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 10 States that have cleaning material regulations that
apply to paper, film, and foil surface coating operations. Of these, 9
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. The cleaning material regulations are summarized in
detail in the draft CTG.

B. Recommended Control Techniques

    The draft CTG recommends certain control techniques for reducing
VOC emissions from paper, film, and foil coatings and cleaning
materials. As explained in the draft CTG, we are recommending these
control options for facilities whose paper, film, and foil surface
coating operations emit 6.8 kg VOC/day (15 lb VOC/day or 3 tons VOC/
year) or more before the consideration of control. 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 2 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-VOC content coatings, such as
ultraviolet (UV) cure coatings. Furthermore, based on the 2002 NEI data
and the 2004 ozone nonattainment designations, facilities emitting
below the recommended threshold level collectively emit less than 2
percent of the total reported VOC emissions from paper, film, and foil
coating facilities in ozone nonattainment areas. For these reasons, we
did not extend our recommendations in the draft CTG to these low
emitting facilities. For purposes of determining whether a facility
meets the above recommended threshold, aggregate emissions from all
paper, film, and foil surface coating operations and related cleaning
activities at a given facility are included. This recommended threshold
is also consistent with our recommendations in many previous CTGs.
    We nevertheless solicit comment on the above proposed applicability
threshold of the coating and cleaning recommendations in the draft CTG
for paper, film, and foil coating facilities. We specifically solicit
comment on whether there are small operations emitting at or
immediately above the proposed threshold and how many of these
facilities exist. If information is provided during the comment period
indicating that there are many small operations emitting at and/or
immediately above the proposed threshold, we may consider modifying the
recommended threshold. We specifically solicit comment on whether a
slightly higher threshold of 12.3 kg VOC/day (27 lb VOC/day or 5 tons
VOC/year) would be more appropriate for this category, and we solicit
data and analyses supporting such a threshold.
    Coating performed on or in-line with any offset lithographic,
screen, letterpress, flexographic, rotogravure, or digital printing
press is not subject to the recommendations in the draft CTG. Printing,
coating and laminating

performed on or in-line with such presses is addressed in other CTGs.
1. Coatings
    Coatings are defined in the draft CTG as material applied onto or
impregnated into a substrate for decorative, protective, or functional
purposes. Such materials include, but are not limited to, solvent-borne
coatings, waterborne coatings, adhesives, wax coatings, wax
laminations, extrusion coatings, extrusion laminations, 100 percent
solid adhesives, UV cured coatings, electron beam cured coatings, hot
melt coatings, and cold seal coatings. Materials used to form
unsupported substrates, such as calendaring of vinyl, blown film, cast
film, extruded film, and co-extruded film, are not considered coatings.
    In the draft CTG, we recommend an overall VOC control efficiency of
90 percent for each paper, film, and foil surface coating line.\13\
This emission reduction is based on the San Diego and Ventura levels of
control, as well as the 1983 NSPS. As an alternative, we recommend VOC
content based emission limits that are equivalent to 90 percent overall
control. Specifically, we recommend the ``as-applied'' VOC limits of
0.40 kg VOC/kg (0.40 lb VOC/lb) solids applied and 0.08 kg VOC/kg (0.08
lb VOC/lb) coating for this product category except for pressure
sensitive tape and label surface coating lines. The derivation of these
limits is discussed in detail in the draft CTG.
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    \13\ We are defining a paper, film, and foil surface coating
line as a series of coating applicator(s), flash-off area(s), and
any associated curing/drying equipment between one or more an unwind
(or feed) stations and one or more rewind (or cutting) stations.
---------------------------------------------------------------------------

    For pressure sensitive tape and label surface coating lines, we
recommend 0.20 kg VOC/kg (0.20 lb VOC/lb) solids applied, which is
based on 90 percent control efficiency. We also recommend an equivalent
value of 0.067 kg VOC/kg (0.067 lb VOC/lb) coating. The development of
the recommended limitations is presented in more detail in the draft
CTG.
2. Cleaning Materials
    The draft CTG recommends work practices to reduce VOC emissions
from cleaning materials used in paper, film, and foil surface coating
operations. 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 emissions from cleaning of storage, mixing,
and conveying equipment.

C. Impacts of Recommended Control Techniques

    Based on the 2002 NEI database, we estimate that there are a total
of 474 paper, film, and foil surface coating facilities located in
ozone nonattainment areas (using April 2004 designations). As
previously mentioned, we are recommending the control options described
in this draft CTG apply to facilities in ozone nonattainment areas that
emit 6.8 kg/day (15 lb/day) or more of VOC. Based on VOC emissions data
in the 2002 NEI database, 251 of the facilities in ozone nonattainment
areas emit VOC at or above this level.
    Although there is limited cost information available, we believe
that the cost estimates and other related studies developed for the
2002 NESHAP are appropriate for estimating the cost impact of our
recommendations in the draft CTG for the following reasons. The
recommended level of control in the draft CTG covers the same processes
as the 2002 NESHAP (i.e., all coating applicators and any associated
drying/curing equipment between the unwind/feed station and the rewind/
cutting station). In addition, the annual costs estimates developed for
the 2002 NESHAP were based on the use of thermal oxidizers to control
HAP emissions and these oxidizers achieve the same level of control for
VOC. Finally, both the 2002 NESHAP emission limits and the limits
recommended in the draft CTG can be met by the same options (i.e., use
of low-VOC content coatings or add-on control systems when high-VOC
content coatings are used).
    According to studies performed for the development of the 2002
NESHAP, 47 percent of the existing facilities would be subject to the
2002 NESHAP. To estimate the costs associated with the add-on control
recommendation in the draft CTG, we assumed that all facilities subject
to the NESHAP (i.e., 47 percent of the facilities in the 2002 NEI
database (119 facilities)) are currently in compliance with the NESHAP.
We assume that facilities already in compliance with the 2002 NESHAP
would not be required to upgrade or install capture and/or thermal
oxidizers to achieve the emission reduction recommended in the draft
CTG and therefore would have no additional annual costs associated with
the draft CTG.
    We estimated that the nationwide emission reduction would be 20,000
Mg/yr (22,000 tpy) and nationwide total annual costs were $26 million
per year, resulting in cost effectiveness of $1,320 per Mg ($1,200 per
ton). These costs represent worst-case costs, using thermal oxidizers.
Other control options (i.e., carbon adsorbers or solvent recovery
systems) can be expected to have lower costs.
    We believe that our work practice recommendations in the draft CTG
will result in a net cost savings. Implementing work practices reduce
the amount cleaning materials used by reducing the amount that
evaporates and is wasted.

