UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

1650 Arch Street Philadelphia, Pennsylvania 19103

DATE: June 13, 2012

SUBJECT: Technical Support Document for the Maryland State Implementation Plan

Revision for the Control of Volatile Organic Co mpounds Emissions from Vehicle Refinishing

/s/

FROM: Emlyn Vélez

- Rosa, Environmental Engineer

Office of Air Program Planning

TO: File

/s/

THRU: Donna Mastro, Acting Associate Director

Office of Air Program Planning

A. I NTRODUCTION

The U.S. Environmental Protection Agency (EPA) is taking action on a submittal made by the Maryland Department of the Environment (MDE) on May 8 , 2012. The SIP revision amends Maryland’s COMAR 26.11.19.23 “Control of Volatile Organic Compound s Emi ssions from Vehicle Refinishing ” to establish new volatile organic compound s (VOC) content limits for coating and cleaning solve nts used in vehicle refinishing and standards for coating application, work practices, monitoring, and recordkeeping.

B. BACKGROUND

Ground

- level ozone, which is a major component of ‘‘smog,’’ is formed in the atmosphere by reactions of VOC and oxides of nitrogen (NO X ) in the presence of sunlight. In order to reduce ground

- level ozone levels, emissions of VOC and NO X mu st be reduced. Maryland was designated nonattainment with respect to the 1

- hour ozone NAAQS in November 15, 1990, with

several serious nonattainment areas, including: the Baltimore, Maryland area, the Maryland portion of the Philadelphia

- Wilmington

- Atlan tic City area , and the Maryland portion of the Washington, DC area. 1 Additionally, the entire State of Maryland corresponds to the ozone transpor t region (O T R ), under section 184(a) of the Clean Air Act (CAA). As a result, the entire state is subject to the ozone nonattainment plan provisions of section 182 and the federal ozone

meas ures of section 183 of the CAA.

1 The 1

- hour ozone standard wa s revoked effective June 15, 2005 for all areas in Ma ryland except the Washington County area where it was revoked effective April 15, 2009.2

Section 182(c) of the CAA requires states with ozone nonattainment areas cla ssified as moderate

or above to submit a SIP revision that provide s VOC emissions reductions of at least 15 percent

from the baseline emissions of 1990

. In Maryland, the 15 percent plans (the 15% rate

- of

progress plans) were required for the 1

- hour ozone nonattainment areas . Pursuant to this requirement, Marylan d revised its SIP on August 4, 1997 to adopt COMAR 26.11.19.23 “Control of Volatile Organic Compounds Emissions from Vehicle Refinishing.” The regulation

would achieve fully enforceable VOC emissions reductions from vehicle refinishing sources through the State of Maryland , which were creditable towards the 15% rate

- of

- progress plans

. The rule, which followed EPA’s “ Alternative Control Techniques (ACT) Document : Automobile Body Refinishing” (EPA

- 453/R

- 94

- 031, April 1994 ), established standards for vehicle refinishing based on VOC content of coatings, methods for calculating the VOC content of a coating system, and standards for operating, monitoring, reporting, and recordkeeping. The coating categories included: pretreatment coatings, precoatings, primer surfacers, primer sealers, topcoats, multi

- stage coating systems, and specialty coatings.

Section 183(e) of the CAA requires EPA to study and report to U.S. Congress on VOC emissions from consumer and commercial products and their potential to contribute to nonattainment of the ozone NAAQS

. In addition, section 183(e) requires EPA to list those categories of consumer and commercial products that account for at least 80 percent of the VOC emissions, on a reactivity

- adjusted basis, in ozone nonattainment ar eas and establish priorities for their regulation. EPA submitted the Report to Congress on March 15, 1995 (“ Consumer and

Commercial Products Report to Congress,'' EPA

- 453/R

- 94

- 066

- A), and on this same date established the priority list for fu ture regulati on of consumer and commercial products (published on M arch 23, 1995, at 56 FR 15264). Automobile refinish coatings were to be regulated by March 1997. A final rule entitled “National Volatile Organic Compound Emissions

Standards for Automobile Refinish C oatings” (EPA’s National Rule) was published by EPA on September 11, 1998 under the authority of section 183(e) of the CAA (63 FR 48806) , as identified in 40 CFR Part 59, s ubpart B . The federal rule applies to all automobile refinish coatings that are man ufactured or imported for sale or distribution in the United States, and sets VOC content limits by automotive refinish category. See EPA’s August 1998 report “Volatile Organic Compound Emissions from Automobile Refinishing

- Background Information for Promulgated Standards” (EPA

- 453/R

- 96

- 011b ).

