Comment submitted by Bill Juris, Division of Air Pollution Control, Ohio Environmental Protection Agency (Ohio EPA)

Docket No. EPA-HQ-OAR-2007-0334 Comments on DRAFT Control Techniques Guidelines for Metal Furniture Coatings: Table 1 and the sections on "The CTG" and the "The NSPS" could be clarified to indicate that the CTG limit is a daily volume-weighted average limit and the NSPS limit is a monthly volume-weighted average limit. Presumably the recommended limit under this draft CTG is a daily volume-weighted average limit. It is suggested that USEPA exclude from the definition of coating any material that does not form a solid film, similar to the exclusion of a "protective oil" under the 2003 NESHAP. "'Protective oil' means an organic material that is applied to a substrate for the purpose of providing lubrication or protection from corrosion without forming a solid film. This definition of protective oils includes, but is not limited to, lubricating oils, evaporative oils (including those that evaporate completely), and extrusion oils." In Appendix B, the summary of the metal furniture coating regulation for Ohio should be revised to state that it applies to a prime coat, topcoat, or single coat coating line coating line as follows: (a) in 24 counties [listed in OAC rule 3745-21-09(A)(1)], to existing and new coating lines; (b) in the other 64 counties, to any new coating line and to existing and new coating lines at a facility with potential to emit equal to or greater than 100 tons VOC per year. A new coating line is a coating line for which construction or modification commenced on or after October 19, 1979. The VOC numerical limit is 3.0 lb/gal coating (minus water and exempt solvent) or 5.1 lb/gal solids (if using a control system). The emission limitation is achieved by: (a) complying coatings; or (b) control system that meets either 5.1 lbs VOC/gal solids or an overall 81% reduction with a control device efficiency of at least 90%; or (c) an alternative emissions limitation based upon a "tested" transfer efficiency greater than 60%. Also, the information on the regulation of cleaning materials under OAC rule 3745- 21-07(G)(4) for metal furniture coating lines should be deleted because the metal furniture coating lines are not regulated under OAC rule 3745-21-07(G).