D. Considerations in Determining Whether a CTG Will Be Substantially as
Effective as a Regulation

    In determining whether to issue a national rule or a CTG for the
paper, film, and foil coatings product category under CAA section
183(e)(3)(C), we analyzed the four factors identified in Section I.D of
this notice in light of the specific facts and circumstances associated
with this product category. Based on that analysis, we propose to
determine that a CTG will be substantially as effective as a rule in
achieving VOC emission reductions in ozone nonattainment areas from
paper, film, and foil surface coating operations.
    As noted above, this section is divided into two parts, each of
which addresses two of the factors relevant to the CAA section
183(e)(1)(C) determination. In the first part, we discuss our belief
that the most effective means of achieving VOC emission reductions in
this category is through controls at the point of use of the product
(i.e., through controls on the use of coatings at facilities that apply
surface coatings to paper, film, and foil products), and this can only
be accomplished through a CTG. We further explain that the approaches
in the draft CTG are consistent with existing effective Federal, State
and local VOC control strategies. In the second part, we discuss how
the distribution and place of use of the products in this category also
support the use of a CTG. We also discuss the likely VOC emission
reductions associated with a CTG, as compared to a regulation. We
further explain that there are control approaches for this category
that result in significant VOC emission reductions and that such
reductions could only be obtained by controlling the use of the
products through a CTG. Such reductions could

not be obtained through a regulation under CAA section 183(e) because
the controls affect the end-user, which cannot be a regulated entity
under CAA section 183(e)(1)(C). For these reasons, which are described
more fully below, we believe that a CTG will achieve greater VOC
emission reductions than a rule for this category.
1. The Most Effective Entity To Target for VOC Reductions and
Consistency With State and Local VOC Strategies
    To evaluate the most effective entity to target for VOC reductions,
it is important to first identify the primary sources of VOC emissions.
There are two main sources of VOC emissions from paper, film, and foil
surface coating operations: (1) Evaporation of VOC from coatings; and
(2) evaporation of VOC from cleaning materials. We address each of
these sources of VOC emissions in turn below as we discuss the CTG
versus regulation approach.
a. Coatings
    A national rule could contain limits for the as-sold VOC content of
paper, film, and foil coatings. However, given the nature of the paper,
film, and foil surface coating process, we believe that such a rule
would result in little reduction in VOC emissions.
    Although significant amounts of low-VOC content coatings are
currently being used for paper, film, and foil surface coating, they
cannot replace the traditional solvent-borne coatings in some
instances. Performance specifications and other functional
characteristics determine the types of coatings that can be used. For
example, hot-melt coatings are virtually solvent free, but cannot be
used on film substrates that are sensitive to heat because the
substrate could melt during the coating process. Accordingly, a
national rule that requires low VOC content in paper, film, and foil
coatings would nevertheless need to include higher VOC limits to allow
for the use of solvent-borne materials when necessary and to maintain
these materials' intended effect. Because such a rule would merely
codify what the paper, film, and foil coating facilities are already
doing, we do not expect that it would result in significant VOC
reductions from these facilities.
    Furthermore, the effect of a national rule setting low VOC content
limits for paper, film, and foil coatings could be easily subverted
because it does not guarantee that only those low-VOC content coating
materials will be used for paper, film, and foil surface coating. Many
coatings used in the paper, film, and foil surface coating industry are
not specifically identified by the supplier as paper, film, and foil
coatings. Therefore, these facilities can purchase and use coating
materials not specified as paper, film, and foil coatings, which would
effectively nullify the reformulation actions of the manufacturers and
suppliers, resulting in no net change in VOC emissions in ozone
nonattainment areas.
    Alternatively, a national rule could set low VOC content limits for
all coatings sold, regardless of specified end use, thus ensuring that
only low-VOC coatings are available for paper, film, and foil surface
coatings. Such an approach would be unreasonable and impractical.
Coatings are sold for multiple different commercial and industrial
purposes. Reducing the VOC content of all coatings would impact uses of
these materials in operations other than paper, film, and foil surface
coating and may inadvertently preclude the use of higher VOC containing
materials in many important, legitimate contexts.
    By contrast, a CTG can reach the end users of the coating materials
and can therefore implement the control measures that are more likely
to achieve the objective of reducing VOC emissions from this product
category in ozone nonattainment areas. As previously discussed, the
draft CTG recommends two VOC control options for this product category:
(1) Emission limits for paper, film, and foil surface coating
operations that can be achieved through the use of low-VOC content
coatings; and (2) a 90 percent control efficiency for facilities that
choose to use add-on controls in conjunction with high-VOC content
coatings. The draft CTG also recommends work practices to reduce VOC
emissions from cleaning materials. The use of low-VOC content coatings,
which are available for paper, film, and foil surface coating, can
greatly reduce VOC emissions. Alternatively, control devices, such as
oxidizers or carbon adsorbers, can achieve a significant reduction in
VOC emissions from high-VOC content materials during surface coating
operations. The recommended work practices have also been shown to be
effective VOC reduction measures. Given the significant reductions
achievable through these recommended VOC control measures, the most
effective entity to address VOC emissions associated with paper, film,
and foil coatings is the facility using the coating.
    These control measures are consistent with existing Federal, State
and local VOC control strategies applicable to paper, film, and foil
surface coating. As mentioned above, previous EPA actions and existing
State and local regulations applicable to paper, film, and foil surface
coating similarly call for VOC emission reduction \14\ either through
the use of control devices in conjunction with high-VOC content
coatings or the use of equivalent low-VOC content coatings.
---------------------------------------------------------------------------

    \14\ The 2002 NESHAP requires reduction of organic HAP, over 99
percent of which are VOC.
---------------------------------------------------------------------------

    We cannot issue a national rule directly requiring paper, film, and
foil surface coating facilities to use low-VOC content coating
materials or control devices because, pursuant to CAA section
183(e)(1)(C) and (e)(3)(A), the regulated entities subject to a
national rule would be the coating manufacturers and suppliers, not the
paper, film, and foil surface coating facilities. By contrast, a CTG
can reach these end users of paper, film, and foil coatings, and can
therefore implement the measures by the users that are identified above
as more likely to achieve the intended VOC emission reduction goal.
Accordingly, we are including these control measures in the draft CTG
that applies to paper, film, and foil surface coating facilities as the
end users of these materials.
b. Cleaning Materials
    There are two primary means to control VOC emissions associated
with the cleaning materials used in paper, film, and foil surface
coating: (1) Limiting the VOC content or vapor pressure of the cleaning
materials, and (2) implementing work practices governing the use of the
cleaning materials. A national rule requiring that manufacturers of
cleaning materials for paper, film, and foil coating operations provide
low-VOC content or low vapor pressure (i.e., replace VOC that have a
high vapor pressure with low vapor pressure VOC) cleaning materials
would suffer from the same deficiencies noted above with regard to the
coatings. Specifically, nothing in a national rule that specifically
regulates manufacturers and suppliers of cleaning materials specified
for use in paper, film, and foil surface coating operations would
preclude the industry from purchasing bulk solvents or other
multipurpose cleaning materials from other vendors. The general
availability of bulk solvents or multipurpose cleaning materials from
vendors that would not be subject to such regulation would directly
undermine the effectiveness of such a national regulation.
    A national rule also could, in theory, limit the VOC content or
vapor pressure of all cleaning materials and all solvents sold
regardless of specified end use,