On January 9

, 2008, EPA published the final rule 40 CFR part 63 subpart HHHHHH “ National

Emission Standards for Hazardous Air Pollutants: Paint Stripping and Miscellaneous Surface

Coat ing Ope rations at Area Sou rces ” (EPA’s 6H NESHAP)

, which includes automobile refinishing. Th is federal rule specific ally applies to area sources that engage in paint stripping operations that use methylene chloride (MeCl) containing paint stripping formulations, and in

spray application of coatings to motor vehicle and mobile equipment, plastic and or metal substrate, where the coatings contain compounds of chromium, lead, manganese, nickel, or

cadmium. M otor vehicle or mobile equipment surface coating operations may petition the

EPA’s Administrator for an exemption from this rule if the owner or operator can demonstrate,

to the satisfaction of the EPA’s Administrator , that the spray appl ied does no t include coatings containing any of these compounds. This rule establishe s im portant requirements for these types of facilities, among the following : training certification of all new and existing pers onnel who3

spray surface coatings, m inimum training requirements , and installation to all facilities of a filtered spray booth and en closed spray gun cleaner.

Maryland’s 1997 SIP

- approved COMAR 26.11.19.23 “Control of Volatile Organic Compounds Emissions from Vehicle Refinishing” complie s with the federal standards established in EPA’s

rules . No c hanges were made to Maryland’s COMAR 2 6.11.19.23 until the 2011 amendments, which Maryland adopted in its regulations on March 26, 2012

. EPA is proposing to approve

these amendments into the Maryland SIP through this action

. The proposed SIP revision is

based on the 2009 “Model Rule for Motor Vehicle and Mobile Equipment Non

- A ssembly Line Coating Operations” ( MVMERR ) developed in conjunction with member states of the Ozone Transport Commission 2 (OTC) . The MVMERR established requirements which comply with

those established in EPA’s National Rule and 6H NESHAP

. The proposed SIP revision will replace the standards and requirements in the current SIP

- approved regulation with new standards and requirements , including VOC content limits in auto motive coatings and cleaning

solvents , contr ols on emis sions from equipment cleaning, the use of coating application methods, recordkeeping, maintenance activities, and operator training.

Source Description

Automobile refinishing includes the application of coatings following the manufacture of original equipment. “ Automobile ” or “vehicle” in this category refers to passenger cars, trucks, vans, motorcycles, and other mobile equipment capable of being driven on the highway.

Automobile r efinishing work typically consists of structural repair, surface preparation, and painting , and includes operations in auto body repair/paint shops, production auto body paint shops, new car dealer repair/paint shops, fleet operator repair/paint shops, and custom made car

fabrication facilities. The steps invol ved in automobile refinishing include surface preparation, coating applications, and spray equipment. VOC emissions result from the evaporation of solvents during each of these processes, and can be controlled through the use of compliant coatings and sol vents, the use of application equipment with increased transfer efficiency, and stringent work practice standards.

The main categories of coatings are primers and topcoats. The primer category consists of pretreatment wash primers, primers, primer surf acers, and primer sealer. Topcoats are applied over the primer coats and provide the final color to the refinished area. Primers and coatings can be classified as lacquer, enamel, or urethane coatings. Each coating differs in its chemistry durability, and VOC content. Some additives and specialty coatings are necessary for unusual performance requirements, and are used in relatively small amounts to improve desirable properties. Additives and special coatings include adhesion promoters, uniform refini sh

2 The Ozone Transport Commission (OTC) is a multi

- state organization created under the CAA, which is responsible for advising EPA on transport issues and for developing and implementing regional solutions to the ground

- level ozone problem in the Northeas t and Mid

- Atlantic regions. The OTC has no rulemaking authority. Model rules and programs designed through the OTC process must then be taken by the individual states through their own rule adoption processes conforming to their state’s requirements.4

blenders, elastomeric materials for flexible plastic parts, gloss flatteners, and anti

- glare /safety coatings. For additional information, see EPA’s “ Alternative Control Techniques (ACT)

Document : Automobile Body Refinishing” (EPA

- 453/R

- 94

- 031, April 19 94 ).