which would ensure that only low-VOC content or low vapor pressure
cleaning materials are available for cleaning operations associated
with paper, film, and foil surface coating. As with a low-VOC content
limit on coatings, setting a low-VOC content or low vapor pressure
limit for all cleaning materials and solvents would be unreasonable and
impractical. Cleaning materials and solvents are sold for multiple
different commercial and industrial purposes. Replacing highly volatile
cleaning materials with less volatile cleaning materials and solvents
would impact uses of these materials other than cleaning operations at
paper, film, and foil surface coating facilities and may inadvertently
preclude the use of such materials in many important, legitimate
contexts.
    The more effective approach for reducing VOC emissions from
cleaning materials used by paper, film, and foil surface coaters is to
control the use of the cleaning materials through work practices. The
draft CTG recommends that paper, film, and foil surface coating
facilities implement work practices to reduce VOC emissions from
cleaning materials during paper, film, and foil surface coating
operations. An example of an effective work practice is keeping
solvents and used shop towels in closed containers. This measure alone
results in significant reduction of VOC emissions from cleaning
materials. Provided immediately below are examples of other effective
work practices that are being required by State and local regulations.
Given the significant VOC reductions achievable through implementation
of work practices, we conclude that the most effective entity to
address VOC emissions from cleaning materials used in paper, film, and
foil surface coating operations is the facility using the cleaning
materials during surface coating operations.
    This recommendation is consistent with measures required by State
and local jurisdictions for reducing VOC emissions from cleaning
materials used in paper, film, and foil surface coating operations. In
addition to keeping solvents and shop towels in closed containers,
State and local requirements include: Minimizing spills of VOC-
containing cleaning materials; cleaning up spills immediately; and
conveying any VOC-containing cleaning materials in closed containers or
pipes. Work practices have proven to be effective in reducing VOC
emissions.
    We cannot issue a national rule requiring such work practices for
paper, film, and foil surface coating facilities because, pursuant to
CAA section 183(e)(1)(C) and (e)(3)(A), the regulated entities subject
to a national rule would be the cleaning materials manufactures and
suppliers and not the paper, film, and foil surface coating facilities.
Accordingly, we are including these work practices in the draft CTG
that applies to these facilities as the end users of the cleaning
materials.
    Based on the nature of the paper, film, and foil surface coating
process, the sources of significant VOC emissions from this process,
and the available strategies for reducing such emissions, the most
effective means of achieving VOC emission reductions from this product
category is through controls at the point of use of the products (i.e.,
through controls on surface coating facilities), and this can only be
accomplished through a CTG. The approaches described in the draft CTG
are also consistent with effective State and local VOC control
strategies. These two factors alone demonstrate that a CTG will be
substantially as effective as a national regulation.
2. The Product's Distribution and Place of Use and Likely VOC Emission
Reductions Associated With a CTG Versus a Regulation
    The factors described in the above section, taken by themselves,
weigh heavily in favor of the CTG approach. The other two factors
relevant to the CAA section 183(e)(3)(C) determination only further
confirm that a CTG will be substantially as effective as a national
regulation for paper, film, and foil coatings and cleaning materials.
    First, paper, film, and foil coatings and associated cleaning
materials are used at commercial facilities in specific, identifiable
locations. Specifically, these materials are used in commercial
facilities that coat paper, film, and foil products, as described in
Section II.A. This stands in contrast to other consumer products, such
as architectural coatings, that are widely distributed and used by
innumerable small users (e.g., individual consumers in the general
public). Because the VOC emissions are occurring at commercial
manufacturing facilities, implementation and enforcement of controls
concerning the use of these products are feasible. Therefore, the
nature of these products' place of use further counsels in favor of the
CTG approach.
    Second, a CTG will achieve greater emission reduction than a
national rule for each source of VOC emissions from paper, film, and
foil surface coating and associated cleaning materials. For the reasons
described above, we believe that a national rule limiting the VOC
content in coatings and cleaning materials used in paper, film, and
foil surface coating operations would result in little VOC emission
reduction. By contrast, a CTG can achieve significant VOC emission
reductions because it can provide for the highly effective emission
control strategies described above that are applicable to the end-users
of the coatings and cleaning materials at paper, film, and foil surface
coating facilities. Specifically, this draft CTG can provide for the
use of control devices in conjunction with high VOC content coatings
and work practices associated with cleaning materials. These
significant VOC reductions could not be obtained through a national
regulation, because they require the implementation of measures by the
end-user. In addition, as previously explained, strategies that
arguably could be implemented through rulemaking, such as a limit on
VOC content in coatings and cleaning materials, are far more effective
if implemented directly at the point of use of the product. For the
reasons stated above it is more effective to control the VOC content of
coatings through a CTG than through a national regulation.
    Furthermore, the number of paper, film, and foil surface coating
facilities affected by our recommendations in this draft CTG, as
compared to the total number of such facilities in ozone nonattainment
areas, does not change our conclusion that the CTG would be more
effective than a rule in controlling VOC emissions for this product
category. As previously mentioned, we recommend the control measures
described in the draft CTG for paper, film, and foil surface coating
facilities that emit 6.8 kg/day (15 lb/day) or more VOC. Based on the
April 2004 ozone nonattainment designations, we estimate that 251 of
the 474 paper, film, and foil surface coating facilities located in
ozone nonattainment areas emit 6.8 kg/day (15 lb/day) or more and are
therefore addressed by our recommendations in the draft CTG. There are
223 paper, film, and foil surface coating facilities that would not be
covered by the recommendations in the draft CTG. According to the 2002
NEI database, these 223 facilities collectively emitted less than 150
Mg/yr (170 tpy), which is less than 2 percent of the total VOC reported
emissions (an average of 0.68 Mg/yr (0.75 tpy) per facility) in ozone
nonattainment areas. The CTG thus addresses 98 percent of the VOC
emissions from these paper, film, and foil surface coating facilities
in ozone nonattainment areas, which further supports our conclusion
that a

CTG is more likely to achieve the intended VOC emission reduction goal
for this product category than a national rule.
    Upon considering the above factors in light of the facts and
circumstances associated with this product category, we propose to
determine that a CTG for paper, film, and foil coatings and cleaning
materials will be substantially as effective as a national regulation.

III. Metal Furniture Coatings

A. Industry Characterization

1. Source Category Description
    This category of consumer and commercial products includes the
coatings that are applied to metal furniture surfaces at facilities
that manufacture metal furniture. Metal furniture includes 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
industry. Metal furniture coatings provide a covering, finish, or
functional or protective layer, and also provide a decorative finish to
metal furniture.
2. Processes, Sources of VOC Emissions, and Controls
    The VOC emissions from metal furniture surface coating operations
are a result of evaporation of the VOC contained in many of the
coatings and cleaning materials \15\ used in these operations. The
primary VOC emissions from metal furniture coatings occur during
coating application, flash-off, and coating drying/curing. The
remaining emissions are primarily from mixing and thinning of the
coatings, and evaporation of the VOC contained in the cleaning
materials during cleaning activities, such as spray gun cleaning, paint
line flushing, rework operations, and touchup cleaning at final
assembly. VOC emissions from surface preparation (where metal furniture
components and products are treated and/or cleaned prior to coating
application), coating storage and handling, and waste/wastewater
operations (i.e., handling waste/wastewater that may contain residues
from both coatings and cleaning materials) are small.
---------------------------------------------------------------------------

    \15\ In a previous notice, EPA identified specific categories,
including metal furniture coating, the cleaning operations of which
would not be covered by EPA's 2006 CTG for industrial cleaning
solvents (71 FR 44522 and 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.
---------------------------------------------------------------------------

    As previously mentioned, some VOC emissions occur during mixing and
thinning operations. These VOC emissions occur from displacement of
VOC-laden air in containers used to mix coatings before coating
application. The displacement of VOC-laden air can occur during the
filling of containers. It can also be caused by changes in temperature
or barometric pressure, or by agitation during mixing.
    The majority of VOC emissions occur from evaporation of solvents
during coating application. The transfer efficiency (the percent of
coating solids deposited on the metal furniture component or product)
of a coating application method affects the amount of VOC emissions
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.
    The coatings used in the metal furniture surface coating industry
may be in the form of a liquid or powder, and may be applied by means
of spray or dip coating. Conventional air atomized spray application
systems utilize higher atomizing air pressure and typically have
transfer efficiencies ranging between 25 and 40 percent. Dip coating is
the immersion of metal furniture components or products into a coating
bath and is typically used on parts that do not require high quality
appearance. The transfer efficiency of a dip coater is very high
(approximately 90 percent); however, some VOC is emitted from the
liquid coating bath due to its large exposed surface area.
    Most spray applied coatings are electrostatically applied. In
electrostatic coating, the presence of an electrostatic field creates
an electrical attraction between the paint, which is positively
charged, and the grounded metal furniture component or product and
enhances the amount of coating deposited on the surface. This coating
method is more efficient than conventional air atomized spray, with
transfer efficiency typically ranging from 60 to 90 percent.
    Other coatings application methods used in the metal furniture
surface coating industry include flow coating, roll coating, high
volume/low pressure (HVLP) spray, electrocoating, autophoretic coating,
and application of coatings by hand. These coating methods are
described in more detail in the draft CTG.
    The coated metal furniture components and products are usually
baked or cured in heated drying ovens, but some are air dried. For
liquid spray and dip coating operations, the coated components or
products are typically first moved through a flash-off area after the
coating application operation. The flash-off area, which lies between
the coating application area and the oven, allows solvents in the wet
coating film to evaporate slowly, thus avoiding bubbling of the coating
while it is curing in the oven. The amount of VOC emitted from the
flash-off area depends on the type of coating used, the speed of the
coating line (i.e., how quickly the component or product moves through
the flash-off area), and the distance between the application area and
bake oven.
    After the flash-off area, the metal furniture components or
products are usually cured or dried. For powder coatings, the curing/
drying step melts the powder and forms a continuous coating on the
component or product. For liquid coatings, this step removes any
remaining volatiles from the coating. The cured coatings provide the
desired decorative and/or protective characteristics. The VOC emissions
during the curing/drying process result from the evaporation of the
remaining solvents in the dryer.
    Until the late 1970's, conventional solvent-borne coatings were
used in the metal furniture surface coating industry. Since then, the
industry has steadily moved towards alternative coating formulations
that eliminate or reduce the amount of solvent in the formulations,
thus reducing VOC emissions per unit amount of coating solids used.
    Currently the metal furniture surface coating industry uses
primarily higher solids solvent-borne coatings and powder coatings and
applies them by electrostatic spraying. This combination of coating
type and application method is an effective measure for reducing VOC
emissions. Not only are VOC emissions reduced by using coatings with
low VOC content, the use of an application method with a high transfer
efficiency, such as electrostatic spraying, lowers the volume of
coatings needed per given amount of production, thus further reducing
the amount of VOC emitted during the coating application.
    Other alternative coatings include waterborne coatings and UV cured

coatings. These coatings are described in more detail in the CTG.
    The most common approach to reduce emission from metal furniture
coating operations is to use low-VOC content coatings, including powder
coatings, higher solids solvent-borne coatings, and UV cured coatings.
Add-on controls may also be used to reduce VOC emissions from metal
furniture coating operations. The majority of VOC emissions from spray
coating operations occur in the spray booth. The volume of air
exhausted from a spray booth is typically high and the VOC
concentration in spray booth exhaust is typically low. The cost of
controlling VOC in spray booth exhaust is therefore greater than the
cost of using low-VOC content coatings. The wide availability and lower
cost of low-VOC content coatings makes them a more attractive option
than add-on controls. For those situations where an add-on control
device is used, thermal oxidation and carbon adsorption are most widely
used. Please see the draft CTG for a detailed discussion of these and
other available control devices.
    To control VOC emissions from containers used to store VOC-
containing solvents or to mix coatings containing VOC solvents, work
practices (e.g., using closed storage containers) are used throughout
the metal furniture surface coating industry.
    As previously mentioned, another source of VOC emissions from metal
furniture surface coating is cleaning materials. The VOC are emitted
when solvents evaporate from the cleaning materials. Cleaning materials
are used for several purposes, including the removal of coating residue
or other unwanted materials from equipment related to the 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 organic solvents.
Work practices are widely used throughout the metal furniture surface
coating industry as a means of reducing VOC emissions from these types
of cleaning operations. These measures include covering mixing tanks,
storing solvents and solvent soaked rags and wipes in closed
containers, and cleaning spray guns in an enclosed system. Another
means of reducing VOC emissions from cleaning operations associated
with surface coating operations is the use of low-VOC content or low
vapor pressure cleaning materials. However, little information is
available regarding the effectiveness of the use of these types of
cleaning materials to reduce VOC emissions in the metal furniture
surface coating industry.
3. Existing Federal, State, and Local VOC Control Strategies
    There are three previous EPA actions that affect metal furniture
surface coating operations. In 1977, EPA issued a CTG document entitled
``Control of Volatile Organic Emissions from Existing Stationary
Sources Volume III: Surface Coating of Metal Furniture'' (EPA-450/2-77-
032) (1977 CTG) that provided RACT recommendations for controlling VOC
emissions from metal furniture surface coating operations. The 1977 CTG
addresses VOC emissions from metal furniture coating lines, which
include the coating application area, the flash-off area, and the
drying/curing ovens. The 1977 CTG recommended RACT for metal furniture
surface coating operations as 0.36 kg VOC/l (3.0 lb/gal) of coating,
excluding water and exempt compounds, as applied. This recommendation
was derived using an assumed VOC density of 0.88 kg/l (7.36 lb/gal).
The recommended limit represents a higher solids solvent-borne coating
with approximately 59 percent volume solids and is equivalent to 0.61
kg VOC/l (5.1 lb VOC/gal) coating solids (the 1977 CTG-equivalent
limit). This equates to an 81 percent reduction of VOC emissions from a
conventional high-VOC content solvent-borne coating.
    In 1982, EPA promulgated the metal furniture surface coating NSPS)
(40 CFR part 60 subpart EE.\16\ The 1982 NSPS is similar to the 1977
CTG in that it applies to metal furniture surface coating operations
which include the coating application station, the flash-off area, and
the drying/curing oven. In contrast to the 1977 CTG, metal furniture
surface coating operations that use less than 3,842 l/yr (1,015 gal/yr)
of coating as-applied, are not subject to the emission limits (other
requirements, such as recordkeeping and reporting, in the 1982 NSPS do
apply). The 1982 NSPS VOC limit is 0.90 kg VOC/l (7.5 lb VOC/gal)
coating solids deposited. Because the 1982 NSPS limit is in terms of
coating solids deposited and the 1977 CTG-equivalent limit is in terms
of coating solids used, these limits cannot be compared directly.
During the implementation of the 1977 CTG, a baseline transfer
efficiency of 60 percent (i.e., 0.60 volume of solids deposited per
unit volume of solids used) was used to express the CTG-equivalent
limit on a solids deposited basis. The CTG-equivalent limit on a solids
deposited basis is 1.01 kg VOC/l (8.4 lb VOC/gal) coating solids
deposited. The 1982 NSPS limit is more stringent than the 1977 CTG-
equivalent limit on a solids deposited basis.
---------------------------------------------------------------------------