C . STATE’S SUBMITTAL

Summary of SIP Revision

The proposed SIP revision establishes VOC content limits for automotive coatings and cleaning solvents used in the preparation , application, and drying phases of vehic le refinishing. The

revision also establishes coating application standards, work practices, operator training standards, and compliance and recordkeeping standards . T he se standards and emissions limits

for control of VOC as established under Maryland’s COMAR 26.11.19.23 are to be effective for

all affected sources as of July 1, 2013. Affected sources include : auto body and repair facilities, fleet operator repair and paint facilities

, new and used auto dealer repair and paint facilities , and

after

- marke t aut o customizing and detailing facilitie s located throughout the State of Maryland ; manufacture rs, suppliers, and distributors of coatings and cleaning solvents intended for use and application to motor vehicles, mobile equipment, and associated componen ts within the State of Maryland; and manufacturers, suppliers, and distributors of application equipment and materials storage such as spray booths, spray guns, and sealed containers for cleaning rags for use within

the State.

The new regulation revises or adds new terms under its definitions . For instance, the definition of “mobile equipment” has being extended to include “automobile,” “truck cabs,” “truck bodies,” “buses,” “motorcycles,” “implements of husbandry or agriculture,” and “trains and

railcars.” In addition to the use of automotive coa tings or cleaning solvents, the applicability requirements have be en extended to include any person who supplies

, sell, offers for sale,

distributes , and manufactures automotive coatings or cleaning solvents within the State of Maryland

. Specific exemptio ns were incorporated into the regulation to exclude coatings and cleaning solvents for sale outside the State, assembly line coatings, aerosol coatings, coatings used in surface coating proc esses under COMAR 26.11.19.03 “ Automotive and Light

- Duty

Truck C oating” and coatings sold in 0.5 fluid ounces or less.

The revision establishes s pecific VOC content limits

, which exclude water and exempt compounds , for automotive coatings and cleaning solvents

. As defined in COMAR 26.11.01.01B(53), exempt VOC compoun ds are those which have been determined to have negligible photochemical reactivity by EPA and which are listed in 40 CFR 51.100(s), as

amended. The limits are established in both pounds per gallon (lbs/gal) and grams per liter (g/L)

for each of the 11 co ating categories and two solvent categories

. Several categories for coat ings were added as part of this revision, including : adhesion promoter, clear coating, color coating, multicolor coating, single

- stage coating, temporary coating, truck bed liner coating, and underbody coating. The VOC content limits for the automotive coatings and solvents establishe d

in section E of the regulation are provided in T able 1 and Table 2, respectively.5

Table 1: VOC Content Limits for Automotive Coatings for Motor Vehicle and Mobile Equipment Refinishing and Recoating VOC Content Limit for Automotive Coatings

Coating Category Maximum VOC Content lbs/gal g/L Adhesion promoter 4.5 540 Automotive pretreatment coating 5.5 660 Automotive primer 2.1 250 Clear coating 2.1 250 Color coating, including metallic/iridescent color coating 3.5 420

Multicolor coating 5.7 680 Other automotive coating type 2.1 250 Single

- stage coating, including single

- stage metallic/iridescent coating 2.8 340

Temporary protective coating 0.5 60 Truck bed liner coating 1.7 200 Underbody coating 3.6 430

Table 2: VOC Content Limits for Cleaning Solvents for Motor Vehicle and Mobile Equipment Refinishing and Recoating VOC Content Limit for Cleaning Solvents

Solvent Category Maximum VOC Content Cleaning solvent (other than bug and tar removers) 0.21 lbs/gal 25 g/L

Bug and tar removers ** 40% VOC by weight

For determining compliance of the VOC content limits of each automotive coating, t he VOC

content should be determined usin g the following equations:

VOC regulatory content = (W v

- Ww

- Wec) / (Vm

- Vw

- Vec);

VOC actual c ontent = ( Wv

- Ww

- Wec) / (Vm).