    \16\ The 1982 NSPS applies to sources that commenced
construction, reconstruction, or modification after November 28,
1980.
---------------------------------------------------------------------------

    In 2003, EPA promulgated the National Emissions Standards for
Hazardous Air Pollutants: Surface Coating of Metal Furniture, 40 CFR
part 63, subpart RRRR, which applies to metal furniture surface coating
operations. The 2003 NESHAP addresses organic HAP emissions, including
VOC HAP emissions, from all activities at a facility that involve
coatings, thinners, and cleaning materials used in metal furniture
surface coating operations. The areas covered by the 2003 NESHAP
include: Coating operations; vessels used for storage and mixing of
coatings, thinners, and cleaning materials; equipment, containers,
pipes and pumps used for conveying coatings, thinners, and cleaning
materials; and storage vessels, pumps and piping, and conveying
equipment and containers used for waste materials.
    The 2003 NESHAP imposes an organic HAP emission limitation for
sources that commenced construction on or before April 24, 2002
(existing sources), of 0.10 kg organic HAP/l (0.83 lb organic HAP/gal)
of coating solids used. For sources that commenced construction after
April 24, 2002 (new sources) the 2003 NESHAP prohibits organic HAP
emissions. The 2003 NESHAP also specifies work practices to minimize
organic HAP emissions from the storage, mixing, and conveying of
coatings, thinners, and cleaning materials used in and waste materials
generated by the coating operation.
    In addition to the EPA actions mentioned above, at least 36 States
and several local jurisdictions have specific regulations that control
VOC emissions from metal furniture surface coating operations. Almost
all of the jurisdictions that specifically address metal furniture
coatings have adopted the emission limit recommended in the 1977 CTG.
The California Bay Area Air Quality Management District (Bay Area),
however, has adopted more stringent limits. The Bay Area has
established two VOC emission limits for metal furniture surface
coatings: (1) 275 g VOC/l (2.3 lb VOC/gal) of coating, excluding water
and exempt compounds, as applied, for baked coating; and (2) 340 g VOC/
l (2.8 lb VOC/gal) of coating, excluding water and exempt compounds, as
applied, for air-dried coating. Under the Bay Area regulation, metal
furniture surface coating facilities must use coatings that

comply with the VOC emission limit or as an alternative to using low-
VOC content coatings, the facility may choose to install add-on
controls. If add-on controls are used, the Bay Area requires that the
VOC emissions generated by all sources of VOC emissions (i.e., the
coating line) are reduced by at least 85 percent. The Bay Area's
emission limit for air dried coating is also more stringent than the
1977 CTG recommended limit. In addition, its rule requires the use of
coating application equipment that can meet a 65 percent or greater
transfer efficiency. Compliance with the standard's 65 percent or
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.
    Like the Bay Area's limits the VOC emission limits established by
the South Coast Air Quality Management District (South Coast) for the
coating of metal parts and products (which includes metal furniture
using a baked general multi-component coating) are: (1) 275 g VOC/l
(2.3 lb VOC/gal) coating, excluding water and exempt compounds, as
applied, for baked coating; and (2) 340 g VOC/l (2.8 lb VOC/gal) of
coating, excluding water and exempt compounds, as applied, for air-
dried coating. In addition to the VOC emission limits, 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. As an alternative to the VOC emission limit
and specified operating equipment, the South Coast regulation allows
metal furniture facilities to choose to install emission capture
systems and add-on control devices. The South Coast regulation requires
that if a facility chooses the capture and add-on control device
alternative, 90 percent of the VOC emissions must be captured and the
add-on control device must have a control efficiency of 95 percent.
    Several jurisdictions in California have requirements to regulate
the VOC content of 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.

B. Recommended Control Techniques

    The draft CTG recommends certain control techniques for reducing
VOC emissions from metal furniture coatings and cleaning materials. As
explained in the draft CTG, we are recommending these control options
for the metal furniture surface coating operations that emit 6.8 kg
VOC/day (15 lb VOC/day or 3 tons/year) or more before consideration of
control. 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 2 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-VOC
content coatings, such as powder or UV cure coatings. 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 the draft CTG to these low emitting facilities. This
recommended threshold is also consistent with our recommendations in
many previous CTGs.
    For purposes of determining whether a facility meets the 6.8-kg/day
(15-lb/day) threshold, aggregate emissions from all metal furniture
surface coating operations and related cleaning activities at a given
facility are included.
1. Coatings
    The draft CTG provides flexibility by recommending two options for
controlling VOC emissions from coatings: (1) An emission limit that can
be achieved through the use of low-VOC content coatings; or (2) an
overall control efficiency of 90 percent for facilities that choose to
use add-on controls instead of low-VOC content coating. Specifically,
the low-VOC content coatings recommendation includes a limit of 0.275
kg VOC/l (2.3 lb VOC/gal) of coating, excluding water and exempt
compounds, as applied, and the use of the following application
methods: Electrostatic spray, HVLP spray, flow coat, roller coat, dip
coat including electrodeposition, brush coat, or other coating
application method capable of achieving a transfer efficiency
equivalent or better than that achieved by HVLP spraying. As an
alternative to using low-VOC content coatings, a facility could choose
to use combinations of capture and add-on control equipment to meet an
overall control efficiency of 90 percent.
    Furthermore, the draft CTG recommends work practices to control VOC
emissions from metal furniture surface coating-related activities. The
draft CTG recommends that these work practices include the following:
(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 coatings, thinners and coating-related waste materials
from one location to another in closed containers or pipes.
2. Cleaning Materials
    The draft CTG recommends work practices to reduce VOC emissions
from cleaning materials used in metal furniture surface coating
operations. The draft CTG recommends that, at a minimum, these work
practices include the following: (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 cleaning materials from one location to
another in closed containers or pipes; and (5) minimize VOC emissions
from cleaning of storage, mixing, and conveying equipment.

C. Impacts of Recommended Control Techniques

    Based on the 2002 NEI database, we estimate that there are a total
of 456 metal furniture facilities in the U.S. Using the April 2004
ozone nonattainment designations, we estimated that a total of 289 of
these facilities are in ozone nonattainment areas. Based on the 2002
NEI VOC emissions data, 143 of the 289 facilities in ozone
nonattainment areas emitted VOC at or above the recommended 6.8-kg/day
(15-lb/day) VOC emissions applicability threshold. According to the
2002 NEI, these 143 facilities, in aggregate, emit about 3,100
Megagrams per year (Mg/yr) (3,400 tons per year (tpy)) of VOC per year,
or an average of about 21 Mg/yr (23 tpy) of VOC per facility.
    As previously mentioned, the draft CTG recommends either the use of
low-VOC content coatings with specified application methods or optional
add-on control technology. Both recommendations also include certain
work practices to further reduce emission from coatings, as well as
controlling VOC emissions from cleaning materials. Because the industry
is already using predominantly low-VOC content coatings, such as powder
coatings, we have estimated the total annual costs to be approximately
$240,500. Since these recommended measures are expected to result in a
VOC emissions reduction of 1855 Mg/yr (2040 tpy), the cost-
effectiveness is estimated to be $130/Mg ($118/ton). The impacts are
further discussed in the draft CTG document.
    The draft CTG also recommends work practices for reducing VOC
emissions from both coatings and cleaning materials. We believe that
our work practice recommendations in the draft CTG will result in a net
cost savings. Implementing work practices reduce the amount of cleaning
materials used by decreasing the amount that evaporates and is wasted.

D. Considerations in Determining Whether a CTG Will Be Substantially as
Effective as a Regulation

    In determining whether to issue a national rule or a CTG for the
product category of metal furniture coatings under CAA section
183(e)(3)(C), we analyzed the four factors identified above in Section
I.D in light of the specific facts and circumstances associated with
this product category. Based on that analysis, we propose to determine
that a CTG will be substantially as effective as a rule in achieving
VOC emission reductions in ozone nonattainment areas from metal
furniture surface coating operations.
    As noted above, this section is divided into two parts. In the
first part, we discuss our belief that the most effective means of
achieving VOC emission reductions in this category is through controls
at the point of use of the product, (i.e., through controls on the use
of coating and cleaning materials at metal furniture surface coating
facilities), and this can only be accomplished through a CTG. We
further explain that the recommended approaches in the draft CTG are
consistent with existing effective EPA, State, and local VOC control
strategies. In the second part, we discuss how the distribution and
place of use of the products in this category also support the use of a
CTG. We also discuss the likely VOC emission reductions associated with
a CTG, as compared to a regulation. We further explain that there are
control approaches for this category that result in significant VOC
emission reductions and that such reductions could only be obtained by
controlling the use of the products through a CTG. Such reductions
could not be obtained through a regulation under CAA section 183(e)
because the controls affect the end-user, which is not a regulated
entity under CAA section 183(e)(1)(C). For these reasons, which are
described more fully below, we believe that a CTG will achieve greater
VOC emission reductions than a rule for this category.
1. The Most Effective Entity To Target for VOC Reductions and
Consistency With Existing Federal, State, and Local VOC Strategies
    To evaluate the most effective entity to target for VOC reductions,
it is important first to identify the primary sources of VOC emissions.
There are two main sources of VOC emissions from metal furniture
coating: (1) Evaporation of VOC from coatings; and (2) evaporation of
VOC from cleaning materials. We address each of these sources of VOC
emissions, in turn, below, as we discuss the CTG versus regulation
approach.
a. Coatings
    A national rule could contain limits for the as-sold VOC content of
metal furniture coatings. However, given the nature of the metal
furniture surface coating process, we believe that such a rule would
result in little reduction in VOC emissions.
    Although the metal furniture surface coating industry currently
uses primarily low-VOC content coatings (such as high solids and powder
coatings), these low-VOC content coatings cannot replace the
traditional solvent-borne coatings in some instances. Specialized
appearance and other functional characteristics determine the types of
coatings that can be used. For example, some products (e.g., recliner
mechanisms) require a thin dried film thickness that can only be
achieved using solvent-borne coatings. Accordingly, a national rule
that requires low VOC content in metal furniture surface coatings would
nevertheless need to include higher VOC limits to allow for the use of
solvent-borne coatings when necessary and to maintain these materials'
intended effect. Because such a rule would merely codify what the metal
furniture surface coating facilities are already doing, we do not
expect that it would result in significant reductions from these
facilities.
    Furthermore, the effect of a national rule setting low VOC content
limits for metal furniture coatings could be easily subverted because
it does not guarantee that only those low-VOC content coating materials
will be used for metal furniture surface coating. Many coatings used in
metal furniture surface coating are not specifically identified by the
supplier as metal furniture coatings. Therefore, these facilities can
purchase and use coating materials not specified as metal furniture
coatings, which would effective nullify the reformulation actions of
the manufacturers and suppliers, resulting in no net change in VOC
emissions in ozone nonattainment areas.
    Alternatively, a national rule could set low VOC content limits for
all coatings sold, regardless of specified end use, thus ensuring that
only low-VOC materials are available for metal furniture surface
coating. Such an approach would be unreasonable and impractical.
Coatings are sold for multiple different commercial and industrial
purposes. Reducing the VOC content of all coatings would impact uses of
these materials in operations other than metal furniture surface
coating and may inadvertently preclude the use of higher VOC containing
materials in many important, legitimate contexts.
    By contrast, a CTG can reach the end users of the coating materials
and can therefore implement the control measures that are more likely
to achieve the objective of reducing VOC emissions from this product
category in ozone nonattainment areas. As previously discussed, the
draft CTG recommends an emission limit for metal furniture surface
coating operations that can be achieved through the use of low-VOC