The VOC content for cleaning solvents, other than for bug and tar removal, must be determined using the following equation:

VOC content = (Wv

- Ww

- Wec) / (Vm)

Where:

VOC content (or actual) = grams of VOC per liter of coating;

Wv = weight of total volatiles, in grams;

Ww = weight of water, in grams;

Wec = weight of exempt compounds, in grams;6 Vm = volume of material (coating or cleaning solvent, including water, exempt compounds, and added solvent) in liters;

Vw = volume of water, in liters; and

Vec = volume of exempt compounds, in liters.

A list of test methods to be used for the purpose of demonstrating compliance with provisions of this regulation is provided in section B of the rule

. Instead of complying w ith the VOC content limits specified in Tables 1 and 2 (section E of the regulation), a person subject to this regulation may use an emission control device that has been approved by MDE, which achieves an overall

emission control efficiency of 85 percent or greater, as determined in accordance with EPA ’s

Te chnical Document, “Guidelines f o r Determining Capture Efficiency ” (January 1995 ), EPA Methods 204 through 204 F as described in 40 CFR part 51, appendix M, and EPA Reference Methods 25, 25A, and 25 C. Th e approved emission control device must be maintained and used at all times in proper working condition.

All affected facilities must use at least one of following m ethods when applying an automotive coating : flow or curtain coating, dip coating, brush co ating, cotton

- tipped swab application, electrodeposition coating, high volume

- low pressure (HVLP) spraying, electrostatic spraying, airless spraying, or an alternate spray equipment method approved by MDE . An alternate spraying method should achieve a tra nsfer efficiency equivalent or higher than HVLP or electrostatic spray application methods, using the methods described under the South Coast Air Quality Management District (SCAQMD) Test Procedure

, “Spray Equipment Transfer Efficiency Test Procedure for E quipment User” (May 1989) and SCAQMD Guidelines, “Guidelines for Demonstrating Equivalency with District Approved Transfer Efficiency Spray Guns” (September 2002), and based on the regulation specifications. The terms “electrostatic spraying” and “airless spraying” are defined in the regulation to be used in this context.

W ork practice st andards include procedures for cleaning the spray gun equipment for applying automotive coatings. T hese procedures should be part of any training program implemented by the owners and operators of affected facilities. Affected facilities are also required to keep extensive records on the total amount of coating used, VOC actual and regulatory contents

, purchase records, etc. Facili ti es using an emission control device must maintain a daily record of system operating parameters such as temperature, pressure drops, and air flow rates to

d emonstrate compliance

.

Emissions Reductions

The use and implementation of compliant low

- VOC automo tive coatings and cleaning solvents coupled with stringent application and work practice standards is expected to reduce VOC emissions from vehicle refinishing operations in the State of Maryland through the use of coatings with less toxic compounds. Base d upon calculations and emissions estimates by the MDE, the SIP revision should provide a statewide VOC emissions reduction potential of 65 percent from the vehicle refinishing category of the current baseline emissions inventory. Maryland’s 2002 baseline emissions inventory indicates that VOC emissions from veh icle refinishing total 3.7 tons per day. This regulation is expected to reduce 2.4 tons per day of VOC emissions through implementation of the coating limits and stand ards established.7

D

. EPA’S EVALUATION

Maryland has adopted most inclusive requirements as VOC content limits and standards in COMAR 26.11.19.23 “Control of Volatile Organic Compound s Emi ssions from Vehicle Refinishing

, ” which should continue to help reduce VOC emissions from the a utomobile refinishing facilities throughout the State of Maryland. The regulation includes the applicability, emissions limits, working standards, requirements for container labeling, monitoring, and reporting and recordkeeping recommended by the OTC mode l rule.

E . CONCLUSIONS AND RECOMMENDED AGENCY ACTION

The Maryland SIP revision for the control of VOC emissions from vehicle refinishing under

COMAR 26.11.19.23

, as adopted by the State of Maryland on March 26, 2012

, meets the applicable requirements of the CAA and the applicable EPA regulations. The SIP revision will help achieve VOC emissions reductions throughout the State of Maryland

. EPA recommends approval of this SIP revision through rulemaking.