content coatings, and specific application methods. Alternatively, the
draft CTG recommends an overall 90 percent control efficiency should a
facility choose to use add-on controls in conjunction with high-VOC
content coatings. In addition, both recommendations in the draft CTG
include work practices to further reduce VOC emissions from coatings as
well as controlling VOC emissions from cleaning materials. The use of
low-VOC content coatings, which are available for metal furniture
surface coating, can greatly reduce VOC emissions. Alternatively,
control devices, such as thermal oxidizers, catalytic oxidizers, or
carbon adsorbers, can achieve a significant reduction in VOC emissions
from high-VOC content coatings. The recommended work practices and
application methods have also been shown to be effective VOC reduction
measures. Given the significant reductions achievable through the use
of these recommended control measures, the most effective entity to
address VOC emissions from metal furniture coatings is the facility
using the coating.
    These control measures are consistent with existing EPA, State, and
local VOC control strategies applicable to metal furniture surface
coating. As mentioned above, previous EPA actions and existing State
and local regulations (in particular, the majority of the California
jurisdictions) that address metal furniture surface coating similarly
call for VOC emission reduction either through the use of control
devices in conjunction with high-VOC content coating materials or the
use of equivalent low-VOC content coating materials; some also include
work practices and specific application methods.
    We cannot, however, issue a national rule directly requiring metal
furniture surface coating facilities to use low-VOC content coatings,
control devices or specific application methods, or to implement work
practices to reduce VOC emissions because, pursuant to CAA section
183(e)(1)(C) and (e)(3)(A), the regulated entities subject to a
national rule would be the coating manufacturers and suppliers, not the
metal furniture surface coating facilities. By contrast, a CTG can
reach the end users of the metal furniture coatings, and can therefore
implement the measures by the users that are identified above as more
likely to achieve the intended VOC emission reduction goal.
Accordingly, we are including these recommended control measures in the
draft CTG that applies to metal furniture surface coatings facilities
as the end users of the coating materials.
b. Cleaning Materials
    There are two primary means to control VOC emissions associated
with the cleaning materials used in the metal furniture surface coating
process: (1) Limiting the VOC content or VOC vapor pressure of the
cleaning materials, and (2) implementing work practices governing the
use of the cleaning materials. A national rule requiring that
manufacturers of cleaning materials for metal furniture coating
operations provide low-VOC content or low vapor pressure (i.e.,
replacing VOC that have a high vapor pressure with low vapor pressure
VOC) cleaning materials would suffer from the same deficiencies noted
above with regard to the coatings. Specifically, nothing in a national
rule that specifically regulates manufacturers and suppliers of
cleaning materials specified for use in metal furniture surface coating
operations would preclude the metal furniture surface coating industry
from purchasing bulk solvents or other multipurpose cleaning materials
from other vendors. The general availability of bulk solvents or
multipurpose cleaning materials from vendors that would not be subject
to such regulation would directly undermine the effectiveness of such a
national regulation.
    A national rule also could, in theory, limit the VOC content or
vapor pressure of all cleaning materials and all solvents sold
regardless of specified end use, which would ensure that only low-VOC
content or low vapor pressure cleaning materials are available for
cleaning operations associated with metal furniture surface coating. As
with a low-VOC content limit on coatings, setting a low-VOC content or
a low vapor pressure limit for all cleaning materials and solvents
would be unreasonable and impractical. Cleaning materials and solvents
are sold for multiple different commercial and industrial purposes.
Replacing highly volatile cleaning materials and solvents would impact
uses of these materials other than cleaning operations at metal
furniture surface coating facilities and may inadvertently preclude the
use of such materials in many important, legitimate contexts.
    The more effective approach for reducing VOC emissions from
cleaning materials used by metal furniture surface coaters is to
control the use of cleaning materials through work practices. The draft
CTG recommends that metal furniture surface coating facilities
implement work practices to reduce VOC emissions from cleaning
materials during metal furniture surface coating operations. An example
of an effective work practice is keeping solvents and used shop towels
in closed containers. This measure alone can significantly reduce VOC
emissions from cleaning materials. Provided immediately below are
examples of other effective work practices that are being required by
State and local regulations. Given the significant VOC reductions
achievable through the implementation of work practices, we conclude
that the most effective entity to address VOC emission from cleaning
materials used in metal furniture surface coating operations is the
facility using the cleaning materials during surface coating
operations.
    This recommendation is consistent with measures required by State
and local jurisdictions for reducing VOC emissions from cleaning
materials used in metal furniture surface coating operations. In
addition to keeping solvents and shop towels in closed containers,
State and local requirements include: Minimizing spills of VOC-
containing cleaning materials; cleaning up spills immediately; and
conveying any VOC-containing cleaning materials in closed containers or
pipes. Work practices have proven to be effective in reducing VOC
emissions.
    We cannot, however, issue a rule requiring such work practices for
metal furniture surface coating facilities because, pursuant to CAA
section 183(e)(1)(C) and (e)(3)(A), the regulated entities subject to a
national rule would be the cleaning materials manufactures and
suppliers and not the metal furniture surface coating facilities.
Accordingly, we are including these work practices in the draft CTG
that applies to metal furniture surface coating facilities as the end
users of the cleaning materials.
    Based on the nature of the metal furniture surface coating process,
the sources of significant VOC emissions from this process, and the
available strategies for reducing such emissions, the most effective
means of achieving VOC emission reductions from this product category
is through controls at the point of use of the products, (i.e., through
controls on metal furniture surface coaters), and this can only be
accomplished through a CTG. The recommended approaches described in the
draft CTG are also consistent with effective existing EPA, State, and
local VOC control strategies for metal furniture surface coating
operations. These two factors alone demonstrate that a CTG will be
substantially as effective as a national regulation.

2. The Product's Distribution and Place of Use and Likely VOC Emission
Reductions Associated With a CTG Versus a Regulation
    The factors described in the above section, taken by themselves,
weigh heavily in favor of the CTG approach. The other two factors
relevant to the CAA section 183(e)(3)(C) determination only further
confirm that a CTG will be substantially as effective as a national
regulation for metal furniture coatings.
    First, metal furniture coatings and associated cleaning materials
are used at commercial facilities in specific, identifiable locations.
Specifically, these materials are used in commercial facilities that
apply surface coating to metal furniture as described in section III.A.
This stands in contrast to other consumer products, such as
architectural coatings, that are widely distributed and used by
innumerable small users (e.g., individual consumers in the general
public). Because the VOC emissions are occurring at commercial
manufacturing facilities, implementation and enforcement of controls
concerning the use of these products are feasible. Therefore the nature
of the products' place of use further counsels in favor of the CTG
approach.
    Second, a CTG will achieve greater emission reduction than a
national rule for each source of VOC emissions from metal furniture
coating and associated cleaning materials. For the reasons described
above, we believe that a national rule limiting the VOC content in
coatings and cleaning materials used in metal furniture surface coating
operations would result in little VOC emissions reduction. By contrast,
a CTG can achieve significant VOC emissions reduction because it can
provide for the highly effective emission control strategies described
above that are applicable to the end-users of the coatings and cleaning
materials at metal furniture surface coating facilities. Specifically,
the draft CTG can provide for the use of control devices in conjunction
with high-VOC content coatings, specific application methods, and work
practices. These significant VOC reductions could not be obtained
through a national regulation, because they require the implementation
of measures by the end-user. In addition, as previously explained,
strategies that arguably could be implemented through rulemaking, such
as a limit on VOC content in coatings and cleaning materials, are far
more effective if implemented directly at the point of use of the
product. For the reasons stated above, it is more effective to control
the VOC content of coatings and cleaning materials used for metal
furniture surface coating through a CTG than through a national
regulation.
    Furthermore, the number of metal furniture surface coating
facilities affected by our recommendations in this draft CTG, as
compared to the total number of such facilities in ozone nonattainment
areas, does not affect our conclusion that the CTG would be
substantially more effective than a rule in controlling VOC emissions
for this product category. As previously mentioned, we recommend the
control measures described in the draft CTG for metal furniture surface
coating facilities that emit 6.8 kg/day (15 lb/day) or more VOC. Based
on the April 2004 ozone nonattainment designations, we estimate that
143 of the 289 metal furniture surface coating facilities located in
ozone nonattainment areas emit 6.8 kg/day (15 lb/day) or more and are
therefore addressed by our recommendations in the draft CTG. There are
146 metal furniture surface coating facilities that would not be
covered by the recommendations in the draft CTG. According to the 2002
NEI database, these 146 facilities collectively emitted less than 103
Mg/yr (115 tpy), which is less than 4 percent of the total reported VOC
(an average of 0.71 Mg/yr (0.78 tpy) per facility) in ozone
nonattainment areas. The fact that the CTG addresses more than 96
percent of the VOC emissions from metal furniture surface coating
facilities in an ozone nonattainment area further supports our
conclusion that a CTG is more likely to achieve the intended VOC
emission reduction goal for this product category than a national rule.
    Upon considering the above factors in light of the facts and
circumstances associated with this product category, we propose to
determine that a CTG for metal furniture coatings will be substantially
as effective as a national regulation.

IV. Large Appliances Coatings

A. Industry Characterization

1. Source Category Description
    This category of consumer and commercial products includes the
coatings that are applied to the surfaces of large appliances parts and
products at facilities that manufacture or assemble large appliances.
Large appliances coatings include, but are not limited to, primers,
basecoats, topcoats, and adhesives used in the manufacture of large
appliance parts or products. A large appliance part is defined as any
organic surface-coated metal lid, door, casing, panel, or other
interior or exterior metal part or accessory that is assembled to form
a large appliance product. A large appliance product is defined as any
organic surface-coated metal range, oven, microwave oven, refrigerator,
freezer, washer, dryer, dishwasher, water heater, trash compactor, or
any other large appliance or equipment manufactured for household,
commercial, or recreational use. The coatings provide a protective and/
or decorative layer to the surface of large appliance products.
2. Processes, Sources of VOC Emissions, and Controls
    VOC emissions from large appliance surface coating operations
result from the evaporation of VOC contained in many of the coatings or
used as cleaning materials.\17\ The primary VOC emissions from large
appliances coatings occur during coating application (prime, single or
topcoat application), flash-off, and drying/curing of the coatings.
Some emissions also occur during mixing or thinning of the coatings.
The primary VOC emissions from the cleaning materials occur during
cleaning operations. VOC emissions from surface preparation (i.e.,
wiping with cleaning materials), storage and handling of coatings and
cleaning materials, and waste/wastewater operations (i.e. handling
waste/wastewater that may contain residues from both coatings and
cleaning materials) are small.
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    \17\ In a previous notice, EPA stated that the cleaning
operations associated with certain specified section 183(e) consumer
and commercial product categories, including large appliances
coatings, would not be covered by EPA's 2006 CTG for industrial
cleaning solvents. 71 Fed. Reg. 44522, 44540 (2006). In that notice,
EPA expressed its intention to address cleaning operations
associated with these categories in the CTGs for these specific
categories if the Agency determines that a CTG is appropriate for a
respective category.
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    VOC emissions from mixing and/or thinning of the coatings occur
from displacement of organic vapor-laden air in containers used to mix
coatings containing solvents (thinners) prior to coating applications.
The displacement of vapor-laden air can occur during the filling of
containers and can also be caused by changes in temperature or
barometric pressure, or by agitation during mixing.
    The majority of VOC emissions occur from evaporation of solvents
during coating application. The transfer efficiency (the percent of
coating solids deposited on the large appliance part or product) of a
coating application method affects the amount of VOC emissions during
coating application. The more efficient a coating application method is
in transferring coatings to the large appliance part or product, the

lower the volume of coatings (and therefore solvents) needed per given
amount of production, thus resulting in lower VOC emissions.
    Most spray applied coatings are electrostatically applied. In
electrostatic coating, the presence of an electrostatic field creates
an electrical attraction between the paint, which is positively
charged, and the grounded metal furniture component or product and
enhances the amount of coating deposited on the surface. This coating
method is more efficient than conventional air atomized spray, with
transfer efficiency typically ranging from 60 to 90 percent.
    Other coatings application methods used in the large appliance
surface coating industry include flow coating, roll coating, high
volume/low pressure (HVLP) spray, electrocoating, autophoretic coating,
and application of coatings by hand. These coating methods are
described in more detail in the draft CTG.
    In typical liquid spray and dip coating operations, the coated
parts/products move from the coating application area through a flash-
off area, where solvents in the wet coating film evaporate slowly, thus
avoiding bubbling of the coating while it is curing in the oven. After
being coated by any of the typical coating operations, large appliance
parts and products are dried and cured using heated dryers or by air
drying. This step removes any remaining volatiles from the coatings so
that the surfaces of the large appliance parts and products meet the
hardness, durability, and appearance requirements of customers.
    Until the late 1970's, the large appliances industry used
conventional solvent-borne coatings almost exclusively. Since then, the
industry has steadily moved towards alternative coating formulations
that eliminate or reduce the amount of solvent in the formulations,
thus reducing VOC emissions per unit amount of coating solids used.
    Currently the large appliance surface coating industry uses
primarily higher solids solvent-borne coatings and powder coatings and
applies them by electrostatic spraying. This combination of coating
type and application method is an effective measure for reducing VOC
emissions. Not only are VOC emissions reduced by using coatings with
low VOC content, the use of an application method with a high transfer
efficiency, such as electrostatic spraying, lowers the volume of
coatings needed per given amount of production, thus further reducing
the amount of VOC emitted during the coating application.
    Other alternative coatings include waterborne coatings and UV cured
coatings. These coatings are described in more detail in the CTG.
    The most common approach to reduce emissions from large appliance
coating operations is to use low-VOC content coatings, including powder
coatings, higher solids solvent-borne coatings, waterborne coatings and
UV cured coatings. Add-on controls may also be used to reduce VOC
emissions from large appliance coating operations. The majority of VOC
emissions from spray coating operations occur in the spray booth. The
volume of air exhausted from a spray booth is typically high and the
VOC concentration in spray booth exhaust is typically low. The cost of
controlling VOC in spray booth exhaust is therefore greater than the
cost of using low-VOC content coatings. The wide availability and lower
cost of low-VOC content coatings makes them a more attractive option
than add-on controls. For those situations where an add-on control
device is used, thermal oxidation and carbon adsorption are most widely
used. Please see the draft CTG for a detailed discussion of these and
other available control devices. As previously mentioned, another main